NC0036269_Inspection_20230918

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
September 18, 2023
Beverly Metcalf, Environmental Compliance Manager
WSACC
6400 Breezy Lane
Concord, North Carolina 28025
SUBJECT: Pretreatment Audit Inspection
WSACC
NPDES Permit No. NCO036269
Cabarrus County
Dear Ms. Metcalf:
Enclosed is a copy of the Pretreatment Audit Inspection (PAI) Report for the inspection of WSACC's Industrial
Pretreatment Program on September 14, 2023, by Mr. Wes Bell of this Office. This Office would like to thank you and all
Pretreatment staff for the cooperation and the assistance provided throughout this inspection.
Should you have any questions concerning this report, please do not hesitate to contact Mr. Bell at [phone] or at
wes.bellkncdeq. nc. gov.
Sincerely,
EA
DocuSigned by:
wNNuft
F161 F669A2D84A3...
Andrew H. Pitner, P.G.
Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
Enclosure: Inspection Report
Cc: NPDES Program Files - Laserfiche
DEQ�
North Carolina Department of Environmental Quality I Division of Water Resources
Mooresville Regional Office 1 610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115
704.663.1699

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT AUDIT REPORT
Background Information
1. Control Authority (POTW) Name: WSACC
2. Control Authority Representative(s): Beverly Metcalf, Wyneisha Bell
3. Title(s): Environmental Compliance Manager/Pretreatment Coordinator, EHS Compliance Tech
4. Address of POTW:
Mailing: 6400 Breezy Lane
City: Concord Zip Code: 28025
Phone Number [phone] Ext. 113 Fax Number [phone] E-Mail bmetcalf(a),wsacc.org
5. Audit Date 09/14/2023
6. Last Inspection Date: 01/06/2022 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. Overall, no consistent compliance problems; however, a monthly average flow violation was
reported in April 2023 at the Rocky River WWTP. No violations were reported at the Muddy Creek WWTP.
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
INIC1010I3 I6 I2 I6 I9
MM/DD/YY
109 114 123
10.
....................................................................................................................................................................................................................................................................................................
Current Number of Significant Industrial Users (SIUs)?
16
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?
..
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)?
3
19.
Number of CIUs in SNC?
0
NC DWR Pretreatment Audit Form Revised: December 2016
Page 1

20. PRETREATMENT PROGRAM ELEMENTS REVIEW:
Program Element
Rocky River WWTP (NC0036269)
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
05/31/22
® Yes ❑ No
02/13/18
® Yes ❑ No
In Review
Industrial Waste Survey (IWS)
11/19/18
® Yes ❑ No
01/03/19
® Yes ❑ No
11/15/23
Sewer Use Ordinance (SUO)
03/29/12
® Yes ❑ No
04/19/12
® Yes ❑ No
Enforcement Response Plan (ERP)
01/15/20
® Yes ❑ No
02/05/20
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
06/30/22
® Yes ❑ No
02/07/22
® Yes ❑ No
Program Element
Muddy Creek WWTP (NC0081621)
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
04/28/20
® Yes ❑ No
01/31/17
® Yes ❑ No
In Review
Industrial Waste Survey (IWS)
11/19/18
® Yes ❑ No
01/03/19
® Yes ❑ No
11/15/23
Sewer Use Ordinance (SUO)
03/29/12
® Yes ❑ No
04/19/12
® Yes ❑ No
Enforcement Response Plan (ERP)
01/15/20
® Yes ❑ No
02/05/20
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
06/30/22
® Yes ❑ No
02/07/22
® 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. CMU, Concord, Kannapolis, Harrisburg, Mt. Pleasant, Cabarrus
Co.
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 06/21/2012
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. All SIUs receive a copy of the ERP every IUP renewal.
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. N/A
NC DWR Pretreatment Audit Form Revised: December 2016 Page 2

