NC0021211_Graham_PCI_Cover Letter_20220930

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Tonya Mann, Utilities Director
City of Graham
PO Drawer 357
Graham, NC 27253-0357
NORTH CAROLINA
Environmental Quality
October 4, 2022
SUBJECT: Pretreatment Compliance Inspection (PCI)
City of Graham
Main Program Permit (NPDES) #NC0021211
Alamance County
Dear Ms. Mann:
On 9/29/2022 a Pretreatment Compliance Inspection (PCI) was performed by Tricia Lowery of the
Winston-Salem Regional Office. Shelby Smith was present for the inspection. The purpose of this
inspection was to determine the effectiveness of the City's pretreatment program, which includes
reviewing the files, POTW plant performance, industry monitoring data, and adherence to the
enforcement response plan (ERP).
Background
This is a 3.5 MGD permitted facility. The City has 5 Significant Industrial Users (Sills), 3 of which are
categorical. The publicly owned treatment works (POTW) had 2 violations in 2022 (02/22 for weekly BOD
and TSS) which resulted in an NOD.
POTW Interview
All dental amalgam reports are complete and in good order. One SIU was in SNC — Novaflex. Notices of
Violations were issued to SIU including a public notice. The SNC did not disturb POTW operations and
enforcement response plan was executed appropriately. One SIU, Prescient Company (Categorical - IUP
#3001) closed and is no longer in operation. All files are in good order and were easily retrieved for
inspector to review. New conditions for the Pretreatment program were added to POTW permit renewal
which required updated HWA, IWS and LTMP to be submitted no later that 180 days from September 28,
2022. Ms. Smith has satisfied the requirements of these conditions.
Pretreatment Program Elements Review
The Headworks Analysis (HWA) was recently submitted on 9/28/2022. The next HWA due date is TBA.
The IWS was recently submitted on 9/28/2022. The next IWS is due date is TBA.
The Sewer Use Ordinance (SUO) was approved on 9/14/2011.
The Enforcement Response Plan (ERP) was submitted on 2/7/2020 and approved on 2/14/2020.
GDE
NORTH C OLI JA '
omm mr� ep..of o�.i
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105
336.776.9800

The Long -Term Monitoring Plan (LTMP) was recently submitted on 9/28/2022 and awaiting approval.
LTMP File Review
The Long -Term Monitoring Plan (LTMP) is being conducted at the proper locations and frequencies
(2/year).
Industrial User Permit (IUP) File Review
A review of the file for Cintas (#0007) revealed that the monitoring data was well organized and
compliant.
A review of the file for Metal Impact (#2001) revealed that the monitoring data was well organized and
compliant.
A review of the file for Stericycle (#0030) revealed that the monitoring data was well organized and
compliant.
The slug control plan for Cintas (#0007) was in good order.
The slug control plan for Metal Impact (#2001) was in good order.
The slug control plan for Stericycle (#0030) was in good order.
Action Items
No other action items were noted.
The pretreatment program is considered satisfactory. Shelby Smith runs an adequate and good pretreatment
program. If you have any questions, please contact Tricia Lowery or me at [phone].
Sincerely,
LDocuSigned by:<
mitte
145B49E225C94EA...
Lon T. Snider
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
Attachment:
1. NC DWR Pretreatment Compliance Inspection (PCI) Report
cc: Municipal Permitting Unit — Keyes McGee (Laserfiche)
WSRO Files (electronic)
D_E
NORTH CAROLINA
gaparMeM of Environment,/quay
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 W. Hanes Mill Rd, Suite 300 I Raleigh, North Carolina 27105
336.776.9800