NC0021024_Pretreatment Audit_20231115

DocuSign Envelope ID: 2F12BA26-8A8E-4985-80D0-BFBE81D968E9
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Mr. Derek Clayton
WWTP Superintendent
City of Roxboro
P.O. Box 128
Roxboro, NC 27573
NORTH CAROLINA
Environmental Quality
November 15, 2023
Subject: Pretreatment Audit
City of Roxboro
NPDES Permit No. NCO021024
Person County
Dear Mr. Clayton:
On August 22, 2023, Cheng Zhang of the Raleigh Regional Office (RRO) conducted a Pretreatment
Compliance Audit of City of Roxboro's pretreatment program. The assistance given by Ms. Crystal
Shotwell, the pretreatment coordinator, was greatly appreciated. The audit report is attached. Findings
during the inspection were as follows:
1. City of Roxboro has two Significant Industrial Users (SIUs), neither is a Categorical Industrial
Users (CIU). It was noted that neither SIU was in SNC during the two most recent semi-annual
periods.
2. The pretreatment inspection file review included Spuntech (Permit No. 0012) and Eaton
Corporation (Permit No. 0002). The files needed for review were available for inspection,
contained all the required elements and were in excellent condition.
3. The POTW and all SIUs reviewed completed monitoring as required by the IUPs during the first
semi-annual period of 2023. Spuntech had one pH and four TSS violations; Eaton had on pH and
six flow violations. The POTW issued NOVs to address these violations.
4. A review of the files containing the pretreatment program elements was conducted. These files
are well organized. Headworks Analysis update was submitted to the Division in April 2023 and
in review.
5. LTMP data were reviewed during the audit. It was noted that all locations were sampled with
required frequencies and all samples analyzed with required detection limits since the last
inspection.
6. During the audit, Ms. Shotwell conducted a thorough inspection at one of the SIUs, Spuntech.
NORTH CAROLINAD ���
Depa ,M NE,Amnm W1 Qu 1K,
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office 1 3800 Barrett Drive I Raleigh, North Carolina 27609
919.791.4200

DocuSign Envelope ID: 2F12BA26-8A8E-4985-80D0-BFBE81D968E9
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,
DocuSigned by:
Vaun t,SSa f.
62916E6AB32144F...
Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Attachment(s): City of Roxboro PT Audit Form
Cc: Laserfiche
Crystal Shotwell, City of Roxboro (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

DocuSign Envelope ID: 2F12BA26-8A8E-4985-80D0-BFBE81D968E9
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 Roxboro
2. Control Authority Representative(s): Crystal Shotwe11
3. Title(s): Pretreatment Coordinator
4. Address of POTW:
Mailing PO Box 128
City Roxboro Zip Code 27573
Phone Number 336-599-8232 Fax Number 336-503-0588 E-Mail crbowes(&cityofroxboro.com
5. Audit Date 08/22/2023
6. Last Inspection Date: 03/24/2021 Inspection Type: PCI
7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s) ? Yes
Missed sampling in 2015.2. Contacted Monti Hassan — make up sampling not required. Has implemented calendar
system to ensure not missed in future.
8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? No
9. Is POTW under an Order That Includes Pretreatment Conditions? No
Order Type and Number: Are Milestone Dates Being Met? NA
Parameters Covered Under Order
ICIS Coding
Main Program Permit Number
INICI010 I2 I1 10 I2 I4
MM/DD/YY
I08I22I23
10.
....................................................................................................................................................................................................................................................................................................
Current Number of Significant Industrial Users (SIUs)?
2
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)?
0
19.
Number of CIUs in SNC?
0
Spuntech SNC for oil & grease 2016.1; none in 2016.2; none so far in 2017.1 — Spuntech resampling for antimony; if compliant will not
be SNC.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 1

DocuSign Envelope ID: 2F12BA26-8A8E-4985-80D0-BFBE8lD968E9
20. PRETREATMENT PROGRAM ELEMENTS REVIEW- Review POTW files, verify POTW has copy of each Program Element
in their File. complete with all suDDortina documents and PERCS ADDroval 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)
4/18/2023
® Yes ❑ No
10/29/2018
® Yes ❑ No
4/30/2023
Industrial Waste Survey (IWS)
8/26/2019
® Yes ❑ No
11/18/2019
® Yes ❑ No
9/1/2024
Sewer Use Ordinance (SUO)
6/4/2012
® Yes ❑ No
7/4/2012
® Yes ❑ No
Enforcement Response Plan (ERP)
1/8/2020
® Yes ❑ No
2/5/2020
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
7/7/2022
® Yes ❑ No
10/302017
® 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? No
No longer receive wastewater from Person County
22. If yes to #21, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? 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? NA
If yes, Explain.
24. Date of Last SUO Adoption by Local Council 05/14/2012
25. Have you had any problems interpreting or enforcing any part of the SUO? No
If yes, Explain.
Enforcement (Enforcement Response Plan-ERP)
26. Did you send a copy of the ERP to your industries? Yes
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? No
28. List Industries under a Schedule or Order and Type of Schedule or Order
None
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 ❑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
NC DWR Pretreatment Audit Form Revised: December 2016 Page 2

