NC0026824_Pretreatment Audit_20221123

DocuSign Envelope ID: EA84EAEE-841B-436E-B052-D63B8FAB2041
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
November 23, 2022
Mr. Scott Schroyer
Executive Director
South Granville Water and Sewer Authority (SGWASA)
415-B Central Ave.
Butner, NC 27509
Subject: Pretreatment Audit
South Granville Water and Sewer Authority
SGWASA WWTP - NPDES Permit No. NC0026824
Granville County
Dear Mr. Schroyer:
On August 31, 2022, Cheng Zhang of the Raleigh Regional Office (RRO) conducted a Pretreatment
Audit of SGWASA's pretreatment program. The assistance given by Ms Shanell Thomas, the
Wastewater Treatment Compliance Supervisor, was greatly appreciated. The audit report is attached.
Findings during the inspection were as follows:
1. SGWASA has one Significant Industrial User (SIU), Newton Instruments, which is not a
Categorical Industrial User (CIU). It was noted that Newton Instruments was not in SNC for the
two most recent semi-annual periods.
2. The pretreatment inspection file review included Newton Instrument (Permit No. 0004. The files
needed for review were available for inspection, contained all the required elements and were in
excellent condition.
3. The POTW and Newton Instrument completed monitoring as required by the IUPs during the
first semi-annual period of 2022. Newton had missed flow in April, May, and June 2022. Flow
meter was repaired on June 14, 2022. The POTW addressed these violations by issuing three
Notices of Violation as required in the Enforcement Response Plan (ERP).
4. A review of the files containing the pretreatment program elements was conducted. These files
are well organized. All elements are up to date. It is recommended that the Long Term
Monitoring Plan (LTMP) be updated by using the updated PQLs for chromium, cyanide,
nickel and selenium.
5. LTMP data were reviewed during the inspection. It was noted that all locations were sampled
with required frequencies and all samples analyzed with required detection levels since the last
inspection. The data were very well organized in spreadsheets.
NORTH CAROLINA
o.y,ror.m or Environmental ou.i�
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office I 3800 Barrett Drive I Raleigh, North Carolina 27609
919.791.4200

DocuSign Envelope ID: EA84EAEE-841B-436E-B052-D63B8FAB2041
6. During the audit, Ms. Thomas inspected the lone SIU, Newton Instrument. The inspection was
very thorough and covered all required areas.
SGWASA's pretreatment Program is very well managed. Thank you for your continued support of the
Pretreatment Program. If you have any questions or comments, please call Cheng Zhang at (919) 791-
4200 (or email: [e-mail]).
Enclosure: 2022 SGWASA PT Audit Form
CC: Laserfiche
Shanell Thomas, SGWASA (electronic copy only)
D_E
NORTH CARCLINA
gaparhnanl of Environmental quality
Sincerely,
—DocuSigned by:
VauA.t,SSA, f. lika tAlta
"—B2916E6AB32144F...
Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11611 Mail Service Center I Raleigh, North Carolina 27699-1611
919.707.9000

