NC0024210_Compliance Evaluation Inspection_20220728

NCNORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
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BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)1
1. Control Authority (POTW) Name: High Point Eastside WWTP
2. Control Authority Representative(s): Carrie Hyler
3. Title(s): Pretreatment Supervisor
4. Last Inspection Date: 8/19/2021 Inspection Type (Check One): ❑ PCI ® Audit
5. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? ® YES ❑ NO
6. Is POTW under an Order That Includes Pretreatment Conditions? ❑ YES ® NO
Order Type, Number, Parameters: Are Milestone Dates Being Met? ❑ YES ❑ NO
ICIS CODING
Main Program Permit Number
1N1C101012141211101
MM/DD/YY
p71281221
7. Current Number Of Significant Industrial Users (SIUs)?
21
8. Number of SIUs With No IUP, or With an Expired IUP?
0
9. Number of SIUs Not Inspected By POTW in the Last Calendar Year?
0
10. Number of SIUs Not Sampled By POTW in the Last Calendar Year?
0
11. Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi -Annual
Periods?
0
12. Number of SIUs in SNC For Reporting During Either of the Last 2 Semi -Annual Periods?
0
13. Number of SIUs in SNC with Pretreatment Schedule?
0
14. Number of SIUs on Schedules?
0
15. Current Number Of Categorical Industrial Users (CIUs)?
12
16. Number of CIUs in SNC?
0
POTW INTERVIEW
17. Since the Last PCI, has the POTW had any NPDES Limits Violations?
If Yes, What are the Parameters and How are these Problems Being Addressed?
18. Since the Last PCI, has the POTW had any Problems Related to an Industrial
Discharge (Interference, Pass -Through, Blockage, Citizens' Complaints, Increased
Sludge Production, Etc.)?
If Yes, How are these Problems Being Addressed?
19. Which Industries have been in SNC for Limits or Reporting during
either of the Last 2 Semi -Annual Periods? Not Been Published for
Public Notice?(May refer to PAR if Excessive SIUs in SNC)
SNC for
SNC for
Not Pul
20. Which Industries are on Compliance Schedules or Orders? For all SIUs on an
Order, Has a Signed Copy of the Order been sent to the Division?
21. Are Any Permits or Civil Penalties Currently Under Adjudication? If Yes, Which
Ones?
VA YES ❑ NO
See item 17 below.
IN YES ❑ NO
See item 18 below.
Limits:
Reporting: N/A
lished:
N/A
❑ YES FA NO
LTMP/STMP FILE REVIEW:
22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES
23. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ® YES ❑ NO
24. Is LTMP/STMP Data Maintained in a Table or Equivalent? ® YES ❑ NO Is Table Adequate? ® YES ❑ NO
25. All LTMP/STMP effluent data reported on Discharge Monitoring Report? ® YES ❑ NO Division Inspector, please verify
yourself!
26. If NO to 23 - 26, list violations
27. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ® NO
See number 25 below.
❑ NO
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1

If yes, which ones? Eliminated: Added:
17. Yes, Eastside WWTP had an exceedence of total phosphorus in January (both concentration and total monthly pounds), and an exceedence of total
phosphorus and ammonia in February (monthly average concentration of phosphorus and weekly and monthly average of ammonia). High rainfall on
January 2nd and 3rd caused sludge and rags to be pulled through system, and DAF lines became clogged. One substance of concern was specified,
which carried a strong petroleum smell. WWTP personnel) conducted sampling upstream of the plant in an attempt to identify point source of the unknown
pollutant. Top suspect Zebra (Terra Nova) was cleared as not responsible. Ms. Hyler suspects it could be an I&I issue in a line adjacent to a dumping pit
somewhere upstream, as it has only been observed during heavy rainfall. Problem is ongoing, but inconsistent.
18. Yes, PET Dairy was suspected of causing clarifiers to turn very white, and when questioned they claimed no activity had taken place at their
pretreatment site on the day the color issue was observed. It was later uncovered that the entire EQ tank at PET was drained on that day due to
operational issues. An NOV as issued to the SIU.
23. All parameters are at PQI or lower except for tin, which isn't available through third party lab. Once machine owned by the City is repaired and
this sample is able to be run onsite, this parameter will meet PQI.
25. Ms. Hyler stated that some effluent data was found to be left off DMRs during the past six-month period. This mistake was made when
staffing changes occured and was not intentional or malicious. Upon discovering the issue, revised versions of the DMR data was submitted.
Due to the communication of this mistake, and the efficient remedy, no enforcement action will be made by DWR.
44. Flow exceedence was reported on June 11, 2022 by KAO contact Patrick Simcox. NOD was issued by City of High Point.
47. TRC TSS exceedence and Failure to Report both listed in NOV dated March 21. Email from Ms. Hyler to Plant Manager Guarav Singhal on May 10 notes no
report follow up was received (due April 18). However, no mention of payment was made. Bill to PET Dairy for $500 fine was included with NOV
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

