NC0055786_Report of Pretreatment Audit Inspection_20221018

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
,g ou.no.
NORTH CAROLINA
Environmental Quality
October 18, 2022
Mr. Tom Johnson — Water Resources Director
City of Lexington
28 West Center Street
Lexington, North Carolina 27292
SUBJECT: Pretreatment Audit Inspection (PAI)
City of Lexington
NPDES# NC0055786
Davidson County
Dear Mr. Johnson:
On September 27, 2022 a Pretreatment Audit Inspection (PAI) was performed by Jim Gonsiewski
of the Winston-Salem Regional Office. Ms. Eglantina Minerali was present for the inspection. The
purpose of this inspection was to determine the effectiveness of the City's pretreatment program,
which included a detailed file review, review of the POTW performance, planning, sampling, and
compliance judgement program, and adherence to the enforcement response plan (ERP).
Additionally, an inspection of the Schutz Container facility was conducted in conjunction with an
inspection by the City of Lexington.
Background
This is a 6.5 MGD permitted facility. The City has six (6) Significant Industrial Users (SIU). Five
(5) are categorical.
POTW Interview
The publicly owned treatment works (POTW) was non -complaint for BOD in April, 2021. The
Ammonia monthly average limit was exceeded in May 2021 due to electrical work at the POTW.
In March 2022 there were monthly and weekly BOD exceedances due to aeration basin
rehabilitation and unforeseen high flow with half the plant being offline for cleaning and major
repairs. As a result, there was a solids washout into the polishing ponds. In April 2022 there was
a monthly exceedance of BOD and Ammonia due to a solids washout. The POTW was fully
operational by the end of April. In May 2022 there were monthly and weekly exceedances of
BOD and Ammonia. In June 2022 there was a BOD exceedance. Effluent from the final clarifiers
was within limits. Rain events upset the ponds and caused the BOD and Ammonia to be out of
compliance. A contractor was scheduled to clean the ponds starting in late July 2022. In August
2022 there was a monthly Ammonia exceedance. This was likely caused by dredging of the ponds.
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

Ammonia samples are collected daily at the #6 manhole just ahead of the ponds. Ammonia results
from this manhole have been <1 mg/L.
Pretreatment Program Elements Review
The Headworks Analysis (HWA) renewal was submitted on January 30, 2020. The HWA was
approved on July 16, 2020. The next HWA is due on July 1, 2024.
The last Industrial Waste Survey (IWS) was submitted on November 28, 2020. The IWS was
approved on December 2, 2020. The next IWS is due on November 23, 2025.
The Sewer Use Ordinance (SUO) was approved on January 9, 2013.
The Enforcement Response Plan (ERP) was approved on February 13, 2020.
The Long Term Monitoring Plan (LTMP) was approved on March 11, 2021.
LTMP File Review
The Long -Term Monitoring Plan (LTMP) is being conducted at the proper locations and
frequencies.
Industrial User Permit (IUP) File Review
A review of the file for MATCOR (#0012) revealed that the monitoring data was well organized
and compliant.
A review of the file for Egger (#0014) revealed that the monitoring data was well organized and
compliant.
A review of the file for Schutz (#0010) revealed that the monitoring data was well organized and
compliant.
The slug control plan for MATCOR (#0012) was in good order.
The slug control plan for Egger (#0014) was in good order.
The slug control plan for Schutz (#0010) was in good order.
npRCD_E
nev..eoe.n a Emetrume.m aueehr
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

Action Items
No other action items were noted.
The pretreatment program is considered satisfactory. Ms. Minerali runs an excellent pretreatment
program. If you have any questions please contact Jim Gonsiewski or me at [phone].
Sincerely,
EDocuStpned by:
4A. T. S�tAcr
145949E225C94EA...
Lon T. Snider
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
Enclosure: PAI Report
cc: PERCS Unit — Mike Montebello (Electronic Copy)
WSRO Electronic Files
Laserfiche Files
DEQ
De WIN t0l E.womaoW auWh `I
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

