NC0026565_Pretreatment Audit Inspection Report_20200304

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
Grant Cheek
Town of Ramseur
P.O. Box 545
Ramseur, North Carolina 27316
NORTH CAROLINA
Environmental Quality
March 4, 2020
SUBJECT: Pretreatment Audit Inspection (PAI)
Town of Ramseur
NPDES# NCO026565
Randolph County
Dear Mr. Cheek:
On February 4, 2020 a Pretreatment Audit Inspection (PAI) was performed by Jim Gonsiewski of
the Winston-Salem Regional office. Ms. Nadine Blackwell, pretreatment coordinator for the Town
of Ramseur was present along with Mr. Terry Lewallen, ORC for the facility. 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, and adherence to the enforcement response plan (ERP). Additionally, an inspection of
the MatLab facility was conducted in conjunction with an inspection by the Town of Ramseur.
Background
This is a 0.48 MGD permitted facility. The City has one (1) Significant Industrial User which is
also a Categorical Industrial User. The SIU (MatLab) was in Significant Non Compliance (SNC)
for the first six (6) months of 2019. A $750 penalty was assessed against MatLab.
Pretreatment Program Element Review
The Headworks Analysis (HWA) was submitted on December 20, 2017. The HWA was approved
on February 8, 2018. The next HWA is due on October 1, 2022.
The Industrial Waste Survey (IWS) was submitted on January 15, 2016. The IWS was approved
on March 7, 2016. The next IWS is due on April 1, 2021.
The Sewer Use Ordinance (SUO) was approved on October 2, 2015.
The Enforcement Response Plan (ERP) was approved on October 2, 2015.
Q North Carolina Department of Environmental Quality I Division of Water Resources
_ Winston-Salem Regional Office 1 450 West Hanes Mill Road, Suite 3001 Winston-Salem, North Carolina 27105
aww*.+e"�u�«mmwft. lli 336.776.9800

STMP File Review
The Short Term Monitoring Plan (STMP) was approved on October 2, 2015 and is being conducted
at the proper locations and frequencies.
Industrial User Permit (IUP) File Review
A review of the file for Matlab (#0002) revealed that the monitoring data was well organized and
compliant.
The slug control plan for MatLab (#0002) was in good order.
Action Items
No other action items were noted.
The pretreatment program is considered satisfactory. Ms. Blackwell maintains an excellent
program. If you have any questions please contact Jim Gonsiewski or me at [phone].
Sincerely,
EEftcca,OQTEUXNEA
uig.d by:
...
Lon T. Snider
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — W SRO
cc: PERCS Unit — Vivien Zhong (Electronic Copy)

