NC0021211_Preteatment Audit Inspection_20191011

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
Ms. Shelby Smith
Pretreatment Coordinator
City of Graham
P.O. Box 357
Graham, North Carolina 27253
NORTH CAROLINA
Environmental Quality
October 11, 2019
SUBJECT: Pretreatment Audit Inspection (PAI)
Town of Graham
NPDES# NCO021211
Alamance County
Dear Ms. Smith:
On September 12, 2019 a Pretreatment Audit Inspection (PAI) was performed by Jim Gonsiewski
of the Winston-Salem Regional office and Vivien Zhong and Melissa Abbott of the Raleigh
Central office. Ms. Shelby Smith, pretreatment coordinator for the City of Graham 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 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 Stericycle facility was conducted
in conjunction with an inspection by the City of Graham.
Background
This is a 3.5 MGD permitted facility. The City has five (5) Significant Industrial Users and three
(3) Categorical Industrial Users.
Pretreatment Program Element Review
The Headworks Analysis (HWA) was submitted on August 30, 2018. The HWA was approved
on October 3, 2018. The next HWA is due on September 1, 2023.
The Industrial Waste Survey (IWS) was submitted on March 29, 2018. The IWS was approved
on April 4, 2018. The next IWS is due on April 2, 2022.
The Sewer Use Ordinance (SUO) was approved on September 14, 2011.
D North Carolina Department of Environmental Quality I Division of Water Resources
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Winston-Salem Regional Office 1 450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105
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The Enforcement Response Plan (ERP) was approved on January 23, 2012.
LTMP File Review
The Long Term Monitoring Plan (LTMP) was approved on October 4, 2018 and is being conducted
at the proper locations and frequencies.
Industrial User Permit (IUP) File Review
A review of the file for Luxfer (#2001) revealed that the monitoring data was well organized and
compliant.
A review of the file for Stericycle (#0030) revealed that the monitoring data was well organized
and compliant.
A review of the file for Nova Flex (# 1001) revealed that the monitoring data was well organized
and compliant.
The slug control plans for Luxfer (#2001) was in good order.
The slug control plans for Stericycle (#0030) was in good order.
The slug control plans for Nova Flex (# 1001) was in good order.
Action Items
No other action items were noted.
The pretreatment program is considered satisfactory. Ms. Smith maintains an excellent program.
If you have any questions please contact Jim Gonsiewski or me at [phone].
Sincerely,
Docu Signed by:
LJn. -T JMdtt'
145B49E225C94EA...
Lon T. Snider
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
cc: PERCS Unit — Vivien Zhong (Electronic Copy)