WQCS00150_Pretreatment Audit_20220712

DocuSign Envelope ID: CFA76D6B-2463-44AC-B5C4-9A24C9D484B2
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Mr. Alan Moore, Public Works Director
Town of Burgaw
109 North Walker Street
Burgaw, NC 28425
Subject: Pretreatment Audit
Program: Town of Burgaw
Permit No. WQCS00150
Pender County
Dear Mr. Moore:
NORTH CAROLINA
Environmental Quality
July 14, 2022
A Pretreatment Audit of the Town of Burgaw's Pretreatment Program was conducted by Helen Perez from this office on
July 12, 2022. This audit was conducted to determine the effectiveness of the pretreatment program by reviewing various
aspects of the program, which included files and records, industrial user inspections and monitoring data, data management
procedures and adherence to the Enforcement Response Plan.
The Town of Burgaw continues to do an effective job of achieving the pretreatment program goals. The findings and
comments noted during this inspection are provided in the enclosed copy of the audit report. There were no significant
issues or findings noted during this inspection thus a response to this inspection report is not required.
Thank you for your continued support of the North Carolina Pretreatment Program. If you should have any questions,
please contact Helen Perez at [phone] or at [e-mail] .
Sincerely,
DocuSigned by:
TOM- -11A4.Cr1106.
7F141E73B6F3456...
Tom Tharrington, Assistant Regional Supervisor
Water Quality Regional Operations Section
Wilmington Regional Office
Division of Water Resources, NCDEQ
Cc: Lisa Osthues, Pretreatment Coordinator
Upload to Laserfiche
c OE
North Carolina Department of Environmental Quality I Division of Water Resources
Wilmington Regional Office 1127 Cardinal Drive Extension I Wilmington, North Carolina 28405
910.796.7215

DocuSign Envelope ID: CFA76D6B-2463-44AC-B5C4-9A24C9D484B2
1� D_E
Department m Enmmamemai oval;
North Carolina Department of Environmental Quality I Division of Water Resources
Wilmington Regional Office 1127 Cardinal Drive Extension I Wilmington, North Carolina 28405
910.796.7215

DocuSign Envelope ID: CFA76D6B-2463-44AC-B5C4-9A24C9D484B2
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 Burgaw
2. Control Authority Representative(s): Robert Moore, Lisa Osthues
3. Title(s): Director of Public Works, Pretreatment Contractor
4. Address of POTW:
Mailing 109 N. Walker Street
City Burgaw, NC
Phone Number 910-259-5003, 910-990-0329 Fax Number
[e-mail]
Zip Code 28425
E-Mail [e-mail]
5. Audit Date 07/12/2022
6. Last Inspection Date: 05/06/2021 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 El No El NA
Parameters Covered Under Order
ICIS Coding
Main Program Permit Number
1WIoIcIsIo 10 11 15 10 1
10. Current Number of Significant Industrial Users (SIUs)?
MM/DD/YY
107 112 22 1
11. Number of SIUs with No IUP, or with an Expired IUP? 1
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? 1
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? 1
17. Number of SIUs on Schedules? 1
18. Current Number of Categorical Industrial Users (CIUs)? 1
19. Number of CIUs in SNC? 0
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 1

