NC0023876_Pretreatment_Compliance_Audit_20240805

Docusign Envelope ID:3FC83COE-394F-431C-9EE6-ED835128AE77
Et,,`STATE
ROY COOPER a
Governor
ELIZABETH S.BISER
Secretary *�f QUAMN°�'*
RICHARD E.ROGERS,JR. NORTH CAROLINA
Director Environmental Quality
8/5/2024
Via Electronic Mail(bpatterson@burlin onnc.gov)
Robert C. Patterson,Jr.,P.E.
Water Resources Director
City of Burlington
P.O. Box 1358
Burlington,NC 27216
Subject: Pretreatment Compliance Audit
Program: City of Burlington
Wastewater Treatment Plant: East WWTP and South
NPDES #: NCO023868 and NCO023867,Alamance County
Dear Robert Patterson:
On July 17,2024 a Pretreatment Compliance Audit(PCA)was performed by Octavio Henriquez, Stephanie
Zorio,and Natalie Gorensek of the Central Office. Kristy King Hylton of the City of Burlington was present for
the audit. The purpose of this audit was to determine the effectiveness of the City's pretreatment program,which
includes the review of files,including industrial monitoring data, POTW plant performance, industry monitoring
data, adherence to the enforcement response plan(ERP),an industry inspection, and other pretreatment elements
as outlined by 15A NCAC 02H .0900.
Background
The city has thirteen(13) Significant Industrial Users(SIUs),three(3)of which are categorical under federal
regulations. The City of Burlington's Publicly Owned Treatment Works(POTW)operates two Wastewater
Treatment Plants(WWTP).Both Burlington East(NC0023868)and Burling South(NC0023786)WWTP are
permitted for 12 MGD.
POTW Interview
There are no known POTW issues related to pretreatment at the time of this PCA.
Pretreatment Program Elements Review
The Headworks Analysis(HWA)renewal was submitted on March 17, 2020. The HWA renewal is currently
awaiting review by the Division.
The Industrial Waste Survey(IWS)was approved on August 10, 2022.
The Sewer Use Ordinance(SUO)was approved on March 1,2013.
The Enforcement Response Plan(ERP)was approved on February 5,2020.
The Long Term Monitoring Plan(LTMP)was approved on January 27,2006.
D E Q�� 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
Uapad—t of E,,kon—tal Quay

Docusign Envelope ID:3FC83COE-394F-431C-9EE6-ED835128AE77
LTMP File Review Findings
The Division reviewed the LTMP from 2006 and found the PQLs to be out of date.A new PQL list was released
in 2022. We request that the City of Burlington revises the LTMP with the updated PQLs. The Division requests
that the City of Burlington proposes an appropriate timeline for implementation.
The Long Term Monitoring Plan(LTMP)is being conducted at the proper locations and frequencies.
Industrial User Permit(IUP)File Review
None of the thirteen(13) SIUs were in significant noncompliance(SNC) in 2023.
A review of the file for ITG Burlington Industries dba Elevate Textiles (#0006)revealed that the monitoring data
was well-organized and in compliance with pretreatment rules.
A review of the file for Alamance Foods (#0067)revealed that the monitoring data was well-organized and in
compliance with pretreatment rules.
A review of the file for Engineering Controls International, LLC(#0019)revealed that the monitoring data was
well-organized and in compliance with pretreatment rules.
The slug control plan for ITG Burlington Industries dba Elevate Textiles(#0006)was in good order.
The slug control plan for Alamance Foods (#0067)was in good order.
The slug control plan for Engineering Controls International, LLC(#0019)was in good order.
Industry Inspection
The team from the Division and Kristy King Hylton visited ITG Burlington Industries dba Elevate Textiles for an
annual inspection. The inspection revealed that Kristy King Hylton used the Division Model Inspection Form or
Equivalent and performed a thorough inspection including: Initial Interview,Plant Tour, Sampling Review, and
an Exit Interview. The plant tour revealed an area of chemical storage that could benefit from additional spill
containment(such as spill containment pallets)and this was noted during the inspection and the City of
Burlington will take action.
