NC0037508_PC-2019-0774_20200113

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
NORTH CAROLINA
Environmental Quality
January 13, 2020
CERTIFIED MAIL 7016 2140 0000 4371 1223
RETURN RECEIPT REQUESTED
Ivey Knowles, Director of Public Utilities
Town of Rose Hill
PO Box 8
Rose Hill, NC 28458
Subject: Pretreatment Compliance Audit Report and Notice of Violation
NOV-2019-PC-0774
Failure to implement the Short Term Monitoring Plan
Program: Town of Rose Hill (NC0037508); Duplin County
Mr. Knowles:
On September 26, 2019, Tom Tharrington and Brian Lievre of the Wilmington Region Office and
Vivien Zhong of PERCS Unit conducted a Pretreatment Audit Inspection at the above referenced
wastewater treatment system. Carl Wheeler, the Pretreatment Coordinator and Jimmy Holland,
the Consultant, were present for the inspection. The purpose of this inspection was to determine
the effectiveness of the pretreatment program, which included: a detailed file review, review of
the POTW facility performance, sampling and compliance judgement program, adherence to the
enforcement response plan, and observing an industrial user inspection.
Please see attached audit report for more detailed information about the inspection. Findings
during the inspection are as follows:
1. The town has two Significant Industrial Users (SIUs) and neither are Categorical Industrial
Users (CIUs). Valley Proteins (IUP No. RH001) has not been discharging since April 2016.
The Town has completed all the sampling, inspection requirement for both SIUs. It was
also noted that no SIUs were in Significant Non -Compliance (SNC) in the two most recent
semi-annual periods.
2. Pretreatment Program Elements were not available for review during the inspection.
Headworks Analysis (HWA) and Industrial Waste Survey (IWS) were submitted on April
30, 2019 and February 13, 2019 respectively. More information was requested and had
not yet received until this date. An NOV (NOV-2019-PC-0571) was sent on August 6, 2019
e � ���,C �EQ��
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617
919.707.9000

and no response has been received. The STMP needs to be updated in regards to sampling
requirements/frequency and detection limits.
3. The review of STMP data indicated that only NPDES required parameters were sampled
and the Town has failed to properly implement the approved STMP for establishing a site -
specific HWA. The Division of Water Resources (DWR) has determined that the Town's
Pretreatment Program has failed to meet the minimum requirements as specified in 15A
NCAC 2H .0905, NPDES permit conditions Part IV, D3 and 40 CFR 403.8(f).
4. Inspection forms for both SIUs could not be located during the Industrial User Permit (IUP)
files review. It is recommended to revise the inspection form to address questions in
Division's model inspection form (enclosed). The application for Duplin Winery (Permit
No. RH002) were one year after the permit issue date. Additional information for both
permit was requested and had not yet received, see NOV-2019-PC-0571. The detection
levels for chromium and copper needs to be lowered in Duplin Winery's POTW sampling.
Carefully review this violation and respond in writing to this office before January 31, 2020. You
should address the causes of noncompliance and all actions that will be taken to prevent the
recurrence of similar situations. Additional program documents must also be submitted by
January 31, 2020, including IWS, STMP, IUP renewal packages (including the renewed permits
with IU transmittal letters, signed applications within a year of permit issuance, most recent on -
site inspections and updated allocation table). Start STMP sampling the 1st quarter of 2020 and
submit an updated HWA by February 28, 2021.
The Division is considering recommending to the Director that furthei Ci,forcement actions be
taken, including penalty assessments. If you have any supporting documents as to why further
action should not be taken, please provide that information in the required response.
If you have any questions or comments, please contact me at 919-707-3600 [email:
[e-mail]] or Vivien Zhong at 919-707-3627 [email: [e-mail]].
;Sincerely,
Jeff Poupart
Water Quality Permitting Section Chief
vz/ Rose_Hill_Audit_2019_NOV
Enclosures: RoseHillAudit9-26-19
SIU Inspection Form
EC: Tom Tharrington, Wilmington Regional Office
Carl Wheeler, Pretreatment Coordinator
Central Files (LF)
PERCS Unit

rNORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT AUDIT REPORT
Water Resources
ENVIRONMENTAL QUALITY
Background Information (Complete prior to audit; review Program Info Database Sheet(s)]
1. Control Authority (POTW) Name: Town of Rose Hill
2. Control Authority Representative(s): Carl Wheeler, Jimmy Holland
3. Title(s): WWTP ORC & Proiect Manager (WK Dickson & Co.)
4. Address of POTW:
Mailing P.O. Box 8
City Rose Hill, NC Zip Code 28458-0008
Phone Number 910-289-3159 Fax Number E-Mail rosehill.administrator(a)embargmail.com
5. Audit Date 09/26/2019
6. Last Inspection Date: 09/26/2017 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
INICI0I0I5 I6 18 I6 13
MM/DD/YY
109126119 �
10. Current Number of Significant Industrial Users (SIUs)? *Comment
...........................................
2
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)?...........................................................................................
0
19. Number of CIUs in SNC?
0
NC DWR Pretreatment Audit Form Revised: December 2016
Paee 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 Annroval Letter. and dates consistent with Program Tnfh-
Program Element
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
04/30/19
® Yes ET No
More info
requested
Yes LJ No
2/28/2021
Industrial Waste Survey (IWS)
02/13/19
® Yes No
More info
requested
❑ Yes ❑ No
1/31/2020
Sewer Use Ordinance (SUO)
02/15/13
El Yes El No
03/11/13
❑ Yes ® No
Enforcement Response Plan (ERP)
10/10/2008
Yes El No
1/5/2009
❑ Yes ® No
Long Term Monitoring Plan (LTMP)
11/30/2012
Yes No
12/20/2012
❑ Yes ® No
1/31/2020
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.
22. If yes to #21, Do you have current Intedurisdictional Agreements (IJAs) or other Contracts? ❑ Yes ® No ❑ NA
A copy, if not already submitted, should be sent to Division. * Comment
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 02/12/2013
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. * Comment
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
Computer Equipment (Hardware and
Software)
®S ❑M ❑U
NC DWR Pretreatment Audit Form Revised: December 2016 Page 2

30. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No
Explain Yes or No.
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Surcharges applied to some industries in the past, permit renewal fees, sewer rates and sampling fees.
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. The House of Raeford Hatchery has discontinued discharge to the Rose Hill facility.
33. Has anyone from the public ever requested to review pretreatment program files? ❑ Yes ® No
If yes, Explain procedure. If no, how would the request be addressed? Information could be requested through the Town
Administrator
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? Creation of a non-public file for this information
35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? ® Yes ❑ No
SW informs POTW of batch wastewater discharges
36. Is the public notified about changes in the SUO or Local Limits? ❑ Yes ® No * Comment
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? By review of IWS and permit modifications requested
by existing permit holders. When the facility signs up for utility service, the POTW would be notified.
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 of IWS and related SIC codes
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
❑Yes ®No If Yes, How many are there? n/a
Please list each site and how it is permitted, if applicable. n/a
41. Does the POTW accept waste by (mark if applicable) ® Truck ❑Dedicated Pipe ❑ NA * Comment
42. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples drawn,
manifests required) Logbook entry of delivery date and designated dumping location
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?
45. If yes to #44, What is being done to address the over allocations? (short-term IUPs, 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 25%
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)
The town uses application listed pollutants, categorical and NPDES pollutants of concern to determine permit limits
NC DWR Pretreatment Audit Form Revised: December 2016 Page 3

