NC0036269_Inspection_20180828

NORTH CAROLINA
ROY COOPER Envrranrh#1t1G1 QUdlfly
G&V eeltw
MICHAEL S. REGAL
Secr�rary
LINDA CULPEPPER
In redm D,'rsctor
28 August 2018
Ms. Beverly Metcalf
Environmental Compliance Manager
WSACC
Post Office Box 428
Concord, North Carolina 28026-0428
Subject: Pretreatment Audit Inspection
WSACC
NPDES Permit No. NC0036269
Cabarrus County
Dear Ms. Metcalf:
Enclosed is a copy of the Pretreatment Audit Inspection Report for the inspection of WSACC's Industrial Pretreatment
Program on August 23, 2018, by Mr. Wes Bell of this Office.
The report should be self-explanatory; however, should you have any questions concerning this report, please do not hesitate
to contact Mr. Bell at [phone], or via email at wes.bellkncdenr.gov.
Enclosure:
Inspection Report
Sincerely,
DocuSigned by:
A14CC681 AF27425...
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
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North Carolina Department of Environmental Quality I Division of Water Resources
610 East Center Avenue I Suite 3011 Mooresville, North Carolina 28115
704.663.1699

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NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT AUDIT REPORT
Water Resources
ENVIRONMENTAL QUALITY
Background Information
1. Control Authority (POTW) Name: WSACC
2. Control Authority Representative(s): Beverly Metcalf
3. Title(s): Environmental Comuliance Manager/Pretreatment Coordinator
4. Address of POTW:
Mailing: P.O. Box 428
City: Concord Zip Code: 28026-0428
Phone Number [phone] Fax Number [phone] E -Mail bmetcalf(a),wsacc.org
5. Audit Date 08/23/2018
6. Last Inspection Date: 02/24/2016 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. Rocky River Regional WWTP — No limit violations; Muddy Creek WWTP - BOD weekly average
limit violation (July 2017), Ammonia — weekly and monthly average limit violations (July 2017), Flow monthly
average limit violation (March 2018).
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
INIC101013 I6 12 16 I9
MM/DD/YY
1 08 1 23 1 18
10.
....................................................................................................................................................................................................................................................................................................
Current Number of Significant Industrial Users (SIUs)?
15
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?
..
1
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)?
3
19.
Number of CIUs in SNC?
0
NC DWR Pretreatment Audit Form Revised: December 2016
Page 1

20. PRETREATMENT PROGRAM ELEMENTS REVIEW:
Program Element
Rocky River Regional WWTP
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
09/05/17
® Yes ❑ No
02/13/18
® Yes ❑ No
09/01/22
Industrial Waste Survey (IWS)
11/13/13
® Yes ❑ No
11/21/13
® Yes ❑ No
11/15/18
Sewer Use Ordinance (SUO)
03/29/12
® Yes ❑ No
04/19/12
® Yes ❑ No
Enforcement Response Plan (ERP)
08/01/16
® Yes ❑ No
09/23/16
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
11/07/16
® Yes ❑ No
12/22/16
® Yes ❑ No
Program Element
Muddy Creek WWTP
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
11/02/16
® Yes ❑ No
01/30/17
® Yes ❑ No
09/01/19
Industrial Waste Survey (IWS)
11/13/13
® Yes ❑ No
11/21/13
® Yes ❑ No
11/15/18
Sewer Use Ordinance (SUO)
07/09/12
® Yes ❑ No
08/02/12
® Yes ❑ No
Enforcement Response Plan (ERP)
08/01/16
® Yes ❑ No
09/23/16
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
11/07/16
® Yes ❑ No
12/22/16
® Yes ❑ No
Legal Authoritv (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. Harrisburg, Mt. Pleasant, Concord, Cabarrus County, Midland,
Charlotte Water.
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 06/21/2012
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
NC DWR Pretreatment Audit Form Revised: December 2016 Page 2

Resources
29. Please Rate the Following: S=Satisfactory M=Marginal U=Unsatisfactory
30. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No
Explain Yes or No. Excel
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Permit Fees, Pretreatment Program Fees (monthly), Sampling Fees.
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? A request would be made to the Pretreatment
Coordinator and files would be reviewed at the Rocky River Regional WWTP with the Pretreatment staff in attendance.
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? A written request would be made to the Pretreatment Coordinator.
Confidential files would be kept in a locked file cabinet located in the main office.
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? The Pretreatment Coordinator is contacted directly by
the Economic Development staff and/or the City/Town staff outside WSACC's annexed jurisdiction of any new
potential industrial users. The IWS Surveys also used by Pretreatment Coordinator to ensure all new industries
are evaluated.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 3
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
30. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No
Explain Yes or No. Excel
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Permit Fees, Pretreatment Program Fees (monthly), Sampling Fees.
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? A request would be made to the Pretreatment
Coordinator and files would be reviewed at the Rocky River Regional WWTP with the Pretreatment staff in attendance.
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? A written request would be made to the Pretreatment Coordinator.
Confidential files would be kept in a locked file cabinet located in the main office.
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? The Pretreatment Coordinator is contacted directly by
the Economic Development staff and/or the City/Town staff outside WSACC's annexed jurisdiction of any new
potential industrial users. The IWS Surveys also used by Pretreatment Coordinator to ensure all new industries
are evaluated.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 3