DocuSign Envelope ID: CFA76D6B-2463-44AC-B5C4-9A24C9D484B2
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)
N/A
❑ Yes ❑ No
N/A
❑ Yes ❑ No
N/A
Industrial Waste Survey (IWS)
11/04/2019
A/ Yes ❑ No
03/04/2020
a Yes ❑ No
10/01/2024
Sewer Use Ordinance (SUO)
01/11/2013
A/ Yes ❑ No
02/06/2013
r Yes ❑ No
Enforcement Response Plan (ERP)
05/15/2020
A/ Yes ❑ No
08/11/2020
r Yes ❑ No
Long Term Monitoring Plan (LTMP)
N/A
❑ Yes ❑ No
N/A
❑ Yes ❑ No
N/A
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 04/10/2012
25. Have you had any problems interpreting or enforcing any part of the SUO? El Yes ® No
If yes, Explain.
Enforcement (Enforcement Response Plan-ERP)
26. Did you send a copy of the ERP to your industries? ® Yes El No
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
Cardinal Foods under a Consent Order with compliance schedule.
Resources
29. Please Rate the Followine: S=Satisfacto
M=Mareinal U=Unsatisfacto
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
A/ S ❑M ❑U
Access to POTW Vehicles for
Sampling, Inspections, and
Emergencies
A/ S ❑M ❑U
Access to Operable Sampling
Equipment
1 S ❑M ❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
1 S ❑M ❑U
Reference Materials
1S❑M❑U
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
1 S ❑M ❑U
Computer Equipment (Hardware and
Software)
A/ S ❑M ❑U
NC DWR Pretreatment Audit Form
Revised: December 2016
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DocuSign Envelope ID: CFA76D6B-2463-44AC-B5C4-9A24C9D484B2
30. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No
Explain Yes or No. Excel spreadsheets
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Through civil penalties, permit modification charges, sampling costs charged to the industries.
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? A request to the Town's Director of Public Works.
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? A request can be made in writing to the Town's Director of Public
Works which then would be reviewed and determined if information qualifies for confidential status.
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? The IWS, through the Town's billing and access to the
on-line Manufacturer Registry.
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?) A review of the short form, POCs, sampling results or long forms as needed.
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)
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: The Town of Wallace treats the flow from the Town of Burgaw's collection system. Wallace's HWA
is currently in review.
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? N/A
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 N/A%
47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) ❑ Yes ❑ No
If yes, Explain. N/A
NC DWR Pretreatment Audit Form
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DocuSign Envelope ID: CFA76D6B-2463-44AC-B5C4-9A24C9D484B2
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)
All the following is taken into consideration: Town of Wallace's NPDES permit, IWS, type of industry, POCs, categorical
parameters, stream standards.
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Flow volume, POCs, historicaUpredicted load, variability of load, over-all impacts to POTW.
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 judgement spreadsheet, post marks for reporting
requirements, annual inspections for permit conditions.
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. All SIUs are required to have a slug/spill plan.
54. What criteria are used to determine if a slug/spill control plan is needed?
All SIUs have the potential to spill, and therefore, the Town requires all of them to have a slug/spill plan.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Chemical control to keep out of drains, training requirements, posted signs for contact info/spill procedures.
56. How does the POTW decide where the sample point for an SIU should be located?
Downstream of process and before mixing with other wastes.
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. Envirochem Lab samples and analyzes all
parameters for the POTW and the industries.
58. Who performs sample analysis for the POTW for Metals Envirochem
Conventional Parameters Envirochem
Organics Envirochem
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Envirochem COC forms used with all relevant information entered: date, time, temp, pH, type of analysis, preservative,
signatures.
Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis (HWA) — N/A (see comments below)
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? El YES El NO
60c. Is LTMP/STMP Data Maintained in Table or Equivalent? El YES El NO Is Table Adequate? El YES El 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? El YES El 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 El No
If yes, what is the reason for the revision? (mark all that apply) ❑Increased average flow EINPDES limits change
❑More LTMP data available ['Resolve over allocation 05 year expiration ['Other
Explain.
NC DWR Pretreatment Audit Form
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DocuSign Envelope ID: CFA76D6B-2463-44AC-B5C4-9A24C9D484B2
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 significant changes to the program are planned.
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 5

