NC0055786_Pretreatment Audit Inspection_20170922

September 22, 2017
Ms. Gisele Comer
City of Lexington
28 West Center Street
Lexington, NC 27292
SUBJECT: Pretreatment Audit Inspection
City of Lexington
NPDES Permit #NC0055786
Davidson County
ROY COOPER
t7o"er nor•
MICHAEL S. REGAN
Secretcary
S. JAY ZIMMERMAN
Dwectnr
;R CEIV DINCDEQ/DWR
SEP 2 7 2017
',r'iator Quality
Perrnitting Section
A Pretreatment Audit Inspection was performed by George Smith and Jim Gonsiewski of the
Winston-Salem Regional Office, on the subject facility on September 21, 2017. Ms. Gisele Comer
and Ms. Eglantina Minerali 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, and adherence to the
enforcement response plan (ERP).
The City currently has six (6) Significant Industrial Users (SIU), five (5) of which are categorical.
There were no SIUs in significant non-compliance (SNC) during the previous semi-annual period for
permit limits or reporting violations.
The audit showed the pretreatment program maintained in an excellent manner. Please refer to the
attached report for further detail. If you have any questions, please contact George Smith at (336)
776-9700.
Sincerely,
N°r/ herri V. Knight, Regional Supervisor
�� Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
enclosure:
cc• Mr. Robert Jones, Public Operations Manager — City of Lexington
Monti Hassan — PERCS Unit
WSRO Files
State of North Carolina I Environmental Quality
450 W Hanes Mill Road, Suite 300, Winston-Salem, North Carolina 27105
Phone- 336-776-98001 FAX [phone]

ENR NORTH CAROLINA DIVISION OF WATER RESOURCES
NCD
EN PRETREATMENT AUDIT REPORT
Background Information [Complete prior to audit; review Program Info Database// Sheet(s)]
1. Control Authority (POTW) Name �l N �LQ l �`v � ' ° l4 74
C.
2 Control Authority Representative(s)-a
3. Title(s).
4 Address of POTW
Mailing
city P.�� �b Zip Code ;;ea 9a
Phone Number 3.3 -, 57 - %��% Fax Number `J6 3" ?I
5 Audit Date % 1,41 /,40/1 U 1-iConneeCOD levm 4-2 4`j j,,
6. Last Inspection Date 6 / -7 17 Inspection Type. E�PCI B` 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 problems9 ,Yes ❑ No
If Yes, Explain & �� V —
9 Is POTW under an Order That Includes Pretreatment Conditions? ❑ Yes 0 --go
Order Type and Number Are Milestone Dates Being Met9 ❑ Yes ❑ No 2/*NA
Parameters Covered Under Order
PCS (WENDB)Coding
Trans Code Main Program Permit Number MM/DD/YY
Inspec.Type
Inspector
Fac Type
LsrJ I N I C 1 0 1 0 1 S 151 71 b 1 �1 19 I st 1 r7 I
Lal
LS -1
LLL
(DTIA)
(TYPI)
(INSP)
(FACC)
10 Current Number of Significant Industrial Users (SIUS)9
11 Current Number of Categorical Industrial Users (CIUS)9
12 Number of SIUs Not Inspected by POTW in Last Calendar Year9
13. Number of SIUs Not Sampled by POTW in Last Calendar Year9
14 Enter Higher Number of 12 or 13
15 Number of SIUs with No IUP, or with an Expired IUP
16. Number of SIUs in SNC for Either Reporting or Limits Violations During Either of Last 2
Semi -Annual Periods (Total Number of SIUs in SNC)
17 Number of SIUs in SNC for Reporting During Either of Last 2 Semi -Annual Periods
18 Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi -Annual Periods
19 Number of SIUs in SNC for Both Reporting and Limits Violations During Either of Last 2
Semi -Annual Periods
20. Number of SIUs in SNC for Self -Monitoring Requirements that were Not Inspected or Sampled
NC DWR Pretreatment Audit Form Revised July 25, 2007
SNS
CNS
NOIN
NOCM
PSNC
MSNC
SNPS
SNIN
Page 1

21. PRETREATMENT PROGRAM ELEMENTS REVIEW- Review POTW files, verify POTW has copy of each Program Element }
In tbp..ir File_ comnlete with All sunnortmA document- and PFRCS Annroval Lettel. and dates consistent with Proeram Info
Program Element
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
O�
E]-�es ❑ No
� ,D
[]'des ❑ No
1 l
Industrial Waste Survey (IWS)
8 !�
G%'Yes ❑ No
2 --Yes ❑ No
�1/
Sewer Use Ordinance (SUO)
No
[, es E]'i
/
.❑es ❑ No
Enforcement Response Plan (ERP)
-2-Yes ❑ No
* d
2 1res ❑ No
Long Term Monitoring Plan (LTMP)
L /7❑Yes
❑ No
���
es ❑ 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 Jurisdiction9
❑ Yes
P,No If yes, Please list these towns and/or areas
