NC0021211_202309PAI_20230928

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
City of Graham
Tonya Mann
Utilities Director
PO Box 357
Graham, NC 27253
NORTH CAROLINA
Environmental Quality
September 26, 2023
SUBJECT: Pretreatment Audit
City of Graham
Main Program Permit (NPDES) #NC0021211
Alamance County
Dear Ms. Mann:
On September 12th, 2023, a Pretreatment Audit was performed by Tricia Lowery of the Winston-Salem
Regional Office. Shelby Smith, Pretreatment Coordinator, assisted Ms. Lowery and was present during the
audit. The purpose of this audit was to determine the effectiveness of the Control Authority's pretreatment
program regarding SIU 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), of which 3 are categorical users (CIU).
Control Authority Interview
There are no plant problems related to pretreatment issues.
Pretreatment Program Elements Review
The Headworks Analysis (HWA) renewal was submitted on 9/28/2022 and is awaiting approval by the
Division.
The last Industrial Waste Survey (IWS) was submitted on 9/28/2022 and is awaiting approval by the
Division.
The Sewer Use Ordinance (SUO) was approved on 9/14/2011.
The Enforcement Response Plan (ERP) was submitted on 2/7/2020 and approved on 2/14/2020.
The Long -Term Monitoring Plan (LTMP) was submitted on 9/28/2022.
DffNorth Carolina Department of Environmental Quality I Division of Water Resources
oan caaouNn
Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105
M336.776.9800
oep.m.m or em�nmen� Qualm

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 USA Dutch, #IUP 4001 revealed that the monitoring data was organized and
compliant.
The slug control plan for USA Dutch, #IUP 4001 was in order.
Industrial Inspection Comments
See Pretreatment Compliance Inspection Report
Action Items
The following item of concern were noted during audit of SIU:
1. No spill pallets for caged poly totes
The pretreatment program is considered satisfactory. The Control Authority runs an excellent pretreatment
program. If you have any questions, please contact Tricia Lowery at [phone], or me at (336) 776-
9800.
Sincerely,
EI D-ocu S�igfned 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
naparMeM of EmironmanW 9uallly

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 Graham
2. Control Authority Representative(s): Shelby Smith
3. Title(s): Pretreatment Coordinator
4. Address of POTW: Mailing P.O. Drawer 357
City Graham
Zip Code 27253
Phone Number 336-570-6721 Fax Number 336-513-4402 E-Mail ssmith(&cityofgraham.com
5. Audit Date 09/12/2023
6. Last Inspection Date: 09/29/2022 Inspection Type: ® PCI ❑ Audit
7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s) ? ® Yes ❑ No
If No, Explain.
8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? ® Yes ❑ No
If Yes, Explain. June 1-3, 2023 — BOD Weekly Average Violation — 42.7 mg/L Result — Limit is 18 mg/L
June 1-3, 2023 — TSS Weekly Average Violation —132.5 mg/L Result — Limit is 45 mg/L
June 25 — 30, 2023- BOD Weekly Average Violation — 25.7 mg/L Result — Limit 18 mg/L
June, 2023 — Ammonia Monthly Limit — 5.2 mg/L Result — Limit is 4.0 mg/L
June, 2023 — TSS Monthly Limit — 34.2 mg/L Result — Limit is 30 mg/L
June, 2023 — BOD Monthly Limit —18.3 mg/L Result — Limit is 12.0 mg/L
See copy of attached explanations
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
INICI0I0I2 I1 12 I1 I1
MM/DD/YY
�4 11 122I
10: Current Number of Significant Industrial Users (SIUs)?
11: Num..ber..of .SIUs. .wi.th No IUP, or with an Expired IUP?
...............
12: Number of SIUs Not Inspected by POTW in Last Calendar Year?
......................................................................................................
13 : Number of SIUs Not Sampled by POTW in Last Calendar Year?
................................................................................................
14: Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi -Annual Periods?
15: Number of SIUs in SNC for Reporting During Either of Last 2 Semi -Annual Periods?
