NC0023906_Pretreatment Audit_20240718

Docusign Envelope ID:7A78EA7E-BO5A-4BB7-8A59-7901426DOA17
tME 4
ROY COOPER
Governor
ELIZABETH S.BISER
Secretary
RICHARD E.ROGERS,JR. NORTH CAROLINA
Director Environmental Quality
July 18, 2024
Mr. Jimmy Pridgen
Water Reclamation Manager
City of Wilson
P.O. Box 10
Wilson,NC 27894
Subject: Pretreatment Audit
City of Wilson, Hominy Creek Water Reclamation Facility
NPDES Permit No.NCO023906
Wilson County
Dear Mr. Pridgen:
On July 15, 2024, Donald Smith of the Division of Water Resources (DWR) -Raleigh Regional Office
conducted a Pretreatment Compliance Audit(PCI) of the pretreatment program at the City of Wilson
(City). The assistance given by Ms. Laura Pruitt Water Reclamation Compliance Coordinator was
greatly appreciated. Findings during the inspection were as follows:
1. Currently,the city has nine(9) Significant Industrial Users(SIUs), 8 of which are also
Categorical Industrial User. It was noted that no SIUs were in Significant Non-Compliance
(SNC) for the most recent two semi-annual periods.
2. The pretreatment files of Bridgestone (Permit No. 8412), Evans Machining(Permit No. 2000-
015)and Kidde-Aerospace(Permit No. 8402)were reviewed during the inspection. The files
needed for review were readily available for inspection,contained all the required elements and
were in good condition and well organized. Bridgestone and Evans Machining both received a
notice of violation for late reporting during the most recent semi-annual period. The city's
pretreatment program inspected and sampled all three SIUs as identified in their permits. Ms.
Pruitt indicated that there is a potential for a couple new SIUs soon and is monitoring their status.
3. A review of the files containing the pretreatment program elements (head works analysis,
industrial wastewater survey, enforcement response plan, long-term monitoring plan, sewer use
ordinance, and enforcement response plan)was conducted. These files were available for review
and well organized.
4. The review of Long-Term Monitory Plan(LIMP)data indicated that all locations were sampled
at required frequencies and samples analyzed using required detection limits except for Selenium
(Se)where the laboratory detection limit was reported higher(<2 µg/L) than the LTMP(<1.0
µg/L) stipulated detection limit. During the inspection, Ms. Pruitt notified the laboratory of the
LTMP required Se detection limit. Sampling is performed at a pump station for uncontrollable
and the WRF influent, mixed liquor,biosolids, and effluent. Effluent data is reported on the
E Q North Carolina Department of Environmental Quality 1 Divtsion of Water Resources
Raleigh Regional Office 1 3800 Barrett Dnve I Raleigh,North Carolina 27609
919.791.4200

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electronic discharge monitoring report(eDMR) and the remainder of data is maintained
electronically in a spreadsheet.
5. During the audit,Ms. Pruitt inspected Purdue(Permit No. 3000-001)a pharmaceutical
manufacturer(40 CFR 439-Subpart D.). The inspection was conducted thoroughly and included
a review of all process wastewater discharges from the facility. The inspection included a review
of permit files,data files,composite sampler,effluent flume, inspected utilities,packaging,
laboratories, and formulation suites.
6. The city conducts an ongoing survey of new industrial users. The city has developed a technical
review committee that includes the Water Reclamation Facility Compliance Coordinator and
management staff to review all new prospective industrial users. If an industrial is suspected of
being significant, the compliance coordinator will contact, and an industrial wastewater survey
form may be required to be completed for review.
The city's pretreatment program is very well managed and appears to be in tune with NPDES
compliance initiatives. Thank you for your continued cooperation and support of the Pretreatment
Program. If you have any questions or comments,please call Donald Smith at(919)791-4234 or
[e-mail].
Sincerely,
6lpned by:
lk�
16 Nlaa A41
6@eae3ziMF...
