NC0037834_Compliance Evaluation Inspection_20190712

ROY COOPER ��Z' ' `
Governor W"
MICHAEL S.REGAN
Secretary
LINDA CULPEPPER NORTH CAROLINA
Director Environmental Quality
July 12, 2019
Joel Freeman
IWC Supervisor
City of Winston-Salem
Mason-Meads Complex t2ECEIVE®/NCDE61/DWR
2799 Griffith Road
Winston-Salem,North Carolina 27103 AUG 0 8 7019
SUBJECT: Pretreatment Compliance Inspection (PCI) Water y
City of Winston-Salem Permittingg Section
NPDES#NC0037834
Forsyth County
Dear Mr. Freeman:
On June 14,2019 a Pretreatment Compliance Inspection(PCI)was performed by Jim Gonsiewski
of the Winston-Salem Regional Office. Mr. Joel Freeman was present for the inspection. The
purpose of this inspection was to determine the effectiveness of the City's pretreatment program,
which includes reviewing the files, POTW plant performance, industry monitoring data, and
adherence to the enforcement response plan(ERP).
Background
This is a 51 MGD permitted facility with the Archie Elledge and Muddy Creek facilities. The City
has twenty seven (27) Significant Industrial Users (SIUs) of which ten (10) are categorical. One
SIU(Kaba-Ilco) closed. The last discharge from this facility occurred on May 10, 2019.
POTW Interview
There are no plant problems related to pretreatment issues from June 2018 through May 2019. The
Muddy Creek facility had NPDES violations for pH in June and October 2018 and flow in
December 2018. No other NPDES permit limit or monitoring violations were recorded during this
period. The facility is very well operated.
Pretreatment Program Elements Review
The Headworks Analysis (HWA) renewal was submitted on October 2, 2017. The HWA was
approved on February 28, 2018. The next HWA is due on October 1,2022.
The last Industrial Waste Survey (IWS) was submitted on July 1, 2016. The IWS was approved
on September 2,2016. The next IWS is due on July 1,2021.
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4.
The Sewer Use Ordinance(SUO)was approved on February 9, 2012.
The Enforcement Response Plan(ERP)was approved on April 18, 2012.
The Long-Term Monitoring,Plan(LTMP)was approved on March 5,2019.
LTMP File Review
The Long-Term Monitoring Plan (LTMP) is being conducted at the proper locations and
frequencies.
Industrial User Permit(IUP) File Review
A review of the file for Ardagh Metal Beverage (#3010) revealed that the monitoring data was
well organized and compliant.
A review of the file for Hanes Dye&Finishing(#1155)revealed that the monitoring data was well
organized and compliant.
A review of the file for Suiza Dairy Group (1189) revealed that the monitoring data was well
organized and compliant.
The slug control plan for Ardagh Metal Beverage (#3010)was in good order.
The slug control plan for Hanes Dye &Finishing(#1155)was in good order.
The slug control plan for Suiza Dairy Group (1189) was in good order.
Action Items
No other action items were noted.
The pretreatment program is considered satisfactory. Mr. Freeman runs an excellent pretreatment
program. If you have any questions please contact Jim Gonsiewski or me at(336) 776-9800.
Sincerely,
Doaualpn0d by:
L.pti I. SM2!r
orITTErter
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources,NCDEQ—WSRO
cc: PERCS Unit—Monti Hassan
Central Files
WSRO Files

