NC0023876_Pretreatment Audit (PAI)_20150904

C®ENR
North Carolina Department of Environment and Natural Resources
Pat McCrory Donald R. van der Vaart
Governor Secretary
September 4, 2015
J. Wes Goswick
City of Burlington
P.O. Box 1358
Burlington, NC 27216-1358
RECEIVEDIDENRIDWR
SUBJECT: Pretreatment Audit Inspection (PAI)
South Burlington and East Burlington WWTPs SEP 16 2015
NPDES Permit#s NCO023876 and NCO023876
Alamance County Water Quality
Permitting Section
Dear Mr. Goswick:
On September 2, 2015, Ms. Jenifer Carter of the Winston-Salem Regional Office, and Deborah Gore of the
PERCS unit, performed an audit of the City of Burlington's pretreatment program. You were present for the
inspection. The purpose of this inspection was to determine the effectiveness of the pretreatment program
and included a review of pretreatment program elements, POTW plant performance, Industry monitoring
data, adherence to the enforcement response plan (ERP) and an industry inspection.
The City currently has seventeen (17) Significant Industrial Users (SIUs), one (1) of which is categorical.
During this review period, Carolina Biological Supply was the only SIUs in significant non-compliance for
limits violations. South Burlington WWTP had BOD and Ammonia NPDES limits violations in April 2014
that were not pretreatment related, and were addressed during the Division's regular monthly enforcement
program. The East Burlington WWTP plant did not have any NPDES limits violations in 2014.
Overall, you are learning the pretreatment program very quickly, and your efforts to continue implementing
the City's excellent Pretreatment Program are greatly appreciated. Please refer to the attached inspection
report for further comments. If you have any questions please contact Jenifer Carter at [phone] or
Deborah Gore at [phone].
Sincerely,
lo*e",­ '
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NC DENR
attachment
cc: Mr. Robert C. Patterson, Jr., P.E. (same address)
DWR Central Files
WSRO Files
Deborah Gare — PERCS Unit
450 W Hanes Mill Rd.,Suite 300,Winston-Salem,NC 27105
Phone:[phone]\Internet:www,ncdenr.gov
An Equal Opportunity\Affirmative Action Employer—Made in part by recycled paper

DE � NORTH CAROLINA DIVISION OF WATER QUALITY
NCN, PRETREATMENT AUDIT REPORT
Background Information [Complete prior to audit; review Program Info Database Sheet(s)]
1. Control Authority(POTW)Name: City of Burlington
2. Control Authority Representative(s): J.Wes Goswick
3. Title(s): Industrial Pretreatment Specialist
4. Address of POTW:
Mailing P.O.Box 1358
City Burlington Zip Code 27216
Phone Number 336-222-5133 Fax Number 336-570-6175 E-Mail wgoswickAci.burlington.nc.us
5. Audit Date 09/02/2015
6. Last Inspection Date: 07/21/2014 Inspection Type: ®PCI ❑Audit
7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? ❑ Yes ❑ No ® NA
If No,Explain.
8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? ® Yes ❑ No
If Yes,Explain. 4/2014: South plant experienced BOD/Ammonia violations due to a power outage,and in 3/2015,
the East plant missed a conductivity sampling event due to a lab mishap.No pretreatment related violations.
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
PCS(WENDB)Coding
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac.Type
INIC10 10 12 13 18 17 16 I 109102 12015 1 Lai LS-1
(DTIA) (TYPI) (INSP) (FACC)
-10: -Current Number of Significant Industrial Users(SNS)? 17 SNS
.................................
.11. Current Number of Categorical Industrial Users,(CNS)?........................................................................................... 1 CIUS
.................................
12. Number of SIUs Not Inspected by in Last Calendar Year? 0
..... . . . . . ... .............................................................................................................................................................. ............................
13: Number of SIUs Not Sampled by.POTW in Last Calendar Year? 0
...................................................................................................................................................... .................................
14: Enter Higher Number of 12 or 13 0 NOIN
................................................................................................................................................................................................................... .................................
.15.:...Number of SIUs with No IUP,..or.with an Expired IUP................................................................................................................................. 0 NOCM
...........................................I. .................................
16. Number of SIUs in SNC for Either Reporting or Limits Violations During Either of Last 2 1 PSNC
Semi-Annual Periods.I...................................................................Total Number of SIUs in SNC
.......................................
....... ............................................. .................. .......................................................................................... .................................
17. Number of SIUs in SNC for Reporting During Either of Last 2 Semi-Annual Periods 0 MSNC
................................................................................................................. .................................
18: Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi-Annual Periods 1 SNPS
........... ....................... .................................
19. Number of SIUs in SNC for Both Reporting and Limits Violations During Either of Last 2 0
Semi-Annual Periods
20: Number of SIUs in SNC for Self-Monitoring Requirements that were Not Inspected_or Sampled 0 SNIN
NC DWQ Pretreatment Audit Form Revised: July 25,2007 Page 1