Action Items
Obtain official IUP review letter from the Division for Alamance Foods(#0067)and Engineering Controls
International, LLC (#0019).
The Division reviewed the LTMP from 2006 and found the PQLs to be out of date.A new PQL list was released
in 2022. We request that the City of Burlington revises the LTMP with the updated PQLs. The Division requests
that the City of Burlington proposes an appropriate timeline for implementation.
Final Comments
The Division set a tentative due date for the next Headworks Analysis of March 2025. The HWA submission from
2020 is still under review and in effect.
D E Q North Carolina Department of Environmental Quality I Division of Water Resources
vvv512 North Salisbury Street 11611 Mail Service Center I Raleigh,North Carolina 27699-1611
NORTH CAROLINA 919.707.9000
Depa"mem of Environmental Duality

Docusign Envelope ID:3FC83COE-394F-431C-9EE6-ED835128AE77
The City of Burlington's Pretreatment Program is in very good shape. The industry files and sampling records were
well organized and Kristy King Hylton fosters good relationships with the industries in the pretreatment program.
Please review the attached inspection sheet.
Thank you for your continued cooperation with the Pretreatment Program. If you have any questions or comments,
please contact Natalie Gorensek [email: natalie.gorensekkdeq.nc.gov] at(919) 707-3660 or Octavio Henriquez at
[phone] [email: octavio.henriquez(a,deq.nc.gov].
Sincerely,
nhg/burlington_pca_2024
Ec: Municipal Unit File DocuSigned by:
Jenny Graznak,WSRO EAbvuu$th
Central Files(Laserfiche) C464531431644FE...
Michael J. Montebello,NPDES Branch Chief
Division of Water Resources
D E Q North Carolina Department of Environmental Quality I Division of Water Resources
vvv512 North Salisbury Street 11611 Mail Service Center I Raleigh,North Carolina 27699-1611
NORTH CAROLINA 919.707.9000
Depa"mem of Environmental Duality

Docusign Envelope ID:3FC83COE-394F-431C-9EE6-ED835128AE77
nt;a 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: City of Burlington(East Plant(Main)and South Plant)
2. Control Authority Representative(s):Kristy King Hylton
3. Title(s): Industrial Pretreatment Specialist
4. Address of POTW:
Mailing East Plant: 225 Stone Quarry Road
City Burlington Zip Code 27217
Phone Number 336-222-5132 Fax Number n/a E-Mail klking(&burlingtonnc.gov
5. Audit Date 07/17/2024
6. Last Inspection Date: 08/18/2022 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.
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 MM/DD/YY
IN ICI0I0I2 I3 18 17 I6 I 1 07 1 02 1 18I
_10:..Current Number of Significant.Industrial Users(SIUs)I................................................................................................................................
13
11. Number of SIUs with No]UP,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) 3
19. Number of C11tJs 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 supporting documents and PERCS Approval Letter,and dates consistent with Pro ram Info:
Program Element Last Submittal Last Approval Date Next Due,
Date In file? Date In file If Applicable
Headworks Analysis(HWA) 3/17/20 ®Yes❑ No 2/2/16 ®Yes❑ No 3/2025
Industrial Waste Survey(IWS) 7/1/21 ®Yes❑ No 8/10/22 ®Yes❑ No N/A
Sewer Use Ordinance(SUO) 2/10/13 ®Yes❑ No 311113 ®Yes ❑ No N/A
Enforcement Response Plan(ERP) 11/2/19 ®Yes❑ No 2/5/20 ®Yes ❑ No N/A
Long Term Monitoring Plan(LTMP) 1/27/06 ®Yes❑ No 1/27/06 ❑Yes ❑ No TBD
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.Elon,Gibsonville,Swepsonville,Town of Haw River,Village of
Alamance
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.Copies received and filed on Sharepoint 7/17/24
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 11/19/2013
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. Sent with applications for IUPs.
