NC0025071_Pretreatment Audit_20210309 (2)

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NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT AUDIT REPORT
Background Information [Complete prior to audit; review Program Info Database Sheet(s)]
1. Control Authority (POTW) Name: Mebane Bridge WWTP
2. Control Authority Representative(s): Chris Powell
3. Title(s): Pretreatment Coordinator
4. Address of POTW:
Mailing
City
204 Mebane Bridge Rd
Eden, NC
Zip Code 27288
Phone Number Fax Number E-Mail
[phone]
5. Audit Date 03 / 09 / 2021
6. Last Inspection Date: 02 / 13 / 20 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. Some unaddressed frequency violations are flagged on the DMRs via BIMS,
but the dates correspond to the end -of -year holidays.
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
INICI0101 21 510 1 711 I
10. Current Number of Significant Industrial Users (SIUs)?
11. Number of SIUs with No IUP, or with an Expired IUP?
12. Number of SIUs Not Inspected by POTW in Last Calendar Year?
13. Number of SIUs Not Sampled by POTW in Last Calendar Year?
MM/DD/YY
03 09 21 1
14. Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi -Annual Periods?
15. Number of SIUs in SNC for Reporting During Either of Last 2 Semi -Annual Periods?
16. Number of SIUs in SNC with Pretreatment Schedule?
3
0
0
0
0
0
0
17. Number of SIUs on Schedules?
0
18. Current Number of Categorical Industrial Users (CIUs)?
19. Number of CIUs in SNC?
2
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 Program Info:
Program Element
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
03/13/2017
7 Yes ❑ No
08/10/2017
VA Yes ❑ No
04/01/2022
Industrial Waste Survey (IWS)
9/21/2020
VA Yes ❑ No
12/17/2020
VA Yes ❑ No
Sewer Use Ordinance (SUO)
12/11/2012
F Yes ❑ No
12/14/2020
F1 Yes ❑ No
Enforcement Response Plan (ERP)
01 /09/2020
FA Yes ❑ No
02/05/2020
F Yes ❑ No
Long Term Monitoring Plan (LTMP)
02/24/2020
FA Yes ❑ No
06/01 /2020
VA 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. Contract with county for service to government buildings and landfill.
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 11 / 20 / 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
None
Resources
29. Please Rate the Followine: S=Satisfacto
M=Marginal U=Unsatisfacto
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
M S ❑M ❑U
Access to POTW Vehicles for
Sampling, Inspections, and
Emergencies
M S ❑M ❑U
Access to Operable Sampling
Equipment
M S ❑M ❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
M S ❑M ❑U
Reference Materials
MS❑M❑U
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
M S ❑M ❑U
Computer Equipment (Hardware and
Software)
M 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. POTW uses Excel spreadsheet with pre -built formula to show max, minimum, and average for all parameters
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Annual billing for pretreatment permitted sites, as well as Civil Penalties and renewal 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. Purina Nestle is coming into town, and SIU permit is in the works (100K gallons per day estimated).
Site of future factory is located far from residential areas, so there is not much worry of odor causing issues.
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?
POTW would provide public information if ever approached with a request.
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? If harm to public would be possible, POTW would deny. If the SIU is working through an issue,
POTW would present the issue to the public with acknowledgement of the
general situation along with a proposed timeline for any safety advisories.
35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? ® Yes ❑ No
Occasional check -ins with industries, at least once at an unannounced visit, and beyond that during sampling events (2x per year)
36. Is the public notified about changes in the SUO or Local Limits? ® Yes ❑ No
Wastewater report is sent out monthly on government website and posted at city hall.
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? Survey to local businesses every five years
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?) If a business uses domestic flow only, they receive short -form only; industrial or production businesses receive long -form and may be considered
for local permit (monitoring only) or NPDES pretreatment permit if flow increases to 25K, or reported data shows reason for concern with BOD and/or TSS.
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
®Yes ❑No If Yes, How many are there? Duke Energy - Dan River (Categorical)
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
No grease waste - septic and portable toilet trucks only.
42. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples drawn,
manifests required) Isolated septic receiving station is in place. Each truck operator must obtain a dump ticket, which is only given to permitted sites,
and must be purchased ahead of time at city hall. Manual bar screen is in place to keep rags out. If any signs of FOG or film are
present, the truck must remove dumped waste from the pit to protect the plant.
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: Spikes in data are a sign that closer monitoring needs to be done before allocating to an industry.