Resources
29. Please Rate the Following: S=Satisfactory M=Marginal 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
Computer Equipment (Hardware and
Software)
®S ❑M ❑U
30. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No
Explain Yes or No. Excell, Hach WIMS, Microsoft Office
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Surcharges and monthly fees (covers lab and Pretreatment administration costs).
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? Schedule appointment with the Pretreatment Program
Coordinator at the Pretreatment Office. The file review is supervised by the Pretreatment Program 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? The information is reviewed by the Pretreatment Program
Coordinator. Confidential files are kept locked in a cabinet at the main WSACC Office (off Davidson Highway).
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 ❑ N/A
Permitting (Industrial Waste Survey-IWS)
38. How does the POTW become aware of new or changed Users? The Pretreatment staff is contacted by the municipal
personnel and/or Economic Development Groups. WSACC's Engineering Department will also contact the
Pretreatment staff during review for new flow acceptance requests.
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?) IWS Short/Long Form information reviewed for type of industrial activity (SIC Code), flow, discharge
characteristics/loading, POCs (including >5% of MAHL), and categorical parameters.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 3

40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
®Yes ❑No If Yes, How many are there? 1
Please list each site and how it is permitted, if applicable. CMS Landfill V/SIU permit
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 Rocky River WWTP has a designated point and piping system for septage haulers with
automated tracking system (badges), no grease allowed and no industrial wastes allowed unless prior approval.
Random sampling of septage haulers (Quarterly minimum) is also implemented by Pretreatment staff.
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.)
46. Does the POTW keep pollutant loading in reserve for future growth / safety? ® Yes ❑ No
If yes, what percentage of each parameter 20 - 25 %
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) NPDES POCs, POCs >5% MAHL, and
categorical parameters.
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
All SIUs are required to monitor on a quarterly basis. New SIUs may have to monitor more frequently based on the
projected discharge concentrations.
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. Compliance Judgment Worksheet used for SNC determinations,
violations (limit, monitoring, reporting, permit conditions, etc.) are addressed per ERP.
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?
Chemicals stored on -site, potential of the discharge to enter sewer system, capability of facility to contain a discharge via in
the drainage system or a holding tank.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate? All emergency contacts kept
updated, proper secondary containment/chemical storage practices, presence and location of emergency response
equipment to floor drains.
56. How does the POTW decide where the sample point for an SIU should be located? Sampling location must be safely accessible
for sampling staff and sampling only for the process wastewater discharge is preferred.
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. Sampling SOPS and sampler O&M manuals
58. Who performs sample analysis for the POTW for Metals: POTW's on -site certified lab
Conventional Parameters: POTW's on -site certified lab
Organics: Waypoint Analytical
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
POTW uses internal COC and/or contracted lab's COC; SIU's used contracted lab's COC.
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?
All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? ® YES ❑ NO
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 ()
® YES ❑ NO
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 El 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. Construction activities are ongoing at the Rocky River WWTP to expand capacity to 30 MGD. The project is
estimated to be completed by September 2024. Phase two of the Rocky River WWTP construction project will expand the
capacity to 34 MGD by 2027.
Summary
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment? No.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 5

