NC0037834_Inspection_20180801

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ROY COOPER NORTH CAROLINA
Governor Environmental Quality
MICHAEL S.REGAN
Secretary
LINDA CULPEPPER
Interim Director •
August 1,2018
Mr.Joel Freeman i�ECE�VE®(®ENRIDWR
Pretreatment Coordinator
City of Winston-Salem AUG 14 2018
Mason Meads Complex
2799 Griffith Road Water Resources
Winston-Salem,North Carolina 27103 permitting Section
SUBJECT: Pretreatment Audit Inspection(PAI)
City of Winston-Salem
NPDES#NC0037834
Forsyth County
Dear Mr.Freeman:
On May 9, 2018 a Pretreatment Audit Inspection (PAI) Was performed by Jim Gonsiewski and Paul
DiMatteo of the Winston-Salem Regional office and Mr.Monti Hassan of the PERCS Unit of the Raleigh
Central Office. Mr. Joel Freeman, pretreatment coordinator for the City of Winston-Salem, was present.
The purpose of this inspection was to determine the effectiveness of the pretreatment program, which
included: a detailed file review,review of the publicly owned treatment works(POTW)plant performance,
sampling, and compliance judgement program, adherence to the enforcement response plan (ERP), and
observing an industrial user inspection. Additionally, an inspection of the Pepsi Bottling facility was
conducted in conjunction with an inspection by the City of Winston-Salem.
Background
This is a 51 MGD permitted system with the Archie Elledge and Muddy Creek facilities. The City has
twenty six(26) Significant Industrial Users(SIUs) of which eleven(11)are categorical.
Pretreatment Program Element Review
The Headworks Analysis(HWA)renewal was submitted on October 2,2017. The HWA was approved on
February 28,2018.The next HWA is due on October 1,2022.
The last Industrial Waste Survey (IWS) was submitted on July 1, 2016. The IWS was approved on
September 2,2016.The next IWS is due on July 1,2021.
The Sewer Use Ordinance(SUO)was approved on February 9,2012.
The Enforcement Response Plan(ERP)was approved on April 18,2012.
DEQ
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 Hanes Mill Road,Suite 300 I Winston-Salem,North Carolina 27103
336.776.9800

LTMP File Review
The Long Term Monitoring Plan(LTMP)is being conducted at the proper locations and frequencies.The
plan expires on August 1,2018. The plan renewal was submitted on July 1,2018.
Industrial User Permit(IUP)File Review
A review of the file for Siemens Energy(#3026)revealed that the monitoring data was well organized and
compliant.
The slug control plan for Siemens Energy(#3026)was in good order.
A review of the file for Johnson Controls(#1044)revealed that the monitoring data was well organized and
compliant.
The slug control plan for Johnson Controls(#1044)was in good order.
A review of the file for Ingredion (#1191) revealed that the monitoring data was well organized and
compliant.
The slug control plan for Ingredion(#1191)was in good order.
Action Items
No other action items were noted.
The pretreatment program is considered satisfactory. Mr. Freeman maintains the program in an excellent
manner.If you have any questions please contact Jim Gonsiewski or me at(336)776-9800.
Sincerely,
Sherri V.Knight,PE
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources,NCDEQ—WSRO
cc: PERCS Unit—Monti Hassan
Central Files
WSRO Files

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT AUDIT REPORT
Water Resources - •
ENVIRONMENTAL DUALITY
Background Information [Complete prior to audit; review Program Info Database Sheet(s)]
1. Control Authority(POTW)Name: City of Winston-Salem
2. Control Authority Representative(s):Joel Freeman
3. Title(s): Utility Plant Supervisor/IWC
4. Address of POTW:
Mailing 2799 Griffith Road
City Winston-Salem,NC Zip Code 27103
Phone Number 336-765-0130 Fax Number 336-699-4320 E-Mail joelfncityofws.org
5. Audit Date 05/09/2018
6. Last Inspection Date: 09/19/2017 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. Muddy Creek was non-compliant for permit sampling monitoring. TKN and TP were not collected
for two of the five weeks in August 2017. This deficiency was due to a mix up with Muddy Creek's and Archie
Elledge's permits. Notification of this deficiency was sent to the DEQ Winston-Salem Regional Office.
9. Is POTW under an Order That Includes Pretreatment Conditions? ❑ Yes ® No
Order Type and Number: Are Milestone Dates Being Met? ❑Yes ❑ No El NA
Parameters Covered Under Order
ICIS Coding
Main Program Permit Number MM/DD/YY
1NICIOIOI3 17 IR H 14 I 1051091181
10. Current Number of Significant Industrial Users(SIUs)? 26
11. Number of SIUs with No IUP,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)? 11
19. Number of CIUs in SNC? 0
NC DWR Pretreatment Audit Form Revised: December 2016 Page 1

