NC0024228_Compliance Evaluation Inspection_20180823

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ROY COOPER NORTH CAROLINA
Governor Environmental Quality
MICHAEL S.REGAN
Secretory
LINDA CULPEPPER
Interim Director
August 23, 2018
Ms. Carrie Hyler, Pretreatment Supervisor
City of High Point
PO Box 230
High Point, NC 27261
.Subject: Pretreatment Compliance Inspection Report
NPDES Permit# NC0024210 and NC0024228
City of High Point
Dear Ms. Hyler:
On August 7, 2018, Paul DiMatteo of the Division of Water Resources Winston-Salem Regional Office
conducted a Pretreatment Compliance Inspection at the above referenced wastewater treatment system.The
purpose of this inspection was to determine the effectiveness of the Town's pretreatment program, which
included: reviewing the files, POTW plant performance, sampling and compliance judgement program, and
adherence to the enforcement response plan (ERP).
Background
The City operates one 6.2 MGD facility and one 26 MGD facility, and has 21 significant industrial users
(SIUs), 13 of which are categorical.
POTW Interview
During the most recent semi-annual period (January through June, 2018),the City determined that one
industry, Dairy Fresh (#151), was in significant noncompliance for limits violations. Ms. Hyler said that public
notice would be published in 2019 before the Pretreatment Annual Report (PAR) is submitted. Additionally,
bypass issues with Hunter Farms described in the previous PAR were resolved through an agreement by their
and the town's lawyers earlier this year. All other violations are identified and handled according to the
Enforcement Response Plan.
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NORTH CAROLINA /'
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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

Pretreatment Program Elements Review
The Headworks Analysis (HWA) renewal was submitted for the Westside plant on April 27, 2017 and
approved on July 26, 2017, and for the Eastside plant on June 5, 2017 and approved on August 10, 2017. The
next HWA will be due for Westside and'Eastside on December 1, 2019 and May 31, 2022 respectively.
The City's last Industrial Waste Survey (IWS) was submitted on January 21, 2015 and was approved on
February 5, 2015. The next IWS is due January 31, 2020.
The last Long Term Monitoring Plan (LTMP) for both plants was submitted on May 14, 2018 and
approved on August 8, 2018.
The Sewer Use Ordinance (SUO) was approved on January 10, 2013
The ERP was approved on October 9, 2008.
LTMP Review
The LTMP is being conducted at the proper locations and frequencies.
Industrial User Permit (IUP) File Review
A review of the files for Diary Fresh (#151), Zebra Environmental (#153) and Innospec Performance
Chemicals (#120) revealed that monitoring data was well organized and violations were addressed in a timely
manner consistent with the ERP. The slug control plans were in good order.
The pretreatment compliance inspection was satisfactory. The program is being implemented in an
excellent manner. If you should have any questions, please do not hesitate to contact Paul DiMatteo at (336)
776-9691 or our office at [phone].
Sincerely,
jitau,
Sherri V. Knight, P.E., Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
Enclosures—PCI Report
CC: PERCS Unit—Monti Hassan
WSRO Files
Central Files

NORTH CAROLINA DIVISION OF WATER RESOURCES
- PRETREATMENT COMPLIANCE INSPECTION(PCI) REPORT
Water Resources
ENVIRONMENTAL QUALITY
BACKGROUND INFORMATION[Complete Prior To PCI;Review Program Info Database Sheet(s)1
1. Control Authority(POTW)Name: Hi•i Point
2. Control Authority Representative(s):_Carrie Hyler
3. Title(s): Pretreatment Supervisor
4. Last Inspection Date:_9/12/2016 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: Are Milestone Dates Being Met? ❑YES ❑NO
ICIS CODING
Main Program Permit Number MM/DD/YY
NIC10 10 1 214 1 211 10 1 1081161181
7. Current Number Of Significant Industrial Users(SIUs)? 21
8. Number of SIUs With No IUP, or With an Expired IUP? 0
9. Number of SIUs Not Inspected By POTW in the Last Calendar Year? 0
10.Number of SIUs Not Sampled By POTW in the Last Calendar Year? 0
11.Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi-Annual Periods? 1
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)? 13
16. Number of CIUs in SNC? 0
POTW INTERVIEW
17. Since the Last PCI,has the POTW had any NPDES Limits Violations? ®YES ❑NO
If Yes,What are the Parameters and How are these Problems Being Addressed? Reportedly not related to
pretreatment.
18. Since the Last PCI,has the POTW had any Problems Related to an Industrial ®YES ❑NO
Discharge(Interference,Pass-Through,Blockage,Citizens' Complaints,Increased Hunter Farms bypass events were
Sludge Production,Etc.)? documented in PAR and resolved
If Yes,How are these Problems Being Addressed? through an agreement by,their and
the town's lawyers this year.
19. Which Industries have been in SNC for Limits or Reporting during SNC for Limits:Dairy Fresh
either of the Last 2 Semi-Annual Periods?Not Been Published for SNC for Reporting:None
Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not Published:Dairy Fresh—to be published
in 2019.
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 Division? None
21. Are Any Permits or Civil Penalties Currently Under Adjudication?If Yes,Which ❑YES ®NO
Ones?
LTMP/STMP FILE REVIEW:
22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ®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 (Reviewed 4/2018 DMR detection levels)
27. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑YES ®NO
NC DWR Pretreatment Compliance Inspection(PCI)Form Updated December 2016 Page 1

