NC0037834_Pretreatment_Audit_PCI Cover Letter_20220418

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Joel Freeman
Utilities Plant Supervisor
City of Winston Salem
2801 Griffith Road
Winston-Salem, NC 27103
NORTH CAROLINA
Environmental Quality
April 18, 2022
SUBJECT: Pretreatment Audit of Hood Container & Pretreatment Compliance Inspection
City of Winston Salem
Main Program Permit (NPDES) #NC0037834
Forsyth County
Dear Mr. Freeman:
On 4/6/2022, a Pretreatment Audit and PCI was performed by Tricia Lowery of the Winston-Salem
Regional Office. The purpose of the PCI and audit was to determine the effectiveness of the City of Winston
Salem's pretreatment program overall and their effectiveness in regard to SIU inspections, which includes
the initial interview, tour of SIU facility, sampling review, an exit interview.
Industrial Inspection Comments:
During the initial interview, a thorough review of records was conducted. Production rate, sampling,
updated contact information, monthly reports spill/slug plan, permits was reviewed. Discussion of new
reporting requirements to pretreatment programed was reviewed. Plant tour was systematic and
comprehensive, examining all paints, primers, multi -bond agents, and their containment, treatment and/or
disposal in production process. Additionally, pretreatment personnel checked for leaks, condition of lines,
machinery, and floor drains. Investigated industry's storage practices, spill response kits, housekeeping
practices etc. Inspection of pretreatment area revealed no issues or concerns. Exit interview involved time
for IU manager to ask questions or express any concerns and for pretreatment personnel to assess and
discuss plant inspection.
Background
The City of Winston Salem has 28 Significant Industrial Users (SIUs), of which 10 are categorical users.
Pretreatment Program Interview
All files are in order. Since last PCI, the POTW has had no NPDES violations, and no problems related to
industrial discharges. No SNCs for reporting, however Bekaert, Suiza Dairy, ERT, Pepsi, Clarios, Adele
Knits, WestRock were in SNC for limits. All SNCs were appropriately published. ETR is currently on
compliance schedule/order.
GDE
NORTH C OLI JA '
omm mr� ep..of o�.i
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105
336.776.9800

Pretreatment Program Elements Review
The Headworks Analysis (HWA) renewal was submitted on 10/2/2017. The HWA last approval date is
2/28/2018. The next HWA is due on 10/1/2022.
The last Industrial Waste Survey (IWS) was submitted on 6/30/2021. The IWS approval is pending. The
next IWS due date is pending.
The Sewer Use Ordinance (SUO) was approved on 2/9/2012.
The Enforcement Response Plan (ERP) was submitted on 1/13/2020 and approved on 2/5/2020.
The Long -Term Monitoring Plan (LTMP) was submitted on 12/20/2018 and approved on 3/5/2019.
LTMP File Review
The Long -Term Monitoring Plan (LTMP) is being conducted at the proper locations and frequencies.
Industrial User Permit (IUP) File Review
A review of the files for Hood Container (IUP #1042) revealed the monitoring data was well organized and
compliant.
A review of the files for Ardagh Packaging (IUP #3010) revealed the monitoring data was well organized
and compliant.
A review of the files for John -Deere Kernersville (IUP #2014) revealed the monitoring data was well
organized and compliant.
Action Items
No other action items were noted.
The pretreatment program is satisfactory. If you have any questions, please contact Tricia Lowery or me at
[phone].
Sincerely,
EDocuSigned by:
L-0A, T. 3MiCr
145B49E225C94EA...
Lon T. Snider
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
Attachment:
1. NC DWR Pretreatment Audit Form
cc: Municipal Permitting Unit — Keyes McGee
WSRO Files
D_E
NORTH CAROLINA
gaparMeM of Environment,/quay
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 W. Hanes Mill Rd, Suite 300 I Raleigh, North Carolina 27105
336.776.9800