49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Additional sampling needs are determined if exceedances or other compliance issues arise and are then addressed on a case
by case basis depending on industry type and process
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 judge's compliance. This should include compliance judgment on all violations of limits, reporting
requirements, and permit conditions, as well as for SNC. Division's compliance judgement spreadsheets were used for limits
violations and SNC determination. Any valid or consistent non-compliance indicated by EDMR's or town sampling is
typically used to determine compliance. Case by case evaluation of individual SIU is also taken into account and a tiered
enforcement schedule is followed
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?
Evaluation of site inspections, materials maintained on -site and process activities with their potential to impact the POTW.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Case by case basis with emphasis on possible POTW impacts and whether the SIU addressed the inspector's concern.
56. How does the POTW decide where the sample point for an SIU should be located?
Determined during SIU permitting, usually the last point before the process water is discharged into the collection system.
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. Both POTW and SILT sampling events are typically
performed at the same time and location by both parties.
58. Who performs sample analysis for the POTW for Metals Envirochem
Conventional Parameters Envirochem
Organics Envirochem
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Envirochem is a large commercial laboratory located in Wilmington, NC that performs both sampling and analysis for
these parameters. The laboratory has established/sufficient lab sheets and COC's that document these events
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 STMP sampling was not performed.
60f. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ® YES ❑ NO
If yes, which ones? Eliminated: Added: will be evaluated and undated, due date for
submitting STMP is January 31, 2020.
61. Do you complete your own headworks analysis (HWA)? ❑ Yes ® No
If no, who completes your HWA? Jimmy Holland Phone [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.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 4

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. Treatment capacity remaining at the WWTP
Summary
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW Q IUP FILE REVIEWS AND 1 IU INSPECTION)
66. User Name
1. Valley Proteins 2. Duplin Winery
3.
67. IUP Number
R11001
R11002
68. Does File Contain Current Permit?
N Yes Lj No
Yes
Lj Yes Ll No
69. Permit Ex iration Date
06/30/22
06/30/22
70. Categorical Standard Applied I.E. 40 CFR, Etc. Or N/A
n/a j
n/a
71. Does File Contain Permit Application Completed Within One Year Prior
Ll Yes LJ
7WTs ED No
Yes No
to Permit Issue Date?
72. Does File Contain Inspection Completed Within Last Calendar Year?
Yes NNo
❑ Yes ® No-11
El 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 PO
b. []Yes ®No
I b. ❑Yes ®No
b. ❑Yes ❑No
74. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
❑Yes❑No®N/A
OYes❑NoON/A
❑Yes❑NOON/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.oYesMoON/A
b.mesMoON/A
b.oYesONoON/A
76. During Most Recent Semi -Annual Period, Did POTW Complete its
LJ Yes LJ No
LA Yes LJ No i7es
❑ No
Sampling as Required by IUP, including Flow?
N/A
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
0 Yes ❑
0 Yes No
❑ Yes No
N/A
78. During Most Recent Semi -Annual Period, Did SIU Complete its
❑Yes❑No®N/A
®Yes❑No❑N;/
❑Yes❑NOON/A
Sampling as Required by IUP, including Flow?
11
79. During Most Recent Semi -Annual Period, Did SILT submit all reports on
®Yes❑No❑NiA
F0Y_es0No0N/A
❑Yes❑No❑N/A
time?
80a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑NOON/A
❑Yes❑NoON/A
❑Yes❑No❑N/A
file includeprocess/dilution flows as Required by IUP?
80b. For categorical IUs with Production based limits, does file include
❑Yes❑No®N/A
OYes❑No®N/A
❑Yes❑No❑N/A
production rates and/or flows as Required b IUP?
81. During Most Recent Semi -Annual Period, Did POTW Identify All
Yes El No
F0
DA Yes U No
ElYes No
Limits Non -Compliance from Both POTW and SIU Sampling?
N/A
82. During Most Recent Semi -Annual Period, Did POTW Identify All
❑Yes❑NoON/A
OYesONoON/A
OYes❑NoON/A
Re ortin Non-Com liance from SIU Sampling?
83. a. Was POTW Notified by SIU (Within 24 Hours) of All Self-
a.OYesMoON/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.pYesONo®N/A
b.pYesONo®N/A
b.OYesONoON/A
c. If applicable, did POTW resample and obtain results within 30 days of
c.OYesMoON/A
c.pYesONo®N/A
c.pYesONoON/A
becomingaware of SIU limit violations in the POTW's sampling of SIU?
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
Yes N No
1 0 Yes Ro-11
❑ Yes No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
❑Yes❑No®N/A
OYesONoON/A
❑Yes❑NOON/A
Specified in POTW's ERP (NOVs, Penalties, timing, etc.)?
86. Does File Contain Penalty Assessment Notices?
❑Yes❑NoON/A
OYesONoO
I ❑YesONo❑N/A
87. Does File Contain Proof Of Penalty Collection?
❑Yes❑NoON/A
❑Yes❑NoON/A
❑Yes❑No❑N/A
88. a. Does File Contain Any Current Enforcement Orders?
azYesOMON/A
a.OYesOMON/A
a.❑YesOMON/A
b. Is SIU in Compliance with Order?
b.OYesm N/A
b.OYesONo®NiA
b.OYesONoON/A
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
Yes Lj No11��
No
❑ Yes No
Information For You?
L!
FILE REVIEW COMMENTS:
10.-The permit for the House of Raeford Hatchery (RH003) was rescinded in January 2018.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 5