28. PRETREATMENT PROGRAM ELEMENTS REVIEW— Please review POTW files, verify POTW has copy of Program Element in
their files, complete with supporting documents and copy of 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)
05/24/2022
I Yes ❑ No
Awaiting Approval
❑ Yes VA No
Industrial Waste Survey (IWS)
01/28/2020
► Yes ❑ No
04/22/2020
I Yes ❑ No
Sewer Use Ordinance (SUO)
06/15/2020
7 Yes ❑ No
Awaiting Approval
❑ Yes M No
Enforcement Response Plan (ERP)
01/29/2020
VA Yes ❑ No
02/14/2020
► Yes ❑ No
Long Term Monitoring Plan (LTMP)
05/29/2020
VA Yes ❑ No
08/25/2020
M Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION
29. User Name
1. Thomas Built Buses
2. Kao Specialties Americas
1 PET Dairy
30. IUP Number
0047
0026
0151
31. Does File Contain Current Permit?
VA Yes ❑ No
! Yes ❑ No
M Yes ❑ No
32. Permit Expiration Date
06/30/2026
06/30/2026
06/05/2026
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
433.17
414.85
N/A
34. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
M Yes ❑ No
M Yes ❑ No
FA Yes ❑ No
35. Does File Contain an Inspection Completed Within Last Calendar Year?
VA Yes ❑ No
FA Yes ❑ No
F Yes ❑ No
36. a. Does the File Contain a Slug/Spill Control Plan?
b. If No, is One Needed? (See Inspection Form from POTW)
a. ► Yes •No
b. ■Yes ■ No
a. ,+iYes •No
b. ■Yes ■ No
a. %Yes •No
b. ■Yes ■ No
Certification, Does File Contain a Toxic
(TOMP)?
® Yes ❑No❑N/A
Dated 06/13/2022
❑Yes❑NoON/A
❑ Yes ❑NoON/A
37. For 40 CFR 413 and 433 TTO
Organic Management Plan
38. a. Does File Contain Original Permit Review Letter from the Division?
b. All Issues Resolved?
a. ► Yes •No
b.❑Yes❑No ON/A
a. ,+iYes ■No
b.❑Yes❑No®N/A
a. %Yes ■No
b.®Yes ❑No❑N/A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
its Sampling as Required by IUP, including flow?
FA Yes ❑ No I
J
M Yes ❑ No
M Yes ❑ No
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
M Yes ❑ No
IM Yes ❑ No
M Yes ❑ No
41. During the Most Recent Semi -Annual Period, Did the SIU Complete its
Sampling as Required by IUP, including flow?
®Yes❑No❑N/A
®Yes❑No❑N/A
®Yes❑No❑N/A
41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports
on time?
®Yes❑No❑N/A
®Yes❑No❑N/A
®Yes❑No❑N/A
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
file include process/dilution flows as Required by IUP?
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑No®N/A
42b. 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
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Limits Non -Compliance from Both POTW and SIU Sampling?
M Yes ❑ No
M Yes ❑ No
M Yes ❑ No
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Reporting Non -Compliance from SIU Sampling?
❑ Yes ❑No®N/A
❑Yes❑No®N/A
® Yes ❑No❑N/A
44. a. Was the 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 within 30 days of becoming aware
of SIU limit violations in the POTW's sampling of the 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
See item 44 above.
c.❑Yes❑NomN/A
a.❑Yes®No❑N/A
b.❑Yes®No❑N/A
c.❑Yes ❑No®N/A
46. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
❑ Yes VA No
❑ Yes M No
❑ Yes FA No
47. During the Most Recent Semi -Annual Period, Was Enforcement Taken
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
❑ Yes ❑NOON/A
® Yes ❑No❑N/A
NOD issued (see 44 above)
® Yes ❑No❑N/A
See item 47 above.
48. Does the File Contain Penalty Assessment Notices?
❑ Yes ❑No®N/A
❑Yes❑No®N/A
® Yes ❑No❑N/A
49. Does The File Contain Proof Of Penalty Collection?
❑ Yes ❑NOON/A
❑Yes❑No®N/A
❑ Yes ®No❑N/A
50. a. Does the 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❑NoON/A
b.❑Yes❑No ON/A
a.❑Yes ❑No®N/A
b.❑Yes❑NoON/A
51. Did the POTW Representative Have Difficulty in Obtaining Any of This
Requested Information For You?
❑ Yes M No
❑ Yes M No
❑ Yes M No
FILE REVIEW COMMENTS:
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3

INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
J I 11 I ILI
I .I y I.. F, l„1.
I..1 L. .taa. ,.,.,.
�. T„ „fI...1 d� 1.
1. L1,.,t., C.,..L.J. T.a,,.
Phone: Fax:
D,. 1.. TOTWUL. L,J,1L
D.1 th . TOTW a,1th . nil 5 n.tf d., L.1tL..,1.1 Tl ,V LISI,iy
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
Ii�d�elriel Iiiepeetien Ceninlente:
OVERALL SUMMARY AND COMMENTS:
Comments: Files were well organized and reflected frequent communication with SIU representatives
to address performance issues.
Requirements:
Recommendations:
NOD: ❑ YES ® NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ® NO
POTW Rating: �(
Satisfactory X Marginal UnSatisfactory
PCI COMPLETED BY: Alex Lowe, DWR, WSRO DATE: July 28, 2022
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 4