NC0037834_Pretreatment_Audit_PCI_20220406

DocuSign Envelope ID: 04C35BEA-9464-4C52-B53B-A81A6F58A197
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 Winston Salem
2. Control Authority Representative(s): Joel Freeman
3. Title(s): Utility Plant Supervisor/IWC
4. Address of POTW:
Mailing 2799 Griffith Rd
City Winston Salem, NC
Zip Code 27103-6417
Phone Number 336.397.7621 Fax Number 336.659.4320 E-Mail ioelf(a/citvofws.org
5. Audit Date 04/06/2022 (including PCI)
6. Last Inspection Date: 11/17/2020 Inspection Type: ® PCI ❑ Audit
7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s) ? ® Yes ❑ No
If No, Explain.
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 MM/DD/YY
IN1C10 013 17 18 13 14 1
10. Current Number of Significant Industrial Users (SIUs)?
Expires 16 30 1 22
Renewal submitted/rec'd 12/28/2021
28
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?
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?
0
0
10
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)?
10
19. Number of CIUs in SNC?
1
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DocuSign Envelope ID: 04C35BEA-9464-4C52-B53B-A81A6F58A197
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)
10/02/2017
01 Yes ❑ No
02/28/2018
0 Yes ❑ No
10/01/2022
Industrial Waste Survey (IWS)
06/30/2021
i4 Yes ❑ No
Pending
❑ Yes ❑ No
Pending
Sewer Use Ordinance (SUO)
01/13/2012
/1 Yes ❑ No
02/09/2012
/1 Yes ❑ No
NA
Enforcement Response Plan (ERP)
01/13/2020
/1 Yes ❑ No
02/05/2020
/1 Yes ❑ No
NA
Long Term Monitoring Plan (LTMP)
12/20/2018
❑ Yes ❑ No
03/05/2019
❑ Yes ❑ No
NA
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. Clemmons, Davidson Co, Davie Co, Kernersville, Rural Hall, King,
Walkertown.
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 11/14/2011 **See File Review Comments
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 Updated 2019 and sent to all industries
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
Environmental Relief Technology - ERT (IUP #3054). Administrative order to correct discharge. Exceeded limits for pH,
TSS, O&G.
Resources
29. Please Rate the Following: S=Satisfactory M=Marginal U=Unsatisfacto
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
e S ❑M ❑U
Access to POTW Vehicles for
Sampling, Inspections, and
Emergencies
/1S ❑M ❑U
Access to Operable Sampling
Equipment
/ / S ❑ M ❑ U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
0 S ❑M ❑U
Reference Materials
OS❑M❑U
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
/1S ❑M ❑U
Computer Equipment (Hardware and
Software)
/1S ❑M ❑U
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DocuSign Envelope ID: 04C35BEA-9464-4C52-B53B-A81A6F58A197
30. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No
Explain Yes or No. Program uses Linko database reporting system.
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
BOD and TSS surcharges.
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. ERT — IUP#3054 (as mentioned in #28)
33. Has anyone from the public ever requested to review pretreatment program files? ❑ Yes ® No
If yes, Explain procedure. If no, how would the request be addressed? The city has a public information officer (PIO) and
would be distributed through the PIO.
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? Follow the Sewer Use Resolution and the Pretreatment Supervisor &
WW Superintendent would submit a letter to industry for specifics concerning confidential information and would
emphasize effluent information is public information and would assure that all data is secured in a locked office and
secured password database software.
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-1WS)
38. How does the POTW become aware of new or changed Users? 1) Billing dept/water; 2) Doing inspection; 3)
Engineering dept will notify Utilities Field operations.
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
SILT?) 1) Allocation Table; 2) HWA; 3) Permit applications
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
®Yes No If Yes, How many are there? 1— Hanes Landfill
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) All trucked waste must fill out a ticket (that includes address/volume) before discharging into
POTW
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? Silver (Ag)
45. If yes to #44, What is being done to address the over allocations? (short-term IUPs, HWA to be revised, pollutant study, etc.)
Mr. Freeman explained this is technically not an over allocation, it appears so due to limit changes.
46. Does the POTW keep pollutant loading in reserve for future growth / safety? ® Yes ❑ No
If yes, what percentage of each parameter %
47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) ❑ Yes ® No
If yes, Explain.
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DocuSign Envelope ID: 04C35BEA-9464-4C52-B53B-A81A6F58A197
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)
Based on AT, LTMP, and laboratory results.
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
1) LTMP; 2) Staffing; 3) Making it work for customers — relevant to sampling.
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. 1) Industrial reports ; 2) local limits; 3) SUO — compare permit
against sample results.
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?
