NC0064050_Pretreatment Audit_20231027

DocuSign Envelope ID: 533234C5-B2F4-425A-BOF2-33A76B139085
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Mr. Michael Deaton, P.E.
Director of Water Resources
Town of Apex
P.O. Box 250
Apex, NC 27502
NORTH CAROLINA
Environmental Quality
October 27, 2023
Subject: Pretreatment Compliance Audit
Town of Apex
NPDES Permit No. NCO064050
Wake County
Dear Mr. Deaton:
On July 18, 2023, Octavio Henriquez of the DWR Central Office and Cheng Zhang of the Raleigh
Regional Office (RRO) conducted a Pretreatment Compliance Audit of Town of Apex's pretreatment
program. The assistance given by Ms. Lori Avent, the pretreatment coordinator, was greatly
appreciated. The audit report is attached. Findings during the inspection were as follows:
1. Currently the town has two Significant Industrial Users (SIUs), both are also Categorical
Industrial Users (CIUs). It was noted that neither SIU was in SNC for the two most recent six-
month periods.
2. A review of the files containing the pretreatment program elements was conducted. These files
were available for review, up to date, and well organized.
3. Long Term Monitoring Plan (LTMP) data for Apex Water Reclamation Facility were reviewed
and it was noted that all locations were sampled with required frequencies and all samples
analyzed with required detection limits since last inspection, the only exception is higher
detection limit was used by contract laboratory for cadmium at Uncontrollable locations. Please
notify the laboratory to use the detection limit for the parameter at the sampling locations
specified in the Town's approved LTMP.
NORTH CAROLINAD ���
Depa ,M NE,Amnm WlQ-1K,
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office 1 3800 Barrett Drive I Raleigh, North Carolina 27609
919.791.4200

DocuSign Envelope ID: 533234C5-B2F4-425A-BOF2-33A76B139085
4. Industrial User Permit (IUP) file review revealed that during the second six-month period of
2022, Tipper Tie, Inc. (Permit No. 0002) and Tipper Tie II (Permit No. 00100) were in
compliance.
5. As part of the audit, Ms. Avent conducted a thorough and detailed SIU inspection at Tipper Tie
II.
Thank you for your continued support of the Pretreatment Program. If you have any questions or
comments, please call Cheng Zhang at [phone] (or email: [e-mail]).
Sincerely,
DocuSigned by:
f.
Vaun t,SSa
62916E6AB32144F...
Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Attachment(s): Town of Apex PT Audit Form
Cc: Laserfiche
Lori Avent, Town of Apex (Electronic copy only)
D � ��� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CAROLINA ��` 919.707.9000
nnpn .mo EnWromm�nfal nual

DocuSign Envelope ID: 533234C5-B2F4-425A-BOF2-33A76B139085
NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT AUDIT REPORT
Water Resources
ENVIRONMENTAL QUALITY
Background Information [Complete prior to audit; review Program Info Database Sheet(s)]
1. Control Authority (POTW) Name: Town of Apex
2. Control Authority Representative(s): Lori Avent
3. Title(s): Pretreatment Coordinator, Water Resources Specialist
4. Address of POTW:
Mailing PO Box 250
City Apex Zip Code 27502
Phone Number 919-249-3366 Fax Number 919-363-8780 E-Mail 1ori.aventAapexnc.or2
5. Audit Date 07/18/2023
6. Last Inspection Date: 7/21/2021 Inspection Type: PCI
7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s) ? ® Yes ❑ No
8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? ❑ Yes ❑ No
If Yes, Explain.
9. Is POTW under an Order That Includes Pretreatment Conditions? ❑ Yes ❑ No No
Order Type and Number: Are Milestone Dates Being Met? ❑Yes❑No❑N/A NA
Parameters Covered Under Order
ICIS Coding
Main Program Permit Number
INIC101016 14 IO Is 10 1
MM/DD/YY
1 07 1 18 123
10.
.................................................................
Current Number of Significant. Industrial Users(SIUs)?...............................................................................................
2
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?
0
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)?............................................................................................
2
19.
Number of CIUs in SNC?
0
NC DWR Pretreatment Audit Form Revised: December 2016 Page 1