21. PRETREATMENT PROGRAM ELEMENTS REVIEW- Review POTW files, verify POTW has copy of each Program
Element in their File, complete with all supportingdocuments and PERCS Approval Letter,and dates consistent with Program Info:
Program Element Last Approval Date Next Due,If Applicable
Date In file
Headworks Analysis(HWA) 04/01/2010 ®Yes ❑ No 12/01/2015
Industrial Waste Survey(IWS) 06/10/2011 ®Yes ❑ No 07/02/2016
Sewer Use Ordinance(SUO) 01/31/2013 ® Yes ❑ No
Enforcement Response Plan(ERP) 07/29/2008 ® Yes ❑ No
Long Term Monitoring Plan(LTMP) 11/18/2005 ®Yes ❑ No
Legal Authority(Sewer Use Ordinance-SUO)
22. 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. Elon,Gibsonville,Swepsonville,Town of Haw River,Village of
Alamance,and now the Town of Green Level(used to go thru Haw River/now directly to Burlington)
23. If yes to 922,Do you have current Interjurisdictional Agreements(IJAs)or other Contracts? ® Yes ❑ No ❑NA
A copy was provided to PERCS during the inspection.
24. If yes to#22,Have you had any trouble working with these towns or districts? ❑Yes ® No ❑NA
If yes,Explain.
25. Date of Last SUO Adoption by Local Council 11/19/2013
26. Have you had any problems interpreting or enforcing any part of the SUO? ❑ Yes ® No
If yes, Explain. Expanded FOG program due to a spill in 2014 and a settlement agreement with SELC.
Enforcement(Enforcement Response Plan-ERP)
27. Did you send a copy of the ERP to your industries? ®Yes❑ No
If no,POTW must send copy within 30 days. Will get new copy with renewal applications
28. 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.
29. List Industries under a Schedule or Order and Type of Schedule or Order None.
Resources
30. Please Rate the Following: S=Satisfacto M=Mar inal U=Unsatisfactory
Rating Explanation,if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program ®S ❑M ❑U
Access to POTW Vehicles for Van
Sampling,Inspections, and ®S ❑M ❑U
Emergencies
Access to Operable Sampling 10 samplers
Equipment ®S ❑M❑U
Availability of Funds if Needed for In budget
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
31. Does the POTW have an adequate data management system to run the pretreatment program? ®Yes ❑ No
Explain Yes or No. Excel and WIMS.
NC DWQ Pretreatment Audit Form Revised: July 25,2007 Page 2