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 Program Info: `W
Program Element Last Submittal Last Approval Date Next Due,
Date In file? Date In file If Applicable
Headworks Analysis(HWA) 10/02/2017 ®Yes❑ No 02/28/2018 ®Yes❑ No 10/01/2022
Industrial Waste Survey(IWS) 07/01/2016 ®Yes ❑ No 09/02/2016 ®Yes❑ No 07/01/2021
Sewer Use Ordinance(SUO) 01/13/2012 ® Yes ❑ No 02/09/2012 ®Yes ❑ No
Enforcement Response Plan(ERP) 03/14/2012 ® Yes ❑ No 04/18/2012 ®Yes❑ No
Long Term Monitoring Plan(LTMP) 08/29/2014 ® Yes❑ No 10/27/2014 ® Yes ❑ No 08/01/2018
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. Clemmons,Davidson,Davie,Kernersville,Rural Hall,King,and
Walkertown.
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 11/ 14 / 2011
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=Satisfactory M=Marginal U=Unsatisfactory
Rating Explanation,if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program ®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
NC DWR Pretreatment Audit Form Revised: December 2016 Pane 2

,,30. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No
Explain Yes or No.Linko Data monitoring for tracking and compliance.
31. How does the POTW recover the cost of the Pretreatment Program from their industries?Explain. •
BOD/TSS Surcharges.
Public Perception/Participation
32. Are there any local issues affecting the pretreatment program(e.g.. odor,plant closing,new or proposed plants)?
®Yes El No If yes,Explain. Industries closed include Flowers Bakery(2017),Rockwell Collins,HP Fabrics.Pepsi is
planning to expand.
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?
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?
35. In addition to annual inspection,does the POTW periodically meet with industries to discuss pretreatment? ® Yes El 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 SNC
Permitting(Industrial Waste Survey-MS)
38. How does the POTW become aware of new or changed Users?Billing,inspections,City Hall.
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?)The user fills out a permit application. A site visit is conducted. The Authority completes the allocation
table and compares it to the Sewer Use Resolution.
40. Does the POTW receive waste from any groundwater remediation projects(petroleum, CERCLA) or landfill leachate?
®Yes ElNo If Yes,How many are there?One
Please list each site and how it is permitted,if applicable. City Landfill. Not permitted(Commercial)
41. Does the POTW accept waste by(mark if applicable) ®Truck ❑Dedicated Pipe El NA
42. If the POTW accepts trucked waste,what controls are placed on this waste? (example. designated point,samples drawn,
manifests required)Septic haulers have a specific area on the plant site to dispose of waste each time. Haulers fill
out manifests and submit them to the POTW. Haulers are monitored entering and leaving the facility.
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?BOD
45. If yes to#44,What is being done to address the over allocations?(short-term IUPs,HWA to be revised,pollutant study,etc.)
Revisit BOD concentrations and reduce limits.
46.Does the POTW keep pollutant loading in reserve for future growth/safety? ®Yes El No
If yes,what percentage of each parameter.Archie Elledge: BOD and Flow 43%,TSS 56%,Ammonia 71%,Arsenic 92%,
Cadmium 72%,Chromium 82%,Copper 82%,Cyanide 22%,Lead 57%,Mercury 94%,Molybdenum 99%,Nickel 58%,
Selenium 99%,Silver N/A,Zinc 78%. Muddy Creek: BOD N/A. Flow 23%,TSS 5%,Ammonia 63%,Arsenic 88%,
Cadmium 99%,Chromium 99%,Copper 88%,Cyanide 86%,Lead 97%,Mercury 99%,Molybdenum 100%,Nickel 97%,
Selenium 98%,Silver 76%,Zinc 90%.
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 Page 3

•
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). LTMP parameters,results on permit
applications,pollutants of concern,allocation table.
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Possibility of upsetting the plant operations,strength of industry discharge,permit application,and industry operations
practices.
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.Industrial reports are sent to the POTW.Visually checked for
accuracy,compared to the user permit for compliance,then entered into the database for additional checks and
monitoring.
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?
Chemicals on site,what they are used for,how they are stored,and how they are disposed of. Chemical makeup. SDS.
Other criteria are valve placement and operational procedures.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Accurate and feasible information is provided to protect the City sewer system, POTW,and receiving waters. Can the plan
be met? Are there circumstances that can harm utilities?
56. How does the POTW decide where the sample point for an SIU should be located?
The sample location is the last point of discharge capturing all process flows for a representative sample.
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.POTW has protocols to sample industries using the
same procedures. These procedures include ensuring the sampler pulls all necessary samples,jugs are cleaned,the sample
is placed on ice,collection protocols are followed,and the sample is collected at the same location every time. The SIU
makes sure the sample location is accessible and safe. Additionally,all equipment is checked to make sure it is operational.
58. Who performs sample analysis for the POTW for Metals Meritech Laboratories
Conventional Parameters Elledge&Meritech
Organics Meritech Laboratories
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
The sample technicians collect samples,fill out the Chains of Custody(COCs)with correct information,and send the
samples and the COCs to the City Laboratory. The COCs are giver to lab personnel to fill out the sample information. A
COC is then filled out to go to the commercial lab with the information provided in the first COC. The samples and COCs
are then sent to the commercial lab. When the analyses are completed,the results are sent back to the Archie Elledge lab
along with a completed 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 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
NC DWR Pretreatment Audit Form Revised: December 2016 Page 4