23 If yes to #22, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? ❑ Yes k No ❑ NA
A copy, if not already submitted, should be sent to Division
24 If yes to #22, Have you had any trouble working wi.h these towns or districts9 ❑ Yes X No ❑ NA
If yes, Explain
25 Date of Last SUO Adoption by Local Council
26 Have you had any problems interpreting or enforcing any part of the SU09 ❑ YesZNNo
If yes, Explain
Enforcement
Plan -
27 Did you send a copy of the ERP to your mdustries9 0 Yes ❑ No
If no, POTW must send copy within 30 days
28. Have you d 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 ` t Mt
Resources
30 Please Rate the Followine. S=Satisfactory M=Margmal U=Unsatisfactory
NC DWR Pretreatment Audit Form Revised July 25, 2007 Paize 2
IN
Ratin
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
❑S M ❑U
Access to POTW Vehicles for
Sampling, Inspections, and
VEN ❑U
Emergencies
Access to Operable Sampling
AM
Equipment
❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
EA ❑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 ❑U
NC DWR Pretreatment Audit Form Revised July 25, 2007 Paize 2
IN

31 Does the POTW have an adequate data management ystem to run the pretreatment programs � es El No
Explain Yes or No. / � SQ <_ -xaw o
32. How does the POTW recover the cost of the Pretreatment Program from their mdustries9 Explain ,
7 e �'��
Yam
Public Perception/ Participation
33 Are there anyTocal issues affecting the pretreatment program (e g odor, plant closing, new or proposed plants)9
❑ Yes No If yes, Explain
34 Has any one from the public ever requested to review pretreatment program files9 ❑ Yes No
If yes, Explain procedure If no, How would the request be addressed9 Afkxar �.
35 Has any industry ever requested that certain information remain confidential from the public9 Yes ❑ No If yes, Explain
procedure for determining whether information qualified for co fidential St tus, as well as procedure for keeps Q files confidential
fi•om public If no how would the request be addressed9 co
��
36. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? ;21111 es ❑ No
37 Is the public notified about changes in the SUO or Local Limits Yes ❑ No O
38 Were all industries in SNC published in the last notice? ❑ Yes ❑ N; 4 ,�� C
Waste
39a How does the POTW become aware of new or changed Users9 —7-14A74 d b7 Q�1� Q7 �.�15 v
39b Once the POTW becomes aware of new or changed Users, how does the POTW determine which industries have the ss
reasonable potential to adversely impact the WWTP and therefore require a new permit or a permit revision? (Who is an
slug) a-j�9 "AA- d7l /,�? 51-2e��l - r -Y-- !>d -.</' Ile -
40 Does,,the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
es ❑No If Yes, How many are there? �
Please list each site and how it is permitted, if applicable /
41 Does the POTW accept waste by (mark if applicable) u l ruck ❑Dedicated Pipe ❑ NAS oat) P�
42 If the POTW accepts trucked waste, what controls are placed on this waste? (example designated point, samples drawn,
manifests required)�—
43 H w does the POT �all catei loading to industrres? Mark all that apply
❑ Uniform Limits n Historical Industry Need .913y Surcharge C 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 allocations9 (short-term IUPs, HWA to be revised, pollutant study, etc )
46 Does the POTW keep pollutant loading in reserve for future gro®h / safety es El No
If yes, what percentage of each parameter �/o f., 5 / �)
47. Has the POTW experienced any difficulty in allocation? (for example- adjudication by an industry) ❑ YesNo
If yes, Explain
48 How does the POTW decide on which pollutants to limit in the permits9 Monitor for9 (for example were only those pollutants
listed on the application limited, categorical parameters, NPDES ollutants of Concern)A0%4 57Y2 -6a1"---1.)
cop
49 How oes the TW decid w a the m�mto mg_ equency shoul be for the various �llutants m ind stry permits 9 Exp
Nrdi _,MRevised July 25, 2007 Page 3

Permit Compliance
50 Does the POTW currently have or during the past year had any permits under adjudication? ❑ Ye No
If yes, which industries? What was (will be) the outcome of the adjudication?
