NC0021474_Pretreatment_Compliance_Inspection_Letter_20240918

North Carolina Department of Environmental Quality Division of Water Resources
512 North Salisbury Street 1611 Mail Service Center Raleigh, North Carolina 27699-1611
919.707.9000

Via Electronic Mail ([e-mail])

John Dodson
Water Resources Director
City of Mebane
106 E. Washington Street
Mebane, NC 27302

Subject: Pretreatment Compliance Inspection
Program: City of Mebane
Wastewater Treatment Plant: City of Mebane Water Resource Recovery Facility
NPDES #: NC0021474, Alamance County

Dear Mr. Dodson:

On August 12th, 2024, a Pretreatment Compliance Inspection (PCI) was performed by Octavio Henriquez of the
Central Office with the assistance of Michael Gearren and Brooke Stevens of the Winston-Salem Regional Office.
Amy Varinoski of the City of Mebane was present for the PCI on behalf of the City of Mebane. The purpose of
this PCI was to determine the effectiveness of the City’s pretreatment program, which includes the review of
program elements files, including industrial monitoring data, Industrial User Permit (IUP) file review, industry
monitoring data, Long Term Monitoring Plant (LTMP) review, and other pretreatment elements as outlined by
15A NCAC 02H .0900.

Background

The city has five (5) Significant Industrial Users (SIUs), three (3) of which are categorical under federal
regulations. The City of Mebane’s Publicly Owned Treatment Works (POTW) operates one Wastewater
Treatment Plant (WWTP), the City of Mebane Water Resource Recovery Facility NPDES # NC0021474

POTW Interview

There are no known POTW issues related to pretreatment at the time of this PCI.

Pretreatment Program Elements Review

The Headworks Analysis (HWA) renewal was submitted on May 7th, 2024. The HWA renewal is currently
awaiting review by the Division.

The Industrial Waste Survey (IWS) was approved on January 13th, 2021.

The Sewer Use Ordinance (SUO) was approved on December 12th, 2012.

The Enforcement Response Plan (ERP) was approved on February 13th, 2020.

The Long Term Monitoring Plan (LTMP) was approved on July 18th, 2019.

Docusign Envelope ID: 975BAD1C-0E67-4E9C-9019-5292ED7A50B7
9/18/2024

North Carolina Department of Environmental Quality Division of Water Resources
512 North Salisbury Street 1611 Mail Service Center Raleigh, North Carolina 27699-1611
919.707.9000

LTMP File Review Findings

The Division reviewed the LTMP from 2019 and found the Practical Quantitation Limits (PQLs) to be outdated.
A new PQL list was released in 2022. the addition of 1,4 dioxane as a pollutant of concern (PoC) is also required.
The Division requests that the updates to both PQLs and PoCs to the LTMP be made with the next local limits
review as required by the City of Mebane’s NPDES permit.

The Long Term Monitoring Plan (LTMP) is being conducted at adequate locations and frequencies.

Industrial User Permit (IUP) File Review

None of the five (5) SIUs were in significant noncompliance (SNC) in 2023.

A review of the file for Liggett Group, LLC (IUP# 0132) revealed that the monitoring data was well-organized
and compliant with pretreatment rules. All files related to the industry were found to be complete and in
compliance with state and federal regulations.

A review of the file for Novo Health Services (IUP# 0126) revealed that the monitoring data was well-organized
and compliant with pretreatment rules. All files related to the industry were found to be complete and in
compliance with state and federal regulations.

A review of the file for Metakote PPG Coating Services Plant 19 Mebane NC (IUP# 0133) revealed that the
monitoring data was well-organized and compliant with pretreatment rules. Metakote has ceased discharging to
the City of Mebane in the first semiannual period of 2024 and is closing operations. The City of Mebane will
provide documentation to drop Metakote’s IUP to the Division once all closing requirements are met by the
industry and POTW.

The spill/slug control plan for Liggett Group, LLC (IUP# 0132) was found to be satisfactory.

The spill/slug control plan for Novo Health Services (IUP# 0126) is not required by the City of Mebane. The
Division agrees with this assessment due to the nature of the industry and its low potential for slug discharges.

The spill/slug control plan for Metakote PPG Coating Services Plant 19 Mebane NC (IUP# 0133) was found to be
satisfactory.

Industry Inspection

An industry inspection was not performed during this PCI.

Action Items

The review letter for the Liggett Group, LLC (IUP# 0132) renewal received by the Division on December 31st,
2023, was not delivered to the City of Mebane. The Division will complete the review and provide a letter to the
City of Mebane for its records.

The Division found that the spill/slug control plans for some of the industries have been developed and dated over
5 years ago. The recommendation is that a spill/slug control plan is revised every permit cycle, which is at most 5
years. Ms. Varinoski reviewed the spill/slug control plans for these industries and found them to be accurate and
sufficient. Ms. Varinoski advised the industries to continue using the documents. After a review of the plans, The
Division finds Ms. Varinoski’s assessment to be accurate and no changes to the spill/slug control plans are
required. The Division does request, as a best practice, to have the industry write a statement of review of the
Docusign Envelope ID: 975BAD1C-0E67-4E9C-9019-5292ED7A50B7

North Carolina Department of Environmental Quality Division of Water Resources
512 North Salisbury Street 1611 Mail Service Center Raleigh, North Carolina 27699-1611
919.707.9000

spill/slug control plan at least once every permit cycle. This acknowledgment assessing the accuracy of the
spill/slug control plan will allow for 3rd parties to review these documents and evaluate whether the plans are
accurate and current.

An IUP drop request package must be delivered to the Division for Metakote PPG Coating Services Plant 19
Mebane NC (IUP# 0133).

Final Comments

The Division set a tentative due date for the next Headworks Analysis in May 2029. The HWA submission from
2024 is still under review and in effect.

The City of Mebane’s Pretreatment Program is in excellent shape. The industry files and sampling records are well
organized, and Amy Varinoski fosters good relationships with the industries in the pretreatment program.

Thank you for your continued cooperation with the Pretreatment Program. If you have any questions or comments,
please contact Octavio Henriquez at [phone] [email: [e-mail]] or Michael Gearren at
919-776-9701 [email: [e-mail]]

oih/mebane_pci_2024
Ec: Municipal Unit File
Jenny Graznak, WSRO
Amy Varinoski, City of Mebane
Central Files (Laserfiche)
Sincerely,

Karen Preston, Municipal Unit Supervisor
Division of Water Resources

Docusign Envelope ID: 975BAD1C-0E67-4E9C-9019-5292ED7A50B7