NC0024333_Inspection_20230525

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Scott Clark, Water Resources Director
City of Monroe
Post Office Box 69
Monroe, North Carolina 28111-0069
SUBJECT: Pretreatment Audit Inspection
City of Monroe
NPDES Permit No. NCO024333
Union County
Dear Mr. Clark:
NORTH CAROLINA
Environmental Quality
May 25, 2023
Enclosed is a copy of the Pretreatment Audit Inspection (PAI) Report for the inspection of the City of Monroe's Industrial
Pretreatment Program on May 17, 2023, by Mr. Wes Bell of this Office. This Office would like to thank all Pretreatment staff
for their cooperation and the assistance provided throughout this inspection. Please advise the City's Pretreatment staff of our
findings by forwarding the enclosed report.
Should you have any questions concerning this report, please do not hesitate to contact Mr. Bell at [phone] or at
wes.bell(a,ncdeq.nc. gov.
Sincerely,
EA
DocuSigned by:
�•�Guw N Pam►
F161 F669A2D84A3...
Andrew H. Pitner, P.G.
Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
Enclosure: Inspection Report
Cc: NPDES Program Files - Laserfiche
D North Carolina Department of Environmental Quality I Division of Water Resources
Mooresville Regional Office 1 610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115
704.663.1699

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT AUDIT REPORT
Background Information
1. Control Authority (POTW) Name: City of Monroe
2. Control Authority Representative(s): Kevin Keesler, Kyle Ketchum
3. Title(s): Pretreatment Coordinator, Wastewater Superintendent
4. Address of POTW:
Mailing: P.O. Box 69
City: Monroe Zip Code: 28111
Pretreatment Coordinator Phone Number [phone] Fax Number [phone] E-Mail kkeeslernmonroenc.org
Wastewater Superintendent [phone] kketchumnmonroenc.org
5. Audit Date 05/17/2023
6. Last Inspection Date: 06/21/2021 Inspection Type: ® PCI ❑ 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. A monthly average effluent cyanide violation was reported for January 2022. The violation was
attributed to interferences and the influent values were below detection for the entire month (weekly sampling).
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
INIC101012 I4 13 13 I3
MM/DD/YY
105 117 123
10.
....................................................................................................................................................................................................................................................................................................
Current Number of Significant Industrial Users (SIUs)?
14
11.
....................................................................................................................................................................................................................................................................................................
Number of SIUs with No IUP, or with an Expired IUP?
0
12.
....................................................................................................................................................................................................................................................................................................
Number of SIUs Not Inspected by POTW in Last Calendar Year?
0
13.
....................................................................................................................................................................................................................................................................................................
Number of SIUs Not Sampled by POTW in Last Calendar Year?
0
14.
....................................................................................................................................................................................................................................................................................................
Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi -Annual Periods?
1
15.
...................................................................................................
Number of SIUs in SNC for Reporting. During Either of Last 2 Semi -Annual Periods?
...................................................................................................................
0
16.
....................................................................................................................................................................................................................................................................................................
Number of SIUs in SNC with Pretreatment Schedule?
0
17.
....................................................................................................................................................................................................................................................................................................
Number of SIUs on Schedules?
0
18.
Current Number of Categorical Industrial Users (CIUs)?
7
19.
Number of CIUs in SNC?
0
NC DWR Pretreatment Audit Form Revised: December 2016 Page 1

20. PRETREATMENT PROGRAM ELEMENTS REVIEW:
Program Element
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
06/29/20
® Yes ❑ No
10/29/21
® Yes ❑ No
10/O1/25
Industrial Waste Survey (IWS)
10/O1/19
® Yes ❑ No
12/26/19
® Yes ❑ No
10/O1/24
Sewer Use Ordinance (SUO)
12/27/12
® Yes ❑ No
01/04/13
® Yes ❑ No
Enforcement Response Plan (ERP)
06/02/20
® Yes ❑ No
09/02/20
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
07/27/16
® Yes ❑ No
08/29/16
® 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. Union County (Wingate and Marshville)
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 05/21/2013
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
N/A
Resources
29. Please Rate the Following: S=Satisfactory M=Marginal U=Unsatisfactory
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
®S ❑M ❑U
Access to POTW Vehicles for
Sampling, Inspections, and
®S ❑M ❑U
Emergencies
Access to Operable Sampling
Equipment
®S ❑M ❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
®S ❑M ❑U
Reference Materials
®S ❑M ❑U
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
®S ❑M ❑U
Computer Equipment (Hardware and
Software)
®S ❑M ❑U
NC DWR Pretreatment Audit Form Revised: December 2016 Page 2

30. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No
Explain Yes or No. Excell,
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Permit application fees, annual administration fees, surcharges.
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. A SIU (DiscoverFresh IUP#: CM-36) has been temporarily closed but may initiate
permanent closure plans.
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? A written request would be submitted to the Water
Resources Director and/or Wastewater Superintendent and files would be reviewed at the Pretreatment Office with POTW
staff in attendance.
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? A written request would be submitted to the Water Resources
Director and/or Wastewater Superintendent and confidential files would be kept in a locked file cabinet. The Water
Resources Director, Wastewater Superintendent and City Attorney would all be involved with the review/approval process.
35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? ® Yes ❑ 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 ® N/A
Permitting (Industrial Waste Survey-IWS)
38. How does the POTW become aware of new or changed Users? New permits received by the POTW's Permit Center
are reviewed and sent to the Water Resources Engineering Department and Pretreatment staff for additional
evaluations. Satellite communities contact the Pretreatment staff to discuss/review new users/permits. The
Pretreatment staff perform industrial waste surveys in these satellite communities. The Monroe -Union County
Economic Development staff also contact the Pretreatment staff for guidance regarding potential future industrial
users.
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
SILT?) IWS Short/Long Form information (including site visits), process wastewater flow, potential impacts based
on industrial processes, POCs, categorical processes.
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 (groundwater remediation systems)
Please list each site and how it is permitted, if applicable. Catalant and Thompkins BP Holdings/local permits.
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) POTW accepts waste from a septage hauler under a local permit. The septage hauler is
randomly sampled with tracking manifests. No trucked industrial waste is accepted.
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?
45. If yes to #44, What is being done to address the over allocations? (short-term IUPs, HWA to be revised, pollutant study, etc.)
46. Does the POTW keep pollutant loading in reserve for future growth / safety? ® Yes ❑ No
If yes, what percentage of each parameter 20% (except ammonia <5%)
NC DWR Pretreatment Audit Form Revised: December 2016 Page 3

47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) ❑ Yes ® No
If yes, Explain.
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) Application information, NPDES POCs,
categorical parameters, conventional parameters to establish a baseline.
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
New SIUs would be required to monitor monthly for a year (minimum) to establish a baseline; Semi-annual monitoring for
all SIUs at a minimum.
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. Compliance Judgment Worksheet used for SNC determinations,
Division approved ERP is followed for all violations (limit, reporting, permit conditions, etc.).
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?
The POTW requires all SIUs to implement a slug/spill control plan.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Emergency contacts kept up to date, employee training, proper secondary containment/chemical storage practices,
presence of spill response equipment/material.
56. How does the POTW decide where the sample point for an SILT should be located?
Sampling is preferred only on the regulated waste streams.
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 ❑ No SIU: ® Yes ❑ No If yes, Explain. Sampling SOPS, sampler O&M manuals
58. Who performs sample analysis for the POTW for Metals: Pace Analytical Services
Conventional Parameters: Pace Analytical Services
Organics: Pace Analytical Services
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
POTW uses internal and contracted lab's COCs; SIUs use the contracted lab's COC.
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.
60d.
60e.
60f.
Is LTMP/STMP Data Maintained in Table or Equivalent? ® YES ❑ NO Is Table Adequate? ® YES ❑ NO
All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? ® YES ❑ NO
If NO to any above, list violations
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
❑More LTMP data available ❑Resolve over allocation ❑5 year expiration
Explain.
❑NPDES limits change
❑ Other
NC DWR Pretreatment Audit Form Revised: December 2016 Page 4

