NC0024112_202306PAI_20230706

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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 Thomasville Hamby Creek WWTP
2. Control Authority Representative(s): Misty Conder
3. Title(s): Laboratory Supervisor/Pretreatment Coordinator
4. Address of POTW: 110 Optimist Park Road, Thomasville, NC
Mailing PO Box 368
City Thomasville Zip Code 27361
Phone Number 336-475-4246 Fax Number E-Mail misty.conder(&thomasville-nc.gov
5. Audit Date 6/8/2023
6. Last Inspection Date: 3/8/2022 Inspection Type: ® PCI ❑ Audit
7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s) ? ❑ Yes ® No
If No, Explain. The IWS is still outstanding. Multiple factors beginning with COVID have delayed completion.
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
N I C 1 0 0 2 1 4 1 1 1 2 1 Exp: 04 30 1 26
10. Current Number of Significant Industrial Users (SIUs)? 5
.......................................................................................................................................................................................................................................................................................................
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? 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? 2
.......................................................................................................................................................................................................................................................................................................
1.5. Number of SIUs in SNC for Reporting During.. Either of Last 2 Semi -Annual Periods? 3
..........................................................................................................................
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)? 5
19. Number of CIUs in SNC? 4
NC DWR Pretreatment Audit Form Revised: December 2016 Page 1

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)
11/22/22
®Yes ❑ No
4/16/2016
® Yes ❑ No
10/17/23(revision)
Industrial Waste Survey (IWS)
7/3/15
®Yes ❑ No
9/11/15
❑Yes ® No
Ext. 8/1/23
Sewer Use Ordinance (SUO)
10/15/12
®Yes ❑ No
3/25/13
❑ Yes ®No
Enforcement Response Plan (ERP)
2/11/20
®Yes ❑ No
2/14/20
®Yes ❑ No
Long Term Monitoring Plan (LTMP)
10/5/22
®Yes ❑ No
10/27/14
®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. Trinity
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. Trinity has continually protested the cost and has taken over maintenance of the stations. Trinity stated
their intent to redirect those stations to High Point. High Point already receives a portion of Trinity wastewater.
24. Date of Last SUO Adoption by Local Council 10/15/2012
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
lease Rate the Following: S=Satisfacto M=Mar inal U=Unsatisfactory
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
Ms. Conder over the past few months has been maintaining the
POTW's Pretreatment Program
❑S ®M ❑U
PT program and laboratory single-handedly. She is currently
training new personnel to handle laboratory duties so she will
have more time to focus on PT Program.
Access to POTW Vehicles for
Sampling, Inspections, and
®S ❑M ❑U
Emergencies
Access to Operable Sampling
Equipment
®S Elm Flu
Availability of Funds if Needed for
Additional Sampling and/or Analysis
®S ❑M ❑U
Reference Materials
®S ❑M ❑U
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
®S ❑M ❑U
Computer Equipment (Hardware and
See #30
Software)
❑S ®M ❑U
NC DWR Pretreatment Audit Form Revised: December 2016 Page 2

30. Does the POTW have an adequate data management system to run the pretreatment program? ❑ Yes ® No
Explain Yes or No. The city has investigated several FOG software programs to help manage grease trap inspections. A
new program will be implemented in the fall of 2023. The new system will integrate other city personnel and records to
help track rapid change of ownership of restaurants as well as industries. It is anticipated to be more successful than
previous programs. Other areas of pretreatment program (industrial) are managed well through Excel.
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Monthly billing for all participants in SIU program. No fee yet for FOG programs.
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 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? Requests are forwarded to Pretreatment Supervisor.
Industries involved may be notified. Documents are compiled and forwarded to the City Attorney for final approval and
response. If any objections are made of the documents provided, the industries involved may submit a written request to
have information withheld. These requests would be reviewed by the City Attorney. Generally, the information withheld
involves specific process operations.
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? Specific process operations information industries provide on the SIU
application is kept confidential. **See question 33 above.
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? Industries request SIU application, or the IWS of
industries in treatment area. In the past, IT ran a report of businesses the city was billing for water or sewer. The
new software being installed this fall will enable the pretreatment program to run the report frequently and as
needed, helping the program keep track of businesses opening and closing in area.
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?) An SIU application is sent to businesses and/or industries of interest (especially if water use is high).
Application is reviewed by Ms. Conder and a determination is made. If business/industry are deemed an SIU and
need a permit, the application is processed to completion. If not, application is filed. Follow ups will occur if
business/industry changes.
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) The only trucked waste received at POTW is from city lift stations when maintenance is
performed or 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:
44. Review POTW's copies of current allocation tables for each WWTP. Are there any over allocations? ® Yes ❑ No
NC DWR Pretreatment Audit Form Revised: December 2016 Page 3