Vanessa E. Manuel,Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources
Enclosure: City of Wilson Pretreatment Audit Inspection Form
Cc: Laserfiche
D_E North Carolina Department of Environmental Quality ( Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh,North Carolina 27699.1611
919 707.90W

Docusign Envelope ID:7A78EA7E-BOSA4887-&&-%7901426DOA17
NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT AUDIT REPORT
Background Information(Complete prior to audit;review Program Info Database Sbeet(s)i
I. Control Authority(POTW)Name: City of Wilson
2. Control Authority Representative(s): Laura Erttitt
3. Title(s): Water Reclamation Complia■ce Coordinator
4. Address of POTW:
Mailing 3100 Stantensbure Road
City Wilson Zip Code 27894
Phone Number 252539l2499 Fax Number 25239922t19 E-Mail laruitt(a'wilsoanc.ore
5. Audit Date 2215/2424 'Os
6. Last Inspection Date:f'1¢'=inspection Type:. jjj+Cl %Audit
7. Has Program Completed All Requirements from the Previous Inspection and Program Info Shect(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.
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 Codine
Main Program Pennit Number MMIDD;YY
'r1C121oil,_1.119 Le 1f 15 131125I
10. Current Number of Significant Industrial Users t. !jU yl 9
11. Number of SIUs with No[LIP,or with an Ex iTi UP? 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 S[Us 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 Uwrs.(yq? 8
19. Number of CiUs.in SNC? 0
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20. PRETREATMENT PROGRAM ELEMENTS REVIEW-Review POTW files,verify POTW has copy of each Program Element
in their File,complete with all supportinR,documents and PERCS Approval Letter,and dates consistent with Program Info:
Program Element Last Submittal Last Approval Date Next Due,
Date In file`! Date In file If Applicable
Headworks Analysis(HWA) 03/17/2023 0 Yes El No 04/13/2024 UYesU No
Industrial Waste Survey(IWS) 05/30/2019 S Yes El No 08/15/2019 Yes No
Sewer Use Ordinance(SUO) 02/28/2012 0 YesEJ No 03/12/2012 0 Yes LJ No
Enforcement Response Plan(ERP) 02/12/2020 Yes 0 No 02/14/202 ®Yes❑ No
Long Term Monitoring Plan(LTMP) 03/1/2024 N Yes U No 04/3//2024 -JZ-Ycs-U 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. Town of Sims,Town of Slack Creek,and Town of Saratoga
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 04'19 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 If yes, Explain.
28. List Industries under a Schedule or Order and Type of Schedule or Order
None
Resources
29. Please Rate the Following: S=Satisfacto M=Mar inai U=Unsatisfactory
Rating Explanation,if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Pro am ®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
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30, Does the POTW have an adequate data management system to run the pretreatment program? ® Yes❑ No
Explain Yes or No.Ameritech Database/Program
31. I low does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Industrial sampling charges and 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.
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?Compliance Coordinator would review request and
provide relevant information
34. Has any industry ever requested that certain information remain confidential from the public? ®Yes❑ No If yes, Explain
procedure for detennining whether information qualified for confidential status,as well as procedure for keeping files confidential
from public. If no how would the request be addressed? Purdue,Bridgestone,and Kidde Aerospace have requested some
information to be confidential.Coordinator would review request and stamp files as confidential and retain in secure
location.
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® N'A
Permitting(Industrial Waste Survey-IWS)
38. How does the POTW become aware of new or changed Users?Technical review meetings weekly with planning,
permitting,and other city staff to review new businesses and industries prior to construction and permitting.
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?)Call and make contact with new or changed users. Issue IWS for information and review.
40. Does the POTW receive waste from any groundwater remediation projects(petroleum,CERCLA)or landfill leachate?
®Yes❑No If Yes,How many are there?
Please list each site and how it is permitted,if applicable. Kidde Aerospace—required monitoring and submittal of
data for review.
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) Porta-john waste,permitted and disposal location at WWTP. WWTP monitors pH before
discharge is allowed.
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?Overallocation for Ag
45. If yes to#44,What is being done to address the over allocations?(short-term IUPs, IIWA to be revised,pollutant study,etc.)
POTW is monitoring uncontrollable for Ag contributions.
46. Does the POTW keep pollutant loading in reserve for future growth safety? ®Yes❑ No
If yes,what percentage of each parameter 5%
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 Pare i

Docusign Envelope ID 7A78EA7E-BO5A-4BB7-BA59-7901426DOA17
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 limits,monitor for NPDES pollutants of concern,limit chloride
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Fxplain.
