NC0023906_Pretreatment Compliance Inspection_20170915

Yater Resources
ENVIRONMENTAL QUALITY
September 15, 2017
Mr Jimmy Pridgen
Water Reclamation Manager
City of Wilson
P.O. Box 10
Wilson, NC 27894-0010
ROY COOPER
C1ifNreynor
MICHAEL S. REGAN
s crerary
S. JAY ZIMMERMAN
01(wvr
RECEIVEDINCDEWWR
Subject. Pretreatment Compliance Inspection
City of Wilson - Hominy Creek Wastewater Management Facility
NPDES Permit No. NCO023906
Wilson County
Dear Mr Pndgen:
SEP 2 5 2017
Water OantiSection
Permitting
On August 16, 2017, Cheng Zhang of the Raleigh Regional Office conducted a Pretreatment
Compliance Inspection of City of Wilson's pretreatment program The assistance given by Ms Laura
Pruitt, the Water Reclamation Compliance Coordinator, was greatly appreciated. The inspection report
is attached. Findings during the inspection were as follows
There are 13 Significant Industrial Users (SIUs) discharging, 9 of which are also Categorical
Industrial Users (CIUs) It was noted that no SIUs were in Significant Non -Compliance (SNC)
during the last two semi-annual period.
2. The pretreatment inspection file review included Evans-Mactavish-Agncraft (Permit No 2000-
015), Fresenius Kabi (Permit No 2009-013) and Tabaco Rag Processors (Permit No. 2014-018).
The files needed for review were available for inspection, contained all the required elements
and were in excellent condition Fresenius Kabi was compliant during the most recent 6 -month
period. Evans-Mactavish-Agncraft had two cyanide violations and Tabaco Rag Processors had
one oil & grease violation The POTW took enforcement against these violations as required by
the Enforcement Response Plan.
A review of the files containing the pretreatment program elements was conducted. All files
were available and well organized Please be reminded that update of Headwork Analysis is due
April 1, 2018
4 Long Term Monitoring Plan (LTMP) data were reviewed, it was noted that all parameters were
sampled at required locations and analyzed with required detection levels. LTMP data was well
organized and maintained.
Division of Water Resouices, Raleigh Regional Office, Water Quality Opelations Section http //deq nc gov/about/dirislons/%vater-resources
1628 Mall Service Center, Raleigh, NC 27699-1628 Phone [phone]
Location 3800 Bariett Drive, Raleigh, NC 27609 Fax [phone]

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 cheng.zhang@ncdenr. ov).
r"
Smcerel ,
Danny Smith
Surface Water Protection Supervisor
Raleigh Regional Office
Enclosure 2017 City of Wilson PCI Inspection Fonn
CC Monti Hassan, DWR - PERCS Unit
Central Files
Cheng Zhang, RRO
Laura Pruitt, City of Wilson