DocuSign Envelope ID: CFA76D6B-2463-44AC-B5C4-9A24C9D484B2
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION
66. User Name
1. LL Building Products
2. American Skins
3. Cardinal Foods
67. IUP Number
0006
0004
0007
68. Does File Contain Current Permit?
1 Yes ❑ No
A/ Yes ❑ No
P11 Yes ❑ No
69. Permit Expiration Date
12/31/26
12/31/26
10/1/22
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
433.17
n/a
n/a
71. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
/1 Yes ❑ No
1 Yes ❑ No
/1 Yes ❑ No
72. Does File Contain Inspection Completed Within Last Calendar Year?
P11 Yes ❑ No
Al Yes ❑ No
P11 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
74. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
Organic Management Plan (TOMP)?
®Yes❑No❑N/A
❑Yes❑No®N/A
❑Yes❑No®N/A
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. ►I 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?
P11 Yes ❑ No
Al Yes ❑ No
P11 Yes ❑ No
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 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❑No®N/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❑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?
P11 Yes ❑ No
/1 Yes ❑ No
P11 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 ofc.
becoming aware of SIU limit violations in the POTW's sampling of SIU?
a.❑Yes❑No®N/A
b.❑Yes❑NoDN/A
❑Yes❑No®N/A
a.❑Yes❑NoEIN/A
b.❑Yes❑No®N/A
c.❑Yes❑No®N/A
a.❑Yes®No❑NSA
b.®Yes❑No❑N/A
c.❑Yes❑No®N/A
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
❑ Yes 01 No
❑ Yes Al No
P11 Yes ❑ No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
Specified in POTW's ERP (NOVs, Penalties, timing, etc.)?
❑Yes❑NoEIN/A
❑Yes❑NoON/A
®Yes❑No❑N/A
86. Does File Contain Penalty Assessment Notices?
❑Yes❑No®N/A
❑Yes❑NOON/A
®Yes❑No❑N/A
87. Does File Contain Proof Of Penalty Collection?
❑Yes❑NoEIN/A
❑Yes❑No®N/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❑NoEIN/A
a.❑Yes❑No®N/A
b.❑Yes❑No®N/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 /1 No
❑ Yes /1 No
❑ Yes /1 No
FILE REVIEW COMMENTS:
36. Any changes to the SUO or Local Limits can be viewed by the public through the Board Meeting minutes, the Town's website
or the Town's section of the Pender Post newspaper.
43-47. All flow from the Burgaw Collection System goes to the Town of Wallace WWTP, NC0003504, for treatment. The HWA for
Wallace is currently under review by the Division.
60-64. The Town of Wallace WWTP is responsible for the LTMP. The Town of Burgaw monitors their SIUs for all LTMP
parameters at a lower detection level.
NC DWR Pretreatment Audit Form Revised: December 2016
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DocuSign Envelope ID: CFA76D6B-2463-44AC-B5C4-9A24C9D484B2
LL Building Products:
71. Application completed on 12/06/21.
72. Last inspected on 12/10/21.
75. Division Review Letter received on 04/14/22.
76. The POTW completed sampling in June but has not received test results yet.
77. POTW contracts Envirochem for sampling the SIUs. Envirochem COC forms were on file.
78. Monthly required sampling was completed.
American Skins:
71. Application completed on 05/26/21.
72. Last inspected on 12/10/21.
75. Division Review Letter received on 04/14/22.
76. The POTW completed sampling in June but has not received test results yet.
78. Weekly and monthly required sampling was completed.
Cardinal Foods:
71. Application completed on 06/14/22 for the permit that expires on 10/01/22.
72. Last inspected on 06/07/22.
75. Division Review Letter received on 05/27/21.
76. The POTW completed sampling in June but has not received test results yet.
83a. Prior to 2022, the SIU did not notify POTW of all self -monitoring violations.
83c. POTW is waiting on test results from June's sampling event and will resample if applicable.
84. The SIU was in SNC for both Semi -Annual Periods in 2021 and the 1st Period in 2022.
85. Six NOVs have been issued for the 1st semi-annual period of 2022.
87. The Town is currently working on the collection of civil penalties.
88. The file contains a Consent Order with a compliance schedule and the SIU is currently compliant with the Order.
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 7

DocuSign Envelope ID: CFA76D6B-2463-44AC-B5C4-9A24C9D484B2
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
IwIoIcIs Io 10 11 15 0 071121221
1. Industry Inspected: LL Building Products
2. Industry Address: 295 McKoy Road Burgaw, NC 28425
3. Type of Industry/Product: metal ventilation products
4. Industry Contact: Trevor Simmons Title: Engineer Technician 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:
LL Building Products produces metal ventilation products and is a categorical SIU (433.17). The wastewater from the paint line
bash tanks is pretreated through a DAF system before it discharges to Burgaw's Collection System. The Pretreatment Contractor
&roughly completed all parts of the industry inspection.
Audit SUMMARY AND COMMENTS:
Audit Comments: the Town of Burgaw maintains their own Pretreatment Program associated with their Collection System
Permit WQCS00150. The Town continues to manage an efficient pretreatment program. All records and files were available for
review.
Requirements: N/A
Recommendations: N/A
NOD: ❑ Yes ® No
NOV: ❑ Yes ® No
QNCR: ❑ Yes ® No
POTW Rating:
Satisfactory El
Audit COMPLETED BY:
Marginal ❑ Unsatisfactory ❑
DocuSigned by:
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LDocuSigned by:
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Helen Perez, Wilmington Regional Office
DATE:
7/14/2022
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 8