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?) IWS Short/Long information, any categorical processes, flow volume, effluent characteristics, potential
impacts to WWTP.
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
®Yes ❑No If Yes, How many are there? 1(landfill leachate)
Please list each site and how it is permitted, if applicable. BFI — SIU Permit
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) Designated point for septage trucks with automated tracking system (badges), septage haulers
are permitted and sampled quarterly (minimum) along with random sampling and manifest tracking; priority
pollutant scans performed on trucked in waste for incinerator.
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
If yes, what percentage of each parameter 20-25%
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) NPDES POCs, Categorical parameters,
5% of MAHL
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
New SIU — sample monthly for baseline for 12 months; Quarterly sampling required for all SIUs at a minimum.
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. TRC and chronic limit violations are calculated and monitored on
Excel spreadsheet; ERP is followed for all violations (limit, reporting, permit condition, etc.).
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?
Chemical storage practices, presence of floor drains.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Emergency contacts kept up to date, proper chemical storage practices including adequate secondary containment,
presence of emergency response equipment.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 4

56. How does the POTW decide where the sample point for an SIU should be located? End of pipe and process wastewater only,
require an above ground sampling point.
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 for sampling procedures, SIUs that perform
their own sampling use the contracted lab staff.
58. Who performs sample analysis for the POTW for Metals: WSACC
Conventional Parameters: WSACC
Organics: Prism Laboratories
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
POTW uses internal chain of custody (COC) form and the contract lab's COC if applicable; SIUs use the contracted lab's
COC.
Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis (HWA)
60a. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑ NO
60b. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ® YES ❑ NO
60c. Is LTMP/STMP Data Maintained in Table or Equivalent? ® YES ❑ NO Is Table Adequate? ® YES ❑ NO
60d.
60e.
60f.
All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? ® YES ❑ NO
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:
61. Do you complete your own headworks analysis (HWA) ? ® Yes ❑ No
If no, who completes your HWA? 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. More LTMP data for the Muddy Creek WWTP HWA.
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. N/A — WWTP has sufficient capacity.
Summary
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment? No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW
66. User Name
1. BFI
2. Star America
3. Perdue Farms
67. IUP Number
1024
1013
1026
68. Does File Contain Current Permit?
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
69. Permit Expiration Date
12/31/19
12/31/19
6/20/22
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
N/A
410
N/A
71. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
® Yes ❑ No
®WT9WT ❑ No
® Yes ❑ No
72. Does File Contain Inspection Completed Within Last Calendar Year?
® Yes ❑ No
®Yes [:1 No
®Yes ❑ No
73. a. Does File Contain Slug/Spill Control Plan?
b. If No, is One Needed? (See Inspection Form from POTW)
a. ❑Yes ®No
b. ❑Yes ®No
a. ®Yes ❑No
b. []Yes []No
a. ®Yes []No
b. ❑Yes ❑No
74. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
Organic Management Plan (TOMP)?
❑Yes❑No[D❑Yes❑No®N/A
❑Yes❑No®N/A
75. a. Does File Contain Original Permit Review Letter from Division?
b. All Issues Resolved?
a. ®Yes []No
b.❑Yes❑No®N/A 11
a. ®Yes ❑No
b.❑Yes❑No®N/A
a. ®Yes []No
b.❑Yes❑No®N/A
NC DWR Pretreatment Audit Form Revised: December 2016 Page 5