All monitoring is minimum of semi-annual for permitee and for POTW.
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 is judged monthly when data is received.Ongoing
compliance judgement is performed by the POTW.
52. Does the POTW use the Division's model inspection four or equivalent? ® Yes❑ No
If no,does the POTW form include all Division data? ❑Yes❑ No—modified version of Division's model is used.
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?
Based on chemical use and storage at the facility.
55. What criteria does the POTW use to determine if a submitted s.ug spill control plan is adequate?
Reviewed b) Compliance Coordinator. Protective for spills and contains appropriate emergency contacts.
56. How does the POTW decide where the sample point for an Slil should be located?
Identify end of process Wastewater sampling. If not able to sample before mixing with domestic wastenater,combined
waste stream formula may be required.
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.
58. Who performs sample analysis for the POTW for Metals Pace
Conventional Parameters City
Organics City/Eurofin
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Sample data sheet and chain of custody completed with each sampling event. Relinquish and receipt dates and times
included along with start/stop times for composite sample. Sample parameters and preservation included.
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
60e. Is LTMP STMP Data Maintained in Table or Equivalent? ®YES ❑ NO Is'fable Adequate? ®YES ❑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 analysts(HWA)9 ®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
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64. Do you see any way to increase your loading in the fixture(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?
No major changes expected. A couple of permits may be developed in the near future for prospective industrial users.
NC DWR Pretreatment Audit Form Revised December 2016 Page 5

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INDUSTRIAL USER PERMIT(IUP)FILE REVIEW 3 IUP FILE REVIEWS AND 1 IU INSPECTION)
66. User Name l. Bridgestone 2. Evans Machinery 3. Kidde Aerospace
67. IUP Number 8412 2000-015 8402
68. Does File Contain Current Permit? L9 Yes No N Yes Lj No 11 N Yes Lj No
69. Permit Expiration Date 12/31/024 12/3112026 13/31/2028
70. Categorical Standard Applied(I.E.40 CFR,Etc.)Or NiA 1 428 433 433
71, Does File Contain Permit Application Completed Within One Year Prior Eyes U N Yes Ll No X Yes Ll No
to Permit Issue Date?
72, Does File Contain Inspection Completed Within Last Calendar Year? Z Yes El No Z Yes El No 11 NYes 0 No
73. a. Does File Contain Slug/Spill Control Plan? a. ®Yes ONo a. ®Yes ONO a. ®Yes ONo
b. If No, is One Needed?(See Inspection Form from POTW) b. OYes ONo b.❑Yes ONo b.❑Yes ONO
74. For 40 CFR 413 and 433 TTO Certification,Does File Contain a Toxic OYesONoON A OYesONoON.A OYesONoON A
organic Management Plan(TOMP)? 11
75. a. Does File Contain Original Permit Review Letter from Division? Fb.McsMoON
. ®Yes ONo]Ai
a. ®Yes ONo a. ®Yes ONo
b. All Issues Resolved? b.OYesONo®N A b.❑YesONoON A
76, During Most Recent Semi-Annual Period,Did POTW Complete its Yes Lj No Yes No Yes No
Sampling as Required b IUP,including Flow? 7
77, Does File Contain POTW Sampling Chain-Of-CustodyForms9 1 0 Yes 0 Nojl 0 Yes Nol M Yes El No
78 During Most Recent Semi-Annual Period,Did SIU Complete its ®YesDNoDN A OYesONoON A ®YesONoDN A
Sampling as Required b IUP,includingFlow?
79 During Most Recent Semi-Annual Period,Did SIU submit all reports on OYes®NOON A ❑YesONo❑N A OYesONoON A
time? I Late Report Late Report
80a.For categorical[Us with Combined Wastestream Formula(CWF),does OYesONoON A ❑Yes❑NO®N A DYesONo®N A
file include process/dilution flows as Required b IUP?
80b. For categorical Ms with Production based limits,does file include OYesONoON A DYes❑No®N A OYesDNoON A
production rates and/or flows as Required b IUP? 11 IF
81 During Most Recent Semi-Annual Period,Did POTW Identify All N Yes LJ No LA Yes LJ No Z Yes LJ No
Limits Non-Compliance from Both POTW and SIU Sampling?