Potential impact to POTW. What chemicals are on -site: how are they stored, used and disposed? Evaluate SDS, handling
and personnel.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Evaluate measures to see how they protect the collection system/WWTP and how realistic those measures are to meet plan.
56. How does the POTW decide where the sample point for an SIU should be located?
It is always at the last point of discharge as it enters the POTW 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 El No If yes, Explain.
58. Who performs sample analysis for the POTW for Metals: City Lab and/or Meritech
Conventional Parameters: City Lab and/or Meritech
Organics: City Lab and/or Meritech
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
In-house & commercial lab sample COC protocol: must fill all pertinent information on COC and add appropriate
signatures/date/time when relinquishing/receiving sample from field to lab (or in-house to commercial lab). All samples
must be always stored securely while in custody and below 6 C if not being analyzed or awaiting shipment to commercial
lab.
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DocuSign Envelope ID: 04C35BEA-9464-4C52-B53B-A81A6F58A197
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
EMore LTMP data available
Explain.
❑Resolve over allocation ®5 year expiration
ENPDES limits change
❑Other
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. Just recently made upgrades to Muddy Creek WWTP so flow can be sent to AE WWTP if increase in loading.
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: 04C35BEA-9464-4C52-B53B-A81A6F58A197
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION)
66. User Name
1. Hood Container
2. Ardagh Packaging
3. John -Deere Kernersville
67. IUP Number
1042
3010
2014
68. Does File Contain Current Permit?
0 Yes ❑ No
0 Yes ❑ No
A Yes ❑ No
69. Permit Expiration Date
6/30/2022
6/30/2022
6/30/2022
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
NA
465
433
71. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
/1 Yes ❑ No
/1 Yes ❑ No
0 Yes ❑ No
72. Does File Contain Inspection Completed Within Last Calendar Year?
/1 Yes ❑ No
/1 Yes ❑ No
A Yes ❑ No
73. a. Does File Contain Slug/Spill Control Plan?
b. If No, is One Needed? (See Inspection Form from POTW)
a. •Yes rNo
b. •Yes /Z/No
a. ►Yes •No
b. •Yes •No
a. ►Yes •No
b. •Yes •No
Certification, Does File Contain a Toxic
(TOMP)?
❑Yes®No❑N/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 •No
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
/1 Yes ❑ No
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
Al Yes ❑ No
/1 Yes ❑ No
/1 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❑NoON/A
80b. For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
❑Yes❑No❑N/A
❑Yes❑No❑N/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?
i1 Yes ❑ No
r Yes ❑ No
/1 Yes ❑ No
82. During Most Recent Semi -Annual Period, Did POTW Identify All
Reporting Non -Compliance from SIU Sampling?
®Yes❑No❑N/A
® Yes ❑No❑N/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?
❑ Yes 1 No
❑ Yes /1 No
❑ Yes 1 No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
Specified in POTW's ERP (NOVs, Penalties, timing, etc.)?
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑NoON/A
86. Does File Contain Penalty Assessment Notices?
❑Yes❑NoNN/A
❑Yes❑NoIEN/A
❑Yes❑No®N/A
87. Does File Contain Proof Of Penalty Collection?
❑Yes❑NoON/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
❑ Yes i1 No
❑ Yes A No
FILE REVIEW COMMENTS:
24# - SUO: City Administration has not approved updated SUO but operating under updated version.
All files are in order and well organized. Inspector found no issues.
NC DWR Pretreatment Audit Form Revised: December 2016
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DocuSign Envelope ID: 04C35BEA-9464-4C52-B53B-A81A6F58A197
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
INICIOIOII 17 18 13 14 1 16 130 122 I
1. Industry Inspected: Hood Container
2. Industry Address: 555 Aureole St., Winston Salem NC 27107
3. Type of Industry/Product: Cardboard packaging
4. Industry Contact: Stephen Gusefski Title: Plant Manager Phone: [phone] Fax: [phone]
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 review of records was conducted. Production rate, 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, going over all paints, primers, multi -bond agents, and sodium hydroxide. 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.
Audit SUMMARY AND COMMENTS:
Audit Comments: Conducts industrial inspections thoroughly and comprehensively. No issues noted.
Requirements: NA
Recommendations: NA
NOD: ❑ Yes ® No
NOV: ❑ Yes ® No
QNCR: ❑ Yes ® No
POTW Rating:
Satisfactory
Audit COMPLETED BY: Tricia Lowery
Marginal ❑ Unsatisfactory ❑
�DocuSigned by:
�1.l.PA.Cf. �Atti9 0
1/4.---42D62165508C476...
Municipal Permitting Unit, Winston Salem Regional Office
DATE: 4/18/2022
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 7