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
rva;er n snurc.e
_! Ct ME*lea.Y
BACKGROUND INFORMATION [Complete Prior To PCI• Review Program Info Database Sheet(s)]
1 Control Authority (POTW) Name City of Wilson
2 Control Authority Representative(s) Laura Pruit
3 Title(s) Water Reclamation Compliance Coordinator
4 Last Inspection Date 9/2/2015 Inspection Type (Check One) ® PCI ❑ Audit
5 Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? ® YES ❑ NO
6 Is POTW under an Order That Includes Pretreatment Conditions? ❑ YES ®NO
Order Type, Number, Parameters
ICIS CODING
Main Program Permit Number MM/DD/YY
N I C 1 0 1 0 121 31 91 01 6 1 1 08 1 16 1 17 J
Are Milestone Dates Being Met? ❑ YES ❑ NO
7 Current Number Of Significant Industrial Users (SIUs)'?
13
8 Number of SIUs With No IUP, or With an Expired IUP?
p
9 Number of SIUs Not Inspected By POTW in the Last Calendar Years
0
10 Number of SIUs Not Sampled By POTW in the Last Calendar Years
0
11 Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi -Annual Periods?
0
12 Number of SIUs in SNC For Reporting During Either of the Last 2 Semi -Annual Periods?
0
13 Number of SIUs in SNC with Pretreatment Schedule?
0
14 Number of SIUs on Schedules?
0
15 Current Number Of Categorical Industrial Users (CIUs)?
9
16 Number of CIUs in SNC?
0
POTW INTERVIEW
17 Since the Last PCI, has the POTW had any NPDES Limits Violations?
If Yes, What are the Parameters and How are these Problems Being Addressed?
18 Since the Last PCI, has the POTW had any Problems Related to an Industrial
Discharge (Interference, Pass -Through, Blockage, Citizens' Complaints, Increased
Sludge Production, Etc )?
If Yes, How are these Problems Being Addressed9
19 Which Industries have been in SNC for Limits or Reporting during SNC for
either of the Last 2 Semi -Annual Periods? Not Been Published for SNC for
Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not Pul
20 Which Industries are on Compliance Schedules or Orders? For all SIUs on an
Order, Has a Signed Copy of the Order been sent to the Division9
21 Are Any Permits or Civil Penalties Currently Under Adjudication? If Yes, Which
Ones
❑ YES ® NO
❑ YES ® NO
Limits None
Reporting None
dished None
N/A
❑ YES ® NO
LTMP/STMP FILE REVIEW:
22 Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies9 ® YES ❑ NO
23 Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ®YES ❑ NO
24 Is LTMP/STMP Data Maintained in a Table or Equivalent? ® YES ❑ NO Is Table Adequate? ® YES ❑ NO
25 All LTMP/STMP effluent data reported on Discharge Monitoring Report? ® YES ❑ NO Division Inspector, please verify yourself
26 If NO to 23 - 26, list violations
27 Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ®NO
If yes, which ones? Elmunated Added
NC DWR Pretreatment Compliance Inspection (PCI) Form Updatecl December 2016 Page 1

