NC0021920_Pretreatment Audit_20210922

DocuSign Envelope ID: 3E9A7733-F540-4D7D-859C-73007E4AOD8F
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
September 27, 2021
Mr. Brandon Rich, Pretreatment Coordinator
City of Whiteville
P.O. Box 607
Whiteville, NC 28472
Subject: Pretreatment Audit Report
Program: Whitemarsh WWTP
NPDES Permit No. NCO021920
Columbus County
Dear Mr. Rich:
A Pretreatment Audit Inspection of the City of Whiteville, Whitemarsh Wastewater Treatment
Facility was conducted by Helen Perez from this office on September 22, 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 City of Whiteville 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
helen.perez(a)ncdenr.gov .
Sincerely,
DocuSigned by:
I ONE �Aarrl Oti
7F141E73B6F3456...
Tom Tharrington, Assistant Regional Supervisor
Water Quality Regional Operations Section
Wilmington Regional Office
Division of Water Resources, NCDEQ
Cc: Upload to Laserfiche
DE Q�� North Carolina Department of Environmental Quality I Division of Water Resources
_ Wilmington Regional Office 1 127 Cardinal Drive Extension I Wilmington, North Carolina 28405
NORTH CAROLINA
UePenmeet of EnvimemenUl auei;" /Zo 910.796.7215

DocuSign Envelope ID: 3E9A7733-F540-4D7D-859C-73007E4AOD8F
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: City of Whiteville WWTP
2. Control Authority Representative(s): Brandon Rich
3. Title(s): Pretreatment Coordinator
4. Address of POTW:
Mailing 1000 Nolan Avenue
City Whiteville
Zip Code 28472
Phone Number 910-642-5818 Fax Number 910-642-3094 E-Mail brich(&ci.whiteville.nc.us
5. Audit Date 09/22/2021
6. Last Inspection Date: 08/27/2019 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
N I C I OI OI 2 1 1 19 12 10
MM/DD/YY
109 122 121
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?
..................................................................................................
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?
................................................................................................................................................................................................... .
2
0
0
0
0
0
0
0
0
0
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20. PRETREATMENT PROGRAM ELEMENTS REVIEW- Review POTW files, verify POTW has copy of each Program Element
in their File. comnlete with all suDDortina documents and PERCS ADDroval 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)
08/19/20
® Yes ❑ No
waiting
❑ Yes ❑ No
Industrial Waste Survey (IWS)
04/30/19
® Yes ❑ No
06/05/19
® Yes ❑ No
01/31/2024
Sewer Use Ordinance (SUO)
12/18/13
® Yes ❑ No
002/18/14
® Yes ❑ No
Enforcement Response Plan (ERP)
07/14/20
® Yes ❑ No
09/23/20
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
01/28/2019
® Yes ❑ No
03/05/2019
® 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. Town of Bolton and Lake Wacamaw.
22. If yes to #21, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? ® Ycs ❑ 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 02/18/2014
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.
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
Computer Equipment (Hardware and
Software)
®S ❑M ❑U
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30. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No
Explain Yes or No. Uses Excel spreadsheets.
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Permit fees and enforcements.
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? Through City Hall staff.
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? To be determined.
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? The City's Planning Department reviews building,
water/sewer permits.
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?) Industrial Survey, long form.
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) 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 ❑ 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?
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 No set percentage. POTW is lightly loaded so allocation currently exists for
Yg owth.%
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)
Primarily by NPDES limits.
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49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
There is a set monitoring frequency. If SIU violates limits, frequency can be increased.
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. By meeting IUP limits and frequency.
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?
The SUO requires a slug/spill plan.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Plans are sent to Municipal Unit for review.
56. How does the POTW decide where the sample point for an SIU should be located?
Downstream from the process and right before entering the collection system.
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. SIU sampling procedures are reviewed during
inspections.
58. Who performs sample analysis for the POTW for Metals Environment One
Conventional Parameters POTW
Organics Envirochem
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Contract labs provide COCs and pretreatment staff complete the forms for submittal with the sample. The POTW has
their own COC forms for any samples they analyze.
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.
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. N/A
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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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DocuSign Envelope ID: 3E9A7733-F540-4D7D-859C-73007E4AOD8F
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION)
66. User Name
1. Columbus Regional
2. HERR
3.
Healthcare
67. IUP Number
0001
0006
68. Does File Contain Current Permit?
® Yes ❑ No
® Yes ❑ No
❑ Yes ❑ No
69. Permit Expiration Date
3/15/2026
3/16/2022
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
N/A
437.26
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 ❑ No
® Yes
❑ No
❑ 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
b. []Yes []No
74. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑No❑N/A
1
Organic Management Plan (TOMP)?
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 ❑ No
® Yes ❑ 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
®Yes❑No❑N/A
❑Yes❑No❑N/A
Sampling as Required by IUP, including Flow?
79. During Most Recent Semi -Annual Period, Did SIU submit all reports on
EYes❑No❑N/A
®Yes❑No❑N/A
❑Yes❑No❑N/A
time?
80a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑No❑N/A
file include process/dilution flows as Required by IUP?
80b. For categorical IUs with Production based limits, does file include
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑No❑N/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
ElYes ElNo
Limits Non -Compliance from Both POTW and SIU Sampling?
82. During Most Recent Semi -Annual Period, Did POTW Identify All
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑No❑N/A
Reporting 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
becoming aware of SIU limit violations in the POTW's sampling of SIU?
c.❑Yes❑NoEN/A
c.❑Yes❑No®N/A
c.❑Yes❑No❑N/A
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
I
❑
Yes
®
No
❑
Yes
®
No
❑
Yes
❑
No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑No❑N/A
Specified in POTW's ERP (NOVs, Penalties, timing, etc.)?
86. Does File Contain Penalty Assessment Notices?
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑No❑N/A
87. Does File Contain Proof Of Penalty Collection?
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑No❑N/A
88. a. Does File Contain Any Current Enforcement Orders?
a.❑Yes❑NoEN/A
a.❑Yes❑NoEN/A
a.❑Yes❑No❑N/A
b. Is SIU in Compliance with Order?
b.❑Yes❑NoEN/A
b.❑Yes❑NoEN/A
b.❑Yes❑No❑N/A
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
❑Yes ®No
❑ Yes No ®
❑Yes ❑ No
Information For You?
I IF
FILE REVIEW COMMENTS:
72. The last inspection by the POTW for Columbus Regional Healthcare was on 12/0/2020.
The last inspection by the POTW for HERR was on 10/28/2020.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 6

