NC0037508_Pretreatment Program Audit_20211011

ROY COOPER
Governor
DIONNE DELLI-GATTI
Secretary
S. DANIEL SMITH
Director
Connie Flowers
Laboratory Supervisor
Moore County WPCP
1094 Addor Rd.
Aberdeen, NC 28315
NORTH CAROLINA
Environmental Quality
October 11th, 2021
SUBJECT: Pretreatment Program Audit Report
Moore County
NPDES#: NC00357508
Dear Ms. Flowers,
Enclosed please find a copy of the Pretreatment Compliance Inspection (PCI) form from the audit
conducted on September 28nd, 2021. The audit was conducted by Stephanie Zorio, an Environmental
Specialist from the North Carolina Division of Water Resources (DWR) Fayetteville Regional Office.
The findings and comments noted during this inspection are provided in the enclosed copy of the inspection
report entitled " Pretreatment Compliance Inspection".
Issues:
• Please send a copy of the Enforcement Response Plan to all SIUs.
• Erico did not have a TOMP or certification on file. Please ensure that Erico submits a TOMP or complete
testing to negate the need for a TOMP for the next permit cycle.
• The Pretreatment Coordinator currently fills multiple roles, including maintaining the facility's lab. The
Pretreatment Program would be well served by hiring additional staff. In other municipalities such situations
have led to attrition of facility pretreatment staff. As a result, the POTW contractors are hired to maintain the
program. Hiring contractors is often costlier than adequately staffing the WWTP.
Comments:
• The Pretreatment Program files were well -organized and accessible to the inspector. Ms. Flowers was
highly competent and accommodating while answering questions during the inspection and does a
commendable job managing the Pretreatment Program along with her other duties.
• Moore Co. WWTP contracts with Meritech. Low detection limits were consistent with permit and LTMP
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guidelines.
• Southeastern Tool & Die performed testing to certify that toxic organic byproducts were not produced
at the facility. This certification released them from the requirement of a Toxic Organic Management
Plan (TOMP).
• During the inspection at Thermal Metal Treating it was discovered that some COC forms from Pace
were not properly completed. The Division notes that samples must be properly relinquished and
accepted with signature and date.
• The Division notes that the Pretreatment Coordinator has the authority to enforce the ERP, including
the issuance of violations, fines, and the collection thereof.
Thank you for your continued support of the Pretreatment Program. If you should have any questions, please
do not hesitate to contact Stephanie Zorio with the Water Quality Regional Operations Section in the
Fayetteville Regional Office at 910-433-3322 or via email at [e-mail].
ATTACHMENTS
Pretreatment Inspection Report
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Sincerely,
• —DocuSigned by:
• A99704FAED5D494...
Dr. Stephanie Zorio, Environmental Specialist
Water Quality Regional Operations Section
Fayetteville Regional Office
Division of Water Resources, NCDEQ
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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: Moore County Regional WWTP
2. Control Authority Representative(s): Connie Flowers
3. Title(s): Chemist, Pretreatment Coordinator
4. Address of POTW:
Mailing 1094 Addor Rd.
City Aberdeen
Zip Code 28315
Phone Number 910 947 4332 Fax Number 910 281 2047 E-Mail cflowers(a moorecountync.gov
5. Audit Date 9/28/21
6. Last Inspection Date: 2/28/2019 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. BOD limit violations occurred in May and July of 2020. The WWTP's sand filter is in need of
rehabilitation. Sand has been purchases. Filter allowed solids to pass through from weekend cleaning. BOD
violations occur more easily in summer because BOD limits are half the winter limits.
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
INICI0I0I3 17 Is Io 18 1
10. Current Number of Significant Industrial Users (SIUs)?
MM/DD/YY
I 10 I 31 I21I
3
11. Number of SIUs with No IUP, or with an Expired IUP?
0
12. Number of SIUs Not Inspected by POTW in Last Calendar Year?
0
13. Number of SIUs Not Sampled by POTW in Last Calendar Year?
0
14. Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi -Annual Periods?