....................................................................
16. Number of SIUs in SNC with Pretreatment Schedule?
................................................................................................................................................................................................. .
17. Number of SIUs on Schedules?
................................................................................................................................................................................................. .
18: Current Number of Categorical Industrial Users (CIUs)?
19. Number of CIUs in SNC?
................................................................................................................................................................................................. .
1. Cintas — Pipe 01 , Pipe 02 — Industrial Laundry
2. Novaflex — CIU — 428 — Hose Manufacturer — Rubber Manufacturing
3. Stericycle — Medical Waste Incineration Facility
4. Thunder Metals East (Formally Metal Impact East)- CIU — 467.36 — Gas Cylinder Manufacturer - (Aluminum Pressed)
— Aluminum Forming
5. USA Dutch — CIU — 433 — Metal Finishing
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)
9/28/2022
® Yes ❑ No
❑ Yes ❑ No
**
Industrial Waste Survey (IWS)
9/28/2022
® Yes ❑ No
❑ Yes ❑ No
**
Sewer Use Ordinance (SUO)
9/07/2011
® Yes ❑ No
09/14/2011
® Yes ❑ No
--
Enforcement Response Plan (ERP)
2/07/2020
® Yes ❑ No
2/14/2020
® Yes ❑ No
--
Long Term Monitoring Plan (LTMP)
9/28/2022
® Yes ❑ No
❑ Yes ❑ No
**
"submitted and awaiting approval
al Authoritv (Sewer Use Ordinance-S
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. Haw River (CIU — Novaflex)
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. — Adopted by Haw River — 2/6/89 — Adopted by Graham — 2/7/89
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 11/01/11— Graham SUO — per agreement the Industry is under City of
Graham's SUO
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
Resources
-Please Rate the Following: S=Satisfacto M=Mar inal U=Unsatisfactory
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
®S ❑M ❑U
Access to POTW Vehicles for
Sampling, Inspections, and
®S ❑M ❑U
Emergencies
Access to Operable Sampling
Equipment
®S ❑M ❑U
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
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. Use the State's website forms and outlines for our pretreatment program. Additionally use Excel, Word,
Microsoft Office and an IT Department for any technical issues and support.
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Industries are charged cost plus 20% for sampling when done by a commercial lab. They are charged per the City of
Graham fee schedule for sampling/analysis done by the City of Graham. The fee schedule is reviewed and adjusted
annually, and adjustments are made inline with the cost of the analysis and supplies. Additionally have a BOD and TSS
surcharge program which is 32C per lb. for BOD over 300 mg/L and TSS over 250 mg/L
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. We are currently in the process of a plant upgrade from 3.5 MGD to 5.0 MGD which should
be completed in 2026. This upgrade will include BNR. The new permit includes the permit limits which will go into effect
with the plant expansion flow.
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 consulting group requested info on one of the
industries (Stericycle) because of an environmental audit. They had a direct request for information. Had this request before
so followed the Freedom of Information Act in providing the information and informed the industry of the request.
Additionally had a request for PFAS testing results which were done on POTW influent during the requested pretreatment
office 2019 sampling event. Once again followed the Freedom of Information Act and provided the requested information.
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? If this request was made, the industry would need to prove why the
info was proprietary, then refer industry to City's pretreatment manual stating any effluent discharge information cannot
be confidential.
35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? ® Yes ❑ No
Periodically meet with industries if they have new employees involved in pretreatment, new rules about pretreatment are
coming, problems are occurring at the industries or they are looking at potential changes they would like to explore.
36. Is the public notified about changes in the SUO or Local Limits? ® Yes ❑ No
Changes would have to be approved by City Council so there would be notice of the meeting in the paper, it would be
updated on website and the changes would be noted in bi-annual newsletter to the citizens.
37. Were all industries in SNC published in the last notice? ® Yes ❑ No Novaflex, in SNC for BOD in 2021 and they
were published.
