NC0021474_Compliance Report_20190909

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ROY COOPER NORTH CAROLINA
Governor Environmental Quality
MICHAEL S.REGAN
Secretory
LINDA CULPEPPER
Interim Director
September 9,2019
Amy Varinoski
Compliance Manager
City of Mebane
106 East Washington Street
Mebane,North Carolina 27302
RECEIVED
SUBJECT: Pretreatment Compliance Inspection(PCI)
City of Mebane OCT 10 2019
NPDES#NC0021474
Alamance County NCDEQIDWRINPDES
Dear Ms. Varinoski:
On July 25, 2019 a Pretreatment Compliance Inspection (PCI) was performed by Jim Gonsiewski and
Michael Meilinger of the Winston-Salem Regional Office. Ms. Amy Varinoski was present for the
inspection. The purpose of this inspection was to determine the effectiveness of the Town's pretreatment
program, which includes reviewing the files, POTW plant performance, industry monitoring data, and
adherence to the enforcement response plan(ERP).
Background
This is a 2.5 MGD permitted facility.The City has five(5) Significant Industrial Users(SIUs),three(3)of
which are categorical. The publicly owned treatment works (POTW) had exceedances of BOD and
ammonia in 2018 due to hydraulic issues caused by the weather(heavy rain and cold temperatures)and an
exceedance of toxicity,possibly due to a clarifier coating.
POTW Interview
There are no plant problems related to pretreatment issues and, other than BOD, Ammonia, and Toxicity,
there are no NPDES permit limit or monitoring violations recorded from January 2018 through December
2018. The facility is very well operated.
Pretreatment Program Elements Review
The Headworks Analysis(HWA)renewal was submitted on March 24,2016. The HWA was approved on
June 3,2016. The next HWA is due on March 31, 2021.
The last Industrial Waste Survey (IWS) was submitted on January 4, 2016. The IWS was approved on
March 7,2016. The next IWS is due on December 1,2020.
o.o.u.sa 61411111111101 OMB
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

The Sewer Use Ordinance(SUO)was approved on December 10, 2012.
The Enforcement Response Plan(ERP)was approved on April 11,2013.
The Long Term Monitoring Plan(LIMP)was approved on July 18,2019.
LTMP File Review
The Long Term Monitoring Plan(LTMP)is being conducted at the proper locations and frequencies.
Industrial User Permit(IUP)File Review
A review of the file for PPG Coating Services(#0133)revealed that the monitoring data was well organized
and compliant.
A review of the file for Synergy Health. (#0I26)revealed that the monitoring data was well organized and
compliant.
A review of the file for Liggett(#0132)revealed that the monitoring data was well organized and compliant.
The slug control plan for PPG Coating Services(#0133)was in good order.
The slug control plan for Synergy Health. (#0126)was in good order.
The slug control plan for Liggett(#0132)was in good order.
Action Items
No other action items were noted.
The pretreatment program is considered satisfactory.Ms.Varinoski runs an excellent pretreatment program.
If you have any questions please contact Jim Gonsiewski or me at(336) 776-9800.
Sincerely,
CDocuSigned by:
Lo� T 5.4jer
445B49E225C94EA...
Lon T. Snider
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources,NCDEQ—WSRO
cc: PERCS Unit—Monti Hassan
Central Files
WSRO Files

