NC0023876_Pretreatment Comliance Inspection_20171004

Water Resources
Environmental Quality
October 4, 2017
Mr. Robert C. Patterson, Jr., P E.
Water Resources Director
City of Burlington
P.O. Box 1358
Burlington, NC 27216
Subject: Pretreatment Compliance Inspection
City of Burlington
Alamance County
NPDES #: NC0023876/South WWTP & NC0023868/East WWTP
Dear Mr. Patterson.
ROY
COOPER
Governor
MICHAEL S. REGAN
Secretary
C T A V 7TNANAFRAAANT
On September 18, 2017 a Pretreatment Compliance Inspection was performed by Jim Gonsiewski,
Winston-Salem Regional Office and Deborah Gore, DWR PERCS Unit. Ms. Kristy King was present at the
inspection. The purpose of the inspection is to determine the effectiveness of the pretreatment
program by an in-depth review of the files, including industrial monitoring data, appropriate data
management and adherence to the Enforcement Response Plan
Background
The City has seventeen (17) significant industrial users (SIUs), two (2) of which are categorical. Both
treatment plants are permitted for 12 0 MGD
LTMP/STMP File Review
Monitoring is being conducted per the approved long term monitoring plan.
Pretreatment Program Element Review
The next HWA due date is April 1, 2020 and the next industrial waste survey (IWS) is due July 2, 2021.
Industrial User Permit (IUP) File Review
Three permit files were reviewed. All requested information was readily available.
The inspection is considered satisfactory and in compliance. Ms. King's assistance during the inspection
is greatly appreciated
State of North Carolina I Environmental Quality
1617 Mail Service Center I Raleigh, North Carolina 27699-1617
919-707-9000

Thank you for your continued cooperation with the Pretreatment Program. Please do not hesitate to
contact me at 919-807-6383 [[e-mail]] if you have any questions or concerns.
Sincerely,
Deborah Gore
PERCS Unit Supervisor
Cc• Central Files
Kristy King, City of Burlington (via email)
Jim Gonsiewski, WSRO (via email)
PERC Files (electronic)

LK. NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
Water Resources
ENVIRONMENTAL QUALITY
BACKGROUND INFORMATION 1Complete Prior To PCI• Review Prol4ram Info Database Sheet s -
1 Control Authority (POTW) Name City of Burlington
2 Control Authority Representative(s) Kristy Km
3 Title(s) Pretreatment S eciahst
4 Last Inspection Date 09/13/2016 Inspection Type (Check One) PCI
5 Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)9 YES
6 Is POTW under an Order That Includes Pretreatment Conditions? NO
Order Type, Number, Parameters
ICIS CODING
Main Program Permit Number
MM/DD/YY
N I C1 0 1 0 1 2 1 3 1 8 17 1 6-J 109 1 18 117-1
Are Milestone Dates Being Met? ❑ YES ❑ NO
7 Current Number Of Significant Industrial Users (SIUs)9
17
0
8 Number of SIUs With No IUP, or With an Expired IUP9
0
9 Number of SNs Not Inspected By POTW in the Last Calendar Year?
0
10 Number of SIUs Not Sampled By POTW in the Last Calendar Year9
Number SNs In SNC For Limits Violations During Either of the Last 2 Semi -Annual Periods9
0
11 of
12 Number of SNs in SNC For Reporting During Either of the Last 2 Semi -Annual Periods?
0
0
13 Number of SIUs in SNC with Pretreatment Schedule?
0
14 Number of SNs on Schedules9
2
15 Current Number Of Categorical Industrial Users (CIUs)?
0
I TT__Wt__,cOTT T�—CNM9
POTW INTERVIEW
17 Since the Last PCI, has the POTW had any NPDES Limits Violations
If Yes, What are the Parameters and How are these Problems Being Addressed
18 Since the Last PCI, has the POTW had any Problems Related to an Industrial
Discharge (Interference, Pass -Through, Blockage, Citizens' Complaints, Increased
Sludge Production, Etc )9
If Yes, How are these Problems Being Addressed9
19 Which Industries have been in SNC for Limits or Reporting during SNC fo
either of the Last 2 Semi -Annual Periods9 Not Been Published for SNC fo;
Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not Pu
20 Which Industries are on Compliance Schedules or Orders? For all SNs on an
Order, Has a Signed Copy of the Order been sent to the Division9
21 Are Any Permits or Civil Penalties Currently Under Adjudication? If Yes, Which
Ones9
NO
NO
Limits N/A
Reporting N/A
dished N/A
None
NO
LTMP/STMP FILE REVIEW:
22 Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies YES
23 Are Correct Detection Levels being used for all LTMP/STMP Monitoring? YES
24 Is LTMP/STMP Data Maintained in a Table or Equivalent? YES Is Table Adequate9 YES
25 All LTMP/STMP effluent data reported on Discharge Monitoring Report'? YES
26 If NO to 23 - 26, list violations
27 Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP9 NO
If yes, which ones? Eliminated Added
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1