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=Satisfacto M=Mar inal U=Unsatisfactory
Rating Explanation,if Unsatisfactory
Personnel Available for Maintaining PT coordinator plus lab personnel and some techs if needed
POTW's Pretreatment Pro ram ®S❑M❑U
Access to POTW Vehicles for Improving!
Sampling,Inspections,and ®S❑M❑U
Emergencies
Access to Operable Sampling Plenty of equipment and it's good quality!
Equipment ❑S ❑M ❑U
Availability of Funds if Needed for Good,no issues—looking into updating/improving SUO to help
Additional Sampling and/or Analysis ®S ❑M ❑U in this area a little bit more
Reference Materials NCPC and lots of resources online
❑S ❑M❑U
Staff Training(i.e.Annual and Able to attend any workshops that are offered,member of
Regional Workshops,Etc.) ®S❑M❑U NCPC,plenty of certifications already
Computer Equipment(Hardware and Slow,but it works
Software) ®S❑M❑U
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30. Does the POTW have an adequate data management system to run the prctrcatmcnt program?® Yes ❑ No
Explain Yes or No.Use Excel and Hachwins
31. How does the POTW recover the cost of the Pretreatment Program from their industries?Explain.
Sampling charges,surcharges,and permit renewal fees
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?Formal request made at city hall,PT coordinator made
hard copies and charged the HRA per page
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?Things like trade secrets are able to be kept confidential,they have
never had an industry ask for something other than that be kept confidential.Inspectors discussed with PT Coordinators
that if that happens to refer industry to town attorney and DEQ.Those files are kept in Bob Patterson's office which has a
lock on it.
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 none in the last year,but the year before there
were and they were published in the last notice
Permitting(Industrial Waste Survey-IWS)
38. How does the POTW become aware of new or changed Users?Bob Patterson attends the Technical Review Meeting
where new connections are discussed and then the POTW sends out short forms to determine need for permits
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?)amount of water discharged,process type,they use the short form,etc.
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,2 leachate
Please list each site and how it is permitted,if applicable.All 4 are locally permitted users,GW: Alamance County
Landfill and Republic Services;Leachate: Travel Center of America and Speedway
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)origination report,samples,visual inspections,and at the east plant septage
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 10%
47. Has the POTW experienced any difficulty in allocation?(for example: adjudication by an industry) ❑Yes ® No
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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)
Mostly based on past limits,and look at what the industries ask for in their applications.Also based on what categorical
limits are.
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Quarterly for almost all pollutants(POTW samples 11t and 3rd and Industry samples 2"and 4')ongoing issues may
determine if more frequent sampling is necessary
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 compliance judgement worksheets,highlight violations in sample
result spreadsheets,do calculations,industries email results with any issues right away
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?
If they have an IUP they must have a plan
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Up to date contact info,posted info at the facility,who are they going to call,etc.
56. How does the POTW decide where the sample point for an SIU should be located?
Where they discharge at the end of the facility and before it gets to the plant(CIU at end of process,SIU end of pipe)
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. Clearly marked,PACE and Meritech have worked
with POTW,POTW has gone over sampling plans with CIUs
58. Who performs sample analysis for the POTW for Metals POTW and Meritech
Conventional Parameters Burlington
Organics Mertiech
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Signed when samples are received and transferred.Stored at PT Coordinator's desk
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 LTMP has not been updated
with new PQLs
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 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
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UMore LTMP data available UResolve 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?
No
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INDUSTRIAL USER PERMIT IUP FILE REVIEW 3 IUP FILE REVIEWS AND 1 IU INSPECTION
66. User Name �Fl-ITG Burlington Industries 2.Alamance Foods 3.Engineering Controls
dba Elevate Textiles International,LLC
67. IUP Number 0006 0067 0019
68. Does File Contain Current Permit? ®Yes ❑ No ®Yes ❑ No ®Yes ❑ No
69. Permit Expiration Date 12/31/26 12/31/26 12/31/26
70. Categorical Standard Applied I.E.40 CFR,Etc. Or N/A N/A N/A 433.17
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 ❑ 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 POT 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® Yes No® ®Yes No N/A
Organic Management Plan TOMP ? F ❑ N
1
75. a.Does File Contain Original Permit Review Letter from Division? a. ®Yes ❑No a. ❑Yes®No a. ❑Yes ®No
b.All Issues Resolved? I 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 ]1 ®Yes ❑ 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/
Sampling as Required by IUP,including Flow?
