NC0020648_Washington Pretreatment Audit 2019_20190510

^. e
Seewary
LINDA e e x x
May 10, 2019
Stephen Adam Waters
City of Washington
PO Box 1988
Washington, NC 27889-1988
SUBJECT: Pretreatment Audit Report
Washington WWTP
NPDES WW Permit No. NCOO2O648
Beaufort County
Dear Mr. Waters:
The North Carolina Division of Water Resources conducted a Pretreatment Audit of the City of Washington on
5/07/2019. The findings and comments noted during this audit are provided in the enclosed copy of the
"Pretreatment Audit Report".
If you should have any questions, please do not hesitate to contact me with the Water Quality Regional
Operations Section in the Washington Regional Office at 252-946-6481 or via email at
[e-mail].
Sincerely,
olla&ell
Robbie Bullock, Environmental Specialist II
Water Quality Regional Operations Section
Washington Regional Office
Division of Water Resources, NCDEQ
Cc: Laserfiche
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Krl. NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT AUDIT REPORT
Warer Xesnur<as -
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Background Information [Complete prior to audit; review Program Info Database Sheet(s)]
1. Control Authority (POTW) Name: City of Washington
2. Control Authority Representative(s): Hope Woolard, Palki Desai, Lonnie Woolard
3. Title(s): Water Resources Superintendent, Lab/Pretreatment Supervisor, Operations Supervisor
4. Address of POTW:
Mailing P.O. Box 1988
City Washington Zip Code 27817
Phone Number 252-975-9310 Fax Number 252-975-0249 E-Mail hwoolard(a),washingtonnc.gov
5. Audit Date 5/7/19 '
6. Last Inspection Date: 4/11/18 Inspection Type: ® PCI ❑ Audit
7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s) ? ❑ Yes ❑ No N/A
If No, Explain.
8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? ❑ Yes ® No
If Yes, Explain.
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
NICIOI012 10 16 14 18
10..Current Number of Significant Industrial Users_(SIUs)?
11. Number of SIUs with No IUP, or with an Expired I .P?
12. Number of SIUs Not Inspected by POTW in Last Calendar Year?
........ .........
13.-_ Number. of.SIUs.Not _ Sampled. by. POT W. in Last Calendar Year?
14. Number. of.SIUs. in SNC_ for. Limits Violations During Either of L
15; Number of SIU.s in SNC for Reporting During Either of Last 2 Se
16. Number of SIUs in SNC with Pretreatment Schedule?
........................... .................................................. ................................. .................................................-.................................
17. Number of SIUs on Schedules?
..................................................................................................................................................................................................
18. Current Number Categorical. Industrial. Users (CIUs)?
........
19. Number of CIUs in SNC?
MM/DD/YY
5 17 119
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20. PRETREATMENT PROGRAM ELEMENTS REVIEW- Review POTW files, verify POTW has copy of each Program Element
in their File, complete with all supporting documents and PERCS Approval Letter, and dates consistent with Pro am Info:
Program Element
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
4/28/16
N Yes ❑ No
7/19/16
N Yes ❑ No
5/1/21
Industrial Waste Survey (IWS)
9/25/18
N Yes ❑ No
11/9/18
N Yes ❑ No
10/1/23
Sewer Use Ordinance (SUO)
2/21/13
N Yes ❑ No
5/23/13
N Yes ❑ No
Enforcement Response Plan (ERP)
4/25/18
N Yes ❑ No
5/7/18
N Yes ❑ No
Long Term Monitoring Plan (LTMP)
5/13/14
N Yes ❑ No
7/21/14
N Yes ❑ No
Legal Authority (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?
N Yes ❑ No If yes, Please list these towns and/or areas. Chocowinity
22. If yes to #21, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? N 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 N No ❑ NA
If yes, Explain. ,
24. Date of Last SUO Adoption by Local Council 10/28/13.
25. Have you had any problems interpreting or enforcing any part of the SUO? ❑ Yes N No
If yes, Explain.