• 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.Completion of Muddy Creek Construction allowing for more split flows.
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.Upgrades to plant process would be required to accept additional loading.
Summary
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
No
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 1.Siemens Energy 2.Johnson Controls 3.Ingredion
67. IUP Number 3026 1044 1191
68. Does File Contain Current Permit? ® Yes ❑ No ®Yes ❑ No ® Yes ❑ No
69. Permit Expiration Date 06/30/2022 06/30/22 06/30/22
70. Categorical Standard Applied(I.E.40 CFR,Etc.)Or N/A 433 461 N/A
71. Does File Contain Permit Application Completed Within One Year Prior ®Yes ❑ No ®Yes ❑ No -1 Yes ❑ No
to Permit Issue Date?
72. Does File Contain Inspection Completed Within Last Calendar Year? ®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 Formifrom POTW) 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❑N/A ❑Yes❑No NN/A ❑Yes❑NoNN/A
Organic Management Plan(TOMP)?
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❑NooN/A b.❑Yes❑No®N/A
76. During Most Recent Semi-Annual Period,Did POTW Complete its ®Yes ❑ No ®Yes ❑ No -1 Yes ❑ No
Sampling as Required by IUP,including F1ow?I
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 NYes❑No❑N/A NYes❑No❑N/A NYes❑No❑N/A
Sampling as Required by IUP, including Flow?
79. During Most Recent Semi-Annual Period,Did SIU submit all reports on NYes❑No❑N/A -NYes❑No❑N/A NYes❑No❑N/A
time?
80a. For categorical IUs with Combined Wastestream Formula(CWF),does ❑Yes❑NoNN/A ❑Yes❑NoNN/A ❑Yes❑No®N/A
file include process/dilution flows as Required by IUP?
Ob.For categorical IUs with Production based limits,i does file include ❑Yes❑NoNN/A ❑Yes❑No NN/A ❑Yes❑NoIN/A
production rates and/or flows as Required by RI,,P9
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 NN/A ❑Yes❑NoNN/A ®Yes❑No❑N/A
Reporting Non-Compliance from SIU Sampling?
83. a.Was POTW Notified by SRI(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
becoming aware of SRI limit violations in the POTW's sampling of SIU?
c❑Yes❑No®N/A c.®Yes❑No❑N/A
84. During Most Recent Semi-Annual Period,Was SIU in SNC? El Yes ® No ❑Yes ® No ❑Yes ® No
85. During Most Recent Semi-Annual Period,Was Enforcement Taken as ❑Yes❑No NN/A NYes❑No❑N/A ❑Yes❑NoNN/A
Specified in POTW's ERP(NOVs,Penalties,tirrling, etc.)?
86. Does File Contain Penalty Assessment Notices? ❑YesDNoNN/A ❑YesDNo N/A ❑YesDNoON/A
87. Does File Contain Proof Of Penalty Collection? ❑Yes❑N°SN/A ❑Yes❑NoNN/A ❑Yes❑NoZN/A
88. a.Does File Contain Any Current Enforcement Orders? a.❑Yes❑No®N/A a.❑Yes❑NozN/A a.❑Yes❑No®N/A
b.Is SIU in Compliance with Order? b.❑Yes❑NoeiN/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:
NC DWR Pretreatment Audit Form Revised: December 2016 Pane 6

INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
INICIO 10 13 17 18 13 14 1 105109 1 18 1
1. Industry Inspected: Pepsi
2. Industry Address: 3425 Myer Lee Drive Winston-Salem,NC 27101
3.Type of Industry/Product: Drink/Beverage
4. Industry Contact: Tim Gartley Title: Plant Engineer Phone: [phone] Fax: [phone]
5. Does the POTW Use the Division Model Inspection Form or Equivalent? ®Yes El 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
Industrial Inspection Comments:
Water use is approximately 135,000 to 175,000 gpd,depending on the flavor being produced. It currently employs 110 employees.
It normally is in operation five days a week,although in the summer the number of days in operation will be higher. The facility
is clean and very well run.
Audit SUMMARY AND COMMENTS:
Audit Comments: Mr. Freeman runs an excellent pretreatment program. His has good interaction with the SIUs which helps
the operation run smoothly.
Requirements:
Recommendations:
NOD: ❑ Yes ® No
NOV: ❑ Yes ® No
QNCR: ❑ Yes ® No
POTW Rating:
Satisfactory ® Marginal El Unsatisfactory❑
Audit COMPLETED BY: (-(?) `-�'- DATE: 07/27/2018
Monti Hassan,PERCS,and Jim Gonsiewski and Paul DiMatteo Winston-Salem Regional Office
NC DWR Pretreatment Audit Form Revised: December 2016 Page 7