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT AUDIT REPORT
Water Resources
ENVIRONMENTAL QUALITY
Background Information tComplete prior to audit; review Program Info Database Sheet(s)1
1. Control Authority (POTW) Name: City of Lexington
2. Control Authority Representative(s): Eglantina Minerali
3. Title(s): Lab supervisor/ Pretreatment Coordinator
4. Address of POTW:
Mailing: 500 Glendale Rd
City Lexington Zip Code 27292
Phone Number 336 2503602 Fax Number 336 3577369 E-Mail emineraWlexingtonnc.gov
5. Audit Date 09/27/2022
6. Last Inspection Date: 04/14/2021 Inspection Type: ® PCI El Audit
7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s) ? ® Yes ❑ No
If No, Explain.
8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? ® Yes ❑ No
If Yes, Explain. BOD exceedances in April 2021, March 2022, April 2022, May 2022, and June. 2022. NH3
monthly average limit exceeded in May 2021, May 2022, and August 2022.
9. Is POTW under an Order That Includes Pretreatment Conditions? ❑ Yes ® No
Order Type and Number: Are Milestone Dates Being Met? ❑ Yes ❑ No ® NA
Parameters Covered Under Order
ICIS Coding
Main Program Permit Number
INICIOI015 Is 17 18 I6 1
10. Current Number of Significant Industrial Users (SIUs)?
11. Number of SIUs with No IUP, or with an Expired IUP?
12. Number of SIUs Not Inspected by POTW in Last Calendar Year?
13. Number of SIUs Not Sampled by POTW in Last Calendar Year?
MM/DD/YY
12 1 1 1 21 1
14. Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi -Annual Periods?
15. Number of SIUs in SNC for Reporting During Either of Last 2 Semi -Annual Periods?
16. Number of SIUs in SNC with Pretreatment Schedule?
6
0
0
0
0
0
0
17. Number of SIUs on Schedules?
0
18. Current Number of Categorical Industrial Users (CIUs)?
19. Number of CIUs in SNC?
5
0
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 1

20. PRETREATMENT PROGRAM ELEMENTS REVIEW- Review POTW files, verify POTW has copy of each Program Element
in their File, complete with all supporting documents and PERCS Approval Letter, and dates consistent with Program Infi
Program Element
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
1/30/2020
Yes ❑ No
7/16/2020
V Yes ❑ No
7/1/2024
Industrial Waste Survey (IWS)
11/28/2020
l:1 Yes ❑ No
12/2/2020
/1 Yes ❑ No
11/23/2025
Sewer Use Ordinance (SUO)
1/8/2013
/1 Yes ❑ No
1/9/2013
/1 Yes ❑ No
Enforcement Response Plan (ERP)
2/3/2020
I Yes ❑ No
2/13/2020
0 Yes ❑ No
Long Term Monitoring Plan (LTMP)
9/24/2020
J Yes ❑ No
3/11/2021
' Yes ❑ No
Legal Authority (Sewer Use Ordinance-SUO)
21. Do you have any towns and/or areas from which you receive wastewater which are not in your annexed jurisdiction?
® Yes ❑ No If yes, please list these towns and/or areas. The City of Lexington has an active agreement to serve sewer in the
County that are outside of the City limits. They cover the entire county.
22. If yes to #21, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? ❑ Yes ® No ❑ NA
A copy, if not already submitted, should be sent to Division.
23. If yes to #21, Have you had any trouble working with these towns or districts? ❑ Yes ® No ❑ NA
If yes, Explain.
24. Date of Last SUO Adoption by Local Council 2/25/2013
25. Have you had any problems interpreting or enforcing any part of the SUO? ❑ Yes ® No
If yes, Explain.
Enforcement (Enforcement Response Plan-ERP)
26. Did you send a copy of the ERP to your industries? ® Yes ❑ No
If no, POTW must send copy within 30 days.
27. Have you had any problems interpreting or enforcing any part of the ERP (i.e. any adjudication, improper enforcement, etc?
❑ Yes ® No If yes, Explain.
28. List Industries under a Schedule or Order and Type of Schedule or Order
Resources
29. Please Rate the Following: S=Satisfacto
M=Marginal U=Unsatisfacto
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
/1 S ❑ M ❑ U
Access to POTW Vehicles for
Sampling, Inspections, and
Emergencies
►/S ❑M ❑U
Access to Operable Sampling
Equipment
/1 S ❑ M ❑ U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
►1 S ❑ M ❑ U
Reference Materials
/IS ❑M ❑U
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
►IS ❑M ❑U
NC DWR Pretreatment Audit Form
Revised: December 2016
Page 2