Permitting (Industrial Waste Survey-IWS)
38. How does the POTW become aware of new or changed Users? Work closely with inspection, planning and zoning
dept. New businesses must obtain a permit from inspections and at that time they are given an IWS short form to
complete which is contact information and description of business. This form is also City's first screening for
dental amalgam sources. At the end of the month, the PT program is given the short forms from the planning
dept. and then determine if there is immediate need for an IU application. If not, the short forms are held for 2
months and then request water average usage to determine if they are a >25,000 gpd user and potentially a SIU
due to this. Also have a TRC (technical review committee) meeting to discuss large new businesses within public
works departments. Will also pick out obvious SIU's quickly from the short forms and proceed with the IU
applications.
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?) Investigate nature of the businesses' water usage/disposal needed, evaluate on SIU criteria/CIU criteria,
sample if necessary, pre -inspect if necessary and issue or modify a permit as needed. Current industries stay in
regular contact with PT program and are aware if any changes they must notify and program would re-examine
and evaluate those changes together to determine impact on the WWTP.
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
❑Yes ®No If Yes, How many are there? NA
Please list each site and how it is permitted, if applicable. NA
41. Does the POTW accept waste by (mark if applicable) ❑ Truck ❑Dedicated Pipe ® NA
NC DWR Pretreatment Audit Form Revised: December 2016 Page 3

42. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples drawn,
manifests required) NA — None Accepted
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: Loading based on history if needing a change. CIU limits if CI — maybe more stringent — If
allocation issues, history would sometimes help reduce a limit.
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? NA
45. If yes to #44, What is being done to address the over allocations? (short-term IUPs, HWA to be revised, pollutant study, etc.)
NA
46. Does the POTW keep pollutant loading in reserve for future growth / safety? ® Yes ❑ No
If yes, what percentage of each parameter 10% - Have slightly lower safety reserve right now. With plant expansion will
need to update headworks which will hopefully adjust allocations as the POTW will be more efficient in areas.
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)
Categorical parameters dictate if CIU- use POC from NPDES an LTMP, would also monitor for any specific parameters if
listed on IU permit application if in any high amounts or any concerning chemicals.
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Conduct with minimum frequency as determined by State and Federal Regulations - 2 times per year — once every six
months. Will check more frequently if issues arise and warrant more sampling. Also sampling 2 other times a year for
surchargables.
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? NA
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. Review results from sampling and judging compliance. Follow the
66% and 33% for chronic and TRC SNC determination. Additionally follow 30-day time limits for resamples by the
industries for violations upon their notice of the violation.
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 NA —Use Division's form
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 industries have spill plans.
54. What criteria are used to determine if a slug/spill control plan is needed?
All industries have the spill plans.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Review plan and conduct inspections to verify that all potential spills/slug sites are addressed. Verify during inspections
that emergency contacts are posted, correct, and proper clean-up plans are in place. Industries are asked each year at
inspection to review and update the plan if needed. If not, ask for correspondence stating that.
56. How does the POTW decide where the sample point for an SIU should be located?
Sampling locations are expected to be installed downstream from the process discharge. The locations must always be
accessible by PT staff if required or needed. Safety of the location is considered as well. PT program is usually involved in
the design with large companies that are confirmed to be SIUs / CIUs.
Additionally involved at beginning of construction or go into a new facility.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 4

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. Certified lab pulls all pretreatment program
required samples — POTW randomly accompanies lab for sampling to verify procedures.
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.
Meritech uses their own COC for their sampling — should be filled out completely — it is reviewed when results are received.
In- house COC for POTW surcharge sampling as well.
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? ® YES ❑ 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 05 year expiration ®Other
Explain. Plant expansion
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?
POTW in the construction phase for an upgrade from 3.5 MGD to 5.0 MGD which will also include adding BNR.