If yes, what parameters are over allocated? Total Nitrogen and LL Mercury are over allocated in the last reviewed
but unapproved HWA. Additional uncontrollable testing was suggested to be done for one year to revise and
update the HWA. This is scheduled for completion in October 2023.
45. If yes to #44, What is being done to address the over allocations? (short-term IUPs, HWA to be revised, pollutant study, etc.)
Additional uncontrollable testing was suggested to be done for one year to revise and update the HWA. This is
scheduled for completion in October 2023.
46. Does the POTW keep pollutant loading in reserve for future growth / safety? ® Yes ❑ No
If yes, what percentage of each parameter target 10% Metals limits are being pushed with new industries coming in
47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) ❑ Yes ® No
If yes, Explain.
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)
Pollutants on application, categorical parameters, any parameter deemed potentially damaging or potentially to be
regulated by the State (ie: 1,4-Dioxane, PFAS).
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Most based on historical frequencies. New industries are determined by past SIUs or until a measurable representation of
regular daily operations can be documented. Industries with consistent streams may have less frequency than those with
changing streams.
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 the state provided forms in Excel and Word for determining
compliance, as well as records of SIU submittals for potential reporting SNC violations.
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?
All industries are required to have a plan.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Check for spill containment and clean-up plans, as well as notification of the WWTP of a spill.
56. How does the POTW decide where the sample point for an SIU should be located?
Application and Authorization to Construct specify sample points must be after final treatment but prior to contact with
sanitary waste. Additionally, a covered location is requested to prevent rainfall interference with flow.
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. POTW follows SOP for sampling, SIUs are
periodically asked to describe sampling.
58. Who performs sample analysis for the POTW for Metals Contract Lab
Conventional Parameters POTW Lab
Organics Contract Lab
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
In-house COC has pH calibration data, date, time, preservation used, and type (composite/grab) of sample collected.
Additionally, analysis requested of each sample is specified. Receipt date/time and temperatures are also noted. Date and
time information is transferred from the in-house COC to the contract lab COC for any samples going out for analysis.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 4

Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis (HWA)
60a.
60b.
60c.
60d.
60e.
60f.
Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑ NO
Are Correct Detection Levels being used for all LTMP/STMP Monitoring? EYES ❑ NO
Is LTMP/STMP Data Maintained in Table or Equivalent? ® YES ❑ NO Is Table Adequate? ® YES ❑ NO
All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? ® YES ❑ NO Division Inspector, verify yourself!
If NO to any above, list violations
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. Additional uncontrollable data is being collected per DWR request to resolve TN and mercury issues.
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?
Ms. Conder requests date change for next IWS (since extension of IWS due in 2020 will be submitted 812023) be 12 months
before next HWA due (assuming next HWA would be due 2026- 2027), so both are not being conducted at the same time.
POTW Interview Notes:
• LTMP was submitted October 2022. PQLs have been updated for Cd, Pb, & Hg (Hg method 13 6 1 E). POC's: PFAS, 1,4-
Dioxane, Hardness.
• There was a Barium increase in influent. Ms. Conder stated it was an isolated incident at HERR. No further issues with
Barium reported. Ms. Conder is experiencing difficulties scheduling follow up inspections with HERR. Inspector will
reach out to HERR to aide in scheduling inspection.
• Ms. Conder is working to complete revisions to HWA (due 10/17/23).
• All SIU permits have been updated (was due 12/31/22).
• IWS submittal has been extended to 8/l/23. (Previous extension due date was 11/30/22).
• Historical SNC is incorrect and needs correction/updating.
• Inspector has concerns with 4 of the 5 CIUs being in SNC, 2 SIUs in SNC for limit violations, and 3 in SNC for
reporting. Inspector will follow up after next semi-annual period.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 5

INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION)
66. User Name
1. McIntyre
2.
3.
67. IUP Number
0031
11
11
68. Does File Contain Current Permit?
® Yes ❑ No
I ❑ Yes
❑
No 11
❑
Ycs
❑
No
69. Permit Expiration Date
12/31/2028
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
433
71. Does File Contain Permit Application Completed Within One Year Prior
® Yes ❑ NoIFTWsE]
No
❑ Yes ❑ No
to Permit Issue Date?
72. Does File Contain Inspection Completed Within Last Calendar Year?
®
Yes
❑ No
❑
Yes ❑ No
I ❑ Yes ❑ No
73. a. Does File Contain Slug/Spill Control Plan?
a. ®Yes ❑No
a. ❑Yes ❑No
a. ❑Yes []Nob.
If No, is One Needed? See Inspection Form from POTW)
b. ❑Yes ❑No
❑Yes ❑No
b. ❑Yes ❑No
74. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
®Yes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
Organic Management Plan (TOMP)?
75. a. Does File Contain Original Permit Review Letter from Division?
a. ®Yes ❑No
I
a. ❑Yes ❑No
a. ❑Yes ❑No
b. All Issues Resolved?
b.®Yes❑No❑N/A
b.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
76. During Most Recent Semi -Annual Period, Did POTW Complete its
❑ Yes ❑ !1
❑ Yes ❑ No
❑ Yes ❑ No
Sampling as Required by IUP, including Flow?
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
® Yes
❑
No
❑
Yes
❑
No 11
❑ Yes
❑
No
78. During Most Recent Semi -Annual Period, Did SIU Complete its
®Yes ❑No❑
❑Yes❑No❑N/A
❑Yes❑No❑N/A
Sampling as Required by IUP, including Flow?
N/A
79. During Most Recent Semi -Annual Period, Did SIU submit all reports on
®Yes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
time?
80a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
file includeprocess/dilution flows as Required by IUP?
80b. For categorical IUs with Production based limits, does file include
❑Yes❑NOON/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
production rates and/or flows as Required b IUP?
81. During Most Recent Semi -Annual Period, Did POTW Identify All
®Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
Limits Non -Compliance from Both POTW and SIU Sampling?
82. During Most Recent Semi -Annual Period, Did POTW Identify All
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
Re ortin Non-Com liance from SIU Sampling?
83. a. Was POTW Notified by SIU (Within 24 Hours) of All Self-
a.❑Yes❑No®N/A
a.❑Yes❑No❑N/A
a.❑Yes❑No❑N/A
Monitoring Violations?
b. Did Industry Resample and submit results to POTW within 30 Days?
b.❑Yes❑No®N/A
b.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
c. If applicable, did POTW resample and obtain results within 30 days of
❑ c.Yes❑No®N/A
becomingaware of SIU limit violations in the POTW's sampling of SIU?
c.❑Yes❑No❑N/A
c.❑Yes❑No❑N/A
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
❑
Yes ®
No
11 ❑
Yes ❑
No
❑
Yes
❑
No [I
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
❑Yes❑NoON/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
Specified in POTW's ERP (NOVs, Penalties, timing, etc.)?
86. Does File Contain Penalty Assessment Notices? Historical notices
®Yes❑No❑N/A
I ❑Yes❑No❑N/A II
❑Yes❑No❑N/A II
87. Does File Contain Proof Of Penalty Collection? Historical collections
OYes❑No❑N/A
❑Ycs❑No❑N/A
I ❑Ycs❑No❑N/A
88. a. Does File Contain Any Current Enforcement Orders?
.❑Yes❑No®N/A
Fb.[iYesEiNooN/A
a.❑Yes❑No❑N/A
a.❑Yes❑No❑N/A
b. Is SIU in Compliance with Order?
b.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
Yes ® No
❑ Yes ❑
ElYes ❑ No
Information For You?
1[❑
fl
FILE REVIEW COMMENTS:
LTMP file data correctly entered on DMRs. All files are in order with no discrepancies found.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 6

INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
INIC101012 14111112I 4 130 126
1. Industry Inspected: McIntyre
2. Industry Address: 310 Kendall Mill Rd, Thomasville, NC
3. Type of Industry/Product: Metal Fabricator 4 Retail displays
4. Industry Contact: Alan Russell Title: Facilities Manager 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:
McIntyre does not have a true pretreatment process of production wastewater. The area of concern is contained. The tanks are
cleaned routinely by Shamrock. In case of accidental spills, a dyke is in place.
There are floor drains on paint lines. The drains are directed and pass through flume. Flume goes directly to collection system,
then to WWTP. Flume is monitored daily.
Flow meter to wash basin — checked daily.
Reviewed flume calibration, Meritech sampling data, ERP, spill plan, tank cleaning documentation and preventative
maintenance schedule. No changes in production rates, raw material, or personnel.
McIntyre will be moving operations to new Lexington, NC facility in the future and will cease operation in Thomasville.
Audit SUMMARY AND COMMENTS:
Audit Comments: Inspection of McIntyre was satisfactory.
Requirements:
Recommendations: Inspector recommended spill palates in the dyke area for added protection against spills.
NOD: ❑ Yes ® No
NOV: ❑ Yes ❑ No
QNCR: ❑ Yes ® No
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory ❑
Audit COMPLETED BY: Tricia Lowery DATE: 6/8/2023
XXXX, PERCS, and XXXX, XXXX Regional Office
NC DWR Pretreatment Audit Form Revised: December 2016 Page 7