DocuSign Envelope ID: 2F12BA26-8A8E-4985-80D0-BFBE8lD968E9
30. Does the POTW have an adequate data management system to run the pretreatment program? Yes
Explain Yes or No. Uses State forms and Excel spreadsheets.
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Higher user rate (as for all non-residential users)
Public Perception/ Participation
32. Are there any local issues affecting the pretreatment program (e.g.. odor, plant closing, new or proposed plants)? No
If yes, Explain.
33. Has any one from the public ever requested to review pretreatment program files? No
If yes, Explain procedure. If no, how would the request be addressed? Get files in order and let them look. All is public info,
but will make sure City staff is present during review
34. Has any industry ever requested that certain information remain confidential from the public? 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? Refer to City attorney to determine if trade secret
and production process are confidential.
35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? Meet when
sampling. Email a lot. Good, open communication.
36. Is the public notified about changes in the SUO or Local Limits? Yes
37. Were all industries in SNC published in the last notice? N/A
Permitting (Industrial Waste Survey-IWS)
38. How does the POTW become aware of new or changed Users? Through City/County economic development team.
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?) Based on answers on long form, monitoring (if necessary), flow data
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate? No
41. Does the POTW accept waste by (mark if applicable) Truck. Septage(porta john only), funeral home embalming
fluid
42. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples drawn,
manifests required) 6 companies are permitted to bring sepatge to designated point and sampling is done 1/yr for
metals, TN, TP, BOD, ammonia, and TSS.
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: based on data and allocation table availability; after lst year may be modified
44. Review POTW's copies of current allocation tables for each WWTP. Are there any over allocations? Yes for antimony and
mercury
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
If yes, what percentage of each parameter Not a set % amount, but only allocates what is needed.
47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) Yes, antimony and mercury
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)
Monitoring only if no data; limits for parameters that are detected.
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
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Always done 4 consecutive days/6 months, except for Spuntech's cyanide, four times per month.
Permit Compliance
50. Does the POTW currently have or during the past year had any permits under adjudication? No
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. Uses compliance judgement form. Reporting based on date stamp
received.
52. Does the POTW use the Division's model inspection form or equivalent? Yes
53. Were all SIUs evaluated for the need of a slug/spill control plan during their most recent inspections? Yes
Reviews at every inspection for updates or revisions
54. What criteria are used to determine if a slug/spill control plan is needed?
All SIUs required to have one
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Contact names, phone numbers, plan to call POTW, plan to contain spill, posted for employees, SDS for chemicals
56. How does the POTW decide where the sample point for an SILT should be located?
Have been established prior to Ms. Shotwell taking on responsibilities for pretreatment program, process only if possible
57. Has the POTW established a procedure to ensure that representative samples will be taken by the POTW or SILT each time?
(example: correct location; proper programming of sampler; clean equipment; swirling the sample bucket uniformly)
POTW: Yes SILT: Yes If yes, Explain. Has discussed sampling procedures with SIUs
58. Who performs sample analysis for the POTW for Metals Merritech
Conventional Parameters In-house
Organics Merritech
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Commercial — use their COC; observed in file properly completed. In-house form records all relevant information.
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
Are Correct Detection Levels being used for all LTMP/STMP Monitoring? Yes
Is LTMP/STMP Data Maintained in Table or Equivalent? Yes Is Table Adequate? Yes
All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? Yes
If NO to any above, list violations
Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? NO
If yes, which ones? Eliminated: Added:
61. Do you complete your own headworks analysis (HWA) ? Yes
62. Do you have plans to revise your HWA in the near future? Yes
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 (4/2018)
Explain.
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)? No
Not necessary at this time.
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
Still working on new oxidation ditch (poor concrete work causing cracks and leaks)
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INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION)
66. User Name
1. Spuntech
2. Eaton
3.
67. IUP Number
0012
0002
68. Does File Contain Current Permit?
® Yes ❑ No
® Yes ❑ No
[—]Yes ❑ No
69. Permit Expiration Date
2/28/2025
6/30/2027
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or 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
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
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
® 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
❑ 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❑No❑N/A
file includeprocess/dilution flows as Required by IUP?
80b. For categorical lUs with Production based limits, does file include
❑Yes❑No®N/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❑No®N/A
❑Yes❑No®N/A
❑Yes❑No❑N/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
becomingaware of SIU limit violations in the POTW's sampling of 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❑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
❑ No
Information For You?
L!::
FILE REVIEW COMMENTS:
81. Spuntech had one pH and four TSS violations; Eaton had on pH and six flow violations.
85. The POTW issued NOVs to address these violations.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 5

DocuSign Envelope ID: 2F12BA26-8A8E-4985-80D0-BFBE8lD968E9
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
I N I C 1 0 IO I2 I 1 IO I2 I41 I08 I22 I23 I
1. Industry Inspected: Spuntech
2. Industry Address: 555 North Park Drive, Roxboro, NC 27573
3. Type of Industry/Product: Non -woven fabric
4. Industry Contact: Thomas Breedlove Title: Maintenance Manager Phone: [phone] Fax: [phone]
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
B. Plant Tour Yes
C. Pretreatment Tour Yes
D. Sampling Review Yes
E. Exit Interview Yes
Industrial Inspection Comments:
The inspection was thorough and covered all required areas.
Audit SUMMARY AND COMMENTS:
Audit Comments: Well organized files.
Requirements: None
Recommendations: None
NOD: No
NOV: No
QNCR: No
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory ❑
Audit COMPLETED BY: Chen Zhang, RRO DATE: 8/22/2023
NC DWR Pretreatment Audit Form Revised: December 2016 Page 6