32. How does the POTW recover the cost of the Pretreatment Program from their industries?Explain.
Surcharges,Sampling fees and application fees
Public Perception/Participation
33. Are there any local issues affecting the pretreatment program (e.g.. odor,plant closing,new or proposed plants)?
❑ Yes® No If yes,Explain.
34. 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?Would be made available upon request
35. 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?. Would work with City attorney and keep separate locked files.
36. In addition to annual inspection,does the POTW periodically meet with industries to discuss pretreatment? ®Yes❑ No
37. Is the public notified about changes in the SUO or Local Limits? ®Yes ❑ No via newspaper and City's website
38. Were all industries in SNC published in the last notice? ® Yes ❑ No❑NA
Permitting(Industrial Waste Survey-IWS)
39a...How does the POTW become aware of new or changed Users?Tech Review Committee will inform Mr.Goswick.
Also reviews water consumption reports,and via surveys.
39b. 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?)>25,000 gpd,categorical regs,process type and chemical inventory
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 GW remediation sites that aren't currently discharging; 1 landfill,
with another to apply soon.
Please list each site and how it is permitted, if applicable.
41. Does the POTW accept waste by(mark if applicable) ® Truck ❑Dedicated Pipe ❑NA Landfille and septage at
East plant only.
42. If the POTW accepts trucked waste,what controls are placed on this waste? designated point,samples drawn.All
landfills sampled,with random sampling of others.Visual inspections of each.
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#43,What is being done to address the over allocations?(short-term IUPs,HWA to be revised,pollutant study, etc.)
N/A
46. Does the POTW keep pollutant loading in reserve for future growth/safety? ® Yes❑ No
If yes,what percentage of each parameter 25%. Phosphorus lowest,at 29%
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? Process,chemicals used,categorical
parameters
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Everyone sampled quarterly. SIUs sample in 1"&3rd quarters,and the City samples in the 2"d and 4`h quarters.
NC DWQ Pretreatment Audit Form Revised: July 25,2007 Page 3

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. Use worksheets,and results are in Excel spreadsheets
52. Does the POTW use the Division's model inspection form or equivalent? ®Yes ❑ No
If no, does the POTW form include all DWQ 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?
All SIUs are required to submit 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 should be posted; chemical/bulk storage reviewed
56. How does the POTW decide where the sample point for an SIU should be located?
Closes representative manhole.
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. Designated sampling points,samplers cleaned b
Burlington has observed Pace Analytical between sampling events
58. Who performs sample analysis for the POTW for Metals Meritech—HG only
Conventional Parameters in-house
Organics Meritech
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Uses Meritech's COCs,and in-house COCs
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 ❑ NO
60d. All LTMP/STMP effluent data on Discharge Monitoring Report(DMR)? ®YES ❑NO DWQ Inspector,verify yourself!
60e. If NO to any above,list violations
60£ 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 ®5 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
Explain.
Summary
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
FOG program expanded... is part of PT responsibility.Nutrient removal upgrades to both plants recently,which may
affect HWA,especially phosphorus.
NC DWQ Pretreatment Audit Form Revised: July 25,2007 Page 4