If yes,which ones?Eliminated: See Note Added:
28. PRETREATMENT PROGRAM ELEMENTS REVIEW-Please review POTW files,verify POTW has copy of Program Element in
their files,complete with supporting documents and copy of PERCS Approval Letter, and dates consistent with Pro am Info:
Program Element Last Submittal Last Approval Date Next Due,
Date In file? Date In file If Applicable
Headworks Analysis(HWA) 4/27/2017 ®Yes ❑ No 7/26/2017 ®Yes❑ No 12/1/2019
' (Westside)
Headworks Analysis 6/5/2017 ®Yes❑ No 8/10/2017 ®Yes❑ No 5/31/2022
(Eastside)
Industrial Waste Survey(IWS) 1/21/2015 ►1 Yes Cl No 2/5/2015 ® Yes El No 1/31/2020
Sewer Use Ordinance(SUO) 12/26/2012 ®Yes❑ No 1/10/2013 ® Yes❑ No
Enforcement Response Plan(ERP) 8/1/2008 ®Yes El No 10/9/2008 ®Yes❑ No
Long Term Monitoring Plan(LTMP) 5/14/2018 // Yes❑ No 8/8/2018 ®Yes ❑ No •
NC DWR Pretreatment Compliance Inspection(PCI)Form Updated December 2016 Page 2