63. In general, what is the most limiting criteria of your HWA? ❑Inhibition ❑ Pass Through ®Sludge Quality
64. Do you see any way to increase your loading in the future (Example: obtaining more land for sludge disposal)? ❑ Yes ❑ No
Explain. N/A - WWTP has sufficient capacity.
Summary
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment? No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW
66. User Name
1. Charlotte Pipe & Foundry
2. ORO Manufacturing Co.
3. Pilgrim's Pride Corp.
67. IUP Number
CM-24
CM-25
CM-28
68. Does File Contain Current Permit?
F ® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
69. Permit Expiration Date
6/30/25
6/30/25
6/30/24
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
N/A
433
N/A
71. Does File Contain Permit Application Completed Within One Year Prior
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
to Permit Issue Date?
72. Does File Contain Inspection Completed Within Last Calendar Year?
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
73. a. Does File Contain Slug/Spill Control Plan?
a. ®Yes ❑No
a. ®Yes ❑No
a. ®Yes ❑No
b. If No, is One Needed? (See Inspection Form from POTW)
b. ❑Yes ❑No
b. ❑Yes ❑No
b. ❑Yes ❑No
74. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
❑Yes❑No®N/A
®Yes❑No❑N/A
❑Yes❑No[D
7
Organic Management Plan (TOMP)?
75. a. Does File Contain Original Permit Review Letter from Division?
a. ®Yes ❑No
a. ®Yes ❑No
a. ®Yes ❑No
b. All Issues Resolved?
b.❑Yes❑No®N/A
b.❑YemNo®N/A
b.❑Yes❑No®N/A
76. During Most Recent Semi -Annual Period, Did POTW Complete its
® Yes ❑ No
® Yes ❑ No
1[
® Yes ❑ No
Sampling as Required by IUP, including Flow?
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
78. During Most Recent Semi -Annual Period, Did SIU Complete its
OYesNoN/A
F11
®Yes❑No❑N/A
®Yes❑No❑N/A
Sampling as Required b IUP, includingFlow?
79. During Most Recent Semi -Annual Period, Did SIU submit all reports on
®Yes❑No❑N/A
®Yes❑No❑N/A
®Yes❑No❑N/A
time?
80a. For categorical IUs with Combined Wastestream Formula (CWF), does
0Yes0No[9
❑Yes❑No®N/A
❑Yes❑No®N/A
file include process/dilution flows as Required b IUP?
80b. For categorical IUs with Production based limits, does file include
❑Yes❑No[D
❑Yes❑No®N/A
❑Yes❑No®N/A
production rates and/or flows as Required by IUP?
81. During Most Recent Semi -Annual Period, Did POTW Identify All
®Yes❑No❑N/A
❑Yes❑No®N/A
❑Yes❑NoON/A
Limits Non -Compliance from Both POTW and SIU Sampling?
82. During Most Recent Semi -Annual Period, Did POTW Identify All
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑NOON/A
Re ortin Non-Com liance from SIU Sampling?
83. a. Was POTW Notified by SILT (Within 24 Hours) of All Self-
a.®Yes❑No❑N/A
a.❑Yes❑No®N/A
a.❑Yes❑No®N/A
Monitoring Violations?
b. Did Industry Resample and submit results to POTW within 30 Days?
b.❑Yes❑No®N/A
b.❑Yes❑No®N/A
b.❑Yes❑No®N/A
c. If applicable, did POTW resample and obtain results within 30 days of
c.❑Yes❑No®N/A
becomingaware of SIU limit violations in the POTW's sampling of SIU?
c.❑Yes❑No®N/A
c.❑Yes❑No®N/A
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
❑
Yes
®
No
❑
Yes
®
No
❑
Yes
®
No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
®Yes❑No❑N/A
❑Yes❑No®N/A
❑Yes❑No®N/A
Specified in POTW's ERP (NOVs, Penalties, timing, etc.)?
86. Does File Contain Penalty Assessment Notices?
❑Yes❑No®N/A
❑Yes❑No[D
❑Yes❑No®N/A
87. Does File Contain Proof Of Penalty Collection?
❑Yes❑No[D
❑Yes❑No®N/A
❑Yes❑NoON/A
88. a. Does File Contain Any Current Enforcement Orders?
a.❑Yes❑No®N/A
Fb.[1YesE1No0N/A
a.❑Yes❑No®N/A
a.❑Yes❑No®N/A
b. Is SIU in Compliance with Order?
b.❑Yes❑No®N/A
b.❑Yes❑No®N/A
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
❑ Yes ® No
❑ Yes ®No
❑ Yes ® No
Information For You?
NC DWR Pretreatment Audit Form Revised: December 2016 Page 5