Enforcement (Enforcement Response Plan-ERP)
26. Did you send a copy of the ERP to your industries? N 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 N No If yes, Explain.
28. List Industries under a Schedule or Order and Type of Schedule or Order
N/A
29. Please Rate the Following: S=Satisfactory M=Marginal U=Unsatisfactory
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
Ns ❑M ❑U
Access to POTW Vehicles for
Sampling, Inspections, and
Ns ❑M ❑U
Emergencies
Access to Operable Sampling
Equipment
NS ❑M ❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
Ns ❑M ❑U
Reference Materials
NS ❑M ❑U
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
NS ❑M ❑U
Computer Equipment (Hardware and
Software)
NS ❑M ❑U
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30. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No
Explain Yes or No. POTW uses Hach WIMS for database management
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
If a customer has a meter 2" or larger POTW charges .59 cents more per 1,000 gallons
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? Public would be shown requested files unless the files
were confidential
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? Currently, no facility has requested that any information be kept
confidential. A separate file would be kept for confidential files
35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? ❑ Yes ® No
POTW would meet with facility if issues arise
36. Is the public notified about changes in the SUO or Local Limits? ® Yes ❑ No
Through Council agenda
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? Any time a business requests service they fill out a
"change of use" form and it is sent to all City Departments
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 W WTP and therefore require a new permit or a permit revision? (Who is an
SIU?) Once POTW is aware of a new user the POTW sends the industry a short form to fill out. The long form is
sent out as needed
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
❑Yes ®No If Yes, How many are there?
Please list each site and how it is permitted, if applicable.
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) N/A
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 W WTP. 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.)
N/A
46. Does the POTW keep pollutant loading in reserve for future growth / safety? ❑ Yes ® No
If yes, what percentage of each parameter _%
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)
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The IWS is looked at as well as any laboratory data. Also, historical data and information obtained from industry staff
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
SIU's monitor monthly and POTW monitors semi-annually
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. POTW uses Compliance Judgement worksheets
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 inventory and possible impacts to POTW
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Potential is identified, control measures are identified, contact information is included and training information is up to
date
56. How does the POTW decide where the sample point for an SIU should be located?
Sampling point is at the end of treatment before it enters the City's pipe
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. Educate industry staff, record times and volume of
samples collected
58. Who performs sample analysis for the POTW for Metals Environment 1
Conventional Parameters POTW
Organics Environment 1
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Commercial COC for commercial samples and in house COC is a parameter bench sheet
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. All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? ® YES ❑ NO 12-2018 DMR spot checked
60e. If NO to any above, list violations
60f. 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 El Other
Explain.
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. Obtain more land for sludge application and plant expansion
65. Do you plan any significant changes to the pretreatment program or changes to the W WTP that may affect pretreatment?
Looking into expanding the W WTP due to increased flows over the past few years
NC r1WR PrPtraatm tAn,iit Pn, Pr,A,drl...... Pa d

INDUSTRIAL USER PERMIT (TUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION)
66. User Name
1. Flanders Filters
2.
1 3.
67. IUP Number
0003
00
68. Does File Contain Current Permit?
®Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
69. Permit Expiration Date
1-7-22
00
70. Categorical Standard Applied I.E. 40 CFR, Etc. Or N/A
N/A
00
71. Does File Contain Permit Application Completed Within One Year Prior
®Yes ❑ No
❑Yes ❑ No
❑Yes ❑ No
to Permit Issue Date? 5-23-16
72. Does File Contain Inspection Completed Within Last Calendar Year?
® Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
73. a. Does File Contain Slug/Spill Control Plan?
a. MYes ❑No
a. Dyes ❑No
a. Dyes ❑No
b. If No, is One Needed? See Inspection Form from POTW
b. Dyes ONO
b. Dyes ❑No
b. ❑Yes ❑No
74. For 40 CFR 413 and 433 TTO Certification, Does File Contain aToxic
❑Yesf7No®N/A
❑Yes❑NopN/A
pYes❑No❑N/A
Organic Management Plan TOMP ?
