NC0024210_Compliance Evaluation Inspection_20210819

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT AUDIT REPORT
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Background Information [Complete prior to audit; review Program Info Database Sheet(s)]
1. Control Authority (POTW) Name: City of High Point
2. Control Authority Representative(s): Carrie Hyler, Alannah Russell
3. Title(s): Pretreatment Supervisor, Lab Analyst II
4. Address of POTW:
Mailing PO Box 230
City High Point Zip Code 27261
Phone Number 336-883-3090 Fax Number 336-883-3109 E-Mail carrie.hylerAhighpointnc.gov
Time in: 9:00 AM Time out:12:30 PM
5. Audit Date 08/19/2021
6. Last Inspection Date: 08/13/2020 Inspection Type: ® PCI ❑ Audit
7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s) ? ❑ Yes Z No
If No, Explain. No requirements indicated
8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? ® Yes ❑ No
If Yes, Explain. Eastside: Frequency Violation: Failed to collect EFF 1,4-dioxane sample (12/2020)
Illegal discharge/accidental release 1,330 gal 6% NaC1O into polishing filters (04/2021)
Westside : None
9. Is POTW under an Order That Includes Pretreatment Conditions? ❑ Yes Z No
Order Type and Number: Are Milestone Dates Being Met? ❑ Yes ❑ No ® NA
Parameters Covered Under Order
ICIS Coding
Main Program Permit Number
INICI0I0I2 14 12 11 10 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
08 19 21 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?
22
0
0
0
1
0
0
17. Number of SIUs on Schedules?
0
18. Current Number of Categorical Industrial Users (CIUs)?
19. Number of CIUs in SNC?
13
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) (ES) '
5/26/2017
0 Yes ❑ No
08/10/2017
1/ Yes ❑ No
5/31/2022
7/19/2021
0 Yes ❑ No
4/7/2020
1/ Yes ❑ No
12/31/2024
Headworks Analysis (HWA) (WS)
Industrial Waste Survey (IWS)
1/28/2020
/1 Yes ❑ No
04/22/2020
1/ Yes ❑ No
1/31/2025
Sewer Use Ordinance (SUO)
1/29/2020
' Yes ❑ No
5/5/2020**
1/ Yes ❑ No
Enforcement Response Plan (ERP)
1/29/2020
0 Yes ❑ No
2/14/2020
1/ Yes ❑ No
Long Term Monitoring Plan (LTMP)
5/29/2020
0 Yes ❑ No
8/25/2020
1/ Yes ❑ No
**Submission acknowledgement from M. Hassan, and letter from City engineer approving SUO
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. City of Archdale, Town of Jamestown and Sedgefield Sanitary Dist.
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 05/18/2020
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.
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 Followinc: S=Satisfactory M=Mareinal U=Unsatisfacto
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
(1) supervisor and (1) lab analyst assigned to Pretreatment but analyst
also works in laboratory
CS ❑M ❑U
Access to POTW Vehicles for
Sampling, Inspections, and
Emergencies
(1) truck dedicated primarily to Pretreatment; (1) SUV and (1) van
also available.
L S ❑M ❑U
Access to Operable Sampling
Equipment
(2) portable samplers capable of discreet and composite sampling, flow
metering module, (2) portable refrigerated samplers that run on power
or battery
11 S ❑ M ❑ U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
Pretreatment is funded as part of laboratory services budget; money
allocated as needed for equipment
/1 S ❑ M ❑U
Reference Materials
Purchase as needed
/1S ❑M ❑U
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
Training is encouraged. Participates in NC -PC annual conference, 10-
hr OSHA training and certification. Most analysts certified Grade 1
Pretreatment Specialist
0 S ❑M ❑U
Computer Equipment (Hardware and
Software)
Access to computers. Captains software only accessible by Supv. but
will be added to newly acquired computer for Pretreatment Analyst.
CS ❑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. Data is maintained in Captains database. Same program used since 1997, latest update 2016.
Spreadsheets also used for lab staff to enter LTMP and industrial data requested by Pretreatment. Industrial data then
input into database.
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Pretreatment is included in the lab services budget. Industries are billed for monitoring and analyses fees and permit fees.
City has a surcharge program for BOD & TSS.
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 anyone from the public ever requested to review pretreatment program files? ❑ Yes ® No
If yes, Explain procedure. If no, how would the request be addressed? The policy is the request would have to be made through
the City's FOIA. All records are public except documents considered confidential, which are stored in separate file
location.
