NC0024210_Compliance Evaluation Inspection_20180823

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ROY COOPER NORTH CAROLINA
Governor Environmental Quality
MICHAEL S.REGAN
Secretory
LINDA CULPEPPER
Interim Director
August 23, 2018
Ms. Carrie Hyler, Pretreatment Supervisor
City of High Point
PO Box 230
High Point, NC 27261
Subject: Pretreatment Compliance Inspection Report
NPDES Permit# NC0024210 and NC0024228
City of High Point
Dear Ms. Hyler:
On August 7, 2018, Paul DiMatteo of the Division of Water Resources Winston-Salem Regional Office
conducted a Pretreatment Compliance Inspection at the above referenced wastewater treatment system. The
purpose of this inspection was to determine the effectiveness of the Town's pretreatment program, which
included: reviewing the files, POTW plant performance, sampling and compliance judgement program, and
adherence to the enforcement response plan (ERP).
Background
The City operates one 6.2 MGD facility and one 26 MGD facility, and has 21 significant industrial users
(SlUs), 13 of which are categorical.
POTW Interview
During the most recent semi-annual period (January through June, 2018),the City determined that one
industry, Dairy Fresh (#151), was in significant noncompliance for limits violations. Ms. Hyler said that public
notice would be published in 2019 before the Pretreatment Annual Report (PAR) is submitted. Additionally,
bypass issues with Hunter Farms described in the previous PAR were resolved through an agreement by their
and the town's lawyers earlier this year. All other violations are identified and handled according to the
Enforcement Response Plan.
LD_ Q
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NORTH CAROUNA r�/
Impartment of 6wIn mmnW Gva011 ,
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 Hanes Mill Road,Suite 300 I Winston-Salem,North Carolina 27103
336.776.9800

Pretreatment Program Elements Review
The Headworks Analysis (HWA) renewal was submitted for the Westside plant on April 27, 2017 and
approved on July 26, 2017, and for the Eastside plant on June 5, 2017 and approved on August 10, 2017.The
next HWA will be due for Westside and'Eastside on December 1, 2019 and May 31, 2022 respectively.
The City's last Industrial Waste Survey (IWS) was submitted on January 21, 2015 and was approved on
February 5, 2015. The next IWS is due January 31, 2020.
The last Long Term Monitoring Plan (LTMP) for both plants was submitted on May 14, 2018 and
approved on August 8, 2018.
The Sewer Use Ordinance (SUO) was approved on January 10, 2013
The ERP was approved on October 9, 2008.
LIMP Review
The LIMP is being conducted at the proper locations and frequencies.
Industrial User Permit (IUP) File Review
A review of the files for Diary Fresh (#151), Zebra Environmental (#153) and Innospec Performance
Chemicals (#120) revealed that monitoring data was well organized and violations were addressed in a timely
manner consistent with the ERP.The slug control plans were in good order.
The pretreatment compliance inspection was satisfactory. The program is being implemented in an
excellent manner. If you should have any questions, please do not hesitate to contact Paul DiMatteo at (336)
776-9691 or our office at [phone].
Sincerely,
/c LV-. 4
.-e
Sherri V. Knight, P.E., Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
Enclosures—PCI Report
CC: PERCS Unit—Monti Hassan
WSRO Files
Central Files

