NC0047384_PAI Report_20210624

D
Water Resources
ENVIRONMENTAL QUALITY
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: Greensboro T.Z. Osborne WWTP
2. Control Authority Representative(s): Martie Groomer, Frank Skeet, Alicia Goots3, Wiliam Burdick4, Elijah Williams5
3. Title(s): 1. Water Reclamation Laboratory & Industrial Waste Supervisor
2. Water Reclamation Pretreatment Coordinator
3. Water Reclamation Laboratory Coordinator
4. Water Reclamation Pretreatment Laboratory Specialist
5. Water Reclamation Manager
4. Address of POTW:
Mailing 2350 Huffine Mill Road
City McLeansville Zip Code 27301
Phone Number [phone] Fax Number N/A E-Mail martie.groomeAgreensboro-nc.gov
5. Audit Date 06/24/2021
6. Last Inspection Date: 09/12/2018 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.
Since last inspection, NPDES violations are as follows:
CY2019: 2 flow (attributed to valve malfunction at water treatment plant)
CY2020: 2 flow, 2 fecal, 1 residual chlorine (none attributed to SIUs)
CY2021: 4 CBOD, 6 ammonia, 1 flow, 2 TSS, 1 WET (one ammonia attributed to SIU)
Ms. Groome stated that most of these compliance issues have been attributed to high rainfall during the period of
major construction on the plant.
9. Is POTW under an Order That Includes Pretreatment Conditions? ® Yes ❑ No
Order Type and Number: EMC SOC WQ S19-010 Are Milestone Dates Being Met? ❑ Yes ❑ No 0 NA
Parameters Covered Under Order L4-Dioxane
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 1

ICIS Coding
Main Program Permit Number
INICI0I014 I7 I3 I8 14 1
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
106124121 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?
29
0
0
0
2
0
0
17. Number of SIUs on Schedules?
0
18. Current Number of Categorical Industrial Users (CIUs)?
19. Number of CIUs in SNC?
21
2*
* Machine Specialties (SNC for Cr in 1st 2020) and Shamrock Environmental (NH3N pass through in 1st 2021)
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)
9/5/2018
FA Yes ❑ No
4/16/2019
n Yes ❑ No
3/2022**
Industrial Waste Survey (IWS)
9/30/2019
VA Yes ❑ No
2/12/2020
VA Yes ❑ No
4/1/2024
Sewer Use Ordinance (SUO)
1/30/2020
VA Yes ❑ No
4/27/2020
M Yes ❑ No
Enforcement Response Plan (ERP)
1/22/2020
VA Yes ❑ No
2/12/2020
,II Yes ❑ No
Long Term Monitoring Plan (LTMP)
11/25/2019
VA Yes ❑ No
2/11/2020
VA Yes ❑ No
**Approximation; New HWA due after completion of 16 MGD upgrade.
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.
Guilford County is the major IJA; agreement does not include pretreatment.
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 1/21/2020
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.
ERP is provided and presented to attendees at mandatory Annual IU Meeting
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 2

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 Followinc: S=Satisfactory M=Marcinal U=Unsatisfacto
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
New hybrid position is starting July 1st for laboratory/industrial
waste section. Will provide additional support to both sections.
M S ❑M ❑U
Access to POTW Vehicles for
Sampling, Inspections, and
Emergencies
I S ❑M ❑U
Access to Operable Sampling
Equipment
! S ❑M ❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
Testing is highly valued and supported with generous budget
share. Program has not struggled to keep up, even with SOC.
,II S ❑M ❑U
Reference Materials
MS❑M❑U
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
Present individuals are all grade III pretreatment or higher,
and program sends new staff to schools as needed.
,II S ❑M ❑U
Computer Equipment (Hardware and
Software)
A S ❑ M ❑ U
30. Does the POTW have an adequate data management system to run the pretreatment program?® Yes ❑ No
Explain Yes or No.
System built in-house to work with their unique pretreatment program (see notes on limits vs. allocations at Q51).
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Funded through water and sewer billing, as well as general fund.
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?
Public Information Request Tracking (PIRT) is common since 1,4-dioxane concerns were first reported to the public.
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?
Shamrock Environmental pretreatment system (installed in late 2020 to help address 1,4-dioxane in waste) is proprietary,
so design plans are kept onsite at Shamrock and are therefore not available for public request.
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
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 3

Permitting (Industrial Waste Survey-IWS)
38. How does the POTW become aware of new or changed Users?
IWS, Water Consumption Report (from billing), GSO Economic Development staff, Yellowpages.com, Chamber of
Commerce directory, peer surveillance
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?)
Consider impact of flow or specific waste stream produced by 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?
GSO municipal landfill leachate is discharged to POTW, and six old groundwater remediation projects discharge
to plant. None are SIU according to EPA definition. No new groundwater remediation permits issued since 2000.
Ms. Groome stated that no new remediation projects are considered; only scenario where it might be considered
would be if a spill occurred in the watershed from which the municipality draws its drinking water.
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) Trucks discharging waste to POTW are required to buy tickets at City Hall ahead of time
(sequential, so they can be accounted for), and samples are pulled from every truck before discharging (samples
are run at random).
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 WWTP. Are there any over allocations? ® Yes ❑ No
If yes, what parameters are over allocated? Silver
45. If yes to #44, What is being done to address the over allocations? (short-term IUPs, HWA to be revised, pollutant study, etc.)
Silver over -allocation is due to 0.06 ug/1 WQS. GSO is a member of NC -PC silver work group, which is working
with NCDEQ to create a more reasonable standard.
46. Does the POTW keep pollutant loading in reserve for future growth / safety? ® Yes ❑ No
If yes, what percentage of each parameter 10%
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?
Categorical parameters; NPDES Pollutants of Concern, % MAHL, local allocation numbers
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Categorical requirements, at least EPA minimum of one per six months, (three-day event per six months for surcharged
IUs)
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. NOE(xceedence), NOV(iolation), NOD(eficiency), NSNC
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 4