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NORTH CAROLINA DIVISION OF WATER RESOURCES
. PRETREATMENT COMPLIANCE INSPECTION (PCI)REPORT
Water Resources
ENVIRONMENTAL OU/L!TY
BACKGROUND INFORMATION[Complete Prior To PCI;Review Program Info Database Sheet(s)1
1. Control Authority(POTW)Name: City of Mebane
2. Control Authority Representative(s): Amy Varinoski
3. Title(s): Compliance Manager
4. Last Inspection Date: 06/26/18 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 Z NO
Order Type,Number,Parameters: Are Milestone Dates Being Met? ❑ YES ❑ NO
ICIS CODING
Main Program Permit Number MM/DD/YY
NICIOI 10 12 1 1 14 1 7 14 1 1 07 125 I 19 I
7. Current Number Of Significant Industrial Users(SIUs)? 5
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 0
Periods?
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)? 3
16. Number of CIUs in SNC? 1 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? BOD,Ammonia—weather related
Toxicity— probably clarifier coating
18. Since the Last PCI,has the POTW had any Problems Related to an Industrial ❑YES Z NO
Discharge(Interference,Pass-Through,Blockage,Citizens' Complaints,Increased
Sludge Production,Etc.)?
If Yes,How are these Problems Being Addressed?
19. Which Industries have been in SNC for Limits or Reporting during SNC for Limits:None
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: None
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? Z 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? IZ YES ❑NO Is Table Adequate? ®YES ❑ NO
25. All LTMP/STMP effluent data reported on Discharge Monitoring Report? Z 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 Z NO
If yes,which ones?Eliminated: Added:
NC DWR Pretreatment Compliance Inspection(PCI)Form Updated 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 copy of 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) 03/24/2016 - ®Yes❑ No 06/03/2016 ® Yes❑ No 03/31/2021
Industrial Waste Survey(IWS) 01/04/2016 ®Yes❑ No 03/07/2016 ®Yes❑ No 12/01/2020
Sewer Use Ordinance(SUO) 11/02/2012 ®Yes ❑ No 12/10/2012 ® Yes ❑ No
Enforcement Response Plan(ERP) 11/02/2012 ® Yes❑ No 04/11/2013 ®Yes❑ No
Long Term Monitoring Plan(LTMP) 06/20/2019 ®Yes ❑ No 07/18/2019 ®Yes❑ No
INDUSTRIAL USER PERMIT(IUP)FILE REVIEW(3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name 1.PPG Coating Services 2.Synergy Health 3.Liggett
30. IUP Number 0133 0126 0132
31. Does File Contain Current Permit? ®Yes ❑ No ®Yes ❑ No ®Yes ❑ No
32. Permit Expiration Date 06/30/2024 06/30/2021 12/31/2023
33. Categorical Standard Applied(I.E.40 CFR,Etc.)Or N/A 433.1 — —
34. Does File Contain Permit Application Completed Within One Year Prior ® Yes ❑ No ❑ Yes ® No ®Yes ❑ No
to Permit Issue Date? Submitted early
application
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 a. ®Yes ONo a. ®Yes ONo
b.If No,is One Needed?(See Inspection Form from POTW) b. ❑Yes ONo b. ❑Yes ONo b. ❑Yes ONo
37. For 40 CFR 413 and 433 TTO Certification,Does File Contain a Toxic ®Yes❑No❑N/A ❑Yes❑No®N/A ❑Yes❑No®N/A
Organic Management Plan(TOMP)?
38. a.Does File Contain Original Permit Review Letter from the Division? a. ®Yes ONo a. ®Yes ONo a. ®Yes ONo
b.All Issues Resolved? b.❑Yes❑No®N/A b.❑Yes❑No®N/A b.❑Yes ONo 0N/A
39. During the Most Recent Semi-Annual Period,Did the POTW Complete ®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?
41b.During the Most Recent Semi-Annual Period,Did SIU submit all reports ®Yes❑No❑N/A ®Yes❑No❑N/A ®Yes❑No❑N/A
on time?
42a.For categorical His with Combined Wastestream Formula(CWF),does ❑Yes❑No®N/A ❑Yes❑NoON/A ❑Yes❑No®N/A
file include process/dilution flows as Required by IUP? _
42b.For categorical His 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? N/A N/A N/A
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.D 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❑NouN/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®N/A
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❑NoEIN/A ❑Yes❑No®N/A ❑Yes❑NoEIN/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❑NoEIN/A ❑Yes❑No®N/A
49. Does The File Contain Proof Of Penalty Collection? ❑Yes❑No®N/A ❑Yes❑No®N/A ❑Yes❑No®N/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.Cries❑No®N/A
51. Did the POTW Representative Have Difficulty in Obtaining Any of This ❑Yes ® No ❑Yes ® No ❑Yes ® No
Requested Information For You?
NC DWR Pretreatment Compliance Inspection(PCI)Form Updated December 2016 Page 2

'FILE REVIEW COMMENTS: Good lines of communication are maintained between the facility and the SIUs. Synergy samples twice
a year for pH. No other sampling requirements. The scheduled transfer of three facilities last year did not occur.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
I I I III IL l I I I
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 El YES ❑ NO
Industrial Inspection Comments:
OVERALL SUMMARY AND COMMENTS:
Comments: A very well-run program.
Requirements:
Recommendations:
NOD: ❑ YES ® NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ® NO
POTW Rating:
Satisfactory X Marginal Unsatisfactory
PCI COMPLETED BY: Jim Gonsiewski DATE: 09/09//2019
NC DWR Pretreatment Compliance Inspection(PCI)Form Updated December 2016 Page 3