75. a. Does File Contain Original Permit Review Letter from Division?
a. MYes ❑No
a. Dyes ❑No
a. Dyes ❑No
b. All Issues Resolved?
b.pYesoNo®N/A
I b.oYesciNooN/A
b.oYesONociN/A
76. During Most Recent Semi -Annual Period, Did POTW Complete its
®Yes ❑ No
❑Yes ❑ No
❑Yes ❑ No
Sampling as Required by IUP, including Flow?
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
I ® Yes ❑ No
❑Yes ❑ No
❑ Yes ❑ No
78. During Most Recent Semi -Annual Period, Did SIU Complete its
®Yes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
Sampling as Required by IUP, including Flow?
79. During Most Recent Semi -Annual Period, Did SIU submit all reports on
®Yes❑No❑N/A
❑YespNo❑N/A
❑Yes❑No❑N/A
time?
80a. For categorical lUs with Combined Wastestream Formula (CWF), does
❑Yes❑No®N/A
pYes❑No❑N/A
❑Yes❑No❑N/A
file includeprocess/dilution flows as Required by IUP?
80b. For categorical IUs with Production based limits, does file include
❑YespNo®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
production rates and/or flows as Required by IUP?
81. During Most Recent Semi -Annual Period, Did POTW Identify All
® Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
Limits Non -Compliance from Both POTW and SIU Sampling?
Flow meter
failure
82. During Most Recent Semi -Annual Period, Did POTW Identify All
❑Yes❑NoON/A
pYes❑No❑N/A
❑YespNo❑N/A
Reporting -Non -Compliance from SIU Sampling?
83. a. Was POTW Notified by SIU (Within 24 Hours) of All Self-
a.oYesoNo®N/A
a.oYesoNor]N/A
azYesoNooN/A
Monitoring. Violations?
b. Did Industry Resample and submit results to POTW within 30 Days?
b.oYesoNo®N/A
b.oYesoNooN/A
b.oYesoNooN/A
c. If applicable, did POTW resample and obtain results within 30 days of
p c.YesoNo®N/A
c.oYesoNooN/A
aoYesoNooN/A
becomingaware of SIU limit violations in the POTW's sampling of SIU?
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
❑
Yes
®
No
❑
Yes
❑
No
❑
Yes ❑
No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
®YespNopN/A
❑Yes❑NopN/A
❑Yes❑NopN7A
Specified in POTW's ERP OVs, Penalties, timing, etc.)?
86. Does File Contain Penalty Assessment Notices?
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑NopN/A
87. Does File Contain Proof Of Penalty Collection?
❑YesE NoMN/A
❑Yes[7No❑N/A
❑YespNopN/A
-88. a. Does File Contain Any Current Enforcement Orders?
a.AYesoNo®N/A
a.DYes[1No0N/A
I
a.oYespNoON/A
b. Is SIU in Compliance with Order?
b.o YesoNo®N/A
b.r]YesONo0N/A
b.DYesoNO13N/A
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
❑Yes ®No
❑Yes ❑ No
❑Yes ❑ No
Information For You?
FILE REVIEW COMMENTS:
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INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
INICIO 1012 In 16 14 18 1 5 17 119
1. Industry Inspected: AAF Flanders Filters
2. Industry Address: 531 Flanders Filters Road Washington NC 27889
3. Type of Industry/Product: Filters
4. Industry Contact: Tavner Dixon, David Watson Title: EHS Manager, Maintenance Manager Phone: [phone] Fax: 252-
974-2334
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:
Audit SUMMARY AND COMMENTS:
Audit Comments:
Requirements:
Recommendations:
NOD: ❑ Yes
❑ No
NOV: ❑ Yes
❑ No
QNCR: ❑ Yes
❑ No
POTW Rating:
.Satisfactory ® Marginal ❑ Unsatisfactory ❑
Audit COMPLETED BY // DATE: f �o �g
PERCS, and WaRO Regional Office
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