51 Demonstrate how the POTW fudges compliance This should elude compliance judgment pnvll violations of 11 qts, reporting
requirements, and permit conditions, as well as for SNC (iA V (A-01,
52 Does the POTW use the Division's model mspectio-i 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?,E]'Yes ❑ No
If no, Explain 4-11
54 What criteria e used to determine if a slug/spill control plan is needed?
<X� AA4dtt (tda
55 What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
cif GAJ "g
56 How does the POTW decide where the sample point for an SIU should be locateq.
"&W
57 Has the POTW established a procedure to ensure that representative samples will be taken by the POTW or SIU each time?
(exampleect location, proper programming of sampler, clean equipment, swirling the sample bucket uniformly)
POTW es ❑ No SIU ❑ Yes ❑ No If yes, Explain i
58 Who performs sample analysts for the POTW for Metals 9,V
Conventional Parameters 'I
Organics 7w• %
59 Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
aV W,6" ?T 4t
• a /
Long/Short erm Monitor lan L/ TMP and Headworks Ana is WA '
60a Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations ;��YES
cies? -I� Y)ES ❑ NO
60b Are Correct Detection Levels being used for all LTMP/STMP Monitori ❑ NO
60c Is LTMP/STMP Data Maintained in Table or EquivalenYES ❑ 1�1® Is Table Adequate? [:]YES ❑ NO
60d All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? ES ❑ NO DWQ 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
If yes, which ones? Eliminated, Added
61 Do you complete your own headworks analysis (HWA) Yes ❑ No
If no, Who completes your HWA? Phone --
-q
62. Do you have plans to revise your HWA in the near future? Yes FI No
If yes, What is the reason for the revision? (marls all that apply)F711ncreased average flow ❑NPDES limits change
❑More LTMP data available ❑Resolve over allocationyear expiration ❑Other
Explain
63 In general, what is the most limiting criteria of your HWA? Onhibiti0h nrass 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
NC DWR Pretreatment Audit Form Revised July 25, 2007 Pai;e 4

65 Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
I IQ ()f1 -G 161411tv"-_j
f TNTITTCTT?TAT. TT.CTR P19VAUT (TTTP) FTT,Ti. RF.VTFW (i TTTP FTT.F. REVTEWS AND 1 IU INSPECTION)
66 User Name `-el� ���
3 LC G4 c G
67 IUP Number a 0
0017
Ji'es ❑ No1 ® es ❑ No
68 Does File Contain Current Permrt9i❑
Yes ❑ No
69 Permit Expiration Date
.3- 31 `d % j
3t l L`J 11 157 c i
70 Categorical Standard Applied (I E. 40 CFR, Etc ) Or N/A
y
q 3 ' 3
❑ No
® es ElNo Yes ElNo
I
71 Does File Contain Permit Application Completed Within One Year Prior[Les
ip
to Permit Issue Date
72 Does File Contain Inspection Completed Within Last Calendar Year?
es ❑ No
es ❑ No Q es ❑ No
73 a Does File Contain Slug/Spill Control Plan?
a es ❑No
rb-DY-es-f�I3v 11
a ®Y -es ❑No
a EK6s ❑No
b If No, is One Needed9 (See Inspection Form from POTW)
b❑Y_es gNo
b-EYm-fpNo
74 For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
es❑No❑N/A
I
❑ es❑No❑N/A F es❑No❑N/A
F11
Organic Management Plan (TOMP)?
75 a Does File Contain Original Permit Review Letter from Division
a Z' 'es ❑No
Fa—E F es ❑No
a [21es ❑No
b All Issues Resolved9
b ❑Yes❑NopN/A
b ❑Yes❑No /A
b ❑Yes❑NnrnW/A.