INDUSTRIAL USER PERMIT(IUP)FILE REVIEW(3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name 1.Dairy Fresh 2.Zebra Environmental 3.Innospec Performance Chem.
30. IUP Number 151 153 120
31. Does File Contain Current Permit? ®Yes ❑ No ®Yes ❑ No ® Yes ❑ No
32. Permit Expiration Date 6/6/2021 5/1/2023 6/30/2021
33. Categorical Standard Applied(I.E.40 CFR,Etc.)Or N/A N/A 437.26 414
34. Does File Contain Permit Application Completed Within One Year Prior /1 Yes ❑ No ®Yes ❑ No ❑Yes ® No
to Permit Issue Date? 12/7/2015 9/7/2015 1/4/2016
35. Does File Contain an Inspection Completed Within Last Calendar Year? ®Yes ❑ No _®Yes ❑ No ®Yes ❑ No
36. a.Does the File Contain a Slug/Spill Control Plan? a. Yes ONo ra. ®Yes❑No a. ®Yes ❑No
b. If No,is One Needed?(See Inspection Form from POTW) b. ❑Yes❑No I b. ❑Yes❑No b. ['Yes❑No
37. For 40 CFR 413 and 433 TTO Certification,Does File Contain a Toxic ❑Yes❑NoDN/A ❑Yes❑NoEN/A ❑Yes❑No®N/A
Organic Management Plan(TOMP)?
38. a.Does File Contain Original Permit Review Letter from the Division? a. ®Yes❑No a. ®Yes❑No a. EYes ❑No
b.All Issues Resolved? b❑Yes❑No®N/A b❑Yes❑No®N/A , b.❑Yes❑No®N/A
39. During the Most Recent Semi-Annual Period,Did the POTW Complete L Yes ❑ No ®Yes ❑ No ®Yes ❑ No
its Sampling as Required by IUP,including flow?
40. Does File Contain POTW Sampling Chain-Of-Custody Forms? ®Yes ❑ No ®Yes ❑ No ®Yes ❑ No
41. During the Most Recent Semi-Annual Period,Did the SIU Complete its ®Yes❑No❑N/A ®Yes❑No❑N/A ®Yes❑No❑N/A
Sampling as Required by IUP,including flow?
4 lb.During the Most Recent Semi-Annual Period,Did SIU submit all reports ❑YesEINo❑N/A ®Yes❑No❑N/A ®Yes❑No❑N/A
on time?
42a.For categorical IUs with Combined Wastestream Formula(CWF),does ❑Yes❑No®N/A ❑Yes❑No®N/A ❑Yes❑No®N/A
file include process/dilution flows as Required by IUP?
42b.For categorical IUs with Production based limits,does file include ❑Yes❑No®N/A ❑Yes❑No®N/A ❑Yes❑No®N/A
production rates and/or flows as Required by IUP?
43a. During the Most Recent Semi-Annual Period,Did the POTW Identify ®Yes ❑ No ►/ Yes ❑ No ® Yes ❑ No
All Limits Non-Compliance from Both POTW and SIU Sampling?
43b. During the Most Recent Semi-Annual Period,Did the POTW Identify ®Yes❑No❑N/A ®Yes❑No❑N/A ®Yes❑No❑N/A
All Reporting 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❑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 within 30 days of becoming aware c❑Yes❑No®N/A
of SIU limit violations in the POTW's sampling of the SIU? c.❑Yes❑No®N/A c❑Yes❑No®NIA
46. During the Most Recent Semi-Annual Period,Was the SIU in SNC? ®Yes ❑ No ❑Yes ® No ❑Yes ® No
47. During the Most Recent Semi-Annual Period,Was Enforcement Taken ®Yes❑No❑N/A ®Yes❑No❑N/A ❑Yes❑NoEN/A
as Specified in the POTW's ERP(NOVs,Penalties,timing,etc.)?
48. Does the File Contain Penalty Assessment Notices? ®Yes❑No❑N/A ❑Yes❑NoEN/A ❑Yes❑No®N/A
49. Does The File Contain Proof Of Penalty Collection? ®Yes❑No❑N/A ❑Yes❑No®N/A ❑Yes❑No 0N/A
50. a.Does the 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
51. Did the POTW Representative Have Difficulty in Obtaining Any of This ❑Yes ® No ❑Yes ® No ❑Yes /1 No
Requested Information For You?
FILE REVIEW COMMENTS:
File was very well organized and complete.
NC DWR Pretreatment Compliance Inspection(PCI)Form Updated December 2016 Page 3

INDUSTRY INSPECTION ICIS CODLNG:
Main Program Permit Number MM/DD/YY
1 1 I I J I I J ► l 1 1 I l
1.Industry Inspected:
2.Industry Address:
3.Type of Industry/Product:
4.Industry Contact: 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
D. Sampling Review ❑YES ❑NO
E. Exit Interview ❑YES ❑NO
Industrial Inspection Comments:
Not conducted during PCI.
OVERALL SUMMARY AND COMMENTS:
Comments: High Point's Pretreatment Program appears to be exceptionally well run.
Requirements: Submit the next Pretreatment Annual Report by March 1,2019.Remember to include public notice issued for industries in
SNC.
Recommendations:
NOD: ❑YES ®NO
NOV: ❑YES ®NO
QNCR: EYES ®NO
POTW Rating: /
Satisfactory / Marginal UnSatisfactory
PCI COMPLETED BY: -041.),14,-,(-1---- DATE: i111.1-21%g
NC DWR Pretreatment Compliance Inspection(PCI)Form Updated December 2016 Page 4

