NC0023906_Pretreatment Audit_20231030

DocuSign Envelope ID: D7F365CE-2B76-48F9-9FDB-EC2746BA80FD
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Mr. Jimmy Pridgen
Water Reclamation Manager
City of Wilson
P.O. Box 10
Wilson, NC 27894-0010
NORTH CAROLINA
Environmental Quality
October 30, 2023
Subject: Pretreatment Audit
City of Wilson
NPDES Permit No. NCO023906
Wilson County
Dear Mr. Pridgen:
On August 16, 2023, Cheng Zhang of the Raleigh Regional Office (RRO) conducted a Pretreatment
Audit of City of Wilson's pretreatment program. The assistance given by Ms. Laura Pruitt, the
pretreatment coordinator, was greatly appreciated. The audit report is attached. Findings during the
inspection were as follows:
1. The City has eleven Significant Industrial Users (SIUs), eight of which are also Categorical
Industrial Users (CIUs). It was noted that no SIUs were in Significant Non -Compliance (SNC)
for the two most recent semi-annual periods.
2. The pretreatment audit file review included Smithfield (Permit No. 9525), Linamar Forging, Inc
(Permit No. 8416), and Bridgestone (Permit No. 8412). The files needed for review were
available for inspection, contained all the required elements and were in excellent condition.
3. POTW and SIUs completed monitoring as required by the Industrial User Pretreatment Permits
(IUPs) during the most recent semi-annual period. Bridgestone was in compliance. Smithfield
had two chloride violations and Laminar Forging had two oil and grease violations. The POTW
took appropriate action to address these violations.
4. During the audit, Ms. Pruitt inspected one of the SIUs, Smithfield. The inspection was very
thorough. It was evident that Ms. Pruitt has excellent relationship with the industry
representative, broad knowledge of pretreatment, great attention to details, and proactive attitude
to solve potential problems together with industrial users.
5. A review of the files containing the pretreatment program elements was conducted. These files
were very well organized. It was noted that update of Headworks Analysis and Long Term
Monitoring Plan (LTMP) were submitted to the Division and are in review.
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office 1 3800 Barrett Drive I Raleigh, North Carolina 27609
NORTH CAROLINA ^ 919.791.4200
0�,mo E,Amnm W1 Q­1K,

DocuSign Envelope ID: D7F365CE-2B76-48F9-9FDB-EC2746BA80FD
6. The review of LTMP data indicated that all locations were sampled with required frequencies,
and all samples were analyzed using correct detection limits specified in the LTMP since last
inspection.
Thank you for your continued support of the Pretreatment Program. If you have any questions or
comments, please call Cheng Zhang at [phone] (or email: [e-mail]).
Sincerely,
ocuSigned by:
1�D
A, f.
2916E6AB32144F...
Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Attachment(s): City of Wilson PT Audit Form
Cc: Laserfiche
Laura Pruitt, City of Wilson (Electronic copy only)
D � ��� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CAROLINA ��` 919.707.9000
enpn .mo EnWromm�nfal nual

DocuSign Envelope ID: D7F365CE-2B76-48F9-9FDB-EC2746BA80FD
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 Wilson
2. Control Authority Representative(s): Laura Pruitt
3. Title(s): Pretreatment Coordinator
4. Address of POTW:
Mailing 3100 Stantonsburg Road
City Wilson Zip Code 27893
Phone Number 25253992499 Fax Number 2523992209 E-Mail tyruittAwilsonnc.ora
5. Audit Date 08/16/2023
6. Last Inspection Date: 08/17/2022/ 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.
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
INIC1010 1 21 3 19 10 16 1
MM/DD/YY
08 116 � 23
10.
.................................................................
Current Number of Significant. Industrial Users(SIUs)?...............................................................................................
11
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)?............................................................................................
8
19.
Number of CIUs in SNC?
0
NC DWR Pretreatment Audit Form Revised: December 2016 Page 1

DocuSign Envelope ID: D7F365CE-2B76-48F9-9FDB-EC2746BA80FD
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)
® Yes ❑ No
8/10/2018
® Yes ❑ No
4/1/2023
Industrial Waste Survey (IWS)
5/30/2019
® Yes ❑ No
8/15/2019
® Yes ❑ No
6/1/2024
Sewer Use Ordinance (SUO)
2/12/2012
® Yes ❑ No
3/12/2012
® Yes ❑ No
Enforcement Response Plan (ERP)
2/12/2020
® Yes ❑ No
2/14/2020
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
3/10/2022
® Yes ❑ No
6/23/2022
® 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. Town of Black Creek, Town of Sims, Town of Saratoga (in near
future)
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 4/19/2012
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
N/A
Resources
29. Please Rate the Followine: 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 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
Software)
®S ❑M ❑U
NC DWR Pretreatment Audit Form Revised: December 2016 Page 2

