NC0021873_Pretreatment Audit Report_20210720

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: Mayodan
2. Control Authority Representative(s): Nadine Blackwell, Jamie Whitten
3. Title(s): Pretreatment Coordinator, ORC
4. Address of POTW:
Mailing: 293 Caldwell Rd
City: Mayodan
Zip Code: 27027
E-Mail nadine.blackwellAsuez.com
5. Audit Date: 07/20/2021
6. Last Inspection Date: 08/18/2020 Inspection Type: ® PCI ❑ Audit
7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? Z Yes ❑ No
Previous failure to leverage enforcement within proper timeframe; industries failed to send reports in a timely
manner, so NOVs were issued for failure to report. When report was eventually received, data showed non-
compliance, but period of enforcement had elapsed.
Previous failure to measure flow during semi-annual sampling; changed SOP so backup ORC takes flow at beginning and
end of 24-hour sampling events.
8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? ® Yes ❑ No
If Yes, Explain.
See above deficiencies (details noted in NOD-2020-PC-0435).
9. Is POTW under an Order That Includes Pretreatment Conditions? ❑ Yes ® No
Order Type and Number: N/A Are Milestone Dates Being Met? ❑ Yes ❑ No ® NA
Parameters Covered Under Order: N/A
ICIS Coding
Main Program Permit Number
INICIOIOI 2 I 1 1 8 17 1 3 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
107120121 I
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?
17. Number of SIUs on Schedules?
18. Current Number of Categorical Industrial Users (CIUs)?
19. Number of CIUs in SNC?
3
0
0
0
0
0
0
0
1
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)
9/25/2015
0 Yes ❑ No
12/17/2015
1/ Yes ❑ No
09/30/2025
Industrial Waste Survey (IWS)
9/28/2018
0 Yes ❑ No
01/08/2019
1/ Yes ❑ No
10/01/2023
Sewer Use Ordinance (SUO)
12/4/2012
1/ Yes ❑ No
12/14/2012
1/ Yes ❑ No
Enforcement Response Plan (ERP)
12/20/2012
1 Yes ❑ No
12/27/2012
1/ Yes ❑ No
Long Term Monitoring Plan (LTMP)
3/22/2017
0 Yes ❑ No
06/14/2017
1/ 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.
Stoneville, Madison
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 / /
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 Followinc: S=Satisfactory M=Mareinal U=Unsatisfacto
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
S ❑M ❑U
Access to POTW Vehicles for
Sampling, Inspections, and
Emergencies
S ❑M ❑U
Access to Operable Sampling
Equipment
S ❑M ❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
Al S ❑ M ❑ U
Reference Materials
OS ❑M ❑U
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
OS ❑M ❑ U
NC DWR Pretreatment Audit Form Revised: December 2016
Page 2

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 and Hach Wim are used to manage data for LTMP and DMR effluent data.
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Town bills back the cost to the industries and handles allocation of funds attained through fines or 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?
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?
Proprietary information could be kept confidential, but no industry has requested confidentiality.
35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? ® Yes ❑ No
Checking in while POTW representative is on site for sampling events, and in response to concerns.
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?
Industrial Waste Survey, Town manager will communicate with incoming businesses, other communities
(Stoneville and Madison) are instructed to do the same.
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?)
Discharge sampling would be conducted and compared to HWA; if SIU is determined, need based limits would be
permitted.
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
▪ Yes No
41. Does the POTW accept waste by (mark if applicable) ❑ Truck ®Dedicated Pipe ❑ NA
Dedicated pipe from Ruger
42. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples drawn,
manifests required) N/A
43. How does the POTW allocate its loading to industries? Mark all that apply
❑ Uniform Limits ® Historical Industry Need ❑ By Surcharge ❑ Categorical Limits 111 Other
Explain Other:
44. Review POTW's copies of current allocation tables for each WWTP. Are there any over allocations? ® Yes ❑ No
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 3

If yes, what parameters are over allocated? Mercury
45. If yes to #44, What is being done to address the over allocations? (short-term IUPs, HWA to be revised, pollutant study, etc.)
Mercury is entering the waste stream on the grounds of the WWTP; working with the state to find the source
46. Does the POTW keep pollutant loading in reserve for future growth / safety? ® Yes ❑ No
If yes, what percentage of each parameter
10% on average — some parameters are reserved in higher percentage, some in slightly lower.
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)
Based on what is reported by the industry, and using the MAHL to determine need for the limit
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Build a baseline of sampling with monthly or quarterly sampling, then back down frequency to six-month sampling where
consistency of waste stream is present.
Permit Compliance
50. Does the POTW currently have or during the past year had any permits under adjudication? ❑ Yes ® No
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.
Permit limits and conditions of the permit. NOV is issued as soon as POTW is aware of limit violation or permit violation.
SNC is placed in terms of standard TRC percentages, and for chronic violations.
52. Does the POTW use the Division's model inspection form or equivalent? ® 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.
All SIUs have an up to date spill/slug plan. The primary concern of the POTW is making sure the current employees and
managers are trained in response, and that contact information for all SIU and POTW parties is current.
54. What criteria are used to determine if a slug/spill control plan is needed?
N/A
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Contact information is up to date, consistent training is emphasized, chemical containment standards are met.
56. How does the POTW decide where the sample point for an SIU should be located?
After all pretreatment and before mixing with collections system water (two SIUs have just one sample point, except for
Ruger, which has sample points on both process water pipe and pipe for other facility 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
58. Who performs sample analysis for the POTW for Metals Environment-1
Conventional Parameters Environment-1
Organics Environment-1
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59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Sample is collected by backup ORC at the SIU site. Environment-1 courier pickup occurs at WWTP and provides
transportation to Greenville for testing.
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
Quarterly, same month as toxicity testing
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
Hach Wims and Excel
60d. All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? ® YES ❑ NO Division Inspector, verify yourself!
60f. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ® NO
61. Do you complete your own headworks analysis (HWA) ? ® Yes ❑ No
62. Do you have plans to revise your HWA in the near future? ❑ Yes ® No
Explain. HWA was submitted in September of 2020, and review/approval by the Division is awaited.
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. Increased flow — have several million gallons of growing room, except for I&I
Summary
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
No
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Revised: December 2016 Page 5

INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION
66. User Name
1. Unifi Manufacturing, Inc.
2. Sans Technical Fibers
3. Strum, Ruger & Company
67. IUP Number
0105
0108
0109
68. Does File Contain Current Permit?
1/ Yes ❑ No
// Yes ❑ No
'I Yes ❑ No
69. Permit Expiration Date
06/30/2026
06/30/2026
06/30/2026
70. Categorical Standard Applied
N/A
N/A
(I.E. 40 CFR, Etc.) Or N/A
40 CFR 433
71. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
r Yes ❑ No
0 Yes ❑ No
'I Yes ❑ No
72. Does File Contain Inspection Completed Within Last Calendar Year?
1/ Yes ❑ No
I Yes ❑ No
'I Yes ❑ No
73. a. Does File Contain Slug/Spill Control Plan?
b. If No, is One Needed? (See Inspection Form from POTW)
a. 1 Yes ■ No
b. •Yes ■ No
a. 1 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❑NoEN/A
❑Yes❑NoEN/A
®Yes❑No❑N/A
75. a. Does File Contain Original Permit Review Letter from Division?
b. All Issues Resolved?
a. 1 Yes ■ No
b.❑Yes❑No❑N/A
a. 1 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?
1 Yes ❑ No
1 Yes ❑ No
'I Yes ❑ No
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
1 Yes ❑ No
1/ 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❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑No®N/A
80b. For categorical IUs with Production
production rates and/or flows
based limits, does file include
❑Yes❑NoEN/A
❑Yes❑NoEN/A
®Yes❑No❑N/A
as Required by IUP?
81. During Most Recent Semi -Annual Period, Did POTW Identify All
Limits Non -Compliance from Both POTW and SIU Sampling?
A Yes ❑ No
A Yes ❑ No
/1 Yes ❑ No
82. During Most Recent Semi -Annual Period, Did POTW Identify All
Reporting Non -Compliance from SIU Sampling?
❑Yes❑NoEN/A
❑Yes❑No®N/A
❑Yes❑No®N/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 ofc.
of SIU?
a.❑Yes❑No®N/A
b.❑Yes❑No®N/A
❑yes❑No®N/A
a.®Yes❑No❑N/A
b.NYes❑No❑N/A
c.®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 I No
❑ Yes /1 No
❑ Yes A No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
Specified in POTW's ERP (NOVs, Penalties, timing, etc.)?
EYes❑No❑N/A
❑Yes❑NoEN/A
❑Yes❑NoEN/A
86. Does File Contain Penalty Assessment Notices?
❑Yes❑NoEN/A
❑Yes❑NoEN/A
EYes❑No❑N/A
87. Does File Contain Proof Of Penalty Collection?
❑Yes❑NoEN/A
❑Yes❑NoEN/A
EYes❑No❑N/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❑No®N/A
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
Information For You?
❑ Yes // No
❑ Yes A No
❑ Yes 0 No
FILE REVIEW COMMENTS:
All files were up-to-date, well organized, and contained all necessary documentation.
NC DWR Pretreatment Audit Form Revised: December 2016
Page 6

INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
I N I C I O 1 0 1 2 11 1 8 1 7 1. 1 1 07 1 20 1 21
1. Industry Inspected: Sans Technical Fibers
2. Industry Address: 4721 NC Highway 770, Stoneville NC 27048
3. Type of Industry/Product: Textile Materials
4. Industry Contact: Cory T. Bowman Title: Operations Manager Phone: [phone]
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:
Ms. Blackwell and Mr. Whitten were extremely knowledgeable about the permit requirements, and thoroughly reviewed the
elements of the SIU permit with Mr. Bowman. The plant tour was a start -to -end process review and illuminated the need for
containment pallets/spill dikes to be installed to prevent chiller chemicals from reaching drain in case of spill or puncture.
Audit SUMMARY AND COMMENTS:
Audit Comments: The Mayodan program appears well -run and free from permit violations or non-compliance. Documents were
all present and well -organized, and SIU inspection was productive and thorough.
Requirements: None
Recommendations: None
NOD: ❑ Yes ❑ No
NOV: ❑ Yes ® No
QNCR: ❑ Yes ® No
POTW Rating:
Satisfactory
Marginal ❑ Unsatisfactory ❑
Audit COMPLETED BY: Alex Lowe, DWR Winston-Salem Regional Office DATE: 07/20/2021
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 7