76. During Most Recent Semi -Annual Period, Did POTW Complete its
Sampling as Required by IUP, including Flow?
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
78. During Most Recent Semi -Annual Period, Did SIU Complete its
Sampling as Required by IUP, including Flow?
79. During Most Recent Semi -Annual Period, Did SIU submit all reports on
time?
80a. For categorical IUs with Combined Wastestream Formula (CWF), does
file include process/dilution flows as Required by IUP?
80b. For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
81. During Most Recent Semi -Annual Period, Did POTW Identify All
Limits Non -Compliance from Both POTW and SILT Sampling?
82. During Most Recent Semi -Annual Period, Did POTW Identify All
Re ortin Non -Compliance from SIU Sampling?
83. a. Was POTW Notified by SIU (Within 24 Hours) of All Self -
Monitoring Violations?
b. Did Industry Resample and submit results to POTW within 30 Days?
c. If applicable, did POTW resample and obtain results within 30 days of
becoming aware of SIU limit violations in the POTW's sampling of SIU?
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
Specified in POTW's ERP OVs, Penalties, timing, etc.)?
86. Does File Contain Penalty Assessment Notices?
87. Does File Contain Proof Of Penalty Collection?
88. a. Does File Contain Any Current Enforcement Orders?
b. Is SIU in Compliance with Order?
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
Information For You?
FILE REVIEW COMMENTS:
® Yes ❑ No
FMTcTEJ No
® Yes ❑ No
® Yes ❑ NoI
® Yes ❑ No
® Yes ❑ No
®Yes❑No❑N/A
❑Yes❑No®N/A
®Yes❑No❑N/A
®Yes❑No❑N/A
❑Yes❑No®N/A
®Yes❑No❑N/A
❑Yes❑No[D
FYes❑N00
❑Yes❑NoON/A
❑Yes❑NoON/A
❑Yes❑No®N/A
❑Yes❑NoON/A
PYesONoON/A
❑Yes❑No®N/A
®Yes❑No❑N/A
❑Yes❑No®N/A
❑Yes❑NoON/A
❑Yes❑NoON/A
a.❑Yes❑No®N/A
b.❑Yes❑No®N/A
c.❑Yes❑No®N/A
a.❑Yes❑No®N/A
b.❑Yes❑No®N/A
c.❑Yes❑No®N/A
a.❑Yes❑No®N/A
b.❑Yes❑No®N/A
c.❑Yes❑No®N/A
❑ Yes ® No 11
❑ Yes ® No
1 ❑ Yes ® No
®Yes❑No❑N/A11
❑Yes❑No®N/A
®Yes❑No❑N/A
❑Yes❑No®N/A
❑Yes❑No®N/A
®Yes❑No❑N/A
❑Yes❑No®N/A
❑Yes❑No®N/A
®Yes❑No❑N/A
a.❑Yes❑No®N/Aa.❑Yes❑No®N/A
b.❑Yes❑No®N/A
b.❑Yes❑No®N/A
a.❑Yes❑No®N/A
b.❑Yes❑No®N/A
❑ Yes ®!17
s ®!]FlYes
®No
10. 14 - SIUs for Rocky River Regional WWTP and 1 — SIU for Muddy Creek WWTP.
14. Intertape Polymer Group was in SNC during the July — December 2017 period.
72. POTW performed the SIU inspections on 9/15/17 (BFI), 5/31/17 (Star America), and 4/28/17 (Perdue Farms).
81/85. BFI was issued a Notice of NonCompliance (NoNC) on 3/7/18 for a monthly average ammonia limit violation in February
2018. Perdue Farms was issued a NoNC on 6/11/18 for COD and TSS daily maximum limit violations in May 2018. The SIU was
assessed a $375.00 penalty ($300.00 fine + $75.00 administration fee) and the penalty was paid in full.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
I N I C I 0 I 0 1 3 16 12 16 19 I 1 08 1 23 1 18
1. Industry Inspected: BFI
2. Industry Address: 5105 Morehead Road, Concord, N.C. 28027
3. Type of Industry/Product: Landfill
4. Industry Contact: Bart Keller, Mike Gurley Title(s): General Manager, Environmental. Manager
Phone: [phone] ext. 349 (Bart Keller), [phone] (Mike Gurley) Fax: [phone]
5. Does the POTW Use the Division Model Inspection Form or Equivalent? ® Yes ❑ No
NC DWR Pretreatment Audit Form Revised: December 2016 Page 6

6. Did the POTW Contact Conduct the Following Parts of the Industrial Inspection Thoroughly?
Comments:
NOV: ❑ Yes
® No
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 landfill opened in 1992 and currently processes 4,000 tons/day and 1.1 tons/ year. The facility currently employs 28 employees
(post collection) and 80 —100 employees (hauling). The facility operates Monday through Friday from 6 a.m. to 5 p.m. and 6 a.m.
to 12 p.m. on Saturdays. Garbage is currently being disposed into three active cells (211, 2C, 2D) with an additional cell currently
under construction (2J). All leachate is piped into a main lift station prior to being pumped into a 2.5 million gallon lagoon (lined)
equipped with surface aeration (2 -aerators). The pretreatment system is also equipped with additional treatment units; however,
there has not been a need to activate these treatment units. The pretreatment system is checked 2-3 times per day and equipped
with a telemetry type alarm system to notify staff of selected alarm conditions. The effluent is measured by an in line flow meter
that is calibrated twice per year.
AUDIT SUMMARY/COMMENTS:
The records reviewed during the audit were organized and well maintained. The POTW's Industrial Pretreatment Program was
being properly implemented.
NOD: ❑ Yes
® No
NOV: ❑ Yes
® No
QNCR: ❑ Yes
® No
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory ❑
E�—,96DWCC3437
cuSigneddby:
Audit COMPLETED BY• ... DATE: 8/28/2018
Wes Bell, WQROS, Mooresville Regional Office
DocuSigned by:
I
yfe� 8/28/2018
A14CC681AF27425...
NC DWR Pretreatment Audit Form Revised: December 2016 Page 7