NC0021491_PAI Report_20210623

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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: Dutchman Creek WWTP
2. Control Authority Representative(s): Josh Powers/Madelyn Mills/Todd Robinson
3. Title(s): Piedmont Area Manager/Compliance Coordinator/ORC
4. Address of POTW:
Mailing 295 Garwood Rd
City Mocksville Zip Code 27028
Phone Number Fax Number E-Mail
5. Audit Date 06 / 23 / 21
6. Last Inspection Date: 04 / 10 / 19 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. BOD issues through 2019 and 2020
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
1N1C101012111419111
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
06231211
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?
1
0
1*
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?
0
N/A
*yearly inspection missed due to COVID-19 restrictions. Wastewater system inspected in 11/2020 after installation of DAF system.
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)
12/17/2015
VA Yes ❑ No
02/19/2016
VA Yes ❑ No
11/30/2021
Industrial Waste Survey (IWS) **
05/04/2020
❑ Yes ! No
07/28/2020
❑ Yes M No
06/30/2024
Sewer Use Ordinance (SUO)
06/11/2014
V Yes ❑ No
06/11/2014
V Yes ❑ No
Enforcement Response Plan (ERP) **
03/04/2020
❑ Yes YA No
03/17/2020
❑ Yes M No
Long Term Monitoring Plan (LTMP)
08/28/2018
FA Yes ❑ No
12/03/2018
A Yes ❑ No
**Most recent copies of IWS and ERP were missing from file; previous pretreatment coordinator received them electronically. Digital copies were sent to Ms. Mills to print and file on 06/23/2021.
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 07 / 01 / 2014
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. Work closely with/under the town's guidance to ensure ERP is followed
28. List Industries under a Schedule or Order and Type of Schedule or Order
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.)
ri S ❑M ❑U
Computer Equipment (Hardware and
Software)
VA 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.
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Mocksville will assess fines and fees from SIU; EnviroLink doesn't handle the money
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?
Mocksville puts SIU info out to public through the bimonthly billing process
34. Has any industry ever requested that certain information remain confidential from the public? ❑ Yes V 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?
Coordinated with the town; would conduct site visit to confirm SIU is able to continue operating under permit conditions while maintaining confidentiality
35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? ® Yes ❑ No
POTW reviews flows, results from sampling data monthly. Noting out of ordinary results and discuss/review with SIU.
36. Is the public notified about changes in the SUO or Local Limits? ® Yes ❑ No
Published in town website, on billing cycle paperwork, reverse call, etc.
37. Were all industries in SNC published in the last notice? ® Yes ❑ No
PermittingjIndustrial Waste Survey-IWS)
Flow monitored daily, monthly flow considered
38. How does the POTW become aware of new or changed Users? with help of the town, chemical assessments and inventory
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?)
Has not occured in time of PC, but would be concerned with flow and waste concentration; would recontract with municipality reflect new levels of treatment.
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:
By the letter of the permit - if over, NOV would be issued; if loading increased regularly, surcharge would likely be implemented
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 %
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)
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Following Division guidance provided on SIU approved permit
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. Review of data; email the SIU when concern is found; escalation based on ERP
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?
Slug/spill is in place at SIU, and SIU is monitors stoarge tank levels daily for pump and haul timing.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Follows Division guidance on safety and emergency response.
56. How does the POTW decide where the sample point for an SIU should be located?
Effluent is able to be sampled after treatment is complete, and at influent to the 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. TSS and BODffill to eek about
rflowwirl; top off to neck
Record times and operator for CoC
58. Who performs sample analysis for the POTW for Metals Statesville Analytical
Conventional Parameters Statesville Analytical
Organics Statesville Analytical
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Coordinare date, meet with Cody Chambers (Brakebush Tech),pull samples, fill of CoC, both go to Statesville Analytical on ice in separate vehicles.
Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis (HWA)
Expedited schedule for upcoming HWA: April May July October
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 Madelyn Mills
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
Explain.