76 During Most Recent Semi -Annual Period, Did POTW Complete its
O'Ies ❑ No
l
es ❑ No
Yes [:1 No
Sampling as Required b IUP, includingFlow
-
77 Does File Contain POTW Sampling Chain -Of -Custody Forms
es ❑ No 11
—
DYes El—No-1
UYes ❑ No
78 During Most Recent Semi -Annual Period, Did SIU Complete its
[gYes❑No❑N/A
[OKs—ON-00
es❑No❑N/A
Sampling as Required by IUP, including Flow9
79 During Most Recent Semi -Annual Period, Did SIU submit all reports on
es❑No❑N/A
M es❑No❑N/A
Gj�es❑No❑N/A
time
80a For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑No /A
❑Yes❑No /A
11
❑YesONOC�1 /A
file include process/dilution flows as Required by IUPC
80b For categorical IUs with Production based limits, does file include
❑Yes❑No /A
❑Yes❑No /A
❑Yes❑No /A
production rates and/or flows as Required by IUP9
81. During Most Recent Semi -Annual Period, Did POTW Identify All
❑ No
r
❑ Y ,, No
��
❑ - No
Ick
Limits Non -Compliance from Both POTW and SIU Sampling?
h1
82 During Most Recent Semi -Annual Period, Did POTW Identify All
❑Yes❑No /A
❑Yes❑No /A
❑Yes❑No /A
Re ortin Non -Compliance from SIU Sampling?
83 a Was POTW Notified by SIU (Within 24 Hours) of All Self-
a ❑Yes❑No /A
a.❑Yes❑No9*6A
a ❑Yes❑No /A
Monitoring Violations9
b. Did Industry Resample and submit results to POTW within 30 Days9
b ❑Yes❑No[iN/A
b ❑Yes❑NoLr-i4/A
b ❑Yes❑No[bN-/A
c If applicable, did POTW resample and obtain results within 30 days of
No
c Yes❑z
❑
%
/A
becoming aware of SIU limit violations in the POTW's sampling of SIU
c ❑Yes❑Nofz3N/,A
c ❑Yes❑Noll
84 During Most Recent Semi -Annual Period, Was SIU in SNCL
I ElYes [r No
I [-]Yes N
[:]Yes No
85 During Most Recent Semi -Annual Period, Was Enforcement Taken as
❑Yes❑No /A17es❑!o[gfT/A
I ❑Yes❑No[Zl
Specified in POTW's ERP (NOVs, Penalties, timing, etc )?
86 Does File Contain Penalty Assessment Notices9
❑Yes❑No[9
❑Yes❑No /
❑Yes❑No /A
87. Does File Contain Proof Of Penalty Collection
❑Yes❑No /A
11 ❑Yes❑No /A
❑Yes❑No /A
88 a Does File Contain Any Current Enforcement Orders9
Is SIU in Com liance with Orders
a.❑Yes❑No
b ❑Yes❑No /
Fa-, Yes❑No
❑Yes❑NoM /
a ❑Yes❑Nob.
b ❑Yes❑No /A -
89 Did POTW Representative Have Difficulty in Obtaining Any Requested
❑ Yes [D -No
j[_MTW ❑ No
❑ Yes ®/No
Information For You9
FILE REVIEW COMMENTS:
NC DWR 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
IBJ INI CIO 10 1515;17719_k 1 71 a 1 1 1 71 1 U J L s_I
(DTIA) (TYPI) (INSP)
1. Industry Inspected 174-Teof& 0°! C -7;fie" 01, p
2 Industry Address 9735 �oG� `LcZGs7,4, • e4 c2 7—
3 Type of Industry/Product. 17
4 Industry Contact �/oP 4QAV;Licdo Ti�
le. (�✓ V . Phone 1367-W 67�Fax
5. Does the POTW Use the Division Model Inspection Form or Equivalent9 ❑ Yes ❑ No -FT7y-- //
6 Did the POTW Contact Conduct the Following Parts of the Industrial Inspection Thoroughly? 5 4?
Comments
A Initial Interview[ s ❑ No
B Plant Tour []yes ❑ No
C Pretreatment Tour EvS F1No
D Sampling Review 0 Yes ❑ No
E Exit Interview Yes ❑ No
Indurstrial Inspection Comments:
Audit SUMMARY AND COMMENTS:
Audit Comments
Requirements
Recommendations
NOD: ❑ YesNo
NOV: ❑ Yes /N
❑f
QNCR: ❑ Yes EU, -,No
1
Fac Type ,
(FACC)
��� L"t z-6 P�t,d 1'0_�c /""", C --
POTW Rating:
Satisfactory [D///"
Marginal ❑ Unsatisfactory ❑
Audit COMPLETED BY: al:11�6 DATE: 741 l
Winston-Salem Regional Office
NC DWR Pretreatment Audit Form Revised July 25, 2007 Pate 6