0
15. Number of SIUs in SNC for Reporting During Either of Last 2 Semi -Annual Periods?
0
16. Number of SIUs in SNC with Pretreatment Schedule?
0
17. Number of SIUs on Schedules?
0
18. Current Number of Categorical Industrial Users (CIUs)?
3
19. Number of CIUs in SNC?
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)
9/17/2019
N Yes ❑ No
12/6/2019
N Yes ❑ No
1/31/2025
Industrial Waste Survey (IWS)
3/30/2018
N Yes ❑ No
9/7/2018
N Yes ❑ No
9/1/2023
Sewer Use Ordinance (SUO)
8/22/2019
N Yes ❑ No
7/24/2019
N Yes ❑ No
Enforcement Response Plan (ERP)
12/3/2019
N Yes ❑ No
2/5/2020
N Yes ❑ No
Long Term Monitoring Plan (LTMP)
8/29/2019
/1 Yes ❑ No
12/16/2019
/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.
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 8/20/2019
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 bad 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
The Pretreatment Coordinator currently fills multiple roles,
POTW's Pretreatment Program
❑S /1M ❑U
including maintaining the facility's lab. The Pretreatment
Program would be well served by hiring additional staff. In
other municipalities such situations have led to attrition of
facility pretreatment staff. As a result, the POTW contractors
are hired to maintain the program. Hiring contractors is most
often more costly than adequately staffing the WWTP.
Access to POTW Vehicles for
Sampling, Inspections, and
Emergencies
CS ❑M ❑U
Access to Operable Sampling
Equipment
GSM ❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
OS ❑M ❑U
Reference Materials
OS ❑M ❑U
NC DWR Pretreatment Audit Form Revised: December 2016
Page 2

Staff Training (i e Annual and
Regional Workshops, Etc.)
OS ❑M ❑U
Computer Equipment (Hardware and
Software)
N S ❑M ❑U
30. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No
Explain Yes or No. Microsoft Suite products (Excel, Word) and OneDrive are used to manage and store data.
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Cost is not recovered directly —there are no surcharges. The SIUs pay for their own sampling and pay for the volume they
discharge to the WWTP.
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? Any information that was public knowledge would be
freely available. Staff would send requested information digitally.
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? Details that involve a process or proprietary substances that would
benefit a competitor could gain an advantage from knowing.
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? Contact by the Planning Dept., Director of Public
Works, word of mouth.
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?) Send the new user an IWS to determine if a permit should be required.
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 (Septic Haulers) ®Dedicated Pipe ❑ NA
42. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples drawn,
manifests required) Designated point. There are plans to construct a new septic receiving station.
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: Local limits based on SUO others are customized by SIU (ex. metal limits and flow limits).
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 —detection limits are extremely low. The POTW has reduced limits
on IUPs.
45. If yes to #44, What is being done to address the over allocations? (short-term IUPs, HWA to be revised, pollutant study, etc.)
The POTW ran a year -long study to measure silver amount in order to decrease limits. Ideally, this would allow
detection of silver by SIUs and relieve over -allocation.
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 3

46. Does the POTW keep pollutant loading in reserve for future growth / safety? ® Yes ❑ No
If yes, what percentage of each parameter -40%
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)
NPDES Pollutants of Concern and LTMP
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
State requirements and historical precedence
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. Compliance and non-compliance is determined through use of the
Division's Compliance Judgement worksheet.
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?
Plans are mandatory for all SIUS by order of the POTW if an SIU has chemical inventory and/or spills of any sort that
could affect the function of the WWTP.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Plans should include a chemical product inventory and control process, current emergency contact list, and training
requirements.
56. How does the POTW decide where the sample point for an SIU should be located?
Must be a representative sample at end of pretreatment train and before effluent could reach surface water or storm drain.
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. Varies by SIU. The same composite sampler is
used by the POTW and the SIUs contract lab at Erico. Southeastern Tool and Die contracts through Meritech who sets up
their own sampler. Thermal Metal Treating contracts through Pace that supplies their own sampler.
58. Who performs sample analysis for the POTW for Metals Meritech
Conventional Parameters POTW
Organics Meritech
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Forms must be legibly completed in full including test type, container size, time/date, and sampler. Samples should be
properly relinquished and received with signature and date.
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 None, reviewed Dec. 2020 and found no discrepancies.
60f. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ® NO
If yes, which ones? Many were eliminated during the last LTMP update.