82. During Most Recent Semi-Annual Period,Did POTW Identify All ®YesONoON A ®Yes❑No❑N A OYesONo®N A
Re ortin Non-Com liance from SIU Sampling?
83. a.Was POTW Notified by SIU(Within 24 Hours)of All Self- a.OYcs®NoON A a.OYcs®NoON:A a.OYcsONoON A
Monitoring Violations?
b.Did Industry Resample and submit results to POTW within 30 Days? b OYes❑NoON A b OYesONoON A b OYcsMoON,A
c. If applicable,did POTW resample and obtain results within 30 days of c DYesONo®V A
becomingaware of SIU limit violations in the POTW's sampling of SIU? c OYesONoON A c DYesMo®N A
84. During Most Recent Semi-Annual Period,Was SIU in SNC? U Yes No j Lj Yes DgNo Yes No
85. During Most Recent Semi-Annual Period,Was Enforcement Taken as ®Yes❑NoON A ®Yes❑NoON A OYesONoON A
Specified in POTW's ERP(NOVs,Penalties,timing,etc.)? NOV Letter NOV Letter
86, Does File Contain Penalty Assessment Notices? ❑Yes❑No®N A OYesONoON A 11 OYesONoON A
87. Does File Contain Proof Of Penalty Collection? I 0Yes0NoNNK]l DYesONoON.A DYesDNoON A
88, a.Does File Contain Any Current Enforcement Orders? a.OYesONoON A a❑Yes❑No®N A a OYesONo®N A
b.Is SIU in Compliance with Order? b OYesONo®n A b.OYe%0No®N A b❑Yes❑No®N A
89. Did POTW Representative Have Difficulty in Obtaining Any Requested ❑ Yes No 0 Yes No Yes No
Information For You?
FILE REVIEW COMMENTS:
Files were in order and easily accessible. Since July 2023 to July 15, 2024 -Bridgestone-Late Report; Linamar Forging -(2)oil-grease,
(1) flow violation; Refresco - BOD violation; Smithfield (2) chloride violations, Sun River BOD violation; Evans - Late Report;
Kid&Aerospace-zinc violation. No civil penalties were collected. Noted that Selenium lab detection limit was-2.0 ug/L and LTMP set
at-1.0 ug/L.Compliance Coordinator notified lab to lower Selenium detection limit to match LTMP.
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Docusign Envelope ID:7A78EA7E-B-35A-4BB7-8A59-7901426DOA17
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM DD.YY
INI_CIn In I.2 13 19 10 16 I I05131 1241
1. Industry Inspected: Purdue(IUP#2000-001)
2. Industry Address: 4701 International Blvd,Wilson
3.Type of Industry Product: 439-Subpart D.
4. Industry Contact: Greg Mckeeman Title: EHS Manager Phone: [phone] Fax:
5. Does the POTW Use the Division Model Inspection Form or Equivalent? ®Yes ❑ No-Adapted version of Division Model
6. Did the POTW Contact Conduct the Following Parts of the Industrial Inspection Thoroughly'?
Comments:
A. Initial Interview ® Yes ❑ No Retie,+red permit and current facility operations
B. Plant Tour ® Yes ❑ No Inspected utilities,sampler,packaeing,labs,formulation suites
C. Pretreatment Tour ® Yes ❑ No pH neutralization
D. Sampling Review ® Yes ❑ No Visited refrieerated composite sampler and effluent flume
E. Exit Interview ® Yes ❑ No Reviewed facility inspection and records review.
Industrial Inspection Comments:
Inspection was detailed and covered facility operations as it relates to process wastewater discharge and pretreatment permit.
Audit SUMMARY AND COMMENTS:
Audit Comments: Program appeared to be complete,oreanized,and managed well.
Requirements Adiust selenium detection limit to meet LTMP detection limit
Recommendations: None
NOD: ❑Yes ® No
NOV: ❑Yes ® No
QNCR: ❑Yes ® No
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory❑
Audit COMPLETED BY: Donald Smith tonal Office DATE:July 15,2024
aaf.ald Sa,.X�
r a A 0
NC DWR Pretreatment Audit Form Revised, December 2016 Page'1