NC0023876_Compliance Report_20180918

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ROY COOPER NORTH CAROLINA
Governor Environmental Quality
MICHAEL S.REGAN
Secretary
LINDA CULPEPPER •
Interim Director September 18, 2018
RECEIVED/DENR/DWR
Mr. Robert C. Patterson, Jr., P.E.
Water Resources Director OCT 0 2 2018
City of Burlington
Water Resources
P.O. Box 1358 .Permitting Section
Burlington,North Carolina 27216
SUBJECT: Pretreatment Compliance Inspection (PCI)
City of Burlington
NPDES#NC0023876/South WWTP &NC0023868/East WWTP
Alamance County
Dear Mr. Patterson:
•
On August 2,2018 a Pretreatment Compliance Inspection(PCI)was performed by Jim Gonsiewski
of the Winston-Salem Regional Office. Ms. Kristy King was present for the inspection. The
purpose of this inspection was to determine the effectiveness of the Town's pretreatment program,
which includes reviewing the files,including industrial monitoring data,POTW plant performance,
industry monitoring data, and adherence to the enforcement response plan(ERP).
Background
The City has sixteen (16) Significant Industrial Users (SIUs), two (2) of which are categorical.
Both treatment plants are permitted for 12 MGD. One (1) SIU (National Spinning)was closed in
March 2018.
POTW Interview
There are no plant problems related to pretreatment.
Pretreatment Program Elements Review
The Headworks Analysis (HWA) renewal was submitted on November 16,2015. The HWA was
approved on February 2, 2016. The next HWA is due on April 1, 2020.
The last Industrial Waste Survey(IWS)was submitted on August 2,2016. The IWS was approved
on September 19, 2016. The next IWS is due on July 2, 2020.
The Sewer Use Ordinance (SUO)was approved on March 1, 2013.
The Enforcement Response Plan(ERP) was approved on October 3, 2008:
NORTH CAROLINA
\
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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

The Long Term Monitoring Plan(LTMP)was approved on January 27, 2006.
LTMP File Review
The Long Term Monitoring Plan (LTMP) is being conducted at the proper locations and
frequencies.
Industrial User Permit (IUP) File Review
None of the sixteen(16) Sills were in significant noncompliance (SNC) in 2017.
A review of the file for Indulor America LP (#0089) revealed that the monitoring data was well
organized and compliant.
A,review of the file for Glen Raven Mills (#0008) revealed that the monitoring data was well
organized and compliant.
A review of the file for Alamance Foods (#0067) revealed that the monitoring data was well
organized and compliant.
The slug control plan for Indulor America LP (#0089) was in good order.
The slug control plan for Glen Raven Mills (#0008)was in good order.
The slug control plan for Alamance Foods (#0067)was in good order.
Action Items
No other action items were noted.
The pretreatment program is considered satisfactory. Ms. King continues to maintain an effective
pretreatment program. If you have any questions please contact Jim Gonsiewski or me at (336)
776-9800.
Sincerely,
Sherri V. Knight, PE
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources,NCDEQ—WSRO
Enclosure—PCI Report
cc: PERCS Unit—Vivien Zhong
Kristy King—City of Burlington
Central Files
WSRO Files

