NC0026514_Pretreatment Audit Report_20231011

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
October I Ith, 2023
Ms. Trudy McVicker, Operations Manager
City of Raeford
1606 US Highway 401 Business
Raeford, NC 28376
Subject: Pretreatment Audit Report
City of Raeford WWTP
NPDES Permit No. NCO026514
Hoke County
Ms. McVicker:
A Pretreatment Audit of the City of Raeford WWTP's Pretreatment Program was conducted by
Sharon Moran from this office on September 20, 2023, in conjunction with Trudy McVicker,
Pretreatment Coordinator of City of Raeford WWTP and Larry Pearce, Consulting Engineer. The
purpose of this audit is to determine the effectiveness of the pretreatment program by reviewing
various aspects of the program, which included files and records, industrial user inspections and
monitoring data, data management procedures and adherence to the Enforcement Response Plan.
City of Raeford WWTP is currently a 3.0 MGD permitted facility and has three (3) Significant
Industrial Users (SILT); Burlington, Butterball, and Unilever. All three permit files were reviewed.
A site visit was conducted at Burlington during this audit. The City of Raeford WWTP continues to
do an effective job of achieving the pretreatment program goals. The findings and comments noted
during this inspection are provided in the enclosed copy of the audit report. The Division
recommends following up with the Pretreatment Section to ensure the most up to date copy of the
Headworks Analysis is on file. There were no significant issues or findings noted during this
inspection thus a response to this inspection report is not required.
Thank you for your continued support of the North Carolina Pretreatment Program. If you should
have any questions, please contact Sharon Moran at [phone] or at
[e-mail].
Sincerely,
DocuSigned by,
ar "$�i�P�,$Assistant Regional Supervisor
Water Quality Regional Operations Section
Fayetteville Regional Office
Division of Water Resources, NCDEQ
Cc: Upload to Laserfiche
North Carolina Department of Environmental Quality I Division of Water Resources
Fayetteville Regional Office 1 225 Green Street I Suite 714 1 Fayetteville, North Carolina 28301
NORrH cnRoumn �
DepanmanebEmlm� lQua'� /`s 910.433.3300

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 Raeford WWTP
2. Control Authority Representative(s): Trudy McVicker
3. Title(s): Pretreatment Coordinator
4. Address of POTW:
Mailing 315 North Main St.
City Raeford Zip Code 28376
Phone Number 910-875-4931 Fax Number 910-875-7987 E-Mail tmcvickerAraefordnc.om
5. Audit Date 09/20/2023
6. Last Inspection Date: 02/20/2019 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
INIC101OI2 16 15 I1 14
MM/DD/YY
19 120 I23I
10: Current Number of Significant Industrial Users (SIUs)?
.11....Num..ber...of..SIUs.
..with.No I.UP, 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 C11tJs in SNC?
................................................................................................................................................................................................... .
3
0
0
0
0
0
0
0
0
0
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)
❑ Yes ❑ No
❑ Yes ❑ No
Industrial Waste Survey (IWS)
12/28/2021
® Yes ❑ No
01/042022
® Yes ❑ No
Sewer Use Ordinance (SUO)
12/7/2012
® Yes ❑ No
01/03/2013
® Yes ❑ No
Enforcement Response Plan (ERP)
09/01/2005
® Yes ❑ No
09/05/2005
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
04/06/2010
® Yes ❑ No
06/11/2010
® 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.
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 Counci112/03/2012
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
Resources
29. Please Rate the Followine: S=Satisfactory M=Mareinal 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
Trudy added that she thought a centralized system to provide
Regional Workshops, Etc.)
®S ❑M ❑U
updates on when rules/regulations change would be helpful
Computer Equipment (Hardware and
Software)
®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.
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Surcharges, Standardized costs, tiered 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? Within reason, the individual would be allowed to access
non -confidential 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? This is handled outside of the pretreatment department.
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? Zoning department, city hall meetings
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?) Volume of water used, chemicals being used, whether or not the business is a categorical user.
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
❑Yes ®No If Yes, How many are there?
Please list each site and how it is permitted, if applicable.
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)
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 N/A: low flow
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.
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 and NPDES pollutants of concern.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 3

49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Potential for adverse impacts on the plant as well as sampling results.
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. Spreadsheet that determines SNC.
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?
All industries are required to have a slug/spill control plan.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
The consulting engineer determines whether the plan covers all needed criteria.
56. How does the POTW decide where the sample point for an SIU should be located?
Sample point has been determined since establishment, but must be below all treatment, and in an accessible and safe
location.
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. Yearly review of sampling procedures.
58. Who performs sample analysis for the POTW for Metals Microbac
Conventional Parameters Internal Lab
Organics N/AF
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Fill out the time and date of sample and parameters to be tested. If going to outside lab, sign and date to relinquish custody.
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: Mercury Added:
61. Do you complete your own headworks analysis (HWA) ? ❑ Yes ® No
If no, who completes your HWA? Larry Pearce Phone [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 ® 5 year expiration ❑Other
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)? ❑ Yes ® No
Explain. Unneeded
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 4

INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION)
66. User Name
1. Burlington
2. Butterball
3. Unilever
67. IUP Number
3731
7989
4121
68. Does File Contain Current Permit?
® Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
69. Permit Expiration Date
6/30/25
6/30/25
6/30/25
70. Categorical Standard Applied I.E. 40 CFR, Etc. Or N/A
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?
I ❑ Yes ® No
❑ Yes ® No
❑ 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
P
❑Yes❑NoON/A
❑Yes❑NoNN/A
Organic Management Plan TOMP ?
75. a. Does File Contain Original Permit Review Letter from Division?
a. NYes ❑No
a. ®Yes ❑No
a. NYes ❑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 11
❑ Yes ® Kol
❑ 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
]j
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❑No❑N/A
time?
80a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑No®N/A
❑Yes❑NoNN/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❑NoNN/A
❑Yes❑NoON/A
❑Yes❑NoNN/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-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
becoming aware of SIU limit violations in the POTW s sam ling of SIU?
c.❑Yes❑No®N/A
c.❑Yes❑No®N/A
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
❑
Yes
®
No 11
❑
Yes
®
No 11
❑
Yes
®
No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
❑Yes❑NoNN/A
❑Yes❑NoON/A
❑Yes❑NoNN/A
Specified in POTW's ERP OVs, Penalties, timing, etc.)?
86. Does File Contain Penalty Assessment Notices?
❑Yes❑No®N/A
❑Yes❑NoNN/A
❑Yes❑NoON/A
87. Does File Contain Proof Of Penalty Collection?
❑Yes❑No®N/A
❑Yes❑NoNN/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?
FILE REVIEW COMMENTS:
No inspections were completed during the last calendar year due to medical leave.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 5

INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
INICIO 10 I2 16 Is 11 14 I 19 I20123
1. Industry Inspected: Burlington
2. Industry Address: 1001 Turnpike Rd, Raeford 28371
3. Type of Industry/Product: Wool and Yarn
4. Industry Contact: Mack Johnson Title:
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:
Audit SUMMARY AND COMMENTS:
Audit Comments:
Requirements:
Recommendations:
NOD: ❑ Yes ❑ No
NOV: ❑ Yes ❑ No
QNCR: ❑ Yes ❑ No
POTW Rating:
Satisfactory ® Marginal ❑
Audit COMPLETED BY:
Unsatisfactory ❑
Sharon Moran, Fayetteville Regional Office
DATE:
NC DWR Pretreatment Audit Form Revised: December 2016 Page 6