NORTH CAROLINA DIVISION OF WATER RESOURCES
. PRETREATMENT COMPLIANCE INSPECTION (PCI)REPORT
Water Resources
ENVIRONMENTAL QUALITY
BACKGROUND INFORMATION[Complete Prior To PCI;Review Program Info Database Sheet(s)1
1. Control Authority(POTW)Name:_ High Point_
2. Control Authority Representative(s): Carrie Hyler
3. Title(s): Pretreatment Supervisor
4. Last Inspection Date:_9/12/2016 Inspection Type(Check One): ❑ PCI ❑ Audit
5. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? ®YES ❑NO
6. Is POTW under an Order That Includes Pretreatment Conditions? ❑ YES r NO
Order Type,Number,Parameters: Are Milestone Dates Being Met? ❑YES ❑NO
ICIS CODING
Main Program Permit Number MM/DD/YY
NIC 1010 121412 I1 J0 1 ] 08116118 [
7. Current Number Of Significant Industrial Users(SIUs)? 21
8. Number of SIUs With No IUP, or With an Expired IUP? 0
9. Number of SIUs Not Inspected By POTW in the Last Calendar Year? 0
10.Number of SIUs Not Sampled By POTW in the Last Calendar Year? 0
11.Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi-Annual Periods? 1
12.Number of SIUs in SNC For Reporting During Either of the Last 2 Semi-Annual Periods? 0
13.Number of SIUs in SNC with Pretreatment Schedule? 0
14.Number of SIUs on Schedules? 0
15.Current Number Of Categorical Industrial Users(CIUs)? 13
16. Number of CIUs in SNC? 0
POTW INTERVIEW
17. Since the Last PCI,has the POTW had any NPDES Limits Violations? ®YES El NO
If Yes, What are the Parameters and How are these Problems Being Addressed? Reportedly not related to
pretreatment.
18. Since the Last PCI,has the POTW had any Problems Related to an Industrial ®YES ❑NO
Discharge(Interference,Pass-Through,Blockage,Citizens' Complaints,Increased Hunter Farms bypass events were
Sludge Production,Etc.)? documented in PAR and resolved
If Yes,How are these Problems Being Addressed? through an agreement by their and
the town's lawyers this year.
19. Which Industries have been in SNC for Limits or Reporting during SNC for Limits:Dairy Fresh
either of the Last 2 Semi-Annual Periods?Not Been Published for SNC for Reporting None
Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not Published:Dairy Fresh—to be published
in 2019.
20. Which Industries are on Compliance Schedules or Orders?For all SIUs on an
Order,Has a Signed Copy of the Order been sent to the Division? None
21. Are Any Permits or Civil Penalties Currently Under Adjudication?If Yes,Which ❑YES ®NO
Ones?
LTMP/STMP FILE REVIEW:
22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ®YES ❑ NO
23. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ® YES ❑NO
24. Is LTMP/STMP Data Maintained in a Table or Equivalent? ®YES ❑NO Is Table Adequate? ®YES ❑NO
25. All LTMP/STMP effluent data reported on Discharge Monitoring Report? ®YES❑NO Division Inspector,please verify yourself!
26. If NO to 23-26,list violations (Reviewed 4/2018 DMR detection levels)
27. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑YES ®NO
NC DWR Pretreatment Compliance Inspection(PCI)Form Updated December 2016 Page 1

If yes,which ones?Eliminated: See Note Added:
28. PRETREATMENT PROGRAM ELEMENTS REVIEW-Please review POTW files,verify POTW has copy of Program Element in
their files,complete with supporting documents and copy of PERCS Approval Letter, and dates consistent with Program Info:
Program Element Last Submittal Last Approval Date Next Due,
Date In file? Date In file If Applicable
Headworks Analysis(HWA) 4/27/2017 ®Yes ❑ No 7/26/2017 ®Yes❑ No 12/1/2019
' (Westside)
Headworks Analysis 6/5/2017 ®Yes❑ No 8/10/2017 ®Yes❑ No 5/31/2022
(Eastside)
Industrial Waste Survey(IWS) 1/21/2015 ®Yes❑ No 2/5/2015 ®Yes❑ No 1/31/2020
Sewer Use Ordinance(SUO) 12/26/2012 ®Yes❑ No 1/10/2013 ®Yes ❑ No
Enforcement Response Plan(ERP) 8/1/2008 ®Yes❑ No 10/9/2008 ®Yes❑ No
Long Term Monitoring Plan(LTMP) 5/14/2018 ®Yes❑ No 8/8/2018 ® Yes ❑ No
NC DWR Pretreatment Compliance Inspection(PCI)Form Updated December 2016 Page 2