NORTH CAROLINA DIVISION OF WATER RESOURCES
. PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
Water Resources
..NYIRQNMEN CAL QUALITY
BACKGROUND INFORMATION f Complete Prior To PCI; Review Program Info Database Sheet(s)1
1. Control Authority(POTW)Name: City of Burlington
2. Control Authority Representative(s):_ Kristy King
3. Title(s):Industrial Pretreatment Specialist
4. Last Inspection Date: 09/18/2017 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 ®NO
Order Type,Number,Parameters: Are Milestone Dates Being Met? ❑YES ❑ NO
ICIS CODING
Main Program Permit Number MM/DD/YY
1 N 1 C 1 0 1 0 1 2 1 3 1 8 1 7 1 6 l J08 102 1 18
7. Current Number Of Significant Industrial Users(SIUs)? 16
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? 0
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)? 2
16. Number of CIUs in SNC? 0
POTW INTERVIEW
17. Since the Last PCI,has the POTW had any NPDES Limits Violations? ❑ YES ®NO
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 ❑YES ® NO
Discharge(Interference,Pass-Through,Blockage, Citizens' Complaints, Increased
Sludge Production, Etc.)?
If Yes,How are these Problems Being Addressed?
19. Which Industries have been in SNC for Limits or Reporting during SNC for Limits:N/A
either of the Last 2 Semi-Annual Periods?Not Been Published for SNC for Reporting:N/A
Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not Published. N/A
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? N/A
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 LINO
24. Is LTMP/STMP Data Maintained in a Table or Equivalent9 ®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. IfNO to 23-26,list violations
27. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ® 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 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) 11/16/2015 ® Yes El No 02/02/2016 ® Yes El No 04/01/2020
Industrial Waste Survey(IWS) 08/02/2016 ® Yes ❑ No 09/19/2016 ®Yes El No 07/02/2021
Sewer Use Ordinance(SUO) 01/31/2013 ® Yes El No 03/01/2013 ® Yes El No
Enforcement Response Plan(ERP) 07/29/2008 ® Yes El No 10/03/2008 ® Yes El No
Long Term Monitoring Plan(LTMP) 11/18/2005 ®Yes El No 01/27/2006 ® Yes ❑ No
INDUSTRIAL USER PERMIT(IUP) FILE REVIEW(3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name 1. Indulor America LP 2. Glen Raven Mills 3.Alamance Foods
30. IUP Number 0089 0008 0067
31. Does File Contain Current Permit? ®Yes ❑ No ®Yes El No 06/30/Yes El
No
32. Permit Expiration Date 12/31/21 12/31/21 12/31/21
33. Categorical Standard Applied(I.E.40 CFR,Etc.)Or N/A 414.11 ---- ---- _
34. Does File Contain Permit Application Completed Within One Year Prior ®Yes ❑ No ® Yes ❑ No ® Yes El No
to Permit Issue Date?
35 Does File Contain an Inspection Completed Within Last Calendar Year? ® Yes ❑ No ® Yes ❑ No ® Yes El No
36. a. Does the File Contain a 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
37. For 40 CFR 413 and 433 TTO Certification,Does File Contain a Toxic ®Yes❑No❑N/A ®Yes❑No❑N/A ®Yes❑No❑N/A
Organic Management Plan(TOMP)?
38. a.Does File Contain Original Permit Review Letter from the Division? a. ®Yes❑No a. ®Yes ❑No a. ®Yes ❑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 El No ® Yes El No ® Yes ❑ No
its Sampling as Required by IUP, including flow?
40. Does File Contain POTW Sampling Chain-Of-Custody Forms? ® Yes El No ® Yes El 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 NYes❑No❑N/A NYes❑No❑N/A ®Yes❑No❑N/A
on time?
42a. For categorical IUs with Combined Wastestream Formula(CWF), does ❑YesDNoZN/A ❑YesDNo N/A ❑YesDNoEN/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 ❑YesDNoEN/A ❑YesDNoEN/A
production rates and/or flows as Required by IUP?
43a. During the Most Recent Semi-Annual Period,Did the POTW Identify El Yes El No El Yes ❑ No ❑ Yes El No
All Limits Non-Compliance from Both POTW and SIU Sampling? N/A N/A N/A
43b. During the Most Recent Semi-Annual Period,Did the POTW Identify ❑Yes❑NoNN/A ❑YesDNoNN/A ❑Yes❑NoEN/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❑NoNN/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 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❑No®N/A c❑Yes❑No®N/A
46. During the Most Recent Semi-Annual Period, Was the SIU in SNC? ❑Yes ® No El Yes ® No El Yes ® No
47. During the Most Recent Semi-Annual Period, Was Enforcement Taken ❑YesDNo N/A ❑YesDNoON/A ❑Yes❑NoEN/A
as Specified in the POTW's ERP(NOVs, Penalties,timing,etc.)?
48. Does the File Contain Penalty Assessment Notices? ❑Yes❑NoZN/A ❑Yes❑NoNN/A ❑Yes❑NoNN/A
49. Does The File Contain Proof Of Penalty Collection? ❑YesDNo N/A ❑YesDNo N/A ❑YesDNo N/A
50. a. Does the 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
51. Did the POTW Representative Have Difficulty in Obtaining Any of This El Yes ® No ❑ Yes ® No ❑ Yes ® No
Requested Information For You?
NC DWR Pretreatment Compliance Inspection(PCI)Form Updated December 2016 Page 2

FILE REVIEW COMMENTS:
Well organized files. All information was readily available. One SIU(National Spinning)was bought out and was closed 3/18. Lemco
was in non-compliance several times for copper that is used in a sock brand. The POTW is increasing the limits for copper from 0.1 lbs
to 1.5 lbs.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
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 El NO
6.Did the POTW Contact Conduct the Following Parts of the Industrial Inspection Thoroughly?
Comments:
A. Initial Interview [I] 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:
OVERALL SUMMARY AND COMMENTS:
Comments: A very well run program
Requirements:
Recommendations:
NOD: ❑ YES ®NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ® NO
POTW Rating:
Satisfactory X Marginal Unsatisfactory
�
PCI COMPLETED BY: Jim Gonsiewski t DATE: d o g ( 1 s
NC DWR Pretreatment Compliance Inspection(PCI)Form Updated December 2016 Page 3