DocuSign Envelope ID: 533234C5-B2F4-425A-BOF2-33A76B139085
20. PRETREATMENT PROGRAM ELEMENTS REVIEW- Review POTW files, verify POTW has copy of each Program Element
in their File. complete with all suDDortina documents and PERCS ADDroval 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)
12/31/2020
® Yes ❑ No
7/12/2022
® Yes ❑ No
7/1/2027
Industrial Waste Survey (IWS)
11/22/2019
® Yes ❑ No
2/11/2020
® Yes ❑ No
11/30/2024
Sewer Use Ordinance (SUO)
3/23/2012
® Yes ❑ No
4/2/2012
® Yes ❑ No
Enforcement Response Plan (ERP)
12/20/2019
® Yes ❑ No
2/5/2020
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
7/7/2022
® Yes ❑ No
7/13/2022
® 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 Will have soon. Area around Hwy 55 and Jenks Rd, Cary. IJA will address IWS requirements.
22. If yes to #21, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? An Apex Subdivision discharges to
Cary. Strictly residential, but IJA in place.
23. If yes to #21, Have you had any trouble working with these towns or districts? ❑ Yes ® No
If yes, Explain.
24. Date of Last SUO Adoption by Local Council 02/21/2012
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
28. List Industries under a Schedule or Order and Type of Schedule or Order
None
Resources
29. Please Rate the Following: S=Satisfactory M=Mareinal 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
®S ❑M ❑U
Additional Sampling and/or Analysis
Reference Materials
®S ❑M ❑U
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
®S ❑M ❑U
Computer Equipment (Hardware and
®S ❑M ❑U
Software)
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DocuSign Envelope ID: 533234C5-B2F4-425A-BOF2-33A76B139085
30. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No
Explain Yes or No. Uses Excel spreadsheets from State
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Lab analysis costs for POTW sampling events.
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? Anything would be provided to requestor unless
confidential.
34. Has any industry ever requested that certain information remain confidential from the public? ❑ Yes ® No
If no how would the request be addressed? SUO outlines procedures to gain confidential status
35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? ® Yes ❑ No
Quarterly at sampling events
36. Is the public notified about changes in the SUO or Local Limits? ® Yes ❑ No — Agenda on web site
37. Were all industries in SNC published in the last notice? N/A
Permitting (Industrial Waste Survey-IWS)
38. How does the POTW become aware of new or changed Users? IWS and permitting dept sends notice of any Cos.
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?) SUO definition
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
® Yes ❑ No 1 ground water remediation at Cooper Tools under a local permit.
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) N/A
43. How does the POTW allocate its loading to industries? Mark all that apply
❑ Uniform Limits XX 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? No. Not necessary.
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.
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 and POTW POCs
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
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Monthly due to monthly average limits; not having enough monthly average samples can cause SNC.
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. Uses compliance judgment worksheets.
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
If no, Explain.
54. What criteria are used to determine if a slug/spill control plan is needed?
EPA guidance manual — Control of Slug Loadings to POTWs; look for storage tanks, what's in it, containment, hazardous
aspects, risks.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
EPA guidance manual — Control of Slug Loadings to POTWs review checklist
56. How does the POTW decide where the sample point for an SIU should be located?
EPA Industrial Users Sampling Manual. Representative of production.
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. Lab SOP for CA; commercial lab samples for SIU
58. Who performs sample analysis for the POTW for Metals Env 1 or Enco
Conventional Parameters In -House
Organics Env 1 or Enco
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Has very good in-house COC, as well as field sheet with calibrations, etc.
Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis (HWA)
60a.
60b.
60c.
60d.
60e.
60f.
Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® Yes ❑ No
Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ❑ Yes ® No
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 ❑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
64. Do you see any way to increase your loading in the future (Example: obtaining more land for sludge disposal)? ❑ Yes ❑ No
® NA Final sludge is not land applied.
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
No
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DocuSign Envelope ID: 533234C5-B2F4-425A-BOF2-33A76B139085
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION)
66. User Name
1. Tipper Tie, Inc.
2. Tipper Tie II
3.
67. IUP Number
0002
0010
68. Does File Contain Current Permit?
® Yes ❑ No
® Yes ❑ No
[—]Yes ❑ No
69. Permit Expiration Date
12/28/2025
12/28/2026
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
467
467
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 ❑
I ® Yes ❑
I ❑ 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❑NoSN/A
F
❑Yes❑NoSN/A
❑Yes❑No❑N/A
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.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
76. During Most Recent Semi -Annual Period, Did POTW Complete its
® Yes ❑ No
F977[:] No
❑ 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
®Yes❑No❑N/A
®Yes❑No❑N/A
❑Yes❑No❑N/A
Sampling as Required by IUP, including Flow?
79. During Most Recent Semi -Annual Period, Did SIU submit all reports on
SYes❑No❑N/A
®Yes❑No❑N/A
❑Yes❑No❑N/A
time?
80a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑NoSN/A
❑Yes❑NoSN/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
SYes❑No❑N/A
SYes❑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❑NoSN/A
❑Yes❑NoSN/A
❑ Yes ❑ No
Limits Non -Compliance from Both POTW and SIU Sampling?
82. During Most Recent Semi -Annual Period, Did POTW Identify All
❑Yes❑NoSN/A
❑Yes❑NoSN/A
❑Yes❑No❑N/A
Re ortin
Z-Non-Compliance from SIU Sampling?
1
83. a. Was POTW Notified by SIU (Within 24 Hours) of All Self-
a.❑Yes❑NoSN/A
a.❑Yes❑NoSN/A
a.❑Yes❑No❑N/A
Monitoring Violations?
b. Did Industry Resample and submit results to POTW within 30 Days?
b.❑Yes❑NoSN/A
b.❑Yes❑NoSN/A
b.❑Yes❑No❑N/A
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?
c.❑Yes❑No®N/A
c.❑Yes❑No®N/A
c.❑Yes❑No❑N/A
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
[—]Yes
®
No ji
❑
Yes
®
No
1
❑
Yes
❑
No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
❑Yes❑NoSN/A
❑Yes❑NoSN/A
❑Yes❑No❑N/A
Specified in POTW's ERP (NOVs, Penalties, timing, etc.)?
86. Does File Contain Penalty Assessment Notices?
❑Yes❑NoSN/A
❑Yes❑NoSN/A
❑Yes❑No❑N/A
87. Does File Contain Proof Of Penalty Collection?
❑Yes❑NoSN/A
❑Yes❑NoSN/A
❑Yes❑No❑N/A
88. a. Does File Contain Any Current Enforcement Orders?
a.❑Yes❑No®N/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
b.❑Yes❑No❑N/A
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
❑ Yes ® No
❑ Yes ®No
ElYes ❑ No
Information For You?
FILE REVIEW COMMENTS:
Both SIUs were compliant during the second six-month period of 2022.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 5