Computer Equipment (Hardware and
Software)
®S ❑M ❑U
30. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No
Explain Yes or No.
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Billing the industries for monitoring and sampling.
Public Perception/ Participation
32. Are there any local issues affecting the pretreatment program (e.g.. odor, plant closing, new or proposed plants)?
❑ Yes ® No If yes, Explain.
33. Has any one from the public ever requested to review pretreatment program files? ❑ Yes ® No
If yes, Explain procedure. If no, how would the request be addressed?
34. Has any industry ever requested that certain information remain confidential from the public? ❑ Yes ® No If yes, Explain
procedure for determining whether information qualified for confidential status, as well as procedure for keeping files confidential
from public. If no how would the request be addressed? Send the request to the Water Resources Director, Tom Johnson.
35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? ® Yes El No
36. Is the public notified about changes in the SUO or Local Limits? ® Yes ❑ No
37. Were all industries in SNC published in the last notice? ® Yes ❑ No
Permitting (Industrial Waste Survey-IWS)
38. How does the POTW become aware of new or changed Users? Monthly communication with Business and
Community Development Department.
39. Once the POTW becomes aware of new or changed Users, how does the POTW determine which industries have the
reasonable potential to adversely impact the WWTP and therefore require a new permit or a permit revision? (Who is an
SIU?) Short form or/and long form is sent to collect the appropriate information.
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
®Yes ❑No If Yes, how many are there? 2.
Please list each site and how it is permitted, if applicable. Davidson County Landfill, pump and haul to the PTOW.
The Former Duracell site in Lexington (very low volumes). Not permitted
41. Does the POTW accept waste by (mark if applicable) ® Truck ❑Dedicated Pipe ❑ NA
42. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples drawn,
manifests required) Designated point. Samples drawn.
43. How does the POTW allocate its loading to industries? Mark all that apply
❑ Uniform Limits ® Historical Industry Need ❑ By Surcharge ® Categorical Limits ❑ Other
Explain Other:
44. Review POTW's copies of current allocation tables for each WWTP. Are there any over allocations? ® Yes ❑ No
If yes, what parameters are over allocated? TSS, Ag
45. If yes to #44, What is being done to address the over allocations? (short-term IUPs, HWA to be revised, pollutant study, etc.)
Changed the influent sampling point on 7/23/2020. BOD and TSS loading have dropped since then.
46. Does the POTW keep pollutant loading in reserve for future growth / safety? ® Yes ❑ No
If yes, what percentage of each parameter
47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) ❑ Yes ® No
If yes, Explain.
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 3

