NC0021211_Graham_PCI_20220929

F
Water Resources
ENVIRONI'I ENTAL QUALITY
NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)1
1. Control Authority (POTW) Name: City of Graham
2. Control Authority Representative(s): Shelby Smith
3. Title(s): Utilities Compliance Manager/Pretreatment Coordinator
4. Last Inspection Date: 3/10/2021 Inspection Type (Check One): © PCI ❑ Audit
5. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? ® YES ❑ NO
6. Is POTW under an Order That Includes Pretreatment Conditions? E YES ® NO
Order Type, Number, Parameters: NA
Are Milestone Dates Being Met? E YES ❑ NO NA
ICIS CODING
Main Program Permit Number
NC 0021211
MM/DD/YY
9/29/2022
7. Current Number Of Significant Industrial Users (SIUs)?
5
8. Number of SIUs With No IUP, or With an Expired IUP?
0
9. Number of SIUs Not Inspected By POTW in the Last Calendar Year?
0
10. Number of SIUs Not Sampled By POTW in the Last Calendar Year?
0
11. Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi -Annual
Periods?
1
Novaflex
12. Number of SIUs in SNC For Reporting During Either of the Last 2 Semi -Annual Periods?
0
13. Number of SIUs in SNC with Pretreatment Schedule?
0
14. Number of SIUs on Schedules?
0
15. Current Number Of Categorical Industrial Users (CIUs)?
3
16. Number of CIUs in SNC?
0
POTW INTERVIEW
17. Since the Last PCI, has the POTW had any NPDES Limits Violations?
If Yes, What are the Parameters and How are these Problems Being Addressed?
18. Since the Last PCI, has the POTW had any Problems Related to an Industrial
Discharge (Interference, Pass -Through, Blockage, Citizens' Complaints, Increased
Sludge Production, Etc.)?
If Yes, How are these Problems Being Addressed?
19. Which Industries have been in SNC for Limits or Reporting during either of the
Last 2 Semi -Annual Periods? Not Been Published for Public Notice?(May refer to
PAR if Excessive SIUs in SNC)
20. Which Industries are on Compliance Schedules or Orders? For all SIUs on an
Order, Has a Signed Copy of the Order been sent to the Division?
21. Are Any Permits or Civil Penalties Currently Under Adjudication? If Yes, Which
Ones?
@ YES ❑ NO
Wkly BOD & TSS - Feb 2022
Monthly TSS - Feb 2022
**Heavy rain event last week
in February
■YES ►ENO
SNC for Limits: Novaflex
SNC for Reporting: None
Not Published: None
None
■YES ►ENO
LTMP/STMP FILE REVIEW:
22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies?
23. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ®YES ❑ NO
24. Is LTMP/STMP Data Maintained in a Table or Equivalent? YES El NO Is Table Adequate? DYES ❑ NO
YES ❑ NO
NC DWR Pretreatment Compliance Inspection (PCI) Form
Updated August 2022 Page 1

25. All LTMP/STMP effluent data reported on Discharge Monitoring Report? ®YES ❑ NO (Division Inspector, please verify
yourself!)
26. If NO to 23 - 26, list violations
27. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ® NO
If yes, which ones? Eliminated:
Added:
28. PRETREATMENT PROGRAM ELEMENTS REVIEW— Please review POTW files, verify POTW has copy of Program Element
in their files, complete with supporting documents and copy of PERCS Approval Letter, and dates consistent with Program Info:
Program Element
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
9/28/2022
❑x Yes E No
10/3/2019
❑x Yes E No
TBD
Industrial Waste Survey (IWS)
9/28/2022
® Yes ❑ No
4/4/2018
® Yes ❑ No
TBD
Sewer Use Ordinance (SUO)
9/7/2011
© Yes ❑ No
9/14/2011
© Yes E No
-
Enforcement Response Plan (ERP)
2/7/2020
© Yes ❑ No
2/14/2020
© Yes E No
-
Long Term Monitoring Plan (LTMP)
9/28/2022
© Yes ❑ No
2/13/2020
® Yes E No
-
The recent submittal of HWA, IWS and LTMP satisfies the conditions in recent permit renewal which required pretreatment
updates to HWA, IWS and LTMP (180 days after September 28, 2022).
NC DWR Pretreatment Compliance Inspection (PCI) Form
Updated August 2022 Page 2

INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name
1. Cintas
2. Metal Impact
3. Stericycle
30. IUP Number
0007
2001
0030
31. Does File Contain Current Permit?
8 Yes ❑ No
N Yes ❑ No
N Yes E No
32. Permit Expiration Date
6/30/2026
6/30/2026
6/30/2026
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or
N/A
Na
467
Na
34. Does File Contain Permit Application Completed
Within One Year Prior to Permit Issue Date?
N Yes ❑ No
N Yes ❑ No
/1 Yes ❑ No
35. Does File Contain an Inspection Completed Within
Last Calendar Year?
01 Yes ❑ No
N Yes E No
N Yes E No
36. a. Does the File Contain a Slug/Spill Control Plan?
b. If No, is One Needed? (See Inspection Form from
POTW)
a 8 Yes • No
b. • Yes • No
a. 8 Yes ❑ No
b. ❑ Yes ❑ No
a. N Yes ❑ No
b. ❑ Yes ❑ No
and 433 TTO Certification, Does
a Toxic Organic Management Plan
❑ Yes ❑ No 11 NA
❑ Yes ❑ No Z NA
❑ Yes ❑ No 11 NA
37. For 40 CFR 413
File Contain
(TOMP)?
38. a. Does File Contain Original Permit Review Letter
from the Division?
b. All Issues Resolved?
a. NYes ❑No
b.❑ Yes ❑ No N/A 11
a. NYes No
b.❑ Yes ❑ No N/A 11
a. NYes ENo
b.❑ Yes ❑ No N/A 11
39. During the Most Recent Semi -Annual Period, Did the
POTW Complete its Sampling as Required by IUP,
including flow?
8 Yes ❑ No
N Yes E No
N Yes E No
40. Does File Contain POTW Sampling Chain -Of-
Custody Forms?
8 Yes ❑ No
Z Yes ❑ No
L Yes ❑ No
41. During the Most Recent Semi -Annual Period, Did the
SIU Complete its Sampling as Required by IUP,
including flow?
N Yes E No ❑ NA
Z Yes ❑ No E NA
N Yes E No E NA
41b. During the Most Recent Semi -Annual Period, Did
SIU submit all reports on time?
N Yes E No ❑ NA
N Yes ❑ No E NA
❑X Yes E No E NA
42a. For categorical IUs with Combined Wastestream
Formula (CWF), does file include process/dilution
flows as Required by IUP?
E Yes E No Z NA
❑ Yes Z No E NA
E Yes E No Z NA
42b. For categorical IUs with Production based limits,
does file include production rates and/or flows as
Required by IUP?
E Yes E No Z NA
Z Yes ❑ No E NA
E Yes E No ❑X NA
43a. During the Most Recent Semi -Annual Period, Did
the POTW Identify All Limits Non -Compliance from
Both POTW and SIU Sampling?
N Yes ❑ No
N Yes E No
N Yes E No
43b. During the
the POTW Identify
from SIU Sampling?
Most Recent Semi -Annual Period, Did
All Reporting Non -Compliance
N Yes E No ❑ NA
1 N Yes ❑ No E NA
N Yes E No E NA
44. a. Was the POTW Notified by SIU (Within 24 Hours)
of All Self- Monitoring Violations?
b. Did Industry Resample and submit results to POTW
Within 30 Days?
c. If applicable, Did POTW resample within 30 days
of becoming aware of SIU limit violations in the
POTW's sampling of the SIU?
a. N Yes ❑ No ❑ NA
b N Yes ❑ No ❑ N/A
c. E Yes ❑ No ® N/A
a. E Yes ® No ❑ NA
b ❑ Yes ❑ No ® N/A
c. ❑ Yes ❑ No ® N/A
a. ® Yes ❑ No ❑ NA
b N Yes ❑ No ❑ N/A
c. Z Yes ❑ No ❑ N/A
46. During the Most Recent Semi -Annual Period, Was
the SIU in SNC?
E Yes N No
E Yes N No
E Yes N No
NC DWR Pretreatment Compliance Inspection (PCI) Form
Updated August 2022 Page 3