FILE REVIEW COMMENTS:
10. Tyson Farms, Inc. (IUP #: CM-11) was in SNC for ammonia limit violations (TRC) during second half of 2022.
72. POTW performed SIU inspections on 10/11/22 (Charlotte Pipe & Foundry), 10/10/22 (ORO Manufacturing Co.) and 10/5/22
(Pilgrim's Pride Corp.).
73. The slug/spill plan for ORO Manufacturing Co. will need to be updated to include all chemicals by name, quantity, etc. as required
in the SIU's IUP (Permit Condition Reference: Part III, #1 Slug/Spill Control Plan).
78. The following labs were contracted by the SIUs for sampling/analyses: Pace Analytical Services (Charlotte Pipe & Foundry),
Waypoint Analytical (ORO Manufacturing Co.) and Environmental Chemists, Inc. (Pilgrim's Pride Corp.).
81/85. The POTW issued Notice of Noncompliances (NONCs) to Charlotte Pipe & Foundry for nineteen (19) daily maximum flow limit
violations that occurred from July through December 2022.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
I N I C 1 0 1 0 1 2 14 1 3 1 3 1 3 1 05 1 17 1 23 1
1. Industry Inspected: Pilgrim's Pride Corp.
2. Industry Address: PO Box 668, 5901 W. Marshville Blvd., Marshville, NC 28103
3. Type of Industry/Product: Poultry Slaughter and Processing
4. Industry Contact: Ying Pong George Chang Title: Complex Environmental Manager Phone: [phone]
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 Pilgrim's Pride Corporation (PPC) manufacturing facility processes approximately 650,000 chickens per week. The facility
currently has 800 employees and operates two shifts per day, five days per week. There is also a third shift each day that sanitizes
production areas. The feathers and blood are transported to the Valley Protein processing facility. The rendered meat is transported to
PPC's Sumter, South Carolina plant. The pretreatment facility includes screening, chemical addition, DAF, dual lagoons (in series) and
flow measurement. DAF sludge is land applied in South Carolina by Denali Water Solutions.
As indicated in the POTW's SIU inspection form (Division's Model Form), PPC will need to repair the secondary containment
structure in the chemical storage building (containing sanitizing chemicals, etc.). PPC's records were organized and were adequately
reviewed by POTW staff.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 6

AUDIT SUMMARY/COMMENTS:
The POTW must ensure all SIU Slug/Spill Control Plans adhere to the requirements listed in the IUP permit conditions (Part
III).
The POTW's records were organized and well maintained. The POTW's Industrial Pretreatment Program was being properly
implemented.
NOD: ❑ Yes
® No
NOV: ❑ Yes
® No
QNCR: ❑ Yes
® No
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory ❑
a—"96D9OCC3437
cuSigneddby:
Audit COMPLETED BY: ... DATE: 5/25/2023
Wes Bell, Env. Specialist II, WQROS, DWR/Mooresville Regional Office
DocuSigned by:
...
Audit Reviewed By: EF161FB69A2D84A3DATE:
Andrew H. Pitner, Regional Supervisor, WQROS, DWR/Mooresville Regional Office
NC DWR Pretreatment Audit Form Revised: December 2016 Page 7