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.
GSO follows EPA regulation for spill/slug plan (treated as a one-time requirement)
54. What criteria are used to determine if a slug/spill control plan is needed?
Potential to impact POTW performance, collection system; history of spills or accidents.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Review against model plan.
56. How does the POTW decide where the sample point for an SIU should be located?
Best representative sample point, without adding dilution or non -process effluent.
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.
Notation of correct location, SOP for sampler programming, ensuring clean equipment, and swirling collection jug before
pouring.
58. Who performs sample analysis for the POTW for:
• Metals: POTW Lab (except exotic metals and mercury)
• Conventional Parameter: POTW Lab (except O&G)
• Other: Organics, Bioassay, and TN sent to contract labs (Meritech and Pac
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Performed per 40 CFR 403 standard operating procedure.
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.
Plant upgrade completion and increased design flow from 40 to 56 MGD
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.
Summary
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
$120 million upgrade to add BNR and flow increase to 56 MGD to be completed in 2021.
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 5

INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION
66. User Name
1. Shamrock (Pipe 1)
2. Proctor & Gamble
3•Aramark
67. IUP Number
065
031
051
68. Does File Contain Current Permit?
M Yes ❑ No
► Yes ❑ No
1M Yes ❑ No
69. Permit Expiration Date
8/31/2023
8/31/2023
8/31/2023
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
40 CFR 437
40 CFR 439
N/A
71. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
M Yes ❑ No
M Yes ❑ No
1M Yes ❑ No
72. Does File Contain Inspection Completed Within Last Calendar Year?
' Yes ❑ No
M Yes ❑ No
1M 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. EYes ❑No
74. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
Organic Management Plan (TOMP)?
®Yes❑No❑N/A
®Yes❑No❑N/A
❑Yes❑NoON/A
75. a. Does File Contain Original Permit Review Letter from Division?
b. All Issues Resolved?
a. rA Yes •No
b.❑Yes❑NOON/A
a. ®Yes •No
b.❑Yes❑No®N/A
a. ®Yes ❑No
b.❑Yes❑No®N/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
7 Yes ❑ No
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
! Yes ❑ No
M Yes ❑ No
IM 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
❑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❑No®N/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?
®Yes❑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?
FA Yes ❑ No
M Yes ❑ No
❑ Yes ❑ No
82. During Most Recent Semi -Annual Period, Did POTW Identify All
Reporting Non -Compliance from SIU Sampling?
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑NoON/A
83. a. Was POTW Notified by
Monitoring Violations?
b. Did Industry Resample and
c. If applicable, did POTW
becoming aware of SIU limit
SIU (Within 24 Hours) of All Self-
Days?
days of
of SIU?
a.®Yes❑No❑N/A
b.®Yes❑No❑N/A
e ®yes❑No❑N/A
a.❑Yes❑No®N/A
b.❑Yes❑No®N/A
a❑Yes❑No®N/A
a.❑Yes❑No®N/A
b.❑Yes❑No®N/A
c.❑Yes❑No®N/A
submit results to POTW within 30
resample and obtain results within 30
violations in the POTW's sampling
84. During Most Recent Semi -Annual Period, Was SIU m SNC?
❑ Yes ! No
❑ Yes M No
❑ Yes M No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
Specified in POTW's ERP (NOVs, Penalties, timing, etc.)?
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑No®N/A
86. Does File Contain Penalty Assessment Notices?
❑Yes❑No®N/A
❑Yes❑NOON/A
❑Yes❑No®N/A
87. Does File Contain Proof Of Penalty Collection?
❑Yes❑No®N/A
❑Yes❑NOON/A
❑Yes❑NoON/A
88. a. Does File Contain Any Current Enforcement Orders?
b. Is SIU in Compliance with Order?
a.❑Yes❑No®N/A
b.❑Yes❑No®N/A
a.❑Yes❑No®N/A
b.❑Yes❑No®N/A
a.❑Yes❑No®N/A
b.❑Yes❑NOON/A
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
Information For You?
❑ Yes ! No
❑ Yes M No
❑ Yes M No
FILE REVIEW COMMENTS: Exceptionally well -organized files. No portions missing or out-of-date.
NC DWR Pretreatment Audit Form Revised: December 2016
Page 6

INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
INICI0 10 14 17 13 1s 14 1 106124121 1
1. Industry Inspected: Shamrock Environmental
2. Industry Address: 6106 Corporate Park Drive, Browns Sumit, NC 27214
3. Type of Industry/Product: Central Waste Treatment Center
4. Industry Contact: Title: 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
D. Sampling Review ® Yes ❑ No
E. Exit Interview ® Yes ❑ No
Industrial Inspection Comments:
A thorough review of the SIUs documents and data was conducted by Mr. Burdick, followed by an inspection of the pretreatment
process area. Communication between the POTW representatives was clear and demonstrated a spirit of cooperation and mutual
understanding between the two entities. No violations or concerns were uncovered during the IU inspection.
Audit SUMMARY AND COMMENTS:
Audit Comments:
The pretreatment team were thorough in their presentation and helpful in explaining the pretreatment program. All files were
remarkably well organized and up to date. It is clear that Greensboro has an exceptionally well -run program.
Requirements: None
Recommendations: None
NOD: ❑ Yes ® No
NOV: ❑ Yes ® No
QNCR: ❑ Yes ® No
POTW Rating:
Satisfactory
Marginal ❑ Unsatisfactory ❑
Audit COMPLETED BY: Alex Lowe, DWR, WSRO DWR
DATE: 06/24/2021
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 7