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? Products manufactured and specific manufacturing processes and
maps of facilities have been requested to be kept confidential. Confidential items are locked in pretreatment supervisor's
office, in locking drawer.
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 Presumed yes since any updates to SUO are a
City Council Agenda item and included in meeting minutes; however, any formal public notifications are handled through
Communications and Public Engagement Department.
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? Drive -by, social media, news, and City's plan review
meetings. The manufacturer's index is used when the IWS submittal is required. Monitor water high water usage
locations.
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?) For new users, investigate business through internet, send industrial waste survey form or long form (permit
application) and inspect facility if further clarification is needed. For changed users, ask about the changes, if
actual manufacturing changes or name change. Issue a permit or update the existing permit as needed.
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
®Yes No If Yes, how many are there? 3 permitted (2-ground remediation, 1-landfill), only 2 operating (1 ea
type).
Please list each site and how it is permitted, if applicable. Kersey Valley Landfill is connected to Eastside via pump
station and is permitted as SIU for potential to impact POTW. (2) local permitted ground remediation locations,
one is not online yet. The one that is online, Speedway #6954 runs rotating 3-month cycle per agreement with State.
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) Septage haulers & chemical toilet trucks only. They are issued dump tickets that are paid for in
advance sold as 1 ticket per 1000-gallon or 1 ticket per 3000-gallon tank volume(s) or fraction thereof. They
discharge waste at the designated intake at the head of the plant. Samples are collected by operators and retained,
and random septage hauler sample collected during LTMP and analyzed for COD, TSS and NH3.
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: based on allocation available.
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 3

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? WS over allocated for silver in updated HWA submitted in July, unless
approved to utilize zero for uncontrollable. No other way to reduce, loadings based on % detection for 98% of
samples.
45. If yes to #44, What is being done to address the over allocations? (short-term IUPs, HWA to be revised, pollutant study, etc.)
Requested to use "0" for uncontrollable due to non -detect at required PQL, which alleviates perceived over -
allocation. All effluent discharges BDL at lowest PQL and no silver monitoring required in new permit, therefore
no reasonable potential. Pretreatment supervisor is part of Silver Committee working with NCDEQ because the
over allocation issue caused by chronic silver standard has created same problem for nearly all pretreatment
programs in NC.
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? (for example: were only those pollutants
listed on the application limited; categorical parameters; NPDES Pollutants of Concern)
If categorical, monitored for parameters required by regulation. For others, based on pollutants that may be present or
similar industries. For new industries we analyze for all POCs and determine if any may violate local limits or cause
POTW to violate NPDES limits and limit or monitor in permit. For industrial laundry, the customers serviced (ie: battery
manufacturer) are also factored into the parameters monitored.
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
For surcharged industries (high BOD and/or TSS) monitored monthly otherwise based on EPA minimum requirement
unless enforcement issues or other reason to monitor more frequently.
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? Handcraft initially requested an "adjudication"
but later called it a meeting to discuss pH and sampler requirements. Switched pH monitoring to every sample based on
recorded data and removed sampler requirement; instead, they have to contract with lab for sampling if monthly sampling
is ever required.
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. SIUs notify POTW about non-compliance and record on self -
monitoring report form, if applicable, date, time and by what means (email or tele). When data is entered into database,
daily violations will highlight in red. A report is printed to check monthly averages, if applicable. At the end of each 6-
month period, a summary report is printed for IDSF and at that time SNC is calculated; however, if SIU has repeated
violations and at risk for SNC, will continuously calculate to determine how many samples are needed to "sample out of
SNC" and POTW always keeps SIU representative informed.
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. All industries have been evaluated and have plans if it's been determined they need them. EPA only requires
SIUs to be evaluated once but if there are operational changes, will re-evaluate. For new SIUs, the evaluation is performed
during initial inspection.
54. What criteria are used to determine if a slug/spill control plan is needed?
Assess materials used or stored in a way that creates the potential for spill or slug to the sanitary sewer. Materials that
could cause issues with the collection system, wastewater treatment plant or harm to POTW personnel.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
The plan is adequate if it contains minimum elements such as discharge practices, description of stored chemicals,
procedure for notifying POTW of slug discharge, inspection and storage practices that prevent accident spills and list
personnel with responsibility for notifications and/or ensuring procedures are followed.