22.-Note: CharityMiddle School would have previous met this criteria but ceased operation, recently it was used for emergency housing related
to Hurricane Florence reliefprograms and began sending wastewater to Rose Hill.
26.-The local industries will be sent a copy of the ERP by October 31,2019.
36.-To date changes to SUO or limits have not included public notice, if needed in the future public notice/meetings could be issue&held.
41.- Septage is brought to the site by vacuum truck and discharged to the surface of drying beds, approximately 3-4 loads per year are taken
60a-f.- The STMP is to be revised in the near term, issues with Arsenic, Cadmium, Cyanide, Lead, Selenium and other metals in regards to
sampling requirements/frequency and detection limits were noted in the inspection.
71.- Some program documents could not be located or were at another location. Application on file for Duplin Winery were 1 year after the
permit issue date.
72.- POTW could not locate inspection forms for both RH 001 and RH002 during inspection. It is recommended to revise inspection form to
address questions in Division's model inspection form.
75.- Both RH001 and RH002 permits are pending approval. Additional information was requested and will be revaluated by the Central Office
once submitted.
76.- RH002 Duplin Winery POTW sampling was last conducted on 0611212019. The detection levels for Chromium and Copper need to be
lowered.
79.- RH002 Duplin Winery also conducted sampling in June 2019
76-81.- RH001 Valley Proteins has not sent flow to the Rose Hill WWTP since April 2016
89.- Some program documents could not be located and were to be sent via email to the Central Office. It is recommended to organize all
elements on computer as the POTW is trying to establish a digital file system.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
I NI C10 10 15 16 18 16 13 1 109126 1 191
1. Industry Inspected: Duplin Winery- RH002
2. Industry Address: 342 Yellowcut Road. Rose Hill, NC 28458
3. Type of Industry/Product: Wine/Beverage Processing
4. Industry Contact: Rob Cottle Title: Environmental Manger 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
❑ No
B. Plant Tour
® Yes
❑ No
C. Pretreatment Tour
® Yes
❑ No
D. Sampling Review
® Yes
❑ No
E. Exit Interview
® Yes
❑ No
Industrial Inspection Comments:
The POTW conducted a site inspection with DEQ staff, Engineering Program Manager and Duplin Winery staff. The group
discussed the typical communication between the SIU and POTW including adjusting pumping schedules, excessive volume
notifications, storm preparation, sampling events, etc. Also discussed was the SIU strategy of conducting sampling events
(monthly & quarterly) to maximize pumping volume and alleviate sampling event costs. The pretreatment process was reviewed
during the inspection with discussions of maintenance activities, electrical costs, storm preparations, supplemental bacterial
NC DWR Pretreatment Audit Form Revised: December 2016 Page 6

additions and sampling. The sampling point, discharge pump and discharge filters were viewed. A review of flow volumes
reported to the POTW and other pretreatment riles and their location was performed.
Audit SUMMARY AND COMMENTS:
Audit Comments: Comments located in inspection report
Requirements: The POTW and contract engineering support are to forward any documents not made available during the
inspection to Vivien Zhong (Pretreatment Coordinator- NC DEO) for review. Additional program documents were to be
submitted by January 31, 2020, including IWS, STMP, IUP renewal packages (including the renewed permits with IU transmittal
letters, signed applications within a year of permit issuance, most recent on -site inspections and updated allocation table) and
other information requested during the inspection should be provided for Central Office review. Start STMP sampling the Is
quarter of 2020 and submit an updated HWA by February 28, 2021.
Recommendations: The town should work to consolidate the pretreatment program records (electronic & hard copy) so that all
information can be made available in a timely manner during future inspections.
NOD: ❑ Yes
NOV: ® Yes
QNCR: ® Yes
POTW Rating:
® No
❑ No
❑ No
Satisfactory ❑ Marginal ❑ Unsatisfactory ED
Audit COMPLETED BY: Tom Tharrington and Brian Lievre, Wilmington Regional Office, Vivien Zhong, PERCS
DATE: 9/26/2019
NC DWR Pretreatment Audit Form Revised: December 2016 Page 7