�r" Program Name High Point_.- w �.�-- - �`._
$frea%►'1 Information;.=:�'' IWC% at 7Q10 93.47
WW1? Name West Side _
-m- . 0.67 / 0.43
'rogram Approval Date 06/10/1983 7 ow cfs/mgd
1Q10 Flow cfs/mgd 0.57 / 0.37
Pretreatment Status
Full Stream Classification C
Region WSRO Basin Number YADO7
County Guilford Receiving Stream Name RICH FORK
NPDES Number NC0024228
Last PAR Rec 02/27/2018 PAR Due Date 03/01/2018 mercury
NPDES Effective Date 08/01/2009 1631
Current Fiscal required
NPDES Expire Date 04/30/2014 Year PCI Done
BTW is Primary WWTP FALSE Last Audit on 09/12/2016 Audit Year Next20/21 yes
Design Flow mgd 6.2000 % Design mgd is SIU permitted 9.02 Permitted SIU flow(mgd) [Pt_SIU) .559
IWTP SIU's 4 Program SIUs 121 :=77',",-,-, , ' _,,. 7 ;,n .: :
/WTP CIU's 3Program ClUs 13HWA' 3 ;LTIVMP; °,. WS� `r SOO. s-:ERP' , ;:
J
. . '-,zz...�. , -:zx __ ,
to Inactive Date Next Due 12/01/2019 : 01/31/2020 ;
Date Received by DWR 04/27/2017 ; 05/14/2018 -01/2-1/291-5-
1/21/2015_' 12/26/2012 08/01/2008
Date Approved 07/26/2017 08/08/2018 02/05/2015 01/10/2013 10/09/2008
Adopt Date Required
Date Adopted . 12/17/2012
fo in this Box from Pt_Contacts Date Date Date
PT_Pro Attended Attended Attended
Formal Name g.Prime Phone/ ext Fax HWA Wksp IUP Wksp PAR Wksp
. Bill Frazier I 11336-880-0627 I 1336-883-3109 I) 1 7/31/2001 1 2/4/2004
[e-mail] - Laboratory Services Manager P.O.Box 230 .127261
.Carrie Hyler (Prim 11336 883-3090 l 1336-883-3109 11 2/9/2012 1 9/27/2011 I1/19/2012
[e-mail] Pretreatment Supervisor PO Box 230 127261
.Alannah Russell I 11336-883-3098 I 11
[e-mail] [Laboratory Analyst PO BOX 230 27261
J
?treatment Related NOVs from DWQDWR Central Office Contact Monti Hassan
'1998 Annual Report DWR Regional Contact Jim Gonsiewski
3/1996 PCI-Detection limits;not sending NOVs
3/2001 Annual Report
4/2001 PCI-Compliance evaluation
I

^-cam- . _ _ . �,-,-,-r .. , 7_a ..,-.-7._,,-. 7.- •-• -
)r Program Name High Point IWC%at 7Q10 85.37
.„Strath information- -
WWTP Name East Side �
7( "0roww—cfs/mgd 6.9 / 4.46
'rogram Approval Date 06/10/1983
Pretreatment Status
1Q10 Flow cfs/ mgd 5.74 / 3.71
Full Stream Classification WS IV
Region WSRO Basin Number CPF08
County Guilford Receiving Stream Name Deep River
NPDES Number NC0024210
Last PAR Rec 02/27/2018 - PAR Due Date 03/01/2018 mercury
NPDES Effective Date 01/01/2014 1631
NPDES Expire Date Current Fiscal required
p 12/31/2018 Year PCI Done
BTis Primary WWTP
TRUE Last Audit on 09/12/2016 Audit Year Next20/21 yes
W
Design Flow mgd 26.0000 % Design mgd is SIU permitted 4.38 Permitted SIU flow(mgd)[Pt SIU) 1.14
M/TP SIU's 17 Program Sills 121 _, 7 T:77.7.7:a , ,.,, .":.:: :71-.237,- -,,,.pa
M/TP CIU's 10 Program CIUs 13 HWA , LIMP ;=- =:- `' ,,,-, 'IWSf°:°:.; SU `. F;;--,
te Inactive Date Next Due 05/31/2022 . 01/31/2020
-- = - - - - - - - - - - -- - - -
Date Received by DWR 06/05/2017 05/14/2018 : 01/21/2015 12/26/2012 08/01/2008
Date Approved 08/10/2017 08/08/2018 02/05/2015 01/10/2013 10/09/2008
Adopt Date Required
Date Adopted 12/17/2012
.
fo in this Box from Pt_Contacts Date Date Date
PT_Pro Attended Attended Attended
Formal Name g.Prime Phone/ ext Fax HWA Wksp IUP Wksp PAR Wksp
. Bill Frazier I 11336-880-0627 1336-883-3109 II 1 7/31/2001 I 2/4/2004 I Laboratory ory Services Manager P.O.Box 230 27261
.Carrie Hyler (Prim 11336 883-3090 I 1336-883-3109 II 2/9/2012 1 9/27/2011 11/19/2012 I
[e-mail] Pretreatment Supervisor PO Box 230 . 127261
.Alannah Russell I 11336-883-3098 I I II I I I
[e-mail] Laboratory Analyst PO BOX 230 27261
?treatment Related NOVs from DWQ ) 1 DWR Central Office Contact Monti Hassan
'1998 Annual Report DWR Regional Contact Jim Gonsiewski
3/1996 PCI-Detection limits; not sending NOVs
3/2001 Annual Report
4/2001 PCI-Compliance evaluation
1