INDUSTRIAL USER PERMIT IUP FILE REVIEW
66. User Name 1. Alexander Fabrics 2. Carolina Finishing 3.Laboratory Corp.of America
67. IUP Number 0071 0003 0066
68. Does File Contain Current Permit? ®Yes ❑ No ® Yes ❑ NoI ®Yes ❑ No
69. Permit Expiration Date r 12/31/2016 11 04/30/201 1 12/31/2016
70. Categorical Standard Applied(I.E.40 CFR,Etc.)Or N/A N/A N/A =1 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? I ®Yes ❑ No7j ® Yes ❑ No ®Yes ❑ No
73. a. Does File Contain Slug/Spill Control Plan? a. ®Yes ONO a. ®Yes ❑No a. ®Yes ❑No
b. If No,is One Needed?(See Inspection Form from POTW) b. ❑Yes ❑No b. ❑Yes []Nob. ❑Yes[]No74. For 40 CFR 413 and 433 TTO Certification,Does File Contain a Toxic ❑Yes❑NoO ❑Yes❑NoON/A ❑Yes❑No®N/A
Organic Management Plan(TOMP)? 1 11
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 ®Yes ❑ No ® Yes ❑ No
Sampling as Required by IUP, including Flow?
77. Does File Contain POTW Sampling Chain-Of-Custody Forms? ®Yes ElNo ®Yes [INo ®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? 11 1
79. During Most Recent Semi-Annual Period, Did SIU submit all reports on EYes❑No❑N/A ®Yes❑No❑N/A ®Yes❑No❑N/A
time?
80a.For categorical IUs with Combined Wastestream Formula(CWF), does ❑Yes❑No®N/A ❑Yes❑No®N/A ❑Yes❑No®N/A
file includeprocess/dilution flows as Required by IUP?
80b.For categorical IUs with Production based limits,does file include ❑Yes❑No®N/A ❑Yes❑NoON/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❑NoON/A ❑Yes❑No®N/A ❑Yes❑NoON/A
Limits Non-Compliance from Both POTW and SfU Sampling?
82. During Most Recent Semi-Annual Period,Did POTW Identify All ❑Yes❑NoNN/A ❑Yes❑NoON/A ❑Yes❑No®N/A
Re ortin Non-Com liance from SIU Sampling?
83. a. Was POTW Notified by SIU(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 c.❑Yes❑No®N/A c.❑Yes❑No®N/A
becoming aware of SIU limit violations in the POTW's sampling of SIU?
84. During Most Recent Semi-Annual Period, Was SIU in SNC? ❑ Yes ® No 11 ❑ Yes ® No 11 ❑Yes ® No
85. During Most Recent Semi-Annual Period, Was Enforcement Taken as ❑Yes❑NoON/A ❑Yes❑NoON/A ❑Yes❑No®N/A
Specified in POTW's ERP(NOVs,Penalties,timing,etc.)?
86. Does File Contain Penalty Assessment Notices? I ❑Yes❑No®N/A ❑Yes❑NoON/A I ❑Yes❑No®N/A
87. Does File Contain Proof Of Penalty Collection? ❑Yes❑NoON/A 11 ❑Yes❑No®N/A ❑Yes❑No®N/A
88. a.Does File Contain Any Current Enforcement Orders? a.❑Yes❑No®N/A F
.❑Yes❑No®N/A a.❑Yes❑No®N/A
b.Is SIU in Compliance with Order? b❑Yes❑No®N/A .❑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?
FILE REVIEW COMMENTS:
73. Lab Corp: SPCC plan dated 2004.Noted on June inspection that updated plan is due.Carolina Finishing SPCC dated 3/2012. Will
update and submit.
NC DWQ Pretreatment Audit Form Revised: July 25,2007 Page 5

INDUSTRY INSPECTION PCS CODING:
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac.Type
�1 I N I C I o 1 0 1 2 1 3 1 R 1 7 1 6 1 1 09 1 02 1 201-5 I I tJ I I s I 1 2 1
(DTIA) (TYPI) (INSP) (FACC)
1. Industry Inspected: Alamance Foods
2. Industry Address: 739 S.Worth Street: Burlington,NC
3. Type of Industry/Product: dairy products(whipped cream)and ice pops
4. Industry Contact: Leslie Ames/Janice Overton Title: Quality Supervisors 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 Discussed containment issues(w/in 30 days)and training logs
Industrial Inspection Comments:
• Updated SPCC received during the inspection
e Both Leslie and Janice are new to their jobs(6 months)—Wes did a good job reviewing their permit with them.
e Discussed temperature violations and their solution to the problem.
Audit SUMMARY AND COMMENTS:
Audit Comments: Wes is doing a good iob of continuing to implement a well set up pretreatment program.
Requirements: None.
Recommendations: Put files in order by date
NOD: ❑ Yes ® No
NOV: ❑ Yes ® No
QNCR: ❑ Yes ® No
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory❑
Audit COMPLETED BY: Debora Gore(PERCS)and Jenifer Carter(WSRO) DATE: 09/04/2015
NC DWO Pretreatment Audit Form Revised: July 25,2007 Page 6