NC0024112_202306PAI_Cover Letter_20230713

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
City of Thomasville
Michael Brandt
City Manager
PO Box 368
Thomasville, NC 27361-0368
NORTH CAROLINA
Environmental Quality
July 13, 2023
SUBJECT: Pretreatment Audit
City of Thomasville
Main Program Permit (NPDES) #NC0024112
Davidson County
Dear Mr. Brandt:
On June 8, 2023, a Pretreatment Audit was performed by Tricia Lowery and Jesse Barnes of the Winston-
Salem Regional Office. Misty Conder, Pretreatment Coordinator, assisted staff and was present during the
audit. The purpose of this audit was to determine the effectiveness of the Control Authority's pretreatment
program regarding SI J inspections., which includes the initial interview, tour of SIU facility, sampling
review, and an exit interview.
Background
The Control Authority has 5 Significant Industrial Users (SIUs), to which all 5 are categorical users (CIU).
Control Authority Interview
There are no plant problems related to pretreatment issues other than a temporary Barium increase at
influent noted under "Action Items".
• LTMP was submitted October 2022. PQLs have been updated for Cd, Pb, & Hg (Hg methodl361E).
POC's: PFAS, 1,4-Dioxane, Hardness.
• Ms. Conder is working to complete revisions to HWA (due 10/17/23).
• All SIU permits have been updated (was due 12/31/22).
• Historical SNC is incorrect and needs correction/updating.
Pretreatment Program Elements Review
The Headworks Analysis (HWA) renewal was submitted on 11/22/22. The HWA approval date is pending
as revisions are needed. The revisions to HWA are due 10/17/23.
The last Industrial Waste Survey (IWS) was submitted on 7/3/15. An extension was granted and the IWS
is due 8/1/2023. The next IWS is due date is pending.
DffNorth Carolina Department of Environmental Quality I Division of Water Resources
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Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105
M336.776.9800
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The Sewer Use Ordinance (SUO) was approved on 3/25/13.
The Enforcement Response Plan (ERP) was submitted on 2/11/20 and approved on 2/14/20.
The Long -Term Monitoring Plan (LTMP) was submitted on 10/5/22.
LTMP File Review
The Long -Term Monitoring Plan (LTMP) is being conducted at the proper locations and frequencies.
Industrial User Permit (IUP) File Review
A review of the file for McIntyre, #IUP 0031 revealed that the monitoring data was organized and compliant.
The slug control plan for McIntyre, #IUP 0031 was in order.
Action Items
The following items of concern were noted:
1. 4 of the 5 CIUs were in SNC, 2 SIUs in SNC for limit violations, and 3 in SNC for reporting (over
last 2 semi-annual periods).
2. There was a Barium increase in influent (noted on PAR 2022). 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.
The pretreatment program is considered satisfactory. The Control Authority runs a acceptable pretreatment
program. If you have any questions, please contact Tricia Lowery at [phone], or me at (336) 776-
9800.
Sincerely,
Docu S�igTned by:
145B49E225C94EA...
Lon T. Snider
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
REQ� North Carolina Department ofEnvironmental Quality I Division ofWater Resources
Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Winston-Salem, North Carolina 27105
NORTH CAROLINA 336.776.9800
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