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 4

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.
Summary
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
No
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. Erico
2. Southeastern Tool &
Die
3. Thermal Metal Treating
67. IUP Number
A005
A010
A008
68. Does File Contain Current
Permit?
Yes ❑ No
N Yes ❑ No
Yes ❑ No
69. Permit Expiration Date
6/30/2023
10/31/2023
6/30/2025
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
433
433
433
71. Does File Contain Permit
Application Completed Within One Year Prior
/1 Yes ❑ No
/1 Yes ❑ No
/1 Yes ❑ No
to Permit Issue Date?
72. Does File Contain Inspection Completed Within Last Calendar Year?
/1 Yes ❑ No
N Yes ❑ No
/1 Yes ❑ No
73. a. Does File Contain Slug/Spill
Control Plan?
Inspection Form from POTW)
a. Yes •No
b. •Yes ■ No
a. Yes •No
b. •Yes •No
a. Yes •No
b. •Yes •No
b. If No, is One Needed? (See
74. For 40 CFR 413 and 433 TTO
Organic Management Plan
Certification, Does File Contain
a Toxic
❑ Yes ONo❑N/A
❑ Yes ONo❑N/A
® Yes ❑No❑N/A
(TOMP)?
75. a. Does File Contain Original
Permit Review Letter from Division?
a. Yes •No
b.❑Yes ❑No0N/A
a. Yes •No
b.❑Yes ❑No®N/A
a. Yes •No
b.❑Yes ❑No®N/A
b. All Issues Resolved?
76. During Most Recent Semi -Annual
Sampling as Required by IUP,
Period, Did POTW Complete
its
/1 Yes ❑ No
N Yes ❑ No
/1 Yes ❑ No
including Flow?
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
/1 Yes ❑ No
/1 Yes ❑ No
/1 Yes ❑ No
78. During Most Recent Semi -Annual
Sampling as Required by IUP,
Period, Did SIU Complete its
® Yes [No ❑N/A
® Yes ❑No❑N/A
® Yes ❑No❑N/A
including Flow?
79. During Most Recent Semi -Annual
time?
Period, Did SIU submit all reports
on
®Yes❑No❑N/A
®Yes❑No❑N/A
®Yes❑No❑N/A
80a. For categorical Ills with Combined Wastestream Formula (CWF), does
file include process/dilution flows as Required by IUP?
❑Yes❑NoON/A
❑Yes❑NoON/A
❑Yes❑No®N/A
80b. For categorical Ills with Production based limits, does file include
production rates and/or flows as Required by IUP?
❑ Yes [No ON/A
❑Yes❑No ON/A
❑Yes❑No ON/A
81. During Most Recent Semi -Annual
Limits Non -Compliance from
Period, Did POTW Identify
All
❑ Yes ❑N°ON/A
® Yes ❑No❑N/A
❑ Yes ❑No ON/A
Both POTW and SIU Sampling?
82. During Most Recent Semi -Annual
Reporting Non -Compliance
Period, Did POTW Identify
All
❑ Yes [No ON/A
❑Yes❑No ON/A
❑ Yes ❑No®N/A
from SIU Sampling?
83. a. Was POTW Notified by
Monitoring Violations?
b. Did Industry Resample and
SIU (Within 24 Hours) of All Self-
submit results to POTW within 30 Days?
resample and obtain results within 30 days of
violations in the POTW's sampling of SIU?
a.❑Yes ❑No®N/A
b.❑Yes ❑No®N/A
o.❑Yes ❑No®NSA
a.❑Yes ❑No0N/A
b.❑Yes ❑No®N/A
e.❑Yes ❑No®NSA
a.❑Yes ❑No®N/A
b.❑Yes ❑No®N/A
e.❑Yes ❑No®N A
c. If applicable, did POTW
becoming aware of SIU limit
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
❑ Yes /1 No
❑ Yes N No
❑ Yes /1 No
85. During Most Recent Semi -Annual
Specified in POTW's ERP
Period, Was Enforcement Taken
as
0Yes❑No0N/A
®Yes❑No❑N/A
®Yes❑No❑N/A
(NOVs, Penalties, timing, etc.)?