INDUSTRIAL USER PERMIT(IUP)FILE REVIEW(3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name 1.Dairy Fresh 2.Zebra Environmental 3.Innospec Performance Chem.
30. IUP Number 151 153 120
31. Does File Contain Current Permit? ®Yes ❑ No ®Yes ❑ No ®Yes ❑ No
32. Permit Expiration Date 6/6/2021 5/1/2023 6/30/2021
33. Categorical Standard Applied(I.E.40 CFR,Etc.)Or N/A N/A 437.26 414
34. Does File Contain Permit Application Completed Within One Year Prior /1 Yes ❑ No ®Yes ❑ No ❑Yes ® No
to Permit Issue Date? 12/7/2015 9/7/2015 1/4/2016
35. Does File Contain an Inspection Completed Within Last Calendar Year? ®Yes ❑ No ®Yes ❑ No ®Yes ❑ No
36. a.Does the File Contain a Slug/Spill Control Plan? a. ZYes DNo a. ZYes❑No a. ►ZYes❑No
b.If No,is One Needed?(See Inspection Form from POTW) b. ❑Yes❑No b. ❑Yes ❑No b. ❑Yes ❑No
37. For 40 CFR 413 and 433 TTO Certification,Does File Contain a Toxic ❑Yes❑No®N/A ❑Yes❑NoEN/A ❑Yes❑No_iN/A
Organic Management Plan(TOMP)?
38. a.Does File Contain Original Permit Review Letter from the Division? a. ZYes❑No a. ZYes ❑No a. ZYes ❑No
b.All Issues Resolved? b❑Yes❑No®N/A b❑Yes❑No®N/A b❑Yes❑No®N/A
39. During the Most Recent Semi-Annual Period,Did the POTW Complete ®Yes ❑ No ®Yes ❑ No ®Yes ❑ No
its Sampling as Required by IUP,including flow?
40. Does File Contain POTW Sampling Chain-Of-Custody Forms? ®Yes ❑ No ®Yes LI No ®Yes ❑ No
41. During the Most Recent Semi-Annual Period,Did the SIU Complete its ®Yes❑No❑N/A ®Yes❑No❑N/A ®Yes❑No❑N/A
Sampling as Required by IUP,including flow?
41b.During the Most Recent Semi-Annual Period,Did SIU submit all reports ❑YesENo❑N/A ®Yes❑No❑N/A ®Yes❑No❑N/A
on time?
42a.For categorical IUs with Combined Wastestream Formula(CWF),does ❑Yes❑No EN/A ❑Yes❑No EN/A ❑Yes❑No ON/A
file include process/dilution flows as Required by IUP?
42b.For categorical IUs with Production based limits,does file include ❑Yes❑No EN/A ❑Yes❑No®N/A ❑Yes❑No®N/A
production rates and/or flows as Required by IUP?
43a. During the Most Recent Semi-Annual Period,Did the POTW Identify /1 Yes ❑ No ®Yes ❑ No ®Yes ❑ No
All Limits Non-Compliance from Both POTW and SIU Sampling?
43b. During the Most Recent Semi-Annual Period,Did the POTW Identify ®Yes❑No❑N/A ®Yes❑No❑N/A ®Yes❑No❑N/A
All Reporting Non-Compliance from SIU Sampling?
44. a.Was the 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❑NoZN/A
c.If applicable,Did POTW resample within 30 days of becoming aware c❑Yes❑No®N/A
of SIU limit violations in the POTW's sampling of the SIU? c❑Yes❑NoDN/A c❑Yes❑No®N/A
46. During the Most Recent Semi-Annual Period,Was the SIU in SNC? ®Yes ❑ No ❑Yes ® No ❑Yes ® No
47. During the Most Recent Semi-Annual Period,Was Enforcement Taken ®Yes❑No❑N/A ZYes❑No❑N/A ❑Yes❑No®N/A
as Specified in the POTW s ERP(NOVs,Penalties,timing,etc.)?
48. Does the File Contain Penalty Assessment Notices? ®Yes❑No❑N/A ❑Yes❑No EN/A ❑Yes❑NoEN/A
49. Does The File Contain Proof Of Penalty Collection? _ZYes❑No❑N/A ❑Yes❑No®N/A ❑Yes❑No EN/A
50. a.Does the File Contain Any Current Enforcement Orders? a.❑Yes❑No®N/A a.❑Yes❑No®N/A a.❑Yes❑NoZN/A
b.Is SIU in Compliance with Order? b❑Yes❑No®N/A b❑Yes❑NoZN/A b❑Yes❑No®N/A
51. Did the POTW Representative Have Difficulty in Obtaining Any of This ❑Yes ® No ❑Yes ® No ❑Yes ® No
Requested Information For You?
FILE REVIEW COMMENTS: •
File was very well organized and complete.
•
NC DWR Pretreatment Compliance Inspection(PCI)Form Updated December 2016 Page 3

INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
1 1 1 1 1 I I I I l I I I I
1.Industry Inspected:
2.Industry Address:
3.Type of Industry/Product:
4.Industry Contact: Title:
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:
Not conducted during PCI.
OVERALL SUMMARY AND COMMENTS:
Comments: High Point's Pretreatment Program appears to be exceptionally well run.
Requirements: Submit the next Pretreatment Annual Report by March 1,2019.Remember to include public notice issued for industries in
SNC.
Recommendations:
NOD: ❑YES ®NO
NOV: ❑YES ®NO
QNCR: ❑YES ®NO
POTW Rating:
Satisfactory V Marginal UnSatisfactory
PCI COMPLETED BY: 1-'} 11,11-077) DATE: 1 I
NC DWR Pretreatment Compliance Inspection(PCI)Form Updated December 2016 Page 4

