NC0023965_Pretreatment Audit_20210421

DocuSign Envelope ID: 9A7217E5-5CB7-43A6-A42F-9EC349963002
ROY COOPER
Governor
DIONNE DELLI-GATTI
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
April 29, 2021
Mr. William Roy, Environmental Compliance Manager
Cape Fear Public Utility Authority
235 Government Center Drive
Wilmington, NC 28403
Subject: Pretreatment Audit Report
Program: CFPUA- James A. Laughlin, M'Kean Maffitt WWTP's
NPDES Permit No. NCO023965 & NCO023973
New Hanover County
Dear Mr. Roy:
A Pretreatment Audit Inspection of the CFPUA Wastewater Treatment Facilities was conducted
by Helen Perez from this office on April 21, 2021. This inspection was conducted to determine
the effectiveness of the pretreatment program by reviewing various aspects of the program,
which included files and records, industrial user inspections and monitoring data, data
management procedures and adherence to the Enforcement Response Plan.
The CFPUA continues to do an effective job of achieving the pretreatment program goals. The
findings and comments noted during this inspection are provided in the enclosed copy of the
audit report. There were no significant issues or findings noted during this inspection thus a
response to this inspection report is not required.
Thank you for your continued support of the North Carolina Pretreatment Program. If you
should have any questions, please contact Helen Perez at [phone] or at
[e-mail] .
Sincerely,
DocuSigned by:
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Tom Tharrington, Assistant Regional Supervisor
Water Quality Regional Operations Section
Wilmington Regional Office
Division of Water Resources, NCDEQ
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DQ�� North Carolina Department of Environmental Quality I Division of Water Resources
Ervoan+cnaoi.NA Wilmington Regional Office 1 127 Cardinal Drive Extension I Wilmington, North Carolina 28405
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DocuSign Envelope ID: 110C1C7B-BFDA-456C-ACBA-87D5148DBAC8
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: Cape Fear Public Utility Authority
2. Control Authority Representative(s): William Roy, Maggie Butler
3. Title(s): Environmental Compliance Manager, Environmental Compliance Supervisor
4. Address of POTW:
Mailing 235 Government Center Drive
City Wilmington Zip Code 28403
Phone Number 910-332-6423 Fax Number 910-332-6730 E-Mail william.roy(&cfpua.org ma22ie.but1erAcfpua.or2
5. Audit Date 04/21/2021
6. Last Inspection Date: 08/28/2020 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
INICI01012 I3 19 16 Is I
MM/DD/YY
I04 I21 I21
10.
.................................................................
Current Number of Significant. Industrial Users(SIUs)?...............................................................................................
6
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)?............................................................................................
2
19.
Number of CIUs in SNC?
0
NC DWR Pretreatment Audit Form Revised: December 2016 Page 1

DocuSign Envelope ID: 110C1C7B-BFDA-456C-ACBA-87D5148DBAC8
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-NC0023965
05/25/17
® Yes ❑ No
08/17/17
® Yes ❑ No
05/31/22
Headworks Analysis-NC0023973
06/27-19
Yes
08/07/19
Yes
06/30/24
Industrial Waste Survey (IWS)
07/18/18
® Yes ❑ No
07/31/18
® Yes ❑ No
08/01/23
Sewer Use Ordinance (SUO)
12/29/16
® Yes ❑ No
03/21/17
® Yes ❑ No
N/A
Enforcement Response Plan (ERP)
11/07/19
® Yes ❑ No
02/05/20
® Yes ❑ No
N/A
Long Term Monitoring Plan (LTMP)
12/07/18
® Yes ❑ No
12/12/18
® Yes ❑ No
N/A
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. Pender County and Wrightsville Beach
22. If yes to #21, Do you have current Inter urisdictional 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 05/10/17
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
N/A
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
NC DWR Pretreatment Audit Form Revised: December 2016 Page 2

DocuSign Envelope ID: 110C1C7B-BFDA-456C-ACBA-87D5148DBAC8
Computer Equipment (Hardware and
Software) ®S ❑M ❑U
30. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No
Explain Yes or No. Excel spreadsheets to track SIU data and compliance. Surface Pro used during inspections in the field.
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Surcharges, annual permit fees and monitoring 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? Written requests to view files would have to go through
PIO to schedule appointment for review of files.
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? Corning, confirmed as trade secret.
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 N/A
Permitting (Industrial Waste Survey-IWS)
38. How does the POTW become aware of new or changed Users? New customers are entered into UMax database. This
program sorts the customers as residential or industrial and a short form is sent as needed.
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 short form. May send out long form based on water usage, SIC code, desciption of activities, ect.
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
®Yes ❑No If Yes, How many are there? 1
Please list each site and how it is permitted, if applicable. New Hanover County Landfill
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) There are designated discharge points, 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: Availability
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.)
N/A
46. Does the POTW keep pollutant loading in reserve for future growth / safety? ® Yes ❑ No
If yes, what percentage of each parameter % What they have available.
47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) ❑ Yes ® No
If yes, Explain.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 3