DocuSign Envelope ID: 3E9A7733-F540-4D7D-859C-73007E4AOD8F
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
I NI C1 0 1 0 12 11 19 12 10 1 091 22 1 21
1. Industry Inspected: HERR (formally Clean Water Solution)
2. Industry Address: 303 South Maultsby Street Whiteville, NC 28472
3. Type of Industry/Product: Hazmat emergency response and remediation
4. Industry Contact: Marc Cox Title: Owner 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:
The operation/storage areas appeared well maintained. Containment was constructed to prevent spills or slugs from entering the
collection system. Sampling procedures and location were reviewed. POTW staff conducted a thorough inspection of the industry.
Audit SUMMARY AND COMMENTS:
Audit Comments: All records/files were available for review. The POTW is waiting on the approval of the HWA submitted
on 8/19/2020. They received an acknowledgement email of the submittal from the Municipal Unit on 8/20/2020. The POTW also
submitted IUP 0006 modification to change the industry name from Clean Water Solution to HERR on 2/19/2021. An
acknowledgement or approval was never received. POTW will contact the Municipal Unit for guidance.
Requirements: None
Recommendations: None
NOD: ❑ Yes ® No
NOV: ❑ Yes ® No
QNCR: ❑ Yes ® No
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory ❑
DocuSigned by:
DocuSigned by:
Audit COMPLETED BY: Helen Perez ' � 'lln�-t-9/27/2021
Toµ �� oti DATE•
1D645B4A39694BE...
Wilmington Regional Office 7F141E73B6F3456...
NC DWR Pretreatment Audit Form Revised: December 2016 Page 7