28. PRETREATMENT PROGRAM ELEMENTS REVIEW - Please review POTW files, verify POTW has copy of Program Element in
their files, complete with supporting documents and copv of PERCS Approval Letter_ and dates consistent with Prnaram info
Program Element
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due
If Applicable
Headworks Analysis (HWA)
4/2/2013
® Yes ❑ No
6/24/2013
® Yes ❑ No
4/1/2018
Industrial Waste Survey (IWS)
4/24/2014
® Yes ❑ No
5/5/2014
® Yes ❑ No
6/1/2019
Sewer Use Ordinance (SUO)
2/12/2012
® Yes ❑ No
3/12/2012
® Yes ❑ No
12/31/2021
Enforcement Response Plan (ERP)
5/16/2012
® Yes ❑ No
6/19/2012
® Yes ❑ No
N/A
Long Term Monitoring Plan (LTMP)
8/5/2015
® Yes ❑ No
10/16/2015
® Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29 User Name
1 Evans-Mactavisli-Agrieraft
2 Fresenius Kabi
3 Tabaco Rag Processors
30 IUP Number
2000-015
2009-013
2014-018
31 Does File Contain Current Penmit?
® Yes ❑ Rol
® Yes ❑ No
® Yes ❑ No
32 Permit Expiration Date
12/31/2021
12/31/2019
6/30/2018
33 Categorical Standard Applied (I E 40 CFR, Etc ) Or N/A
433
439 =1
N/A
34 Does File Contain Permit Application Completed Within One Year Prior
® Yes ❑ No
®Yes ❑ No
® Yes ❑ No
to Permit Issue Date?
35 Does File Contain an Inspection Completed Within Last Calendar Years
®Yes ❑ No
®Yes ❑ No
® Yes El No
36 a Does the File Contain a Slug/Spill Control Plan
a ❑Yes NNo
a ®Yes ❑No
a ❑Yes NNo
b If No, is One Needed? (See Inspection Form from POTW)
b ❑Yes NNo
b ❑Yes ❑No
b ❑Yes NNo
37 For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic®Yes❑No❑N/A
❑Yes❑NONN/A
❑Yes❑NoNN/A
Organic Management Plan (TOMP)?
38 a Does File Contain On -mal Permit Review Letter from the Division
a NYes [:]No7F
a NYes ❑No
a ®Yes ❑No
b All Issues Resolved?
b ❑Yes❑No❑N/A 11
b ❑Yes❑No❑N/A
b ❑Yes❑No❑N/A
39 During the Most Recent Semi -Annual Period, Did the POTW Complete
® Yes ❑ No
®Yes ❑ No
❑ No
its Sampling as Required by IUP, including flow
�F77��
40 Does File Contain POTW Sampling Cham -Of -Custody Forms?
®Yes ❑ No
®Yes ❑ No
®Yes ❑ No
41 During the Most Recent Semi -Annual Period, Did the SILT Complete its
®Yes❑No❑N/A
NYes❑No❑N/A
NYes❑No❑N/A
Sampling as Required by IUP, including flow?
41b During the Most Recent Semi -Annual Period, Did SIU submit all reports
NYes❑No❑N/A
NYes❑No❑N/A
NYes❑No❑N/A
on time
42a For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑NoNN/A
❑Yes❑NoNN/A
❑Yes❑NoNN/A
file include process/dilution flows as Required by IUPC
11
42b For categorical IUs with Production based limits, does file include
❑Yes❑NoNN/A
❑Yes❑NoNN/A
❑Yes❑NoNN/A
production rates and/or flows as Required by IUPC
43a During the Most Recent Semi-Amival Period, Did the POTW Identify
F-0 Yes ❑ No
❑Yes❑NoNN/A
® Yes ❑ No
All Limits Non -Compliance from Both POTW and SIU Samplmg9
43b During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑NoNN/A
❑Yes❑NoNN/A
❑Yes❑NoNN/A
All Reportmg_Non-Compliance from SIU Sampling?
44 a Was the POTW Notified by SIU (Within 24 Hours) of All Self-
a ®Yes❑No❑N/A
a ❑Yes❑No®N/A
a ❑Yes❑NoNN/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 within 30 days of becoming aware
of SIU limit violations in the POTW's sampling of the SIU
c ❑Yes❑No®N/A
c ❑Yes❑NoNN/A
c ❑Yes®No❑N/A
46 During the Most Recent Semi -Annual Period, Was the SIU in SNC?
❑ Yes ® No
❑ Yes ® No
I ❑ Yes ® No
47 During the Most Recent Semi -Annual Period, Was Enforcement Taken
NYes❑No❑N/A
❑Yes❑NoNN/A
NYes❑No❑N/A
as Specified in the POTW's ERP (NOVs, Penalties, tinting, etc )?
48 Does the File Contain Penalty Assessment Notices?
NYes❑No❑N/A
❑Yes❑NoNN/A
❑Yes❑NoNN/A
49 Does The File Contain Proof Of Penalty Collection
❑Yes❑NoNN/A
❑Yes❑NoNN/A
❑Yes❑NoNN/A
50 a Does the File Contain Any Current Enforcement Orders9
a ❑Yes❑No®N/A
a ❑Yes❑No®N/A
a ❑Yes❑NoEN/A
b Is SIU in Compliance with Order?
b ❑Yes❑No®N/A
b ❑Yes❑NoNN/A
i b ❑Yes❑No®N/A
51 Did the POTW Representative Have Difficulty in Obtairung Any of This
Yes ®No
❑ Yes ® No
El Yes ® No
Requested Information For YOU?
E
11
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated Decembei 2016 Page 2

FILE REVIEW COMMENTS:
43a — Evans-Mactavish-Agricraft had two CN violations from self-monitoring; Tabaco Rag Processors had one oil & grease violation.
44 — SIUs resampled within 30 days as requested by the POTW.
47 — POTW issued notices of non-compliance to SIUs for limit violations as required by the ERP.
48 — POTW assessed a civil penalty to Evans-Mactivish-Agricraft for repeated CN violations, penalty will be collected in September.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
1 Industry Inspected
2 Industry Address
3 Type of Industry/Product
4 Industry Contact
Phone
Fax
Title
5 Does the POTW Use the Division Model Inspection Form or Equivalents ❑ YES ❑ NO
6 Did the POTW Contact Conduct the Following Parts of the Industrial Inspection Thoroughly9
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
OVERALL SUMMARY AND COMMENTS:
Comments The program is well implemented and managed
Requirements
Recommendations
NOD: ❑ YES ® NO
NOV: ❑ YES ®NO
QNCR: ❑ YES ® NO
POTW Ratins:
Satisfactory X Marginal UnSatisfactory
PCI COMPLETED BY: Cheng Zhan , Raleigh Regional Office _DATE: August 16, 2017
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3