NC0047384_Compliance Evaluation Inspection_20180921

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ROY COOPER NORTH CAROLINA
Governor Environmental Quality
MICHAEL S.REGAN
Secretary
LINDA CULPEPPER
Interim Director
September 21, 2018 RECEIVE®I[J��RI®WR
OCT 0 2 Z018
Ms. Martie Groome, Laboratory and Industrial Waste Supervisor
City of Greensboro Water. ng
Resources
Permitting
P.O. Box 3136
Greensboro, NC 27402-3136
Subject: Pretreatment Compliance Inspection Report
NPDES Permit# NC0047384
City of Greensboro
Dear Ms. Groome:
On September 12, 2018, Paul DiMatteo and Kelli Park 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 40 MGD facility, and has 28 significant industrial users (SIUs), 21 of which are
categorical.
POTW Interview
During the most recent semi-annual period (January through June, 2018),the City determined that no
industries were in significant noncompliance (SNC). POTW also reported that it has been working to
proactively address issues with emerging contaminants.
Pretreatment Program Elements Review
The Headworks Analysis (HWA) renewal was submitted on September 1, 2018 and is still under review.
Pretreatment staff said that a HWA was also submitted in time for the October 1, 2017 due date, but review
was not completed because the POTW said that they would submit a revised HWA shortly. The POTW
reported that another revised HWA will be submitted after plant upgrades are completed sometime next year.
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NORTH CAROIM �/Y
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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 City's last Industrial Waste Survey (IWS) was submitted on April 1, 2014 and was approved on June
20, 2014. The next IWS is due April 1, 2019.
The last Long Term Monitoring Plan (LIMP) for was submitted on July 11, 2011 and approved on
October 6, 2011.The POTW said that it planned to submit a new LIMP in the near future.
The Sewer Use Ordinance (SUO)was approved on January 28, 2013.
The ERP was approved on December 2, 2015.
LTMP Review
The LTMP is.being conducted at the proper locations and frequencies.
Industrial User Permit (IUP) File Review
A review of the files for Precor Strength (#P076), ITG-Brands, LLC (#P004) and ZINK Holdings (#P043)
revealed that monitoring data was well organized.The slug control plans for these SlUswere 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,
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—Vivien Zhong
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: City of Greensboro
2. Control Authority Representative(s): Martie Groome,Frank Skee,Bill Burdick,Elijah Williams,Alicia Goots
3. Title(s): Lab&Industrial Waste Supervisor,Pretreatment Coordinator,Pretreatment Lab Specialist,Water Reclamation Manager,
Lab Coordinator respectively
4. Last Inspection Date: 4/14/2016 Inspection Type(Check One): ® PCI ❑ Audit
5. Has Program Completed All Requirements from the Previous Inspection and Program Tnfo 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
NICIO 0 1 4 1 7 1 3 1 8 1 4 1 1091121181
7. Current Number Of Significant Industrial Users(SIUs)? 28
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)? 21
16. Number of CIUs in SNC? F 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? POTW claims not pretreatment
related.
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 None
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: None
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?
NC DWR Pretreatment Compliance Inspection(PCI)Form Updated December 2016 Page 1

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 yourselfl
26. If NO 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:
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) 9/1/2018 ®Yes ❑ No 3/12/2013 ®Yes ❑ No
Industrial Waste Survey(IWS) 4/1/2014 ®Yes❑ No 6/20/2014 ®Yes ❑ No 4/1/2019
Sewer Use Ordinance(SUO) 1/1/2013 ®Yes❑ No 1/28/2013 ®Yes❑ No
Enforcement Response Plan(ERP) 6/19/2015 ®Yes ❑ No 12/2/2015 ® Yes❑ No
Long Term Monitoring Plan(LTMP) 7/11/2011 ®Yes ❑ No 10/6/2011 ❑Yes® No
NC DWR Pretreatment Compliance Inspection(PCI)Form Updated December 2016 Page 2

