NC0024112_PCI_Cover Letter_20220324

ROY COOPER.
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
Michael Brandt
City Manager
P.O. Box 368
Thomasville NC 27361-0368
NORTH CAROLINA
Environmental Quality
March 24, 2022
SUBJECT: Pretreatment Compliance Inspection (PCI)
City of Thomasville
NPDES# NC0024112
Davidson County
Dear Mr. Brandt:
On March 8, 2022 a Pretreatment Compliance Inspection (PCI) was performed by Tricia Lowery of the Winston-Salem
Regional Office. Misty Conder was present for the inspection. The purpose of this inspection was to determine the
effectiveness of the Town's pretreatment program, which includes reviewing the files, POTW plant performance, industry
monitoring data, and adherence to the enforcement response plan (ERP).
Background
This is a 6.0 MGD permitted facility. The City has 5 Significant Industrial Users (Sills), 5 of which are categorical. The
publicly owned treatment works (POTW) had 5 violations in 2021 (2/2021 for BOD; 3/2021 for BOD/TSS; 7/2021 for
BOD/TSS)
POTW Interview
There are no plant problems related to pretreatment issues other than the BOD and TSS violations previously stated. Two
CIU's were in SNC during the 2021 calendar year: Finch, and McIntyre. Both were appropriately notified of violations and
penalties were accessed and collected. Ms. Conder stated public notices of these violations were currently in progress and
will be posted in local newspaper in the following week post inspection. Custom Drum permit was cancelled January 2021
and was dropped from the program.
Updates to pretreatment program, as specified in the new permit issued on 2/24/2022 (effective 4/1/2022), are due by
September 28th, 2022. Details concerning these updates, in addition to other details regarding the pretreatment program,
are located under 'File Review Comments' in attached PCI report.
Pretreatment Program Elements Review
The Headworks Analysis (HWA) renewal was submitted on 11-2020. The HWA is currently being reviewed for approval.
Once approved, the next due date will be announced. The Allocation Table was updated in 2021 to add HERR, once HWA
is approved, the updated allocation table will be submitted.
The last Industrial Waste Survey (IWS) is currently in progress and is due to be submitted in March 2022. The IWS was
last approved on 9/11/2015. The next 1WS was granted an extension for March 2022.
NORTH
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Dopartmem of Envimnmomni au.i`
North Carolina Department of Environmental Quality Division of Water Resources
Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105
336.776.9800

The Sewer Use Ordinance (SUO) was approved on 3/25/2013.
The Enforcement Response Plan (ERP) was submitted on 2/11/2020 and approved on 2/14/2020.
The Long -Term Monitoring Plan (LTMP) was submitted in 2014 and approved on 1/25/2019.
These dates are fluid as new conditions are in place with new permit. Again, updates are due September 28th, 2022.
Additionally, once the EPA has finalized wastewater methods for PFAS, it will be requirement to sample for PFAS two
times a year.
LTMP File Review
The Long -Term Monitoring Plan (LTMP) is being conducted at the proper locations and frequencies (2/year). Due to
COVID-19, non -industry sampling/testing was limited to once in 2021.
Industrial User Permit (IUP) File Review
A review of the file for FINCH (#0018) revealed that the monitoring data was well organized and compliant.
A review of the file for AMC (#0028) revealed that the monitoring data was well organized and compliant.
A review of the file for McIntyre (#0031) revealed that the monitoring data was well organized and compliant.
The slug control plan for FINCH (#0018) was in good order.
The slug control plan for AMC (#0028) was in good order.
The slug control plan for McIntyre (#0031) was in good order.
Note: It is highly recommended that copies of penalty collections are kept in their respective IUP files. Currently they are
kept at the City's accounting department.
Action Items
No other action items were noted.
The pretreatment program is considered satisfactory. Misty Conder runs an adequate pretreatment program. If you have any
questions, please contact Tricia Lowery or me at [phone].
Sincerely,
r—/DocuSigned
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145B49E225C94EA...
Lon T. Snider
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
Attachment:
1. NC DWR Pretreatment Compliance Inspection (PCI) Report
cc: Municipal Permitting Unit — Keyes McGee
Central Files
WSRO Files
LD_E
NORTH CAROLINA
Department of Environmental quaky
North Carolina Department of Environmental Quality j Division of Water Resources
Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105
336.776.9800