DocuSign Envelope ID: D7F365CE-2B76-48F9-9FDB-EC2746BA80FD
30. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No
Explain Yes or No. Ameritech software.
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Industrial monitoring charge & surcharges
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? Pretreatment coordinator would review relevant files in
program with individual
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? Purdue, Sandos, and Kabi requested that special formulations be
kept confidential, UTC Kidde Aerospace also requested their certain product information be kept confidential. Such
information is stamped confidential and kept in a separate locked file cabinet.
35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? ® Yes ❑ No
Annual pretreatment banquet and email communications.
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? From the City's Technical Review Committee
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?) Review short form, long form and/or site visit, application form, sampling results to determine categorical
industrial user or non -categorical SIUs.
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
®Yes ❑No If Yes, How many are there? One
Please list each site and how it is permitted, if applicable. Kidde Aerospace
41. Does the POTW accept waste by (mark if applicable) ® Truck ❑Dedicated Pipe ❑ NA
Portal John waste only, no septage.
42. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples drawn,
manifests required) Designated point, pH checked before discharge, hauler information
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? Silver, HWA has not been approved yet
45. If yes to #44, What is being done to address the over allocations? (short-term IUPs, HWA to be revised, pollutant study, etc.)
HWA to be revised
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. Silver
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)
NC DWR Pretreatment Audit Form Revised: December 2016 Page 3

DocuSign Envelope ID: D7F365CE-2B76-48F9-9FDB-EC2746BA80FD
NPDES pollutants of concern, categorical limits, FOG and chloride (SUO)
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Heavier pollutant loaders have monthly/quarterly monitoring; minimum monitoring required is semi-annually.
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. Data reviewed on receipt, entered into data management system,
limits formatted into data management system, violations and SNC will be flagged out by the system.
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
Modified version based on the model 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. If needed, the requirement will be in IUP
54. What criteria are used to determine if a slug/spill control plan is needed?
Process, chemicals, containment, potential harm to the WWTP. If plan is required, it will be specified in the IUP.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Secondary containment, spill response, biocide form, and correct contact information.
56. How does the POTW decide where the sample point for an SILT should be located?
If possible, at where flow is measured (flume), preferably process wastewater only
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. SOP outlines sampling requirements, POTW
trained technician; SIUs hire trained lab personnel to collect samples
58. Who performs sample analysis for the POTW for Metals Pace/Metitech
Conventional Parameters Citv
Organics City/Eurofin
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Date, time, who takes samples, locations, lab No., who receives samples, list of parameters, pH and temperature.
Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis (HWA)
60a.
60b.
60c.
60d.
60e.
60f.
61
62.
63.
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:
Do you complete your own headworks analysis (HWA) ? ® Yes ❑ No
If no, who completes your HWA? Phone (_)_-
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
❑More LTMP data available ❑Resolve over allocation ®5 year expiration
Explain. Just updated in 2018
In general, what is the most limiting criteria of your HWA? ❑Inhibition ® Pass Through
❑NPDES limits change
❑ Other
®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. Majority of final sludge goes to composting. No plan for plant expansion.
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 4

DocuSign Envelope ID: D7F365CE-2B76-48F9-9FDB-EC2746BA80FD
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION)
66. User Name
1. Smithfield
2. Laminar Forging
3. Bridgestone
67. IUP Number
9525
8416
8412
68. Does File Contain Current Permit?
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
69. Permit Expiration Date
12/31/2025
12/31/2023
F 1-2/31/2024
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
N/A
433.A
I 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 ❑ NoI
® Yes ❑
NoI
® 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
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)?
75. a. Does File Contain Original Permit Review Letter from Division?
a. ®Yes []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 ElNo
F977E] 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
F
®Yes❑No❑N/A
®Yes❑No❑N/A
Sampling as Required b IUP, includingFlow?
1
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❑NoON/A
file includeprocess/dilution flows as Required by IUP?
80b. For categorical IUs with Production based limits, does file include
❑Yes❑No®N/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
®Yes❑No❑N/A
❑Yes❑NoON/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 -Compliance 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
c.❑Yes®No❑N/A
c.❑Yes❑No®N/A
becomingaware of SIU limit violations in the POTW's sampling of SIU?
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❑NoON/A
Specified in POTW's ERP (NOVs, Penalties, timing, etc.)?
86. Does File Contain Penalty Assessment Notices?
❑Yes❑NoON/A
❑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❑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 ® No
Information For You?
IF
FILE REVIEW COMMENTS:
81. Smithfield had two chloride violations from POTW sampling in March, the POTW issued a NOV, Smithfield resampled chloride in April
and was compliant. Linamar Forging had two oil and grease violations from POTW sampling in March, the POTW issued a NOV, Linamar
Forging resampled chloride in April and was compliant.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 5

DocuSign Envelope ID: D7F365CE-2B76-48F9-9FDB-EC2746BA80FD
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
I N I C 1 0 I0 I2 I3 I9 I0 I6 I I08 I16 I23
1. Industry Inspected: Smithfield Packaged Meat Company
2. Industry Address: 2401 Wilco Blvd., Wilson NC 27893
3. Type of Industry/Product: Meat Cutter/Bacon
4. Industry Contact: Brandon Farley Title: Environmental Coordinator 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:
The SIU inspection was very thorough and met the DWR requirements.
Audit SUMMARY AND COMMENTS:
Audit Comments: The Pretreatment program is well managed and implemented.
Requirements: None
Recommendations: None.
NOD: ❑ Yes ® No
NOV: ❑ Yes ® No
QNCR: ❑ Yes ® No
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory ❑
Audit COMPLETED BY: Cheng Zhang, Raleigh Regional Office DATE: August 16, 2023
NC DWR Pretreatment Audit Form Revised: December 2016 Page 6