86. Does File Contain Penalty Assessment Notices?
❑Yes❑No®N/A
0Yes❑No0N/A
®Yes❑No❑N/A
87. Does File Contain Proof Of Penalty Collection?
0Yes❑No0N/A
❑Yes❑No®N/A
0Yes❑No0N/A
88. a. Does File Contain Any
Current Enforcement Orders?
Order?
a.❑Yes ❑No0N/A
b.❑Yes ❑No®N/A
a.❑Yes ❑No0N/A
b.❑Yes ❑No0N/A
a.❑Yes ❑No0N/A
b.❑Yes ❑No0N/A
b. Is SIU in Compliance with
89. Did POTW Representative
Information For You?
Have Difficulty in Obtaining Any
Requested
❑ Yes 11 No
❑ Yes 11 No
❑ Yes 11 No
FILE REVIEW COMMENTS:
Southeastern Tool & Die received an NOV for late permit application.
Southeastern Tool & Die performed testing to certify that toxic organic byproducts were not produced at the facility. This certification released
them from the requirement of a Toxic Organic Management Plan (TOMP).
Thermal Metal Treating does have a TOMP on file.
Erico did not have a TOMP or certification on file. Please ensure that Erico submits a TOMP or complete testing to negate the need for a TOMP
for the next permit cycle.
NC DWR Pretreatment Audit Form Revised: December 2016
Page 6

INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
INICIO Io 13 17 15 Io Ix I 19 1231211
1. Industry Inspected: Thermal Metal Treating
2. Industry Address: PO Box 367, 9546 NC HWY 211, Aberdeen NC 28315
3. Type of Industry/Product: Metal Finishing
4. Industry Contact: Greg Ritter Title: President 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:
• Justin Huber is the new Process Control Operator who will be in charge of pretreatment for the facility. He will replace
Larry Anderson as Pretreatment Supervisor.
• The SIU no longer performs nickel plating. Otherwise, all processes remain the same.
• Several chemical tanks need replacement signage.
• The entire building has built-in secondary containment.
• The SIU is in the process of setting up a filter press. Currently a flocculent tank is used. Testing is required to determine
remnant amount of toxic substances in the sludge cake produced by the filter press.
• The SIU did not have a copy of the Enforcement Response Plan (ERP). Please send a digital copy to Thermal Metal.
• The SIU contracts with Greenway for spill response.
• Some COC forms from Pace were not properly completed. The Division notes that samples must be properly relinquished
and accepted with signature and date.
Audit SUMMARY AND COMMENTS:
Audit Comments:
• The Pretreatment Program files were well -organized and accessible to the inspector. Ms. Flowers was highly competent and
accommodating while answering questions during the inspection and does a commendable job managing the Pretreatment
Program along with her other duties.
• Moore Co. WWTP contracts with Meritech. Low detection limits were consistent with permit and LTMP guidelines.
• Southeastern Tool & Die performed testing to certify that toxic organic byproducts were not produced at the facility. This
certification released them from the requirement of a Toxic Organic Management Plan (TOMP).
• During the inspection at Thermal Metal Treating it was discovered that some COC forms from Pace were not properly
completed. The Division notes that samples must be properly relinquished and accepted with signature and date.
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 7

• The Division notes that the Pretreatment Coordinator has the authority to enforce the ERP, including the issuance of violations,
fines, and the collection thereof.
Requirements:
• Please send a copy of the Enforcement Response Plan to all SIUs.
• Erico did not have a TOMP or certification on file. Please ensure that Erico submits a TOMP or complete testing to negate the
need for a TOMP for the next permit cycle.
Recommendations:
• The Pretreatment Coordinator currently fills multiple roles, including maintaining the facility's lab. The Pretreatment Program
would be well served by hiring additional staff. In other municipalities such situations have led to attrition of facility pretreatment
staff. As a result, the POTW contractors are hired to maintain the program. Hiring contractors is often costlier than adequately
staffing the WWTP.
NOD: ❑ Yes ® No
NOV: ❑ Yes ® No
QNCR: ❑ Yes ® No
POTW Rating:
Satisfactory
Marginal ❑ Unsatisfactory ❑
Audit COMPLETED BY: Stephanie Zorio DATE: 9/28/2021
Fayetteville Regional Office
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 8