INDUSTRIAL USER PERMIT (IUP) FILE REVIEW
66. User Name IF
I. S&D Coffee Commercial Park Facility
2. IPC
3. Stericycle
67. IUP Number
1045
2001
1039
68. Does File Contain Current Permit?
I ® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
69. Permit Expiration Date
1 6/30/24
12/21/26
12/31/24
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
I N/A
N/A
N/A
71. Does File Contain Permit Application Completed Within One Year Prior
® Yes ❑ No
®Yes ❑ No
® Yes ❑ No
to Permit Issue Date?
72. Does File Contain Inspection Completed Within Last Calendar Year?
® Yes ❑
I ® Yes ❑
I ® Yes ❑
No
73. a. Does File Contain Slug/Spill Control Plan?
a. ®Yes []No
a. ®Yes ❑No
a. ®Yes []No
b. If No, is One Needed? See Inspection Form from POTW
b. ❑Yes ❑No
b. []Yes []No I
b. ❑Yes ❑No
74. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
❑Yes❑NoON/A
F
❑Yes❑No®N/A
❑Yes❑No®N/A
Organic Management Plan (TOMP)?
1
75. a. Does File Contain Original Permit Review Letter from Division?
a. ®Yes []No
I 11
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 ❑ No
F977s ❑ No
® Yes ❑ No
Sampling as Required by IUP, including Flow?
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
78. During Most Recent Semi -Annual Period, Did SIU Complete its
❑Yes❑No®N/A
❑Yes❑NoON/A
❑Yes❑NoON/A
Sampling as Required by IUP, including Flow?
79. During Most Recent Semi -Annual Period, Did SIU submit all reports on
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑NoON/A
time?
80a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑No[D
❑Yes❑No®N/A
❑Yes❑NoON/A
file include process/dilution flows as Required b IUP?
80b. For categorical IUs with Production based limits, does file include
❑Yes❑NoON/A
❑Yes❑No®N/A
❑Yes❑NoON/A
production rates and/or flows as Required by IUP?
81. During Most Recent Semi -Annual Period, Did POTW Identify All
Yes❑No❑N/A
P
❑Yes❑NoON/A
®Yes❑No❑N/A
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❑NoON/A
❑Yes❑NoON/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
becomingaware of SIU limit violations in the POTW's sam lingof SIU?
❑ c.Yes❑No®N/A
c.❑Yes❑No®N/A
c.❑Yes❑No®N/A
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
❑
Yes
®
No
❑
Yes
®
No
❑
Yes
®
No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
®Yes❑No❑N/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?
0Yes0No[9
❑Yes❑No®N/A
❑Yes❑No®N/A
87. Does File Contain Proof Of Penalty Collection?
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑NoON/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
® No
Information For You?
L!::
FILE REVIEW COMMENTS:
72. WSACC performed SIU inspections on 11/22/2022 (S&D Coffee Commercial Facility), 5/18/2022 (IPG) and 5/25/2022 (Stericycle).
78. WSACC performs all IUP sampling and analyses in lieu of the three SIUs reviewed during the audit.
85. WSACC issued a Notice ofNonCompliance (NONC) to S&D Coffee Commerical Park facility for pH and TSS permit limit violations
reported in June 2023. Stericycle was issued a NoNC for an ammonia permit limit violation reported in April 2023.
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 I0 I3 I6 I2 I6 I9 I I09 I14 I23 I
1. Industry Inspected: S&D Coffee Commercial Park Facility (Westrock Coffee)
2. Industry Address: 101 Commercial Park Drive, Concord N.C. 28027
3. Type of Industry/Product: Liquid coffee and tea production/packaging
4. Industry Contact: Jim Murray Title: Project & Facility Maintenance Manager Phone: [phone] x4514
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:
The facility's pretreatment system consists of a baffled sedimentation tank, pH adjustment (with in -line measurement system) and flow
measurement. The solids are pumped out of the holding tank every two weeks by Dunn Services. Spent coffee grinds are disposed (for
reuse) by Republic Services to Wallace Farms (compost). Metal baskets have been placed inside the floor drains to help capture solids.
The pH of the facility's discharge was 7.13 SU at the time of the inspection.
AUDIT COMMENTS:
WSACC's Pretreatment Program records were organized and well maintained. WSACC's Industrial Pretreatment Program was being
properly implemented.
NOD: ❑ Yes
® No
NOV: ❑ Yes
® No
QNCR: ❑ Yes
® No
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory ❑
DocuSigned by:
AUDIT COMPLETED BY: DATE: 9/18/2023
Wes Bell, Environmental Specialist II, Mooresville Regional Office, WQROS/DWR
[DocuSigned by:
444W H P"Ut4 9/18/2023
AUDIT REVIEWED BY: F161FB69A2D84A3... DATE:
Andrew H. Pitner, Regional Supervisor, Mooresville Regional Office, WQROS/DWR
NC DWR Pretreatment Audit Form Revised: December 2016 Page 7