K`ro NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT AUDIT REPORT
warerResources
ENVIRONMENTAL QUALITY
Background Information [Complete prior to audit; review Program Info Database Sheet(s)j
1. Control Authority (POTW) Name: Town of Ramseur
2. Control Authority Representative(s): Nadine Blackwell
3. Title(s): Pretreatment Coordinator
4. Address of POTW:
Mailing P.O. Box 545
City Ramseur, NC Zip Code 27316
Phone Number 336-766-0270 Fax Number 336-766-0469 E-Mail nadine.blackwellansuez-na.com
5. Audit Date 02/04/20
6. Last Inspection Date: 03/20/2019 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 Codine
Main Program Permit Number
IN IC101012 16 15 16 15 I
MM/DD/YY
102104 120
10....................................Current
Number of Significant Industrial Users..(SNs.)........................................................................................................................
.............
1
11.
.........................................................................................................................
Number of SNs with No IUP, or with an, Ex,Aired_IUP?........................................................................................................................
0
12.
.............................................................................
Number of SNs Not Inspected, by POTW, in. Last Calendar Year?
..............................................................................................................................................
0
13.
Number of SNs Not Sampled,byPOTW, in Last Calendar Year?
...............................................................................................................................................................
0
14.
....
Number of SNs, in,SNC. for, Limits.ViolationsDurinp.Either. of Last 2,Semi-Annual ,Periods?
....... ......... ....
1
15.
...............................................................................................
Number of SNs in SNC for Reportin&. During, Either, of Last 2 Semi -Annual Periods?
.............................................................................................................
0
16.
Number of SNs in SNC with Pretreatment Schedule?
0
18. Current Number
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 sunoortina documents and PF.RC9 Annrnvnl T.etter and ..,;rh pr,.R .. rnr
Program Element
Last Submittal
Date - In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
12/20/2017
M Yes No
02/08/2018
M Yes ❑ No
10/01/2022
Industrial Waste Survey (IWS)
01/15/2016
M Yes ❑ No
03/07/2016
M Yes ❑ No
04/01/2021
Sewer Use Ordinance (SUO)
09/22/2015
® Yes ❑ No
10/02/2015
® Yes ❑ No
Enforcement Response Plan (ERP)
09/22/2015
Yes ❑ No
10/02/2015
M Yes ❑ No
Short Term Monitoring Plan (STMP)
09/22/2015
M Yes ❑ No
10/02/2015
M 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 M No If yes, Please list these towns and/or areas.
22. If yes to 921, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? ❑ Yes ❑ No M 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 M NA
If yes, Explain.
24. Date of Last SUO Adoption by Local Council 10/ 12 / 2015
25. Have you had any problems interpreting or enforcing any part of the SUO? ❑ Yes M No
If yes, Explain.
Enforcement (Enforcement Response Plan-ERP)
26. Did you send a copy of the ERP to your industries? M 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 M No If yes, Explain.
28. List Industries under a Schedule or Order and Type of Schedule or Order MatLab was in SNC for zinc the first 6 months of the
inspection period. They needed to clean out the oil/water separator which was completed in October 2019.
29. Please Rate the Following: S=Satisfactory M=Marginal U=Unsatisfactory
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
MS ❑M ❑U
Access to POTW Vehicles for
Sampling, Inspections, and
MS ❑M ❑U
Emergencies
Access to Operable Sampling
Equipment
MS ❑M ❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
MS ❑M ❑U
Reference Materials
MS ❑M ❑U
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
MS ❑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. Uses Hachwims, combined with an Excel spreadsheet.
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Bills the SIU for pretreatment sampling.
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?
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?
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
37. Were all industries in SNC published in the last notice? ® Yes ❑ No
Permitting (Industrial Waste Survey-IWS)
38. How does the POTW become aware of new or changed Users? Town Hall, water billing.
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 W WTP and therefore require a new permit or a permit revision? (Who is an
SIU?) Based on the definition of an SIU.
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
❑Yes ®No If Yes, how many are there?
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. Ammonia 53.6%, Arsenic 97.4%, Cadmium 94.8%, Chromium 73.2%, Copper
35.7%, Cyanide 74.5%, Lead 86.5%, Nickel 43.4%, Silver 86.4%, Zinc 66.4%.
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). Potential impact to the W WTP.
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Potential impact to the W WTP.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 3