48. How does the POTW decide on which pollutants to limit in the permits? Monitor for? (for example: were only those pollutants
listed on the application limited; categorical parameters; NPDES Pollutants of Concern)
Categorical Parameters and Local Limits
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
All SIUs sampled quarterly, other Ws semiannual or annually.
Permit Compliance
50. Does the POTW currently have or during the past year had any permits under adjudication? ❑ Yes ® No
If yes, which industries? What was (will be) the outcome of the adjudication?
51. Demonstrate how the POTW judges compliance. This should include compliance judgment on all violations of limits, reporting
requirements, and permit conditions, as well as for SNC, Background information from the NC DEQ and the HWA
Workshop.
52. Does the POTW use the Division's model inspection form or equivalent? ® Yes ❑ No
If no, does the POTW form include all Division data? ❑ Yes ❑ No
53. Were all SIUs evaluated for the need of a slug/spill control plan during their most recent inspections? ® Yes ❑ No
If no, Explain.
54. What criteria are used to determine if a slug/spill control plan is needed?
What materials are stored, the volume of production, material storage.
55, What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Do they have a plan with all emergency telephone numbers and names. Are the telephone numbers updated.
56. How does the POTW decide where the sample point for an SIU should be located?
This depends on what they are permitted for. The sampling points should be safe and accessible.
57. Has the POTW established a procedure to ensure that representative samples will be taken by the POTW or SIU each time?
(example: correct location; proper programming of sampler; clean equipment; swirling the sample bucket uniformly)
POTW: ® Yes El No SIU: ❑ Yes ® No Byes, Explain. The SIU does no sampling. The POTW completes
all sampling.
58. Who performs sample analysis for the POTW for Metals E1
Conventional Parameters in house
Organics E1
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis (HWA)
60a. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑ NO
60b. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ® YES ❑ NO
60c. Is LTMP/STMP Data Maintained in Table or Equivalent? ® YES ❑ NO Is Table Adequate? ® YES El NO
60d. All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? ® YES ❑ NO Division Inspector, verify yourself!
60e. If NO to any above, list violations
60f. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ® NO
If yes, which ones? Eliminated: Added:
61. Do you complete your own headworks analysis (HWA) ? ® Yes ❑ No
If no, who completes your HWA? Phone ( )
62. Do you have plans to revise your HWA in the near future? ❑ Yes ® No
If yes, what is the reason for the revision? (mark all that apply) ❑Increased average flow
❑NPDES limits change
❑More LTMP data available ['Resolve over allocation 05 year expiration ['Other
Explain.
63. In general, what is the most limiting criteria of your HWA? ®Inhibition ❑ Pass Through ❑Sludge Quality
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 4

64. Do you see any way to increase your loading in the future (Example: obtaining more land for sludge disposal)? ❑ Yes ® No
Explain. Not before 10 years.
Summary
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
No
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 5

INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION
66. User Name
I. MATCOR
2. Egger
3. Schutz
67. IUP Number
0012
0014
0010
68. Does File Contain Current Permit?
/1 Yes ❑ No
►1 Yes ❑ No
0 Yes ❑ No
69. Permit Expiration Date
5/31/24
3/16/26
5/31/24
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
Yes
Yes
Yes
71. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
// Yes ❑ No
►/ Yes ❑ No
0 Yes ❑ No
72. Does File Contain Inspection Completed Within Last Calendar Year?
/1 Yes ❑ No
/4 Yes ❑ No
8 Yes ❑ No
73. a. Does File Contain Slug/Spill Control Plan?
b. If No, is One Needed? (See Inspection Form from POTW)
a. ►S Yes ■ No
b. •Yes ❑No
a. ► Yes ■ No
b. ■Yes •No
a. ►• Yes ❑No
b. •Yes •No
74, For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
Organic Management Plan (TOMP)?
®Yes❑No❑NIA
❑Yes❑NoON/A
❑Yes❑NoON/A
75. a. Does File Contain Original Permit Review Letter from Division?
b. All Issues Resolved?
a. ►A Yes •No
b.❑Yes❑No®N/A
a. Yes •No
b.❑Yes❑No®N/A
a. ►:lYes ■No
b.❑Yes❑No®N/A
76. During Most Recent Semi -Annual Period, Did POTW Complete its
Sampling as Required by IUP, including Flow?
/1 Yes ❑ No
►1 Yes ❑ No
/g Yes ❑ No
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
/1 Yes ❑ No
►/ Yes ❑ No
' Yes ❑ No
78. During Most Recent Semi -Annual Period, Did SIU Complete its
Sampling as Required by IUP, including Flow?
❑Yes❑No®N/A
❑Yes❑NoON/A
❑Yes❑NoON/A
79. During Most Recent Semi -Annual Period, Did SIU submit all reports on
time?
®Yes❑No❑N/A
®Yes❑No❑N/A
®Yes❑No❑N/A
80a. For categorical IUs with Combined Wastestream Formula (CWF), does
file include process/dilution flows as Required by IUP?
❑Yes❑NoON/A
❑Yes❑No®N/A
❑Yes❑NoON/A
80b. For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
❑Yes❑NoON/A
❑Yes❑No®N/A
❑Yes❑NoON/A
81. During Most Recent Semi -Annual Period, Did POTW Identify All
Limits Non -Compliance from Both POTW and SIU Sampling?
a Yes ❑ No
❑ Yes ❑ No
None
❑ Yes ❑ No
None
82. During Most Recent Semi -Annual Period, Did POTW Identify All
Reporting Non -Compliance from SIU Sampling?
❑Yes❑No®N/A
❑Yes❑NoON/A
❑ Yes ❑NoON/A
83. a. Was 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 and obtain results within 30 days of
becoming aware of SIU limit violations in the POTW's sampling of SIU?
a.❑Yes❑No®N/A
b.❑Yes❑No®N/A
c.❑Yes❑No®N/A
a.❑Yes❑No®N/A
b.❑Yes❑No®N/A
c.❑Yes❑No®N/A
a.❑Yes❑No®N/A
b.❑YesDNo®N/A
c.❑Yes❑No®N/A
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
❑ Yes /1 No
❑ Yes /1 No
❑ Yes // No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
Specified in POTW's ERP (NOVs, Penalties, timing, etc.)?
❑Yes®No❑N/A
❑Yes❑NOON/A
❑Yes❑NoON/A
86. Does File Contain Penalty Assessment Notices?
❑Yes❑NoON/A
❑Yes❑NoON/A
❑Yes❑NOON/A
87. Does File Contain Proof Of Penalty Collection?
❑Yes❑NoON/A
❑Yes❑NoON/A
❑Yes❑NoON/A
88. a. Does File Contain Any Current Enforcement Orders?
b. Is SIU in Compliance with Order?
a.❑Yes❑No®N/A
b.❑Yes❑No❑N/A
a.❑Yes❑No®N/A
b.❑Yes❑No®N/A
a.❑Yes❑No®N/A
b.❑Yes❑No®N/A
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
Information For You?
❑ Yes ►1 No
❑ Yes /1 No
❑ Yes /1 No
FILE REVIEW COMMENTS:
MATCO had zinc and copper limit exceedances om 3/1/2021 and 2/23/2022.
NC DWR Pretreatment Audit Form Revised: December 2016
Page 6

INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
INICI0 to I5 Is 17 IR 16 I I 1271221
I. Industry Inspected: Shutz Container
2. Industry Address: 210 Walser Road, Lexington NC 27295
3. Type of Industry/Product: Washing plastic and steel drums
4. Industry Contact: Keith Murdock Title: Production manager Phone: [phone] Ex1832 Fax:
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:
The facility washes plastic and steel drums. It has approximately 110 employees who work in two shifts. It also recycles plastic
drums and totes and fabricates plastic totes. It is a very well -run facility with a good pretreatment system. The facility takes an
active role in improving the operation of the pretreatment system.
Audit SUMMARY AND COMMENTS:
Audit Comments: Very well -run program
Requirements:
Recommendations:
NOD: ['Yes ❑ No
NOV: ❑ Yes ❑ No
QNCR: ❑ Yes ❑ No
POTW Rating:
Satisfactory
Audit COMPLETED BY:
Marginal ❑ Unsatisfactory ❑
Jim Gonsiewski DATE: 10/18/2022
PERCS, and Winston-Salem Regional Office
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 7

United States Environmental Protection Agency
E PA Washington, D C. 20460
Water Compliance Inspection Report
Form Approved.
OMB No. 2040-0057
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code
1 1N 1 2 u
21111111
NPDES yr/mo/day Inspection
3 1 NC0055786 111 121 22/09/27 117
Type
18I G I
11111111111
Inspector Fac Type
19 I I 201 I
1111111111111111111111111
166
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA Reserved
871I 7° I5 1 711 1 721180
N I 73I 1 17471
I 11 1
11
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
Lexington Regional WWTP
500 Glendale Rd
Lexington NC 27292
Entry Time/Date
10:OOAM 22/09/27
Permit Effective Date
21/02/01
Exit Time/Date
01:30PM 22/09/27
Permit Expiration Date
P
25/04/30
Name(s) of Onsite Representative(s)fTitles(s)/Phone and Fax Number(s)
///
Other Facility Data
Name, Address of Responsible OfficialfTitle/Phone and Fax Number
Contacted
Joseph Shaffer,28 W Center St Lexington NC 272923099/Utility Plant
Supervisor/336-357-5090/3363577369 No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit • Records/Reports Pretreatment
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s)
Jim J Gonsiewski
of Inspector(s) Agency/Office/Phone and Fax Numbers Date
, Doousigned by: DWR/Division of Water Quality/336-776-9704/ 10/18/2022
�`•.. a01/15.1zurk.�
'-E197066F179045F...
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
OocuSigned by: 10/18/2022
1 -r. SMa�
EPA Form i ev-u-94) Previous editions are obsolete.
Page# 1