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. USA DUTCH
67. IUP Number
4001
W ii
11
68. Does File Contain Current Permit?
® Yes ❑ No
❑
Ycs ❑
No 11
❑
Yes
❑
No
69. Permit Expiration Date
12-11-2023
70. Categorical Standard Applied I.E. 40 CFR, Etc. Or N/A
1 433
71. Does File Contain Permit Application Completed Within One Year Prior
® Yes ❑ No
❑Yes ❑ No
El Yes El No
to Permit Issue Date?
72. Does File Contain Inspection Completed Within Last Calendar Year?
® Yes ❑ No
I
❑
Yes
❑
No 11
❑
Yes
❑
No
73. a. Does File Contain Slug/Spill Control Plan?
a. NYes ❑No
a. ❑Yes ❑No
a. ❑Yes ❑No
b. If No, is One Needed? See Inspection Form from POTW
b. ❑Yes ❑No
b. ❑Yes ❑No
b. ❑Yes ❑No
74. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
Yes❑No❑N/A
P
❑Yes❑No❑N/A
❑Yes❑No❑N/A
Organic Management Plan TOMP ?
75. a. Does File Contain Original Permit Review Letter from Division?
a. NYes ❑No
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 ❑ �fl
❑ Yes ❑ No
❑Yes ❑ No
Sampling as Required b IUP, includingFlow?
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
® Yes ❑ No
ji
❑ Yes ❑
No
❑ Yes ❑ No
78. During Most Recent Semi -Annual Period, Did SIU` Complete its
®Yes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
Sampling as Required by IUP, including Flow?
79. During Most Recent Semi -Annual Period, Did SIU submit all reports on
EYes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
time?
80a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑NoEN/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 by 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❑NoEN/Ak
es❑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 sam lingof SIU?
c.❑yes❑No❑N/A
c.❑Yes❑No❑N/A
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
I ❑
Yes
®
No
❑
Yes
❑
No 11
❑
Yes
❑
No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
❑Yes❑NoEN/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
Specified in POTW's ERP OVs, Penalties, timing, etc.)?
86. Does File Contain Penalty Assessment Notices?
I ❑Yes❑NoEN/A
I ❑Yes❑No❑N/A I
❑Yes❑No❑N/A
87. Does File Contain Proof Of Penalty Collection?
❑Yes❑NoEN/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
88. a. Does File Contain Any Current Enforcement Orders?
a.❑Yes❑No®N/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
b.❑Yes❑No❑N/A
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
❑Yes ®No
Yes ❑ No
❑ Yes El No
Information For You?
FILE REVIEW COMMENTS:
Files are in good order.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 6

INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
I N I C 1 0 10 I2 I1 I2 I1 I1 I 14 11 1221
1. Industry Inspected: USA Dutch
2. Industry Address: 778 Woody Dr., Graham, NC
3. Type of Industry/Product: Sheet metal fabrication/mechanical assembly/power coat finishing
4. Industry Contact: Jeff Albaugh Title: Operations Manager Phone: [phone] (0206) 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:
Extensive initial interview conducted reviewing fee updates, PFAS/Dioxane updates, product changes, process changes, raw
material changes, production rates, # of employees, future plans, sludge handling, sampling, and spill protocols. Additionally,
records were reviewed (lab results, etc).
Complete plant tour with emphasis on GAT 4-stage alkaline wash system/GFS powder paint booth. This is a self-contained
system involving a concrete barrier in production area. CIU recently switched from barrels to IBC caged poly totes. No spill
pallets for caged poly totes, but on order. CIU did have spill pallets for the barrels they were using previously. Other than the
need for spill pallets, no other issues were found during the plant tour.
Audit SUMMARY AND COMMENTS:
Audit Comments: Make sure they place caged totes on spill pallets with follow up.
Requirements: _
Recommendations:
NOD: ❑ Yes ® No
NOV: ❑ Yes ® No
QNCR: ❑ Yes ® No
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory ❑
Audit COMPLETED BY: Tricia Lowery DATE: 9/12/2023
Winston Salem Regional Office
NC DWR Pretreatment Audit Form Revised: December 2016 Page 7