NC0023906_Pretreatment Audit_20181030

ROY COOPER
Gavel nal
IC
MICHAEL S. REGAN
Secretary
Water Resources LINDA CULPEPPER
ENVIRONMENTAL QUALITY Interim Director
October 30, 2018
Mr. Jimmy Pridgen •
Water Reclamation Manager RECEIVED/DENR/DWR
City of Wilson NOVP.O. Box 10 ® g 2018
Wilson,NC 27894-0010 Water Resources
Permitting Section
Subject: Pretreatment Audit
City of Wilson
NPDES Permit No. NC0023906 _
Wilson County
Dear Mr. Pridgen:
On September 21, Cheng Zhang of the Raleigh Regional Office (RRO) conducted a Pretreatment Audit
of City of Wilson's pretreatment program. The assistance given by Ms. Laura Pruitt, the pretreatment
coordinator,was greatly appreciated. The audit report is attached. Findings during the inspection were
as follows:
1. The City has eleven Significant Industrial Users (SIUs), nine of which are also Categorical
Industrial Users (CIUs). It was noted that Linamar Forging, Inc was in Significant Non-
Compliance (SNC) for oil & grease limit violations for second semi-annual period of 2017.
2. The pretreatment audit file review included Fresenius Kabi (Peiniit No. 2009-013), Linamar
Forging, Inc (Permit No. 8416), and Ardaugh Glass, Inc (Permit No. 8409). The files needed for
review were available for inspection, contained all the required elements and were in excellent
condition.
3. POTW and SIUs completed monitoring as required by the Industrial User Pretreatment Permits
(NPs) during the most recent semi-annual period. All SIUs were in compliance.
4. During the audit, Ms. Pruitt inspected one of the SIUs, Fresenius Kabi. The inspection was very
thorough. It was evident that Ms. Pruitt has excellent relationship with the industry
representative,broad knowledge of pretreatment, great attention to details, and proactive attitude
to solve potential problems together with industrial users.
5. A review of the files containing the pretreatment program elements was conducted. These files
were very well organized. It was noted that Headworks Analysis and Long Term Monitoring
Plan (LTMP) were updated and approved recently in 2018.
Division of Water Resources, Raleigh Regional Office,Water Quality Operations Section http-/!portal ncdenr.orglwehiwq/aps
1628 Mail Service Center,Raleigh,NC 27699-1628Phone: [phone]
Location: 3800 Barrett Drive,Raleigh,NC 27609 Fax• [phone]

City of Wilson
NPDES Permit No NC0023906
Pretreatment Audit
6. The review of LTMP data indicated that all locations were sampled with required frequencies,
and all samples were analyzed Using correct detection limits specified in the LTMP since last
inspection.
Thank you for your continued support olf the Pretreatment Program. If you have any questions or
comments, please call Cheng Zhang at (�i919) 791-4200 (or email: [e-mail]).
Since ely,
iair/2
Danny S . , Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources,NCDEQ
Enclosure: 2018 City of Wilson Audit Report
Cc: Monti Hassan, DWR PERCS Unit
Central Files
Cheng Zhang, RRO
1

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT AUDIT REPORT
Water Resour cos
6v aIRONt•Lt.IPL QUA,.t.
Background Information [Complete prior to audit; review Program Info Database Sheet(s)1
1 Control Authority(POTW)Name: City of Wilson
2. Control Authority Representative(s): Laura Pruitt
3. Title(s): Pretreatment Coordinator
4 Address of POTW:
Mailing 3100 Stantonsburg Road
City Wilson Zip Code 27893
Phone Number 25253992499 Fax Number 2523992209 E-Mail 1pruitt(wilsonnc.org
5. Audit Date 09/21/2018
6. Last Inspection Date: 08/16/2017/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.
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
INICIOIO 1 21 3 19 lo 16 1 1091211181
10. Current Number of Significant Industrial Users(SIUs)? 11
11. Number of SIUs with No IUP, or with an Expired IUP? 0
12 Number of SIUs Not Inspected by POTW in Last Calendar Year9 0
13. Number of SIUs Not Sampled by POTW in Last Calendar Year9 0
14 Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi-Annual Penods9 1
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)7 9
19. Number of CIUs in SNC? 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
Program Element Last Submittal Last Approval Date Next Due,
Date In file? Date In file If Applicable
Headworks Analysis(HWA) 3/29/2018 ® Yes ❑ No 8/10/2018 ® Yes❑ No 4/1/2023
Industrial Waste Survey(IWS) 4/24/2014 ®Yes ❑ No 5/5/2014 ® Yes ❑ No 6/1/2019
Sewer Use Ordinance(SUO) 2/28/2012 ® Yes ❑ No 3/12/2012 ®Yes ❑ No
Enforcement Response Plan (ERP) 5/16/2012 ®Yes ❑ No 6/19/2012 ® Yes ❑ No
Long Term Monitoring Plan(LTMP) 8/31/2018 ®Yes ❑ No 8/18/2017 ® Yes ❑ No
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 an or areas. Town of Black Creek,Town of Sims,Town of Saratoga (in near
future)
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 tol Division.
23. If yes to#21,Have you had any trouble working with these towns or districts9 ❑ Yes ® No ❑NA
If yes,Explain. I
24. Date of Last SUO Adoption by Local Council 4/19/2012
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 industries9 ®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
N/A
Resources
29 Please Rate the Following: S=Satisfactory M=Marginal U=Unsatisfactory
Rating I Explanation,if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program ®S ❑M I❑U
Access to POTW Vehicles for Sampling van and samplers.
Sampling,Inspections, and ®S ❑M❑U
Emergencies
Access to Operable Sampling
Equipment ®S ❑M ❑U
Availability of Funds if Needed for J
Additional Sampling and/or Analysis ®S ❑M U
Reference Materials
®S ❑M❑U
Staff Training(i.e.Annual and I Workshops
Regional Workshops,Etc.) ®S ❑M❑',U
Computer Equipment(Hardware and
Software) ®S ❑M❑U

