NC0026441_NOV-2021-PC-0561_20211115

DocuSign Envelope ID: 09531725-2C49-407B-9122-BC88B37292F5
ROY COOPER.
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
Certified Mail # 7017 2680 0000 2237 4731
Return Receipt Requested
November 15, 2021
Roy Lynch, Town Manager
Town of Siler City
PO Box 769
Siler City, NC 27344
Subject: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY
Case No. NOV-2021-PC-0561
Pretreatment Audit
Town of Siler City
Siler City WWTP - NPDES Permit No. NCO026441
Chatham County
Dear Mr. Lynch:
On September 29, 2021, Cheng Zhang of the Raleigh Regional Office (RRO) conducted an
audit of City of Durham's pretreatment program. The assistance given by Mr. Chris
McCorquodale, the Director of Public Works & Utilities, and Brittany York, the Wastewater
Superintendent, was greatly appreciated. The audit report is attached. Findings during the
inspection were as follows:
1. The city has two Significant Industrial Users (SIUs), neither is Categorical Industrial
Users (CIUs). The Division does not deem Mountaire Farms a CIU, even though
it is classified as 40 CFR 432 (documented on its Industrial User Pretreatment
Permits (IUP)), because of the lack of categorical discharge standards. It was
noted that neither SIU was in SNC for the most recent two semi-annual periods.
2. A review of the files containing the pretreatment program elements was conducted.
All elements are up to date. Update of Headworks Analysis is in review by the
Division.
NOR�D_E
�aearbnenl al Environmental 9uallly
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office 13800 Barrett Drive I Raleigh, North Carolina 27609
919.791.4200

DocuSign Envelope ID: 09531725-2C49-407B-9122-BC88B37292F5
3. Long Term Monitoring Plan (LTMP) data were reviewed during the inspection. It
was noted that all locations were sampled with required frequencies and all samples
analyzed with required detection levels since the last inspection.
4. During the audit, Mr. McCorquodale and Ms. York inspected one of the SIUs,
Mountaire Farms. The inspection was very thorough. It was evident that Mr.
McCorquodale and Ms. York had good relationship with the industry
representatives and knowledge of the SIU's pretreatment operation.
5. The pretreatment inspection file review included Mountaire Farms (Permit No. 004)
and Brookwood Farms (Permit No. 003). During the most recent semi-annual
period, the POTW and the two SIUs reviewed completed monitoring as required by
the Industrial User Pretreatment Permits (IUPs). Brookwood Farms had one BOD
(in March 2021) and one TSS violation (in April 2021). Mountaire Farms two BOD
violations (one in May, one in June 2021). At the time of the audit, the POTW only
issued one Notice of Violation (NOV) to Brookwood Farms for its BOD violation in
March 2021. As a result, Town of Siler City was found to have violated Section D,
9 of its NPDES permit for failure to enforce for limit violations from the SIUs
within the timeframe specified in the Enforcement Response Plan approved
by the Division.
The POTW noted high concentration of ammonia and BOD from Mountaire Farms'
effluent in July and August 2021, which caused "pass through" of the POTW and the
POTW's NPDES permit limit violations in July, August, and September 2021. As
promulgated in 15A NCAC 02H .0903 (34) (C), "Any other violation of a
pretreatment standard or requirement as defined by 40 CFR Part 403.3(1)
(daily maximum, long-term average, instantaneous limit, or narrative
standard) that the control authority (or POTW, if different from the control
authority), determines has caused, alone or in combination with other
discharges, interference or pass through (including endangering the health of
POTW personnel or the general public)", any industrial user which meets this
criterion shall be in Significant Noncompliance (SNC). At the time of audit, the
POTW failed to determine Mountaire Farms was in SNC for causing POTW pass
through and NPDES permit limit violations, and enforce for Mountaire Farms'
significant non-compliance, which also violated Section D, 9 of its NPDES permit.
A Notice of Violation/Intent to Issue Civil Penalty is being issued for the noted violation of
North Carolina General Statute (G.S.) 143-215.1 and the facility's NPDES WW Permit.
Pursuant to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand dollars
($25,000.00) may be assessed against any person who violates or fails to act in accordance
with the terms, conditions, or requirements of any permit issued pursuant to G.S. 43-215.1.