❑Resolve over allocation 05 year expiration
❑NPDES limits change
❑Other
63. In general, what is the most limiting criteria of your HWA? ❑Inhibition ® Pass Through ❑Sludge Quality
BOD loading from Brakebush can be significant during certain times of production
64. Do you see any way to increase your loading in the future (Example: obtaining more land for sludge disposal)? ❑ Yes ® No
Explain. No concern for that now, as they only have one industry and have plenty of room to grow.
Summary
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
Finalization of permit by Willis Engineering to increase flow from Brakebush; long term goal is for Brakebush to discharge to Cooleemee instead (approx. 1-2 years)
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. Brakebush Brothers, Inc.
2. J
3.
67. IUP Number
0004
68. Does File Contain Current Permit?
► Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
69. Permit Expiration Date
2/1/2022
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
N/A
71. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
FA Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
72. Does File Contain Inspection Completed Within Last Calendar Year?
❑ Yes M Noy
❑ Yes ❑ No
❑ Yes ❑ No
73. a. Does File Contain Slug/Spill Control Plan?
b. If No, is One Needed? (See Inspection Form from POTW)
a. n 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 ❑No❑N/A
❑Yes❑No❑N/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. ri Yes ■ No
b.❑Yes❑No❑N/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
❑ Yes ❑ No
❑ Yes ❑ No
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
M Yes ❑ No
❑ Yes ❑ No
❑ 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?
VA Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
82. During Most Recent Semi -Annual Period, Did POTW Identify All
Reportin Non -Compliance from SIU Sampling?
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/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.❑Yes❑No®N/A
b.❑Yes❑NooN/A
c.❑Yes❑No®N/A
a.❑Yes❑No❑N/A
b.❑Yes ❑No❑N/A
c.❑Yes❑No❑N/A
a.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
c.❑Yes❑No❑N/A
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
❑ Yes M No
❑ Yes ❑ No
❑ Yes ❑ 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❑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?
b. Is SIU in Compliance with Order?
a.❑Yes❑NooN/A
b.❑Yes❑No®N/A
a.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
a.❑Yes :No ❑N/A
b.❑Yes❑No❑N/A
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
Information For You?
❑ Yes VA No
❑ Yes ❑ No
❑ Yes ❑ No
FILE REVIEW COMMENTS:
NC DWR Pretreatment Audit Form Revised: December 2016
Page 5

INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
1N1C10 10 1 2 11 14 19 111 1061231211
1. Industry Inspected: Brakebush
2. Industry Address: 251 Eaton Rd. Mocksville, NC 27028
3. Type of Industry/Product: Chicken Cooking/Procoessing
4. Industry Contact: Title: Phone: Fax: Cody Chambers
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 El No
E. Exit Interview ® Yes ❑ No
Industrial Inspection Comments:
Mr. Powers knows the Brakebush system well, and was thorough in his questioning of Mr. Chambers. Tour started in the wastewater building,
with an overview of the system and checking in on the DAF and the recent data. Discussion of BOD issues occured as he reviewed the items
of concern. We then moved into production building to observe the chemical storage rooms, and assess separation practices between
floor drains and thewastewater system. We were told that there are isolation valves just outside of the production plant, as well as just before
the influent to the wastewater system, so valves can be shut and lift stations can be stopped to prevent pass through in case of a spill.
Audit SUMMARY AND COMMENTS:
The IWS and ERP were out of date. The latest copies were absent from the files, likely because they were never provided after previous ORC received
Audit Comments: electronic copies from the Division.
Digital copies of latest IWS and ERP were provided on 6/23/21. Ensure these are printed and filed with the rest of your pretreatment program elements.
Requirements:
Recommendations: Ensure all pretreatment program elements files include the latest submission, the cover letter for that submission, and the Division approval letter.
NOD: El Yes ® No
NOV: El Yes ® No
QNCR: El Yes ® No
POTW Rating:
Satisfactory
Marginal El Unsatisfactory El
Audit COMPLETED BY: Alex Lowe, DWR, WSRO
XXXX, PERCS, and XXXX, XXXX Regional Office
DATE: 06/23/2021
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 6