NC0021211_Compliance Evaluation Inspection_20180926

wsrArtse
;'a ,
ROY COOPER NORTH CAROLINA
Governor Environmental Quality
MICHAEL S.REGAN
Secretory
LINDA CULPEPPER
Interim Director September 26, 2018
Shelby Smith.
Pretreatment Coordinator
City of Graham
P.O. Box 357
Graham,North Carolina 27253 RECEIVE'Dl®ENW8®��
SUBJECT: Pretreatment Compliance Inspection (PCI) OCY 0 201
City of Graham Water Resources
NPDES#NC0021211 Permitting Section
Alamance County
Dear Ms. Smith:
On September 6, 2018 a Pretreatment Compliance Inspection (PCI) was performed by Jim
Gonsiewski of the Winston-Salem Regional Office. 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 five (5) Significant Industrial Users (SIUs), three (3) of which are categorical. The
treatment plant is permitted for 3.5 MGD.
POTW Interview
The ammonia limit of 8 mg/L was exceeded in January 2018 due to operating error of run times
for the aerators. This issue was corrected and no additional exceedances have been noted.
Pretreatment Program Elements Review
The Headworks Analysis(HWA)renewal was due September 1,2018. The renewal was submitted
on August 31, 2018 and is currently under review.
The last Industrial Waste Survey(IWS)was submitted on March 29,2018. The IWS was approved
on April 4, 2018. The next IWS is due on April 2, 2023.
The Sewer Use Ordinance (SUO)was approved on September 14, 2011.
The Enforcement Response Plan(ERP) was approved on January 23, 2012.
E
NORTH CAROLINA
oeMbnem m Urv4muoenNl pain
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 August 30, 2017.
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 five (5) SIUs were in significant noncompliance (SNC) in 2017.
A review of the file for Cintas (#0007) revealed that the monitoring data was well organized and
compliant.
A review of the file for Luxfor Gas Cylinders (#2001)revealed that the monitoring data was well
organized and compliant.
A review of the file for Prescient Company, Inc. (#3001) revealed that the monitoring data was
well organized and compliant.
The slug control plan for Cintas (#0007) was in good order.
The slug control plan for Luxfor Gas Cylinders (#2001) was in good order.
The slug control plan for Prescient Company, Inc. (#3001)was in good order.
Action Items
No other action items were noted.
The pretreatment program is considered satisfactory. Ms. Smith 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
Central Files
WSRO Files

F
NORTHNIZ
CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
Water Resources
EMYIROt MkNTAL OUALIT
BACKGROUND INFORMATION(Complete Prior To PCI; Review Program Info Database Sheet(s)1
1. Control Authority(POTW)Name: City of Graham Wastewater Treatment Plant
2. Control Authority Representative(s): Shelby Smith
3. Title(s):Environmental Laboratory Services Superintendent/Pretreatment Coordinator
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
I NICIO 10 1 211 12 1 1 11 109 106 1 18 I
7. Current Number Of Significant Industrial Users(SIUs)? 5
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)? 3
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?
The Ammonia limit of 8mg/L was exceeded in January 2018 due to a run time
operating error. This was corrected and the exceedance has not reoccurred.
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: 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? 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 LINO
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:TN- LTMP under revision
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(IWA) 08/30/2018 ®Yes ❑ No 10/16/2013 ®Yes ❑ No Under review
Industrial Waste Survey(IWS) 03/29/2018 ® Yes ❑ No 04/04/2018 ® Yes ❑ No 04/02/2023
' Sewer Use Ordinance(SUO) 09/07/2011 ®Yes ❑ No 09/14/2011 ®Yes ❑ No
Enforcement Response Plan(ERP) 12/15/2011 ® Yes ❑ No 01/23/2012 ®Yes❑ No
Long Term Monitoring Plan(LTMP) 06/27/2017 ® Yes ❑ No 08/30/2017 ®Yes ❑ No Under revision
INDUSTRIAL USER PERMIT(IUP)FILE REVIEW(3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name 1. Cintas 2.Luxfor Gas Cylinders 3.Prescient Company,Inc.
30 IUP Number 0007 2001 3001
31. Does File Contain Current Permit? ®Yes ❑ No ®Yes ❑ No ®Yes ❑ No
32. Permit Expiration Date 06/30/21 06/30/21 05/01//22
33. Categorical Standard Applied(I.E.40 CFR,Etc.)Or N/A ---- 467.36 433.17
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. ®Yes ❑No a. ®Yes❑No
b. If No, is One Needed?(See Inspection Form from POTW) b. EYes ❑No b. EYes❑No b. EYes ❑No
37. For 40 CFR 413 and 433 TTO Certification,Does File Contain a Toxic ❑Yes❑NoZN/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 ❑ 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?
41b.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❑NoNN/A ❑Yes❑No®N/A ❑Yes❑No®N/A
file include process/dilution flows as Required by IUP?
42b.For categorical IUs with Production based limits,does file include ❑Yes❑No®N/A ❑Yes❑No®N/A ❑Yes❑No ON/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? N/A N/A N/A
43b. During the Most Recent Semi-Annual Period,Did the POTW Identify ❑Yes❑NoZN/A ❑Yes❑No®N/A ❑Yes❑NoON/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❑NoEN/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 ❑Yes ® No ❑ Yes ® No
47. During the Most Recent Semi-Annual Period,Was Enforcement Taken ❑Yes❑NoON/A ❑Yes❑No®N/A ❑Yes❑NoNN/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®N/A ❑Yes❑No®N/A
49. Does The File Contain Proof Of Penalty Collection? ❑Yes❑No®N/A ❑Yes❑No®N/A ❑Yes❑No®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 ❑ Yes ® No ❑ Yes ® No ❑ Yes ® No
Requested Information For You?
NC DWR Pretreatment Compliance Inspection(PCI)Form Updated December 2016 Page 2

i
FILE REVIEW COMMENTS:
Well organized files. All information was readily available. All lab analyses are run by Meritech Laboratories. Three Mebane SIUs
(Liggett,Sandvik US Machining Solutions,LLC,and Synergy Health)are scheduled to have their flow diverted to the Cherry Lane
Lift Station which flows to the City of Graham. This transfer is scheduled to be completed in fiscal year 2020. Additionally Cintas has
stated they want to increase their flow from 110,000 gpd to 190,000 gpd.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
III II l I l I F ! l 1 l
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:
OVERALL SUMMARY AND COMMENTS:
Comments: A very well run program. With the additional flow from Cintas and the Mebane facilities,total flow at the POTW may
increase by 750,000 gpd. A capacity study for the POTW has been requested.
Requirements:
Recommendations:
NOD: ❑ YES ® NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ® NO
POTW Rating:
Satisfactory X MarginalU'_satisfactory
PCI COMPLETED BY: Jim Gonsiewski ' ip'� DATE: 09/26/2018
NC DWR Pretreatment Compliance In c on(PCI)Form Updated December 2016 Page 3