:1NDUStRIAL USER PERMIT(IUP)FILE REVIEW(3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name 1. Precor Strength 2.ITG-Brands LLC 3.ZINK Holdings
30. IUP Number P076 P004 P043
31 Does File Contain Current Permit? ® Yes ❑ No ®Yes ❑ No ® Yes ❑ No
32. Permit Expiration Date 8/31/2022 8/31/2022 8/31/2022
33. Categorical Standard Applied(I.E.40 CFR,Etc.)Or N/A 433.17 N/A N/A
34. Does File Contain Permit Application Completed Within One Year Prior ®Yes ❑ No ® Yes ❑ No ® Yes ❑ No
to Permit Issue Date?
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. ®Yes ❑No a. EYes ENo a. ®Yes❑No
b.If No,is One Needed?(See Inspection Form from POTW) b. EYes❑No b. ❑Yes ZNo b. EYes❑No
37. For 40 CFR 413 and 433 TTO Certification,Does File Contain a Toxic ®Yes❑No❑N/A ❑Yes❑NoEN/A ❑Yes❑NoON/A
Organic Management Plan(TOMP)?
38. a.Does File Contain Original Permit Review Letter from the Division? a. ['Yes ZNo a. DYes ZNo a. ❑Yes ENo
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 ❑ 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?
4 lb During the Most Recent Semi-Annual Period,Did SIU submit all reports ®Yes❑No❑N/A ®Yes❑No❑N/A ®Yes❑No❑N/A
on time?
42a.For categorical IUs with Combined Wastestream Formula(CWF), does ❑Yes❑NolEN/A ❑Yes❑NoON/A ❑Yes❑NoEN/A
file include process/dilution flows as Required by IUP?
42b.For categorical IUs with Production based limits,does file include ❑Yes❑NoEN/A ❑Yes❑No EN/A ❑Yes❑No EN/A
production rates and/or flows as Required by IUP?
43a. During the Most Recent Semi-Annual Period,Did the POTW Identify ®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❑NoE1N/A ❑Yes❑NoEN/A ❑Yes❑NoEIN/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❑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 SNC9 ❑ Yes ® No ❑Yes ® No ❑Yes ® No
47. During the Most Recent Semi-Annual Period, Was Enforcement Taken ❑Yes❑No oN/A ❑Yes❑No®N/A ❑Yes❑NoEN/A
as Specified in the POTW's ERP(NOVs,Penalties,timing,etc.)?
48. Does the File Contain Penalty Assessment Notices? ❑Yes❑NolEN/A ❑Yes❑No®N/A ❑Yes❑No®N/A
49. Does The File Contain Proof Of Penalty Collection? ❑Yes❑NoE1N/A ❑Yes❑NoON/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❑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 ❑Yes ® No ❑Yes ® No ❑Yes ® No
Requested Information For You?
FILE REVIEW COMMENTS:
28.Division's LIMP Review Letter was not immediately available.However,POTW said that they planned to submit a new LTMP
within the month.If necessary,contact the Division to obtain a copy of the current letter.
38.All IUPs were renewed recently.The POTW has not yet received copies of the review letters.
43a.None of these industries had limits noncompliance.
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 1 1 1 1 1 1 1 1 1
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: 1. POTW reports that it has been very proactive in working to identify potential sources of emerging contaminants and have been
open with their industries about forthcoming NPDES(and thereby IUP)limits.POTW maintains that they take pride in the working relationship
they have with their industries.
2.The T.Z.Osborne Plant is currently undergoing an upgrade that would bring the permitted capacity to 56 mgd.After this upgrade completes
POTW plans to submit another HWA.
Requirements:
Recommendations:
NOD: ❑YES ®NO
NOV: ❑YES ®NO
QNCR: ❑ YES ® NO
POTW Rating: /
Satisfactory Marnal
UnSatisfactory
PCI COMPLETED BY: (--P1-12p A i ) DATE: (7-1 110/
NC DWR Pretreatment Compliance Inspection(PCI)Form Updated December 2016 Page 4