79. During Most Recent Semi-Annual Period,Did SIU submit all reports on ®Yes❑No❑N/A ®Yes❑No❑N/ ®Yes❑No❑N/
time?
80a.For categorical IUs with Combined Wastestream Formula(CWF),does ❑Yes❑No®I
❑Yes❑No®N/ ElYes❑No®N/
file include process/dilution flows as Required b IUP?
80b.For categorical IUs with Production based limits,does file include ❑Yes❑No®N/A ❑Yes❑No®N/A ❑Yes❑No®N/
production rates and/or flows as Required by IUP?
81. During Most Recent Semi-Annual Period,Did POTW Identify All ®Yes ❑ No ®Yes ❑ No ®Yes ❑ No
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❑No®N/
Re ortin Non-Compliance 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❑Nolo 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 a❑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? I ❑Yes ® No 11 ❑Yes ® No I ❑ Yes ® No
85. During Most Recent Semi-Annual Period,Was Enforcement Taken as ❑Yes❑No ®Yes❑No ❑Yes❑No
Specified in POTW's ERP OVs,Penalties,timing,etc.)? ON/A ❑N/A ON/A
86. Does File Contain Penalty Assessment Notices? ❑Yes❑No®N/ ❑Yes❑No N/ ❑Yes❑No®N/
87. Does File Contain Proof Of Penalty Collection? ❑Yes❑No N/ ❑Yes❑No N/ ❑Yes❑No®N/
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 ❑Yes ® No
Information for You?
FILE REVIEW COMMENTS:
Alamance Foods and Engineering Controls are both missing a review letter. There was an email from Keyes McGee to Kristy King Hylton
about missing the documents in the files.Inspectors told PT Coordinator that they would try to figure out what happened with review letters.
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INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
INIC10 In I2 1 -3 IR 16 IR I07 1 17 1 24 1
1.Industry Inspected: ITG Burlington Industries dba Elevate Textiles
2.Industry Address: 906 Anthony Street Burlington,NC 27217
3. Type of Industry/Product: Textile Manufacturing
4.Industry Contact: Allen Tate Title: Phone: 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 N/A no pretreatment
D. Sampling Review ❑Yes ❑ No
E. Exit Interview ®Yes ❑ No
Industrial Inspection Comments:
Facility is a dye and finishing textile manufacturer.Currently production is 65%apparel,35%seating and upholstery.Beginning
3rd quarter they will start dyeing and finishing wool,so the production will move to 55-60% apparel,25% seating,and 15-20%
wool. The facility currently uses PFAS in their production,but they have a compliance schedule to eliminate usage by January
2025.The facility plans to cease using PFAS by the end of this month.
Small spill observed under some pallets and plastic was being used as containment. Suggested that they invest in some
containment pallets to help with this.
Audit SUMMARY AND COMMENTS:
Audit Comments: The Pretreatment program files were well organized and accessible to the inspector. Kristy was highly
competent and accommodating and has a vast knowledge of the requirements of the PT program for each of the POTW's
industries. The Division notes that official review letters for IUPs for Engineering Controls and Alamance Foods were missing,
and that the Inspectors will work with other members of the Division and Kristy to resolve this issue.
Requirements: Please send copies of current IJAs to the Division as well as copies of the DMRs for LTMP/STMP effluent data to
the Division
Recommendations: The Division recommends that the next due date for applicable files (HWA, ERP, etc.) be listed in the PAR
for reference
NOD: ❑Yes ® No
NOV: ❑Yes ® No
QNCR: ❑Yes ® No
No need for enforcement
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory❑
Audit COMPLETED BY: Natalie Gorensek DATE: 07/17/24
NPDES Municipal Permitting Unit-Pretreatment,Central Office
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