30. Does the POTW have an adequate data management system to run the pretreatment program'? ®Yes ❑ No
Explain Yes or No.Ameritech software.
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Industrial monitoring charge&surcharges
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?Pretreatment coordinator would review relevant files in
program with individual
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 keepmg files confidential
from public. If no how would the request be addressed Purdue,Sandos, and Kabi requested that special formulations be
kept confidential,UTC Kidde Aerospace also requested their certain product information be kept confidential.Such
information is stamped confidential and kept in a separate locked file cabinet.
35. In addition to annual inspection,does the POTW periodically meet with industries to discuss pretreatment? ® Yes ❑ No
Annual pretreatment banquet and email communications.
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 N/A
Permitting(Industrial Waste Survey-IWS)
38. How does the POTW become aware of new or changed Users? From the City's Planning Department
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?)Review short form,long form and/or site visit,application form,sampling results to determine categorical
industrial user or non-categorical SIUs.
40. Does the POTW receive waste from any groundwater remediation projects(petroleum,CERCLA) or landfill leachate?
®Yes ❑No If Yes,How many are there? One
Please list each site and how it is permitted,if applicable.Kidde Aerospace
41. Does the POTW accept waste by(mark if applicable) ®Truck ❑Dedicated Pipe ❑NA
Portal John waste only,no septage.
42. If the POTW accepts trucked waste,what controls are placed on this waste? (example. designated point,samples drawn,
manifests required)Designated point,pH checked before discharge,hauler information
43. How does the POTW allocate its loading to industries?Mark all that apply
❑ Uniform Limits ® Historical Industry Need ❑ By Surcharge IN 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 IVPs,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 20%
47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) ❑Yes ® No
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)

NPDES pollutants of concern,categorical li I its,chloride(SUO)
49. How does the POTW decide what the monitoriig frequency should be for the various pollutants in industry permits? Explain.
Heavier pollutant loaders have monthly/quarterly monitoring; minimum monitoring required is semi-annually.
Permit Compliance
I
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?
I
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 Data reviewed on receipt,entered into data management system,
limits formatted into data management syste�,violations and SNC will be flagged out by the system.
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
Modified version based on the model form.
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?
Process,chemicals,containment,potential harm to the WWTP. If plan is required,it will be specified in the IUP.
55. What critena does the POTW use to determine if a submitted slug/spill control plan is adequate?
Secondary containment,spill response,and correct contact information.
56 How does the POTW decide where the sample poi t for an SIU should be located?
If possible, at where flow is measured(flume)
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 ❑ INo If yes,Explain. SOP outlines sampling requirements, POTW
trained technician; SIUs hire trained lab personnel to collect samples
58. Who performs sample analysis for the POTW for Metals City
,
Pace/l�Iicrobac
Conventional Parameters City
Organics City
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Date,time,who takes samples,locations,lab No.i who receives samples,list of parameters,pH and temperature.
Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis(HWA)
60a Is LTMP/STMP Monitoring Bemg Conducted It 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? Z YES ❑ NO
60d. All LTMP/STMP effluent data on Discharge Molnitoring Report(DMR)? Z YES CINO Division Inspector,verify yourself!
60e If NO to any above,list violations II
60f. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ®NO
If yes,which ones?Eliminated. I Added:
61. Do you complete your own headworks analysis(HWA)? ® Yes ❑ No
If no, who completes your HWA? Phone( I ) --
62. Do you have plans to revise your HWA in the near future? El Yes ® No
If yes,what is the reason for the revision? (mark all thlat apply) ❑Increased average flow ❑NPDES limits change
❑More LTMP data available ['Resolve over`allocation ®5 year expiration ['Other
Explain. Just updated in 2018
63. In general, what is the most limiting criteria of your HI A? ❑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. 95% of final sludge goes to composting.No Iplan for plant expansion.
I
Summary I
65. Do you plan any significant changes to the pretreatmen program or changes to the WWTP that may affect pretreatment?No