NPDES yrlmolday
31 NC0055786 I11 121 22/09/27
117
Inspection Type
18n
(Cont.)
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
On September 27, 2022 a Pretreatment Audit Inspection (PAI) was performed by Jim Gonsiewski of
the Winston-Salem Regional Office. Ms. Eglantina Minerali was present for the inspection. The
purpose of this inspection was to determine the effectiveness of the City's pretreatment program,
which included a detailed file review, review of the POTW performance, planning, sampling, and
compliance judgement program, and adherence to the enforcement response plan (ERP).
Additionally, an inspection of the Schutz Container facility was conducted in conjunction with an
inspection by the City of Lexington.
Background
This is a 6.5 MGD permitted facility. The City has six (6) Significant Industrial Users (SIU). Five (5)
are categorical.
POTW Interview
The publicly owned treatment works (POTW) was non -complaint for BOD in April 2021. The Ammonia
monthly average limit was exceeded in May 2021 due to electrical work at the POTW. In March 2022
there were monthly and weekly BOD exceedances due to aeration basin rehabilitation and
unforeseen high flow with half the plant being offline for cleaning and major repairs. As a result,
there was a solids washout into the polishing ponds. In April 2022 there was a monthly exceedance of
BOD and Ammonia due to solids washout. The POTW was fully operational by the end of April. In
May 2022 there were monthly and weekly exceedances of BOD and Ammonia. In June 2022 there
was a BOD exceedance. Effluent from the final clarifiers was within limits. Rain events upset the
ponds and caused the BOD and Ammonia to be out of compliance. A contractor was scheduled to
clean the pond starting in late July 2022. In August 2022 there was a monthly Ammonia exceedance.
This was likely caused by dredging of the ponds. Ammonia samples are collected daily at the #6
manhole just ahead of the ponds. Ammonia results from this manhole have been <1 mg/L.
Pretreatment Program Elements Review
The Headworks Analysis (HWA) renewal was submitted on January 30, 2020. The HWA was
approved on July 16, 2020. The next HWA is due on July 1, 2024.
The last Industrial Waste Survey (IWS) was submitted on November 28, 2020. The IWS was
approved on December 2, 2020. The next IWS is due on November 23, 2025.
The Sewer Use Ordinance (SUO) was approved on January 9, 2013.
The Enforcement Response Plan (ERP) was approved on February 13, 2020.
The Long Term Monitoring Plan (LTMP) was approved on March 11, 2021.
LTMP File Review
The Long -Term Monitoring Plan (LTMP) is being conducted at the proper locations and frequencies.
Industrial User Permit (IUP) File Review
A review of the file for MATCOR (#0012) revealed that the monitoring data was well organized and
compliant.
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Permit: NC0055786
Owner - Facility: Lexington Regional VWVfP
Inspection Date: 09/27/2022 Inspection Type: Pretreatment Audit
A review of the file for Egger (#0014) revealed that the monitoring data was well organized and
compliant.
A review of the file for Schutz (#0010) revealed that the monitoring data was well organized and
compliant.
The slug control plan for MATCOR (#0001) was in good order.
The slug control plan for Egger (#0014) was in good order.
The slug control plan for Schutz (#0010) was in good order.
Action Items
No other action items were noted.
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Permit: NC0055786
Inspection Date: 09/27/2022
Owner - Facility: Lexington Regional VWVfP
Inspection Type: Pretreatment Audit
Permit Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new ❑ ❑• El
application?
Is the facility as described in the permit? •❑ ❑ ❑
# Are there any special conditions for the permit? ❑ ❑ ❑ •
Is access to the plant site restricted to the general public? MOOD
Is the inspector granted access to all areas for inspection? ❑ ❑
Comment:
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