DocuSign Envelope ID: EA84EAEE-841B-436E-B052-D63B8FAB2041
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: South Granville Water and Sewer Authority
2. Control Authority Representative(s): Shanell Thomas
3. Title(s): Wastewater Treatment Compliance Supervisor
4. Address of POTW:
Mailing 415-B Central Ave.
City Butner Zip Code 27509
Phone Number 919-575-3367 Fax Number 919-575-4547 E-Mail sthomasAsgwasa.org
5. Audit Date 08/31/2022
6. Last Inspection Date: 09/28/2021 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 ❑ No ® NA
Parameters Covered Under Order
ICIS Coding
Main Program Permit Number
IN IC I OI OI 2 1 6 1 8 1 2I 4 I
10. Current Number of Sivnificant Industrial Users (SIUs)?
11. Number of SIUs with No IUP, or with an Expired IUP?
MM/DD/YY
I 08 I 31 I 22
1
0
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?
0
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)?
19. Number of CIUs in SNC?
0
0
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DocuSign Envelope ID: EA84EAEE-841B-436E-B052-D63B8FAB2041
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)
7/29/2021
01 Yes ❑ No
3/14/2016
0 Yes ❑ No
4/1/2021
Industrial Waste Survey (IWS)
6/25/2019
I4 Yes ❑ No
9/3/2019
I:1 Yes ❑ No
7/1/2024
Sewer Use Ordinance (SUO)
12/28/2012
/1 Yes ❑ No
1/2/2013
/1 Yes ❑ No
Enforcement Response Plan (ERP)
2/13/2020
/1 Yes ❑ No
2/14/2020
/1 Yes ❑ No
Long Term Monitoring Plan (LTMP)
7/31/2019
0 Yes ❑ No
10/25/2019
/1 Yes ❑ No
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. SGWASA owns Town of Creedmoor's collection system.
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 11/7/2013
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
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
None
Resources
29. Please Rate the Following: S=Satisfactory M=Marginal 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
/1 S ❑M ❑U
Access to Operable Sampling
Equipment
0 S ❑M ❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
0 S ❑M ❑U
Reference Materials
►1S ❑M ❑U
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
0 S ❑M ❑U
Computer Equipment (Hardware and
Software)
0 S ❑M ❑U
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30. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No
Explain Yes or No. Spreadsheet
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Permit renewal fee
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? If a citizen were to request a review of pretreatment
program files, an appointed time/place would be arranged, all confidential material would be removed from the respective files,
and the citizen would be given access to the requested files in the presence of the Industrial Pretreatment Coordinator.
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? Made sure that the information was proprietary to their process and
keeps information in a separate file.
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 ® NA
Permitting (Industrial Waste Survey-IWS)
38. How does the POTW become aware of new or changed Users? From Town Planning Department, main office. Any
new commercial/industrial user needs to complete short IWS form, long form (if needed), onsite visit before
water/sewer service is online.
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?) A new Industrial Waste Survey and permit application is proceeded.
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) N/A
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?
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 20%
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: EA84EAEE-841B-436E-B052-D63B8FAB2041
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)
Reviewing HWA, determine what the plant can handle, and categorical limits, parameters on LTMP.
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Looking at industry historical discharge. State requirement is once/6 months to sample industries. More frequent sampling
for new industries.
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. Use DWR spreadsheet.
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
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Slug control guidance on the DWR website
56. How does the POTW decide where the sample point for an SIU should be located?
End of process
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 ❑ No If yes, Explain.
58. Who performs sample analysis for the POTW for Metals Meritech
Conventional Parameters Meritech
Organics Meritech
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
POTW uses Meritech's COC, no in-house.
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 ❑NPDES limits change
❑More LTMP data available ❑Resolve over allocation ❑5 year expiration ❑Other
Explain.
63. In general, what is the most limiting criteria of your HWA? ❑Inhibition ® Pass Through ❑Sludge Quality
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DocuSign Envelope ID: EA84EAEE-841B-436E-B052-D63B8FAB2041
64. Do you see any way to increase your loading in the future (Example: obtaining more land for sludge disposal)? ❑ Yes ® No
Explain. No needed.
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: EA84EAEE-841B-436E-B052-D63B8FAB2041
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION)
66. User Name
1. Newton
2.
3.
67. IUP Number
0004
68. Does File Contain Current Permit?
0 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
69. Permit Expiration Date
7/31/23
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
N/A
71. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
/1 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
72. Does File Contain Inspection Completed Within Last Calendar Year?
/1 Yes ❑ No
❑ Yes ❑ No
❑ 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
Certification, Does File Contain a Toxic
(TOMP)?
❑Yes❑NoON/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
❑ Yes ❑ No
❑ Yes ❑ No
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
Al Yes ❑ No
❑ Yes ❑ No
❑ 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 ❑No❑N/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❑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?
❑Yes❑NoON/A
❑ Yes ❑ No
❑ 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 ❑ No
❑ Yes ❑ No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
Specified in POTW's ERP (NOVs, Penalties, timing, etc.)?
DYes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
86. Does File Contain Penalty Assessment Notices?
❑Yes❑NoNN/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
87. Does File Contain Proof Of Penalty Collection?
❑Yes❑NoON/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❑No®N/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?
i1 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
FILE REVIEW COMMENTS:
#82 — Newton had missed flow in April, May, and June 2022. Flow meter was repaired on June 14, 2022.
#85 — POTW addressed these violations by issuing 3 NOVs per ERP requirements.
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DocuSign Envelope ID: EA84EAEE-841B-436E-B052-D63B8FAB2041
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
INICIO 10 I 21 61 8 12 14I I08I14 I17I
1. Industry Inspected: Newton Instrument Company
2. Industry Address: 111 E A St, Butner, NC 27509
3. Type of Industry/Product: Metal Finisher/Racks, cabinets, frames and superstructure
4. Industry Contact: Sammy Clayton Title: Environmental & Safety Administrator 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:
Thorough and detailed inspection
Audit SUMMARY AND COMMENTS:
Audit Comments: Well managed program
Requirements: None
Recommendations: Update LTMP by using updated PQLs for chromium, cyanide, nickel, and selenium.
NOD: ❑ Yes ® No
NOV: ❑ Yes ® No
QNCR: ❑ Yes ® No
POTW Rating:
Satisfactory
Marginal ❑ Unsatisfactory ❑
Audit COMPLETED BY: Cheng Zhang, Raleigh Regional Office DATE: 08/31/2022
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