NORTH CAROLINA DIVISION OF WATER RESOURCES
. PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
Water Resources
ENVIRONMENTAL QUALIFY
BACKGROUND INFORMATION[Complete Prior To PCI;Review Program Info Database Sheet(s)1
1. Control Authority(POTW)Name: City of Winston-Salem
2. Control Authority Representative(s): Joel Freeman
3. Title(s): Utility Plant Supervisor/IWC
4. Last Inspection Date: 05/09/18 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
J NICIO 10 1 317 1318 14 l I06 I14 119 I
7. Current Number Of Significant Industrial Users(SIUs)? 27
8. Number of SIUs With No IUP,or With an Expired RIP? 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)? 10
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? Flow and pH violations at Muddy
Creek.
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?
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
27. Should any Pollutants of Concern.be Eliminated from or Added to LTMP/STMP? ❑ YES Z 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) 10/02/2017 ®Yes ❑ No 02/28/2018 ® Yes❑ No 10/01/2022
Industrial Waste Survey(IWS) 07/01/2016 ®Yes ❑ No 09/02/2016 ® Yes ❑ No 07/01/2021
Sewer Use Ordinance(SUO) 01/03/2012 ®Yes ❑ No 02/09/2012 ® Yes ❑ No
Enforcement Response Plan(ERP) 03/14/2012 ®Yes ❑ No 04/18/2012 ®Yes❑ No
Long Term Monitoring Plan(LTMP) 12/20/2018 ®Yes ❑ No 03/05/2019 ®Yes ❑ No
INDUSTRIAL USER PERMIT(IUP)FILE REVIEW(3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name 1. Ardagh Metal Beverage 2.Hanes Dye&Finishing 3.Suiza Dairy Group,LLC
30. IUP Number 3010 1155 1189
31. Does File Contain Current Permit? ® Yes El No ®Yes ❑ No ® Yes El No
32. Permit Expiration Date 06/30/2022 06/30/2022 06/30/2022
33. Categorical Standard Applied(I.E.40 CFR,Etc.)Or N/A 465 --- ---
34. Does File Contain Permit Application Completed Within One Year Prior ® Yes El No ® Yes ❑ No ® Yes ❑ No
to Permit Issue Date?
35. Does File Contain an Inspection Completed Within Last Calendar Year? ®Yes El 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. ❑Yes LINO b. ❑Yes❑No b. ❑Yes ❑No
37. For 40 CFR 413 and 433 TTO Certification,Does File Contain a Toxic ❑Yes❑NoEN/A ❑Yes❑NoEN/A ❑Yes❑NoEN/A
Organic Management Plan(TOMP)?
38. a.Does File Contain Original Permit Review Letter from the Division? a. ❑Yes No a. ❑Yes ENo a. ❑Yes ENo
b.All Issues Resolved? b.❑Yes❑No®NIA b❑Yes❑NoElN/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 EYes❑No❑N/A EYes❑No❑N/A ❑Yes❑NoEN/A
Sampling as Required by IUP, including flow?
4 lb. During the Most Recent Semi-Annual Period,Did SIU submit all reports EYes❑No❑N/A EYes❑No❑N/A EYes❑No❑N/A
on time?
42a.For categorical IUs with Combined Wastestream Formula(CWF),does ❑Yes❑NoEN/A ❑Yes❑NoEN/A ❑Yes❑NoEN/A
file include process/dilution flows as Required by IUP?
42b.For categorical lUs with Production based limits,does file include ❑Yes❑NoEN/A ❑Yes❑NoEN/A ❑Yes❑NoEN/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 El No
All Limits Non-Compliance from Both POTW and SIU Sampling? In Compliance Flow,BOD Flow
43b. During the Most Recent Semi-Annual Period,Did the POTW Identify ❑Yes❑NoEN/A EYes❑No❑N/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❑NoEN/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❑NoEN/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❑NoEN/A ❑Yes❑NoEN/A . ❑Yes❑NoEN/A
as Specified in the POTW's ERP(NOVs,Penalties,timing,etc.)?
48. Does the File Contain Penalty Assessment Notices? ❑Yes❑NoEN/A ❑Yes❑NoEN/A ❑Yes❑NoEN/A
49. Does The File Contain Proof Of Penalty Collection? ❑Yes❑NoEN/A ❑Yes❑NoEN/A ❑Yes❑NoEN/A
50. a.Does the File Contain Any Current Enforcement Orders? a.❑Yes❑No®N/A a.❑Yes❑No®N/A a.❑Yes❑NoEN/A
b. Is SIU in Compliance with Order9 b❑Yes❑NoEN/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 El Yes ® No
Requested Information For You?
NC DWR Pretreatment Compliance Inspection(PCI)Form Updated December 2016 Page 2

•
FILE REVIEW COMMENTS: Good lines of communication are maintained between the facility and the SIUs. One facility,Kaba
Ilco,has closed. The last discharge from the facility occurred on May 10,2019.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
1 I I a I I I I I l 1 I 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.
Requirements:
Recommendations:
NOD: ❑YES 1 NO
NOV: ❑ YES ®NO
QNCR: ❑ YES ® NO
POTW Rating:
Satisfactory X Marginal Unsatisfactory
PCI COMPLETED BY: Jim Gonsiewski DATE: 7/12/2019
NC DWR Pretreatment Compliance Inspection(PCI)Form Updated December 2016 Page 3