47. During the Most Recent Semi -Annual Period, Was
Enforcement Taken as Specified in the POTW's ERP
(NOVs, Penalties, timing, etc.)?
48. Does the File Contain Penalty Assessment Notices?
49. Does The File Contain Proof Of Penalty Collection?
50. a. Does the File Contain Any Current Enforcement
Orders?
b. Is SIU in Compliance with Order?
51. Did the POTW Representative Have Difficulty in
Obtaining Any of This Requested Information For
You?
❑Yes ❑ No 0 N/A
❑Yes ❑ No 0 N/A
❑Yes ❑ No N N/A
❑ Yes ❑ No ® NA
❑ Yes ❑ No ❑x NA
❑ Yes ❑ No ® NA
❑Yes ❑No®NA
❑ Yes ❑No©NA
❑Yes ❑No®NA
a. ■ Yes ❑ No N/A N
b E Yes ❑ No N/A N
a. ❑ Yes ❑ No N/A N
b ❑ Yes ❑ No N/A N
a. ❑ Yes ❑ No N/A N
b E Yes ❑ No N/A N
• Yes I/ No
❑ Yes Z No
❑ Yes V/ No
FILE REVIEW COMMENTS:
No issues were found in file review. Everything in good order. Ms. Smith recently submitted the HWA, IWS and LTMP for review
and approval, therefore due dates TBA once approved. Ms. Smith informed inspector one SIU has closed and no longer in
operation: Prescient Company (Cat 433 - Metal Finisher) IUP #3001
***NO AUDIT CONDUCTED — AUDIT DUE SEPT 2023
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
Click or tap here to enter text.
1.IndustryInspected: Click or tap here to enter text.
2.IndustryAddress:Click or tap here to enter text.
3. Type oflndustry/ProductClick or tap here to enter text.
4.IndustryContact: Click or tap here to enter text. Title:Click or tap here to enter
text
Phone:Click or tap here to enter text. Fax:_Click or tap here to enter text.
5. Does the POTW Use the Division Model Inspection Form or Equivalent? ❑ YES ❑ NO
6. Did the POTW Contact Conduct the Following Parts of the Industrial Inspection Thoroughly?
Comments:
A. Initial Interview ❑ YES ❑ NO
B. Plant Tour ❑ YES ❑ NO
C. Pretreatment Tour ❑ YES ❑ NO
D. Sampling Review ❑ YES ❑ NO
E. Exit Interview ❑ YES ❑ NO
Industrial Inspection Comments:
NC DWP Pretre•° cut C^mpk^roc^ la-po^tieta (PrI) Farm
Updated August 2022 Page /I

OVERALL SUMMARY AND COMMENTS:
Comments: Recent NPDES violations were due to a heavy rain event. Comments on Feb 2022 DMR: Weekly BOD and TSS results were
both non -compliant for week #4. The weekly limit for BOD is 36.0 mg/L and the weekly result was 44.95 mg/L. The weekly limit for TSS
is 45.0 mg/L and weekly result was 89.45 mg/L. Also, the monthly average Effluent TSS concentration was non -compliant. The monthly
average concentration shall not exceed 15% and the reported concentration was 24.8%. Heavy rainfall on February 24th resulting in high
flows for almost 24 hours upset our plant. BOD and TSS weekly results were both in compliance by the next week.
Requirements: none
Recommendations: none
NOD: DYES ® NO
NOV: OYES ® NO
QNCR: OYES ® NO
POTW Rating:
Satisfactory @ Marginal ❑ Unsatisfactory 0
PCI COMPLETED BY: Tricia Lowery DATE: 9/29/2022
NC DWR Pretreatment Compliance Inspection (PCI) Form
Updated August 2022 Page 5