DocuSign Envelope ID: 110C1C7B-BFDA-456C-ACBA-87D5148DBAC8
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)
Historical data, LTMP, NPDES and categorical parameters, review application for any industry specific POCs.
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Compliance history, consistency of data -more variable=more frequent, POCs that are more critical to WWTP, new IUs-
more frequent at first.
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. Data and date reports recieved are entered into a spreadsheet which
flags violations. Data is reviewed by more than one staff member to ensure accuracy and to determine follow-up action.
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?
If there is potential for spills to reach collection system.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Does it include containment, chemical storage, manefest, spill procedures and proper notification.
56. How does the POTW decide where the sample point for an SIU should be located?
Downstream of process and before mixing with other wastes.
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. Reviews sampling procedures at inspections to
include correct sample bottles, sampler, refrigeration, proper transfer procedures, PPE.
58. Who performs sample analysis for the POTW for Metals Pace
Conventional Parameters CFPUA
Organics Gel
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
ISO standard forms used with all relevant information entered: date, time, temp, pH, type of analysis, preservative,
signatures.
Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis (HWA)
60a.
60b.
60c.
60d.
60e.
60f.
Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑ NO
Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ® YES ❑ NO
Is LTMP/STMP Data Maintained in Table or Equivalent? ® YES ❑ NO Is Table Adequate? ® YES ❑ NO
All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? ® YES ❑ NO Division Inspector, verify yourself!
If NO to any above, list violations
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
❑More LTMP data available ❑Resolve over allocation 05 year expiration
Explain.
❑NPDES limits change
❑ Other
NC DWR Pretreatment Audit Form Revised: December 2016 Page 4

DocuSign Envelope ID: 110C1C7B-BFDA-456C-ACBA-87D5148DBAC8
63. In general, what is the most limiting criteria of your HWA? ®Inhibition ❑ Pass Through El 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.
Summary
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 5

DocuSign Envelope ID: 110C1C7B-BFDA-456C-ACBA-87D5148DBAC8
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION)
66. User Name
1. Corning, Inc.
2. Unifirst Corp IFT
Waste Management
67. IUP Number
N321
N102
N2313A
68. Does File Contain Current Permit?
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
69. Permit Expiration Date
06/30/2025
06/30/2025
06/30/2025
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
N/A
N/A
N/A
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 ❑
I ® Yes ❑
I ® 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 I
b. ❑Yes ❑No
74. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
❑Yes❑NoON/A
F
❑Yes❑No®N/A
❑Yes❑NoON/A
Organic Management Plan (TOMP)?
1
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 ElNo
F977E] 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
®Yes❑No❑N/A
F
®Yes❑No❑N/A
®Yes❑No❑N/A
Sampling as Required b IUP, includingFlow?
1
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 IUs with Combined Wastestream Formula (CWF), does
❑Yes❑No[D
❑Yes❑Noll
❑Yes❑NoON/A
file includeprocess/dilution flows as Required by IUP?
80b. For categorical lUs with Production based limits, does file include
❑Yes❑No[D
❑Yes❑No®N/A
❑Yes❑NoON/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
❑Yes❑No®N/A
❑Yes❑No®N/A
®Yes❑No❑N/A
Re ortin Non -Compliance 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.❑Yes❑No®N/A
c. If applicable, did POTW resample and obtain results within 30 days of
becomingaware of SIU limit violations in the POTW's sampling of SIU?
❑ c.Yes❑No®N/A
c.❑Yes❑No®N/A
c.❑Yes❑No®N/A
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
❑
Yes
®
No
❑
Yes
®
No
❑
Yes
®
No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑No®N/A
Specified in POTW's ERP (NOVs, Penalties, timing, etc.)?
86. Does File Contain Penalty Assessment Notices?
❑Yes❑NoON/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❑NoON/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
® No
❑ Yes ® No
❑ Yes ®No
I[E]Yes
Information For You?
FILE REVIEW COMMENTS:
75. Waste Management -A Streamlined IUP Review completed by William Roy (#0132).
79. Waste Management -In 10/20, SIU submitted electronic copy but was late in submitting paper copy of monthly report. NOD was issued.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 6

DocuSign Envelope ID: 110C1C7B-BFDA-456C-ACBA-87D5148DBAC8
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
I N I C 1 0 10 12 13 19 16 15 04121 1211
1. Industry Inspected: Waste Management
2. Industry Address: 3920 River Road Wilmington 28412
3. Type of Industry/Product: Waste and recycling pick-up
4. Industry Contact: David Greer Title: District Operations Manager 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 Operator knowledgeable of treatment system.
D. Sampling Review ® Yes ❑ No Compared monthly submittal with SIU's files.
E. Exit Interview ® Yes ❑ No
Industrial Inspection Comments:
Waste Management hauls portable toilet, grease trap and simuliar waste by truck 2 to 4 times a week to the Northside WWTP
after pretreatment process. CFPUA staff thoroughly completed all parts of the industry inspection.
Audit SUMMARY AND COMMENTS:
Audit Comments: CFPUA continues to manage an efficient pretreatment program. All records and files were available for review.
Requirements: N/A
Recommendations:
None
NOD: ❑ Yes
® No
NOV: ❑ Yes
® No
QNCR: ❑ Yes
® No
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory ❑
Audit COMPLETED BY: Helen Perez -Wilmington Regional Office DATE: 04/21/2021
,,—DocuSigned by:
NC DWR Pretreatment Audit Form Revised: December 2016 Page 7