1:11
Nra-n rnan. iw>
Oopammenl al Enrironmenui 9uali
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office r 3800 Barrett Drive I Raleigh, North Carolina 27609
919.791.4200

DocuSign Envelope ID: 09531725-2C49-407B-9122-BC88B37292F5
Please respond in writing to RRO within 30 days of receipt of this letter regarding
Item 5. If you have any questions or comments, please call Cheng Zhang at [phone]
(or email: [e-mail]).
Sincerely,
�DocuSigned by:
Sit �U,
�BCDA9D825D4A46D...
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources
Enclosure: Town of Siler City Pretreatment Audit Form
CC: Central Files w/attachment (Laserfiche)
Cheng Zhang, RRO
Chris McCorquodale, Town of Siler City (Electronic copy only)
D p rm,em of e��i�,me�u�o�.rm\ �"
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office r 3800 Barrett Drive I Raleigh, North Carolina 27609
919,791.4200

DocuSign Envelope ID: 09531725-2C49-407B-9122-BC88B37292F5
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: Town of Siler City
2. Control Authority Representative(s): Chris McCorauodale, Brittany York
3. Title(s): Director of Public Works & Utilities; Wastewater Superintendent
4. Address of POTW:
Mailing PO Box 769
City Siler City
Zip Code 27344
Phone Number 919-742-4732 Fax Number 919-663-3874 E-Mail cmccorquodale(a,silercitv.org
5. Audit Date 09/29/2021
6. Last Inspection Date: 08/24/2020 Inspection Type: ® PCI ❑ Audit
7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s) ? ® Yes ❑ No
If No, Explain. HWA?
8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? ® Yes ❑ No
If Yes, Explain. Experienced plant upset in 2020 and 2021, resulted in multiples NPDES limit violations (BOD,
ammonia, fecal coliform)
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
INICI0I0I2I6I4I4I1
10. Current Number of Significant Industrial Users (SIUs)?
MM/DD/YY
I 09 I 29 I 21 I
2
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?
0
0
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)?
0
19. Number of CIUs in SNC?
0
NC DWR Pretreatment Audit Form
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DocuSign Envelope ID: 09531725-2C49-407B-9122-BC88B37292F5
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)
8/28/2020
a1 Yes ❑ No
5/6/2016
0 Yes ❑ No
9/1/2020
Industrial Waste Survey (IWS)
5/4/2018
II Yes ❑ No
5/15/2018
I:1 Yes ❑ No
2/28/2023
Sewer Use Ordinance (SUO)
12/18/2012
/1 Yes ❑ No
1/2/2013
/1 Yes ❑ No
Enforcement Response Plan (ERP)
6/2/2020
/1 Yes ❑ No
9/3/2020
/1 Yes ❑ No
Long Term Monitoring Plan (LTMP)
4/25/2016
0 Yes ❑ No
5/6/2016
/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 1/22/2013
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. Sent on 10/18/2021 and 11/4/2021.
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 Following: S=Satisfactory M=Mareinal U=Unsatisfacto
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
0 S ❑M ❑U
Access to POTW Vehicles for
Sampling, Inspections, and
Emergencies
/1 S ❑M ❑U
Access to Operable Sampling
Equipment
0 S ❑M ❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
0 S ❑M ❑U
Reference Materials
►1S ❑M ❑U
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
0 S ❑M ❑U
Computer Equipment (Hardware and
Software)
0 S ❑M ❑U
NC DWR Pretreatment Audit Form
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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. Excel spreadsheet.
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Industrial water/sewer rate, surcharge for BOD, TSS, and Oil & grease
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? Need to make an appointment with Utilities Director and
pretreatment files are reviewed on site.
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? Town Attorney will determine whether Confidential information
request is valid, if so, such information will be kept in sealed envelope and locked file.
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
Permitting (Industrial Waste Survey-IWS)
38. How does the POTW become aware of new or changed Users? From the Town's Pre -development meetings
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?) Complete short form and long form if needed, whether the industry is a SIU is determined based on flow,
percentage of MAHL, or categorical user.
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) At designated point, requires manifest for each load.
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 specific %
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)
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DocuSign Envelope ID: 09531725-2C49-407B-9122-BC88B37292F5
Parameters to limit are BOD, ammonia (may impact POTW operation), TSS and oil & grease (surcharge); monitoring
only parameters are those on NPDES permit and LTMP.
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
For facility with less potential to impact POTW operation, monthly sampling is required; otherwise, more frequent
sampling is required.
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. Use State compliance judgement sheet for SNC (limit violations); use
report receipt dates for reporting compliance; permit conditions violations (causing POTW pass -through, interference or
endangerment).
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?