SIU INSPECTION FORM
Name Of Industry:
Address Of Industry: .
Industry Representatives:
POTW Representatives:
Date Of Inspection:
Purpose of Inspection: Annual
POTW to which IU discharges
Is SIU currently in SNC? _
Title
Title
Time Of Inspection: _
Other (Describe)
NPDES #
If yes, for what?
PART I - INITIAL INTERVIEW
Has anything changed since the last inspection or IUP application in the following:
COMMENTS
Product
YES / NO
Raw materials used
YES / NO
Manufacturing processes
YES / NO
Categorical, if applicable
YES / NO
Production rate
YES / NO
Number of employees
YES / NO
Number of shifts YES / NO
Comments:
IUP #
IUP Expiration Date:
am/pm
PART II - PLANT TOUR - Visit all areas where wastewater is generated or where there are
drains to the POTW.
Plant Tour Section A - PRODUCTION AND STORAGE AREAS
1. Are there floor drains in the production area? YES / NO Where do they go?
2. Are production areas diked, contained, or otherwise constructed in such a way as to prevent harm to the W WTP,
especially from spills or slugs? YES / NO Comments:
3. Are there floor drains in the storage area? YES / NO Where do they go?
4. Are storage tanks and areas diked, contained, or otherwise constructed in such a way as to prevent harm to the
WWTP, especially from spills or slugs? YES / NO Comments:
5. Are process and storage tanks and pipes labeled? YES / NO
6. How are off -spec raw materials, and products disposed of? _
7. When is the production area cleaned?
8. Is the wastewater from cleaning the production area discharged to the POTW?
9. What non -process wastewaters are discharged to POTW?
Comments:
YES/NO
Title: SIU lnpsection Form
File name: COMP.INSP App 7-D
Revision data: August 1, 1994 Page 1

SIU INSPECTION FORM
PART II - Plant Tour Section B - PRETREATMENT SYSTEM
Ask the operator to describe pretreatment system.
1. Does operator seem knowledgable about the system? YES / NO Comments:
2. Are all units operational? YES / NO
3. How often does operator/maintenance person check system?
4. Is there an operator for each shift? YES / NO
5. How and when is sludge disposed oP
6. Is there a schedule for preventative maintenance? YES / NO
Comments:
PART II - Plant Tour Section C - SAMPLING POINT(S) AND FLOW MEASUREMENT
(Collect a sample if desired.)
1. Does an outside lab complete sampling? YES / NO If yes, name of lab.
2. If industry completes sampling, ask the industry representative to describe sampling procedures. Comments:
3. Is flow measurement equipment operational? YES / NO Comments:
4. Is there a calibration log for the flow meter? YES / NO Comments:
Comments:
PART III - EXIT INTERVIEW
Review monitoring records and other SILT records required by IUP.
1. Are files well organized? YES / NO Comments:
2. Are sample collection / chain -of -custody forms filled out properly?
YES / NO Comments:
3. Do results in files agree with reports sent to POTW? YES / NO Comments:
4. Who has authority to shut down production should a spill or slug discharge occur?
5. How does SIU inform employees of whom to call at POTW in case of spill/slug?
If slug/spill plan is already required by POTW, review procedures.
6. Is SIU implementing slug/spill plan? YES / NO Comments:
Comments:
INSPECTION RESULTS
Slug/Spill Control Plan Needed? YES / NO
Comments, Required Or Recommended Actions:
Signature Of Inspector(s)
Title: SIU Inpsection Form
File name: COMP.INSP App 7-D
Revision data: August 1, 1994
Date:
Date:
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