28. PRETREATMENT PROGRAM ELEMENTS REVIEW— Please review POTW files, verify POTW has copy of Program Element in
their files, complete with supporting documents and coy of 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
Headworlo Analysis (HWA)
11/16/15
Yes
2/2/16
Yes
4/1/2020
Industrial Waste Survey (IWS)
8/2/16
Yes
9/19/16
Yes
7/2/2021
Sewer Use Ordinance (SUO)
1/31/13
Yes
3/1/13
Yes
N/A
Enforcement Response Plan (ERP)
7/29/08
Yes
10/3/08
Yes
N/A
Long Term Monitoring Plan (LTMP)
11/18/05
Yes
1/27/06
Yes
N/A
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29 User Name
Kayser Roth
2 Carolina Bio. Supply 11
3 Engineered Controls
30 IUP Number
0052
0065
F7776019
31 Does File Contain Current Permit?
Yes
Yes
I Yes
32 Permit Expiration Date
6/30/2021 _][__12/31/2021
F12/31/2021
33 Categorical Standard Applied (I E 40 CFR, Etc ) Or N/A
N/A
N/A
433 17
34 Does File Contain Permit Application Completed Within One Year Prior
Yes
Yes
Yes
to Permit Issue Date9
35 Does File Contain an Inspection Completed Within Last Calendar Year?
Yes
Yes
Yes
36 a Does the File Contain a Slug/Spill Control Plan?
Yes
Yes
Yes
b If No, is One Needed? (See Inspection Form from POTW)
37 For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
N/A
N/A
Yes
Organic Management Plan (TOMP)?
j
38 a Does File Contain Original Permit Review Letter from the Division?
Yes
Yes IF
Yes
b All Issues Resolved?
39 Durmg the Most Recent Semi -Annual Period, Did the POTW Complete
Yes
Yes
Yes
its Sampling as Required by IiJP, including flow
40 Does File Contam POTW Samplmg Cham -Of -Custody Forms?
Yes
Yes
Yes
41 Durmg the Most Recent Semi -Annual Period, Did the SIU Complete its
Yes
Yes
Yes
Sampling as Required by IUP, including flow?
41b Durmg the Most Recent Semi -Annual Period, Did SIU submit all reports
Yes
Yes
Yes
on time?
42a For categorical IUs with Combined Wastestream Formula (CWF), does
N/A
N/A
N/A
file include process/dilution flows as Required by IUP?
42b For categorical IUs with Production based limits, does file include
N/A
N/A
N/A
production rates and/or flows as Required by IUP?
43a During the Most Recent Semi -Annual Period, Did the POTW Identify
None
None
Yes
All Limits Non -Compliance from Both POTW and SIU Samplmg?
43b Durmg the Most Recent Semi -Annual Period, Did the POTW Identify
None
None
None
All Reportm� Non -Compliance from SIU Samplmg?
44 a Was the POTW Notified by SIU (Within 24 Hours) of All Self-
a N/A
a N/A
a N/A
Monitormg Violations
b Did Industry Resample and submit results to POTW Within 30 Days?b
N/A
b N/A
b Yes
c If applicable, Did POTW resample within 30 days of becommg aware
c N/A
e N/A
c N/A
of SIU limit violations m the POTW's samr)lmg of the SIU?
46 During the Most Recent Semi -Annual Period, Was the SIU m SNC?
No
No
No
47 During the Most Recent Semi -Annual Period, Was Enforcement Taken
N/A
N/A
Yes
as Specified in the POTW's ERP (NOVs, Penalties, tuning, etc )?
48 Does the File Contam Penalty Assessment Notices?
N/A
N/A
N/A
49 Does The File Contam Proof Of Penalty Collection?
N/A
N/A
N/A
50 a Does the File Contam Any Current Enforcement Orders?
a N/A
a N/A
a N/A
b Is SIU to Compliance with Order?
b N/A
b N/A
b N/A
51 Did the POTW Representative Have Difficulty in Obtaining Any of This
No
No
No
Requested Information For Your
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

FILE REVIEW COMMENTS:
41 Ensure SIUs are reading water meter as required for sampling events
41b Appears reports are received on time, but make sure reports are date stamped to ensure compliance with report due dates
OVERALL SUMMARY AND COMMENTS:
Comments Discussed nonsignificant CIU definition Please contact PERCS if you think you have a CIU that meets the definition
Discussed recent request from Advanced Environmental to discharge (via pump and haul) remediated groundwater from gasoline contaminated
sources Reviewed the organics HWA If you have further concerns, contact PERCS to discuss
Requirements Next headworks analysis (HWA) due 4/1/2020, next IWS summary due 7/2/2021
Recommendations
NOD: NO
NOV: NO
QNCR: NO
POTW Rating: Satisfactory
PCI COMPLETED BY: Jim Gonsiewski (WSRO) and Deborah Gore (PERCS Unit) DATE: September 18, 2017
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3