Required for all SIUs.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
EPA Guidelines.
56. How does the POTW decide where the sample point for an SIU should be located?
1st manhole before entering the city sewer.
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.
58. Who performs sample analysis for the POTW for Metals Meritech
Conventional Parameters In house
Organics Meritech/In house
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Use in house or contract lab chain of custody forms
Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis (HWA)
60a. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES El 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 El NO Is Table Adequate? ® YES El NO
60d. All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? ® YES El 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? El 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? El 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.
63. In general, what is the most limiting criteria of your HWA? ❑Inhibition ® Pass Through El Sludge Quality
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64. Do you see any way to increase your loading in the future (Example: obtaining more land for sludge disposal)? ® Yes ❑ No
Explain.
Obtain more land. Composting final sludge.
Summary
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
POTW will be upgraded by the end of 2023 (from 4 MGD to 6 MGD, with BNR capability)
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DocuSign Envelope ID: 09531725-2C49-407B-9122-BC88B37292F5
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION)
66. User Name
1. Mountaire Farms
2. Brookwood Farms
3.
67. IUP Number
004
003
68. Does File Contain Current Permit?
0 Yes ❑ No
0 Yes ❑ No
❑ Yes ❑ No
69. Permit Expiration Date
12/1/2025
12/31/2025
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
432
N/A
71. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
/1 Yes ❑ No
/1 Yes ❑ No
❑ Yes ❑ No
72. Does File Contain Inspection Completed Within Last Calendar Year?
/1 Yes ❑ No
/1 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. ►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❑NoON/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. ►Yes •No
b.❑Yes❑No❑N/A
a. •Yes ONo
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?
0 Yes ❑ No
/1 Yes ❑ No
❑ Yes ❑ No
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
Al 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❑NoON/A
❑Yes❑NoON/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❑NoON/A
❑ Yes ❑NOON/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 /1 No
❑ Yes r No
❑ Yes ❑ No
82. During Most Recent Semi -Annual Period, Did POTW Identify All
Reporting Non -Compliance from SIU Sampling?
❑Yes❑No®N/A
❑Yes❑NoON/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 in SNC?
1 Yes 1 No
❑ Yes /1 No
❑ Yes ❑ No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
Specified in POTW's ERP (NOVs, Penalties, timing, etc.)?
DYes❑No❑N/A
❑ Yes ®No❑N/A
❑Yes❑No❑N/A
86. Does File Contain Penalty Assessment Notices?
❑Yes❑NoNN/A
❑ Yes ❑No®N/A
❑Yes❑No❑N/A
87. Does File Contain Proof Of Penalty Collection?
❑Yes❑N°ON/A
❑ Yes ❑NoON/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❑NoEIN/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 A No
i1 Yes ❑ No
❑ Yes ❑ No
FILE REVIEW COMMENTS:
# 75 - Brookwood's permit review letter from Division was not available for review.
# 81- The POTW did not identify the following violations: Mountaire, BOD in May and June 2021; Brookwood, TSS in April 2021.
Notices of Violation and Intent to Assess Civil Penalty were issued for these violations on September 30, 2021.
# 84 - The POTW issued one NOV to Mountaire for BOD violation in March 2021.
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DocuSign Envelope ID: 09531725-2C49-407B-9122-BC88B37292F5
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
INICIO 10 I2 I6 14 14 111 I09 I29 I21 I
1. Industry Inspected: Moutaire Farms
2. Industry Address: 1101 East Third St., Siler City NC 27344
3. Type of Industry/Product: Food/Poultry processing
4. Industry Contact: Jim Hendrick Title: Environmental and Engineering Manager Phone: [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:
Thorough inspection covered all required areas.
Audit SUMMARY AND COMMENTS:
Audit Comments: POTW failed to enforce for limit violations within the timeframe specified in the ERP. POTW failed to
determine Mountaire Farms was in SNC for causing POTW pass through and NPDES permit limit violations in July, August,
and September 2021, and enforce for Mountaire Farms' significant non-compliance.
Requirements: Take enforcement action against limit violations from SIUs in 1st half of 2021; take enforcement action on
Mountaire Farms' significant non-compliance.
Recommendations:
NOD: ❑ Yes ❑ No
NOV: ® Yes ❑ No
QNCR: ❑ Yes ❑ No
POTW Rating:
Satisfactory ❑
Marginal ❑ Unsatisfactory
Audit COMPLETED BY: Cheng Zhang, Raleigh Regional Office DATE: 9/29/2021
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 8