`i
nr Program Name High PointF ".,.w 7: •
ream Information IWC%at 7Q10 93.47
WWTP Name West Side _�_ u;, _,v; -��•.,,x•
7! I ow cfs/mgd 0.67 / 0.43
'rogram Approval Date 06/10/1983
1Q10 Flow cfs/mgd 0.57 / 0.37
Pretreatment Status
Full Stream Classification C
Region WSRO Basin Number YADO7
County Guilford Receiving Stream Name RICH FORK l
NPDES Number NC0024228
Last PAR Rec 02/27/2018 PAR Due Date 03/01/2018 mercury
NPDES Effective Date 08/01/2009 1631
NPDES Expire Date Current Fiscal required
P 04/30/2014 Year PCI Done
BTW is Primary WWTP
FALSE Last Audit on 09/12/2016 Audit Year Next20/21 yes
Design Flow mgd 6.2000 % Design mgd is SIU permitted 9.02 Permitted SIU flow(mgd)[Pt SIU) .559
/WTP SIU's 4 Program SIUs 21 . y :'
,;',77:77,4-
� K .� .,--777,-,,,,,,,,, -- ,:
IWP CIU s Program CIUs 13 :HWA LTMPC; ° IWS ;} ' SUO 3ERP -
° �
_: <- . ` _ a . ' 't
_
te Inactive Date Next Due 12/01/201901/31/2020 ,
_______ - ._ _- --------- _ - _ _____ -_ - - _
Date Received by DWR 04/27/2017 ; 05/14/2018 01/21/2015 12/26/2012 08/01/2008
Date Approved 07/26/2017 08/08/2018 ! 02/05/2015, 01/10/2013 . 10/09/2008
Adopt Date Required
Date Adopted 12/17/2012
N
fo in this Box from Pt Contacts Date Date Date
PT_Pro Attended Attended Attended
Formal Name g.Prime Phone/ ext Fax HWA Wksp IUP Wksp PAR Wksp
. Bill Frazier I 11336-880-0627 J1336-883-3109 II I 7/31/2001 1 2/4/2004
[e-mail] Laboratory Services Manager P.O.Box 230 27261
.Carrie Hyler (Prim 11336 883-3090 j 1336-883-3109 11 2/9/2012 19/27/2011 I 1/19/2012 I
[e-mail] Pretreatment Supervisor PO Box 230 27261
.Alannah Russell 1 II336-883-3098 1 1 II I I
[e-mail] Laboratory Analyst PO'BOX 230 27261
J
treatment Related NOVs from DWQ , DWR Central Office Contact Monti Hassan
'1998 Annual Report DWR Regional Contact Jim Gonsiewski
3/1996 PCI-Detection limits;not sending NOVs
3/2001 Annual Report
4/2001 PCI-Compliance evaluation
I

. 7r^'n , _ '..725't n ,. __.^.. ..7r:.--r”cr- �.,
ll- Program Name High Point
StreamrInformatron, . IWC%at 7Q10 85.37
WWTP Name East Side
th-
'rogram Approval Date 06/10/1983 �z ow cfs/mgd 6.9 / 4.46
1Q10 Flow cfs/ mgd 5.74 / 3.71
Pretreatment Status
Full Stream Classification WS IV
Region WSRO Basin Number CPF08
County Guilford Receiving Stream Name Deep River
NPDES Number NC0024210
Last PAR Rec 02/27/2018 PAR Due Date 03/01/2018 mercury
NPDES Effective Date 01/01/2014 1631
NPDES Expire Date Current Fiscal - required
P 12/31/2018 Year PCI Done
BTW is Primary WWTP
TRUE Last Audit on 09/12/2016 Audit Year Next20/21 yes
Design Flow mgd 26.0000 % Design mgd is SIU permitted 4.38 Permitted SIU flow(mgd)[Pt_SIU) 1.14
IWTP SIU's 17 Program Sills 1 .;. _'W_; % s 7 7,'" ,':77:7771':k.,
, . .. y ,-:: .w
„ '
WTP CIU's 10 Program CIUs 13 HA-, , ; LIMP ) 11VPf SUOy `ERP"- _
to Inactive Date Next Due 05/31/2022 01/31/2020
Date Received by DWR 06/05/2017 05/14/2018 01/21/2015 1 12/26/2012 08/01/2008
--- - -- -- - - --
Date Approved 08/10/2017 08/08/2018 , 02/05/2015 , 01/10/2013 , 10/09/2008 _
Adopt Date Required
Date Adopted 12/17/2012
fo in this Box from Pt Contacts ' Date Date Date
PT_Pro Attended Attended Attended
Formal Name g.Prime Phonel ext Fax HWA Wksp IUP Wksp PAR Wksp
. Bill Frazier I 11336-880-0627 1336-883-3109 II I7/31/2001 I2/4/2004 1
Laboratory tory Services Manager P.O.Box 230 127261
.Carrie Hyler IPnm 0336 883-3090 II1336-883-310911 2/9/2012 1 9/27/2011 1 1/19/2012 1
[e-mail] Pretreatment Supervisor PO Box 230 . 27261
.Alannah Russell I 11336-883-3098 I I 11 I I I
[e-mail] , Laboratory Analyst PO BOX 230 - 127261
r
l
?treatment Related NOVs from DWQ , DWR Central Office Contact Monti Hassan
1998 Annual ReportDWR Regional Contact Pim Gonsiewski
3/1996 PCI-Detection limits;not sending NOVs
3/2001 Annual Report
4/2001 PCI-Compliance evaluation
,
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