Permit
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. Based on definitions for SNC.
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?
Required for every facility where chemicals are stored and reflects how they are stored.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Whether it protects and prevents spills into the sewer.
56. How does the POTW decide where the sample point for an SIU should be located?
The sample location is the point that would capture all potential discharges.
57. Has the POTW established a procedure to ensure that representative samples will be taken by the POTW or SIC 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. POTW samples at the point where process water
exits the facility, immediately after the oil/water separator. Standard sampling procedures are followed at each sampling
event. Additionally, all equipment is checked to make sure it is operational.
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.
The samples are collected semi-annually using standard methods. Standard chain of custody procedures are followed
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
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 ❑5 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. Accept more flow and users. Currently the POTW averages 140,000 GPD. Design flow is 480,000 GPD.
65. Do you plan any significant changes to the pretreatment program or changes to the W W TP that may affect pretreatment?
No
NC D WR 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 IF1.
MatLab
.
67. IUP Number
0002
0�
68. Does File Contain Current Permit?
® Yes No
❑Yes No
Yes No
69. Permit Expiration Date
12/31/2020
70. Categorical Standard Applied I.E. 40 CFR, Etc. Or N/A
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 ❑No
a. ❑Yes []No
b. If No, is One Needed? See Inspection Form from POTW
b. ❑Yes ❑No
b. ❑Yes ❑No
b. ❑Yes ❑No
74. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
NYesONoON/A
OYesONOON/A
OYesONoON/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.OYesONo®N/A
b.OYesONo0N/A
b.OYesONo11N/A
76. During Most Recent Semi -Annual Period, Did POTW Complete its
®Yes ❑ No
ElYes ❑ 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
OYesONoON/A
OYesONoON/A
[]YesONOON/A
Sampling as Required by IUP, including Flow?
79. During Most Recent Semi -Annual Period, Did SIU submit all reports on
®YesONoON/A
OYesONoON/A
[]Yes❑NoON/A
time?
80a. For categorical Ns with Combined Wastestream Formula (CWF), does
OYesONoON/A
OYes[]NoON/A
❑Yes[]NOON/A
file includeprocess/dilution flows as Required by IUP?
80b. For categorical IUs with Production based limits, does file include
OYesONo®N/A
❑YesONoON/A
❑YesONoON/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?
82. During Most Recent Semi -Annual Period, Did POTW Identify All
OYes[]No[]N/A
OYesONoCIN/A
[]YesONoON/A
Re ortin Non-Com liance from SIU Sampling?
83. a. Was POTW Notified by SIU (Within 24 Hours) of All Self-
amYesONo®N/A
a.OYesONoON/A
a.oYesONoON/A
Monitoring Violations?
b. Did Industry Resample and submit results to POTW within 30 Days?
b.OYesONo®N/A
b.DYes[3No0N/A
b.DYesONoON/A
c. If applicable, did POTW resample and obtain results within 30 days of
cmYesoxooN/A
c.OYesONoON/A
c.OYesONoON/A
am lin of SIU?
becomingaware of SIU limit violations in the POTW's sampling
84. DuringMost Recent Semi -Annual Period, Was SIU in SNC?
®Yes
❑ No
El ❑ No
❑ Yes ❑
No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
®YesONo[3N/A
[]Yes[]No❑N/A
[]Yes❑No❑N/A
Specified in POTW's ERP OVs, Penalties, timing, etc.)?
86. Does File Contain Penalty Assessment Notices?
®YesONoON/A
❑YesONo❑N/A I
❑Yes❑No❑N/A
87. Does File Contain Proof Of Penalty Collection?
OYesONoON/A 11
❑Yes[]No❑N/A
❑YesONo[]N/A
88. a. Does File Contain Any Current Enforcement Orders?
axwesmo®N/A
a.OYesONoON/A
a.OYesONoON/A
b. Is SIU in Compliance with Order?
b.OYesONo N/A
KoYespNOON/A
b.OYesONoON/A
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
❑ Yes ® No
❑ Yes 0 No
❑ Yes D No
Information For You?
FILE REVIEW COMMENTS:
Excellent spill response plan. The SIU came back into the program in 2015 due to the use of zinc phosphate.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 5

INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
I N I C I I) 1 0 1 2 16 15 1 6 1 5 1 102 104 1 20
1. Industry Inspected: MatLab
2. Industry Address: 7307 Jordan Road Ramseur NC 27316
3. Type of Industry/Product: Eauipment Parts
spraying
4. Industry Contact: Mitch Almond Title:
Plant Manager Phone: [phone] Fax:
5. Does the POTW Use the Division Model
Inspection Form or Equivalent? N 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 N Yes
❑ No
C. Pretreatment Tour NYes
❑ No
D. Sampling Review N Yes
❑ No
E. Exit Interview - N Yes
❑ No
Industrial Inspection Comments:
Mr. Press Bower, Vice President for Engineering for MatLab, was also present for the tour. The facility has 30 employees who
run 2 shifts, 5 days a week. The primary function is to prep and paint John Deere tractor transmission parts. Normally 500
units are processed per day. The facility is clean and very well run. An oil/water separator is present on the site. Tibbett &
Sons cleans out the separator quarterly. Garco takes the oil from the separator.
Audit SUMMARY AND COMMENTS:
Audit Comments: Ms Blackwell runs an excellent Pretreatment Program Her 2ood interaction with the SIU helos the operation
run smoothly.
Requirements:
Recommendations:
NOD: ❑ Yes N No
NOV: ❑ Yes N No
QNCR: ❑ Yes N No
POTW Rating:
Satisfactory N Marginal ❑ Unsatisfactory ❑
raocu919ned by:
Audit COMPLETED BY: I �µ DATE: 03/04/2020
Jim won ieEwsOfflin loh-Salem Regional Office
NC D WR Pretreatment Audit Form Revised: December 2016 Page 6