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 50 % or higher for each pollutant
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)
Pollutants listed on IWS and categorical parameters; fluctuations in flow or spike in data
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Flow is daily, pH is weekly. Pollutants frequently reported as 'less thans" are done monthly if its a pollutant of concern, and any metals that get high enough numbers to be detectable are done monthly.
Everything else is done quarterly or 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. Since Powell has been there, only minor issues have occured (flow slightly over, something broke and
affected Zinc concentration). All occuranecs of violation have been resolved and re -tested quickly.
SNC is reserved for repeated or extreme violations.
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?
Onsite safety measures for SIUs (dykes, containment pallets, process controls, feasibility for reaching discharge pipes)
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Raw materials are up to date, emergency contacts listed, countermeasure plan, people trained and certified in material spill cleanup, using proper containment measures, personnel) training, proper SOPs
incident report from SIU, stormwater contact review
56. How does the POTW decide where the sample point for an SIU should be located?
Sample is always pulled after the process to represent final discharge (includes domestic and treatment water).
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.
Collection from autosampler includes onsite calibration of meters, a thorough swirling of the collections jug, and proper storage of the allocated samples.
58. Who performs sample analysis for the POTW for Metals PACE
Conventional Parameters POTW
Organics PACE
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Logbook for DO, pH is used for calibration records and maintenance, and Pace CoCs are used for third -party sampling.
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 05 year expiration
❑Other
Explain. Will revise for HWA due in 2022 because Duke Energy site is being phased out of treatment monitoring,
and Purina Nestle will be added before 2022 HWA.
63. In general, what is the most limiting criteria of your HWA? ❑Inhibition ❑ Pass Through ❑Sludge Quality
None have that problem - all are well within parameter. No effects felt on the POTW
64. Do you see any way to increase your loading in the future (Example: obtaining more land for sludge disposal)? ❑ Yes ❑ No
Explain. Reworking HWA for low -usage SIUs, and decreasing overall flow allowances. New digester system just came on board - chemical digester (Clean Bee).
Duke landfill leachate is decreasing in volume and in concentration, Can decant a whole tank in 24 hours. Capacity via volume is at less than 50%.
so the POTW is planning to use those additional pounds to buffer any increasing needs from Purina Nestle coming to town.
Summary
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
Purina Nestle and removal of Duke Energy - both in the works, but timing is TBD.
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.Weil-McClane Technologies
2. Duke Energy - Dan River
3. Karastan Rug Mill
67. IUP Number
1012
1013
1005
68. Does File Contain Current Permit?
E. Yes ❑ No
I Yes ❑ No
,II Yes ❑ No
69. Permit Expiration Date
07/31/2025
02/28/2022
09/30/2023
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
40 CFR 433.17
40 CFr 423.16
N/A
71. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
M Yes ❑ No
M Yes ❑ No
VA Yes ❑ No
72. Does File Contain Inspection Completed Within Last Calendar Year?
FA Yes ❑ No
F Yes ❑ No
F Yes ❑ No
73. a. Does File Contain Slug/Spill Control Plan?
b. If No, is One Needed? (See Inspection Form from POTW)
a. ►Yes ■ No
b. •Yes ■ No
a. •Yes % No
b. •Yes % No
a. % Yes ■ No
b. •Yes ■ No
Certification, Does File Contain a Toxic
(TOMP)?
® Yes ❑No❑N/A
❑ Yes ❑NogN/A
❑Yes❑NoON/A
74. For 40 CFR 413 and 433 TTO
Organic Management Plan
75. a. Does File Contain Original Permit Review Letter from Division?
b. All Issues Resolved?
a. %Yes ■No
b.❑Yes❑No❑N/A
a. ► Yes ■No
b.❑Yes❑NogN/A
a. %Yes ■No
b.❑Yes❑NogN/A
76. During Most Recent Semi -Annual Period, Did POTW Complete its
Sampling as Required by IUP, including Flow?
M Yes ❑ No
M Yes ❑ No
M Yes ❑ No
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
'M Yes ❑ No
M Yes ❑ No
M Yes ❑ No
78. During Most Recent Semi -Annual Period, Did SIU Complete its
Sampling as Required by IUP, including Flow?
®Yes❑No❑N/A
® Yes ❑No❑N/A
®Yes❑No❑N/A
79. During Most Recent Semi -Annual Period, Did SIU submit all reports on
time?