DocuSign Envelope ID: 533234C5-B2F4-425A-BOF2-33A76B139085
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
I N I C 1 0 I0 I6 14 I0 I5 I0 I I07 I18 I23
1. Industry Inspected: Tipper Tie II
2. Industry Address: 2000 Lufkin Road, Apex 27502
3. Type of Industry/Product: 467 Aluminum Former: metal clips for food packaging and machines to apply clips
4. Industry Contact: Randy Davis Title: Environmental Manager Phone: [phone] Fax: [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
B. Plant Tour
C. Pretreatment Tour
D. Sampling Review
E. Exit Interview
Industrial Inspection Comments:
® Yes ❑ No Yes
® Yes ❑ No Yes
® Yes ❑ No Yes
® Yes ❑ No Yes
® Yes ❑ No Yes
The inspection was thorough and covered all required areas.
Audit SUMMARY AND COMMENTS:
Audit Comments: Very well oreanized files. Everything ready for inspection.
Requirements: Notify contract lab to use LTMP specified DL for cadmium at Uncontrollable locations
Recommendations:
NOD: ❑ Yes ® No
NOV: ❑ Yes ® No
QNCR: ❑ Yes ® No
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory ❑
Audit COMPLETED BY: Octavio Henriquez, DWR Central Office; Cheng Zhang, RRO DATE: 7/18/2024
NC DWR Pretreatment Audit Form Revised: December 2016 Page 6