INDUSTRIAL USER PERMIT(IUP)FILE REVIEW(3 IUP FILE REVIEWS AND 1 IU INSPECTION)
66. User Name 1.Fresenius Kabi 2 Linamar 3.Ardaugh Glass,Inc
67. IUP Number 2009-013 8416 8409
68. Does File Contain Current Permit? ®Yes ❑ No ® Yes ❑ No ®Yes ❑ No
69. Permit Expiration Date 12/31/2019 12/31/2018 6/30/2023
70. Categorical Standard Applied(I.E 40 CFR,Etc.)Or N/A 439.D 433.A 426.H
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's ® 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 POTW) b ❑Yes ❑No b. ❑Yes ❑No b. EYes ❑No
74. For 40 CFR 413 and 433 TTO Certification,Does File Contain a Toxic ❑Yes❑NoEN/A ®Yes❑No❑N/A ❑Yes❑NoEN/A
Organic Management Plan(TOMP)9
75. a Does File Contain Original Permit Review Letter from Division? a. ®Yes ❑No a ®Yes ❑No a ZYes ❑No
b.All Issues Resolved? b❑Yes❑No®N/A b❑Yes❑No®NIA b❑Yes❑No®N/A
76. During Most Recent Semi-Annual Period,Did POTW Complete its ® Yes ❑ No ® 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/A
Sampling as Required by IUP,including Flow9
79. During Most Recent Semi-Annual Period,Did SIU submit all reports on ®Yes❑No❑N/A ®Yes❑No❑N/A ®Yes❑No❑N/A
time9
80a. For categoncal 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'
80b.For categorical IUs with Production based limits,does file include ❑Yes❑NoEN/A ❑Yes❑NoEN/A ❑Yes❑NoZN/A
production rates and/or flows as Required by IUP?
81. During Most Recent Semi-Annual Period,Did POTW Identify All ❑Yes❑NoEN/A ❑Yes❑NoEN/A ❑Yes❑NoEN/A
Limits Non-Compliance from Both POTW and SIU Sampling?
82 During Most Recent Semi-Annual Period,Did POTW Identify All ❑Yes❑NoZN/A ❑Yes❑NoEN/A ❑YesDNoEN/A
Reporting 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❑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 SIU limit violations m 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? ❑ Yes ® No r Yes ® No ❑ Yes ® No
85 During Most Recent Semi-Annual Period,Was Enforcement Taken as ❑Yes❑NoEN/A ❑YesDNo N/A ❑Yes❑NoZN/A
Specified in POTW's ERP (NOVs,Penalties, timing,etc.)9
86. Does File Contain Penalty Assessment Notices? ❑Yes❑NoEN/A ❑Yes❑No N/A EYes❑No❑N/A
87. Does File Contain Proof Of Penalty Collection? ❑YesDNo N/A ❑Yes❑No N/A EYes❑No❑N/A
88. a.Does File Contain Any Current Enforcement Orders? a.❑Yes❑No®N/A a.❑Yes❑No®N/A a❑Yes❑NonN/A
b. Is SIU in Compliance with Orders 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:
All SIUs were in compliance during the first six-month period of 2018.

INDUSTRY INSPECTION ICIS CODING: '
Main Program Permit Number MM/DD/YY
INICIO to 12 13 19 to 16 1 1091211181
1.Industry Inspected: Fresenius Kabi
2. Industry Address: 5200 Corporate Parkway,Wilson NC 27893
3.Type of Industry/Product. Medical devices and sterile injection-and infusion-based drug-delivery products
4.Industry Contact: Greg McGuire Title: EH&S Manager Phone: [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 ❑ N
B. Plant Tour ®Yes iii N�
C. Pretreatment Tour ® Yes ❑ No
D. Sampling Review ® Yes Ill Nol
E .Exit Interview ® Yes ❑ No,
Industrial Inspection Comments:
The SIU inspection was very thorough and met the DWR requirements.
Audit SUMMARY AND COMMENTS:
Audit Comments: The pretreatment program is well managed and implemented.
Requirements: None
Recommendations: None.
NOD: ❑Yes ® No
NOV: ['Yes ® No
QNCR: ❑Yes ® No
1
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory❑
1
Audit COMPLETED BY: Cheng Zhang,Raleigh Regional Office DATE: September 21,2018