NC0025348_Cover letter Pretreatment Audit_20200717

NORTH 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: City of New Bern
2. Control Authority Representative(s): Bruce Van Apeldoorn Jr
3. Title(s): Pretreatment Coordinator
4. Address of POTW:
Mailing PO Box 1129
City New Bern Zip Code 28563
Phone Number 252-639-7562 Fax Number 252-636-4065 E-Mail vanapeldoornb(a,newbernnc.org
5. Audit Date 7/16/2020
6. Last Inspection Date: 5/2/2018 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
INICI0I0I2 I5 13 14 Is
MM/DD/YY
17 116 120I
10.
...................................................
Current Number of Significant Industrial Users..(SIUs)?..............................................................................................
5
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 SI .s 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)?............................................................................................
2
19.
Number of CIUs in SNC?
0
NC DWR Pretreatment Audit Form Revised: December 2016
Page 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 Pro am Info:
Program Element
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
4/27/2015
® Yes ❑ No
5/7/2015
® Yes ❑ No
4/1/2020
Industrial Waste Survey (IWS)
7/24/2015
® Yes ❑ No
9/15/2015
❑ Yes ® No
12/1/2020
Sewer Use Ordinance (SUO)
7/23/2012
® Yes ❑ No
8/6/2012
® Yes ❑ No
Enforcement Response Plan (ERP)
2/3/2020
® Yes ❑ No
2/5/2020
❑ Yes ® No
Long Term Monitoring Plan (LTMP)
7/8/2015
® Yes ❑ No
10/1/2015
® 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 and/or areas.
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 to Division.
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 12/11/2012
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 industries? ® 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
Resources
29. Please Rate the Following: S=Satisfacto M=Mar inal 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 Elm Flu
Availability of Funds if Needed for
Additional Sampling and/or Analysis
®S Elm ❑ 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. The facility uses Microsoft Word and Excel spreadsheets
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
POTW charges SIU's a $100 monthly fee, fee for inspection and permit 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.
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? The POTW would make files available
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? These items would be kept in a separate file not available to the
public
35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? ® Yes ❑ No
36. Is the public notified about changes in the SUO or Local Limits? ® Yes ❑ No Updates on website
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? All industries have to be reviewed by the City
Engineer.
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?) Short form is sent to the industry
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
®Yes ❑No If Yes, How many are there? Coastal Regional Solid Waste Management
Please list each site and how it is permitted, if applicable.
41. Does the POTW accept waste by (mark if applicable) ❑ Truck ❑Dedicated Pipe ® NA
42. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples drawn,
manifests required)
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 W WTP. 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 %
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 POTW uses the Sewer Use Ordinance and they look to see if the industry sends more than 5% of the MAHL of any
parameter
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Every Industry samples monthly with the POTW sampling each industry twice per year.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 3

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 judges compliance. This should include compliance judgment on all violations of limits, reporting
requirements, and permit conditions, as well as for SNC. POTW reviews iDMR's and fills out Compliance Judgement
Worksheets when a parameter exceeds permitted limit
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?
All SIU's are required to have a slug/spill plan. (The POTW needs to keep a copy of the plan in the file)
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
The POTW ensures that discharges can not make it to WWTP
56. How does the POTW decide where the sample point for an SIU should be located?
SIU's have to sample at the last access point before industry discharges to POTW
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. The POTW discussed sampling point during
inspections
58. Who performs sample analysis for the POTW for Metals Environment 1
Conventional Parameters Environment 1
Organics Environment 1
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Environment 1 has own Chain of Custody
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 10-2019 DMR spot checked
60e. If NO to any above, list violations
60f. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ® NO
If yes, which ones? Eliminated: Added:
61. Do you complete your own headworks analysis (HWA) ? ® Yes ❑ No
If no, who completes your HWA? 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 05 year expiration ❑Other
Explain.
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. Sludge is taken to the landfill for disposal. Currently, there is no limit on how much sludge they can dispose of at
the landfill
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
No
NC DWR Pretreatment Audit Form Revised: December 2016 Page 4

INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION)
66. User Name
1. Craven County Wood
2. BSH Home Appliances,
3. Chatsworth Products Inc
Energy L.P.
Range Facility
67. IUP Number
1200
1100
0600
68. Does File Contain Current Permit?
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
69. Permit Expiration Date
12-31-2020
12-31-2022
12-31-2022
70. Categorical Standard Applied I.E. 40 CFR, Etc. Or N/A
N/A
466.15
433
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?
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
73. a. Does File Contain Slug/Spill Control Plan?
a. ❑Yes ®No
a. ❑Yes ME
a. ❑Yes ®No
b. If No, is One Needed? See Inspection Form from POTW
b. ®Yes ❑No
b. ®Yes
b. ®Yes ❑No
74. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
❑Yes0No[9
❑Yes❑NOON/A
®Yes❑No❑N/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.❑Yes❑No®N/A
b.❑Yes❑No®N/A
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?
1 ® Yes ❑ N=ol
® Yes ❑ No
® Yes ❑ No
78. During Most Recent Semi -Annual Period, Did SILT Complete its
®Yes❑No❑N/A
®Yes❑No❑N/A
®Yes❑No❑N/A
Sampling as Required by IUP, including Flow?
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
time?
80a. For categorical Ns with Combined Wastestream Formula (CWF), does
❑Yes❑No®N/A
❑Yes❑No®N/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
❑Yes❑No®N/A
❑Yes❑No®N/A
production rates and/or flows as Required by IUP?
81. During Most Recent Semi -Annual Period, Did POTW Identify All
❑ Yes ❑ No
❑ Yes ❑ No
® Yes ❑ No
Limits Non -Compliance from Both POTW and SIU Sampling?
N/A
N/A
82. During Most Recent Semi -Annual Period, Did POTW Identify All
❑Yes❑NoON/A
❑Yes❑No®N/A
❑Yes❑No®N/A
Re ortin Non-Com liance 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.OYes❑No®N/A
c. If applicable, did POTW resample and obtain results within 30 days of
c.❑Yes❑No®N/A
becomingaware of SIU limit violations in 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?
I
❑ Yes ®
No
1
❑
Yes ®
No
I
❑
Yes ®
No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
❑Yes❑No®N/A
❑Yes❑No®N/A
11
®Yes❑No❑N/A
Specified in POTW's ERP OVs, Penalties, timing, etc.)?
86. Does File Contain Penalty Assessment Notices?
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑No®N/A
87. Does File Contain Proof Of Penalty Collection?
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑No®N/A
88. a. Does 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
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
❑ Yes ®No
®Yes ❑ No
❑ Yes ® No
Information For You? 111
FILE REVIEW COMMENTS:
A copy of each SIU's Slug/Spill Control plan needs to be in the permit file.
There was not a permit renewal application in the file for BSH Home Appliances Range Facility. The POTW was reminded that the permit
renewal application needs to be maintained in the file.
Chatsworth did not calibrate their flow meter in 2019. Civil Penalty assessment will be sent in second half of 2020.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 5

INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
INIC101012 1513 1418 7 116120
1. Industry Inspected: Craven Wood Energy,
L. P.
2. Industry Address: 201 Executive Parkway
3. Type of Industry/Product: Power Plant
4. Industry Contact: Harry Purvis Title: Chemical Tech and Water Quality Phone: [phone] ext. 226 Fax: [phone]
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 Sample is taken every hour to make the composite sample
E. Exit Interview ® Yes
❑ No
Industrial Inspection Comments:
On the day of inspection, the facility was down for maintenance. The facility hopes to start operating again within the next two
weeks.
Audit SUMMARY AND COMMENTS:
Audit Comments: The POTW requires all SIU's to have a swill/slug Dlan. A couv of the sDill/slug elan needs to be maintained in
the SIU's file. The facility was reminded that the Industrial Waste Survey is due 12/1/2020. A copy of the approval letter for the
Industrial Waste Survey and Enforcement Response Plan is included in this inspection. The attached approval letters need to be
kept in the appropriate file.
Requirements: The Headworks Analysis was due on 4/1/2020. The City requested and was granted an extension until 8/1/2020.
The Headworks Analysis needs to be submitted by 8/1/2020.
Recommendations:
NOD: ❑ Yes ❑ No
NOV: ❑ Yes ❑ No
QNCR: ❑ Yes ❑ No
POTW Rating:
Satisfactory ❑ Marginal ❑ Unsatisfactory ❑
Audit COMPLETED BY: zq�u&.9-Cle, DATE: 7/17/2020
PERCS, and WaRO Regional Office
NC DWR Pretreatment Audit Form Revised: December 2016 Page 6