®Yes❑No❑N/A
® Yes ❑No❑N/A
El Yes ❑No❑N/A
80a. For categorical IUs with Combined Wastestream Formula (CWF), does
file include process/dilution flows as Required by IUP?
❑Yes❑No®N/A
❑ Yes ❑NoON/A
❑Yes❑No®N/A
80b. For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
0Yes ❑No❑N/A
® Yes ❑No❑N/A
❑ Yes ❑No®N/A
81. During Most Recent Semi -Annual Period, Did POTW Identify All
Limits Non -Compliance from Both POTW and SIU Sampling?
M Yes ❑ No
M Yes ❑ No
M Yes ❑ No
82. During Most Recent Semi -Annual Period, Did POTW Identify All
Reportin Non -Compliance from SIU Sampling?
❑Yes❑No®N/A
❑ Yes ❑NogN/A
❑Yes❑NOON/A
83. a. Was POTW Notified by SIU (Within 24 Hours) of All Self-
Monitoring Violations?
b. Did Industry Resample and submit results to POTW within 30 Days?
c. If applicable, did POTW resample and obtain results within 30 days of
becoming aware of SIU limit violations in the POTW's sampling of SIU?
a.gYes❑No❑N/A
b.gYes❑No❑N/A
c.❑Yes❑NogN/A
a.gYes❑No❑N/A
b.❑Yes❑NogN/A
c.❑Yes❑NogN/A
a.❑Yes❑NogN/A
b.❑Yes❑NogN/A
c.❑Yes❑NogN/A
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
❑ Yes 7 No
❑ Yes I No
❑ Yes M No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
Specified in POTW's ERP (NOVs, Penalties, timing, etc.)?
0Yes ❑No❑N/A
® Yes ❑No❑N/A
❑Yes❑No®N/A
86. Does File Contain Penalty Assessment Notices?
®Yes❑No❑N/A
❑ Yes ❑NoWIN/A
❑Yes❑NOON/A
87. Does File Contain Proof Of Penalty Collection?
0Yes ❑No❑N/A
❑ Yes ❑NogN/A
❑Yes❑No®N/A
88. a. Does File Contain Any Current Enforcement Orders?
b. Is SIU in Compliance with Order?
a.❑Yes❑NogN/A
b.❑Yes❑NogN/A
a.❑Yes❑NogN/A
b.❑Yes❑NogN/A
a.❑Yes❑NogN/A
b.❑Yes❑NogN/A
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
Information For You?
❑ Yes M No
❑ Yes M No
❑ Yes VA No
FILE REVIEW COMMENTS:
Files were well sorted and all requested information was presented - either in hard copy, or digital copy.
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 0 1 0 1 2 1 5 1 0 1 7 1 1 1 1031 09 1 21 1
1. Industry Inspected: Weil-McClane Technologies
2. Industry Address: 523 S. New St. #3623 Eden, NC 2728f
3. Type of Industry/Product: Metal Fabrication (Boilers)
4. Industry Contact: Title: Phone: Fax:
5. Does the POTW Use the Division Model Inspection Form or Equivalent?
Holly Siddens
Quinton Lewis
Yes ❑ No
6. Did the POTW Contact Conduct the Following Parts of the Industrial Inspection Thoroughly?
Comments:
A. Initial Interview ll 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:
Notes from previous year were well maintained and on hand,
so it was easy to compare to the current plant situation.
ORC Powell was knowledgable of the plant operations
and the ongoing efforts to maintain permit compliance.
Wash areas ("the pit") and floor sweeper dumping line fed to
outgoing line. Compressor room sealed off from floor drains.
Sampling was thorough, with onsite calibration of pH meter.
Portable autosampler set up on 3/8, and sample is collected 3/9.
Composite sample was 3 degrees at time of sampling (kept on ice overnight).
ORC stated that sample volume is set to and calibrated for 110 ml per pull.
Senior Manager of QA
EHS Manager
Audit SUMMARY AND COMMENTS:
Audit Comments: Powell is knowledgable of his SIUs, and demonstrates good practices in oversight and sampling. No signs of deficiencies were uncovered.
Requirements: None
Recommendations: None
NOD: ❑ Yes ® No
NOV: ❑ Yes ® No
QNCR: ❑ Yes ® No
POTW Rating:
Satisfactory 12
Marginal ❑ Unsatisfactory ❑
Audit COMPLETED BY: Alex Lowe
XXXX, PERCS, and XXXX, XXXX Regional Office
DATE: 03/09/2021
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 6