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 4

56. How does the POTW decide where the sample point for an SIU should be located?
The sample location should be the site that is most representative of all process wastewater, after all processes and is well -
mixed but not have sanitary wastewater co -mingling.
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. Location that POTW and SIU collect sample(s) is
indicated in permit. Sample containers for SIU sampling are cleaned after use and new tubing is used if POTW samplers
are used. Swirling or rolling sample jug to mix thoroughly is in the Industrial Sampling operating guideline.
58. Who performs sample analysis for the POTW for Metals Contract & City lab
Conventional Parameters Contract & City lab
Organics Contract lab
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
In house: Sample locations or sampling points are entered along with sample start and end dates and times, whether grab
or composite, number of bottles, if bottle is plastic or glass, preservative(s) and analyses requested. If field chlorine or
sulfates are checked in the field, it is documented on the CoC. IPP personnel record person(s) who sampled who is also the
one that is to relinquish samples to lab staff. Once signed, CoC is returned to pretreatment supervisor and filed. Same
procedure is followed for contract lab except different CoC form and normally CoC is not signed in by lab personnel, the
sample is put directly into lab walk-in fridge and kept secure until contract lab arrives to pick up sample(s). They are
relinquished at that time and if contract lab CoC is in duplicate or triplicate, a copy of the CoC is left with lab personnel to
forward to IPP for file(s). Otherwise, the CoC is copied and filed with IPP file(s).
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 ®5-year expiration ®Other
Explain. If Eastside receives new permit, technical evaluation is required to determine any local limit changes.
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. Expansion is the only option at this time. Westside recently completed their upgrade and discussions taking place
regarding possible Eastside expansion.
Summar
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
None that I am aware of.
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. Slane Hosiery
2. Thomas Built Buses
3. Handcraft Linen Services
67. IUP Number
0043
0047
0166
68. Does File Contain Current Permit?
I Yes ❑ No
Yes ❑ No
I Yes ❑ No
69. Permit Expiration Date
6/30/2026
6/30/2026
4/1/2025
70. Categorical Standard Applied
N/A
433.17
N/A
(I.E. 40 CFR, Etc.) Or N/A
71. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
I Yes ❑ No
3/2/2021
1/ Yes ❑ No
12/11/2020
'I Yes ❑ No
12/20/2019
72. Does File Contain Inspection Completed Within Last Calendar Year?
1/ Yes ❑ No
12/17/2020
1/ Yes ❑ No
12/15/2020
0 Yes ❑ No
11 / 11/2020
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❑No®N/A
®Yes❑No❑N/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
3/9/2021
1 Yes ❑ No
'I Yes ❑ No
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
1 Yes ❑ No
1/ Yes ❑ No
'I 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?
// Yes ❑ No
/1 Yes ❑ No
/1 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❑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❑No®N/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 m SNC?
❑ Yes A No
❑ Yes No
/1 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❑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 0 No
❑ Yes A No
❑ Yes 0 No
FILE REVIEW COMMENTS: All program element documents were filed and in good order. Search in Laserfiche suggests no
DWR approval letter was issued for latest SUO updates, so documentation is sufficient (see note on #20). Ms. Hyler does an
excellent job documenting and reporting for the pretreatment program.
NC DWR Pretreatment Audit Form Revised: December 2016
Page 6

INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number
IN1c101012141211101
MM/DD/YY
081921
1. Industry Inspected: Cintas
2. Industry Address: 4345 Federal Drive, Greensboro NC 27410
3. Type of Industry/Product: Industrial Laundry
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: Sampling and sampling review conducted by Ms. Russell, per standard procedure.
Ms. Hyler conducted a well-rounded inspection of pretreatment operations.
Audit SUMMARY AND COMMENTS:
Audit Comments: Ms. Hyler and her team presented a well -run program, and demonstrated in-depth knowledge of each of
their SIUs. No program shortcomings were observed in auditor's file review or POTW's industrial inspection.
Requirements: None
Recommendations: None
NOD: ❑ Yes ® No
NOV: ❑ Yes Z No
QNCR: ❑ Yes Z No
POTW Rating:
Satisfactory
Marginal ❑ Unsatisfactory ❑
Audit COMPLETED BY: Alex Lowe, Winston-Salem Regional Office DATE: 08/19/2021
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 7