NC0023876_Compliance Evaluation Inspection_20190731

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
Mr. Robert C. Patterson, Jr., P.E.
Water Resources Director
City of Burlington
P.O. Box 1358
Burlington, North Carolina 27216
NORTH CAROLINA
Environmental Quality
July 31, 2019
SUBJECT: Pretreatment Compliance Inspection (PC])
City of Burlington
NPDES# NC0023876/South WWTP & NC0023868/East WWTP
Alamance County
Dear Mr. Patterson:
On July 2, 2019 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 Towns 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 fifteen (15) Significant Industrial Users (SIUs), two (2) of which are categorical. Both
treatment plants are permitted for 12 MGD. One (1) SIU (Copland Industries) closed in January 2019.
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, 2021.
The Sewer Use Ordinance (SUO) was approved on March 1, 2013.
The Enforcement Response Plan (ERP) was approved on October 3, 2008.
The Long Term Monitoring Plan (LTMP) was approved on January 27, 2006.
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1 450 West Hanes Mill Road, Suite 3001 Winston-Salem, North Carolina 27105
nioan+cuainw �'
336.776.9800

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 fifteen (15) SIUs were in significant noncompliance (SNC) in 2018.
A review of the file for Engineered Controls (#0019) revealed that the monitoring data was well organized
and compliant.
A review of the file for Carolina Biological Supply (#0065) revealed that the monitoring data was well
organized and compliant.
A'review of the file for Graham Dye & Finishing (#0015) revealed that the monitoring data was well
organized and compliant.
The slug control plan for Engineered Controls (#0019) was in good order.
The slug control plan for Carolina Biological Supply (#0065) was in good order.
The slug control plan for Graham Dye & Finishing (#0015) 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 [phone].
Sincerely,
Docuftned by:
145B49E225C94EA..
Lon T. Snider
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
ENViRONMEN rA QUALITY
BACKGROUND INFORMATION [Complete Prior To PCI• Review Program Info Database Sheet(s)l
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: 08/02/2018 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:
ICIS CODING
Main Program Permit Number
I N I C 1 0 1 0 1 2 1 3 1 8 1 7 1 6 I
Are Milestone Dates Being Met? ❑ YES ❑ NO
MM/DD/YY
► 07 1 02 1 18 1
7. Current Number Of Significant Industrial Users (SIUs)?
15
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?
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
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
either of the Last 2 Semi -Annual Periods? Not Been Published for SNC for
Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not Put
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?
21. Are Any Permits or Civil Penalties Currently Under Adjudication? If Yes, Which
Ones?
❑ YES ® NO
❑ YES ® NO
Limits: N/A
Reporting: N/A
dished: N/A
N/A
❑ YES ® NO
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. 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
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis A
11/16/2015
® Yes ❑ No
02/02/2016
® Yes ❑ No
04/01/2020
Industrial Waste Survey IWS
08/02/2016
® Yes ❑ No
09/19/2016
® Yes ❑ No
07/02/2021
Sewer Use Ordinance SUO
01/31/2013
® Yes ❑ No
03/01/2013
® Yes ❑ No
Enforcement Response Plan RP
07/29/2008
® Yes ❑ No
10/03/2008
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
11/18/2005
® Yes ❑ No
01/27/2006
® Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR I FILE REVIEW AND 1 IU INSPECTION)
29. User Name
1. Engineered Controls
2. Carolina Biological
3. Graham Dye & Finishing
Supply
30. lUP Number
0019
0065 11
0015
31. Does File Contain Current Permit?
® Yes ElNo
® Yes El IF
06/30/ Yes ❑
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
433
----
----
34. Does File Contain Permit Application Completed Within One Year Prior
® Yes ❑ No
Fffws ❑ No
®Yes ❑ No
to Permit Issue Date?
35. Does File Contain an Inspection Completed Within Last Calendar Year?
® Yes
❑
Rol
®Yes
❑
No1
®
Yes
❑ No
36. a. Does the File Contain a Slug/Spill Control Plan?
a. ®Yes ❑No
a. ®Yes ❑No
a. MYes ❑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
I ®Yes❑No❑N/A
❑Yes❑NoMN/A
❑Yes❑No®N/A
Organic Management Plan (TOMP)?
38. a. Does File Contain Original Permit Review Letter from the Division?
a. MYes ❑No
a. MYes ❑No
a. MYes []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, ineluding flow?
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
®
Yes ❑
No
®
Yes
❑ N—o-1
®
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 LUP, 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❑NoMN/A
❑Yes❑No®N/A
❑Yes❑NoON/A
file includeprocess/dilution flows as Required b IUP?
42b. For categorical IUs with Production based limits, does file include
❑Yes❑No®N/A
❑Yes❑NoUN/A
❑Yes❑NoNN/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❑No®N/A
❑Yes❑NoON/A
❑Yes❑No®N/A
All Re ortin Non-Com liance from SILT 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
c ❑Yes❑No®N/A
c.❑Yes❑No®N/A
of SIU limit violations in the POTW's sampling of the SIU?
46. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
I
El
es
®
No
❑
Yes
®
No
11
❑ Yes ®
No
47. During the Most Recent Semi -Annual Period, Was Enforcement Taken
❑Yes❑NoMN/A
❑Yes❑NoMN/A
❑Yes❑NoMN/A
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
48. Does the File Contain Penalty Assessment Notices?
❑Yes❑NoMN/A
❑Yes❑NoMN/A
❑Yes❑NoMN/A
49. Does The File Contain Proof Of Penalty Collection?
❑Yes❑NoMN/A
❑Yes❑NoNN/A
IF ❑Yes❑NoMN/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 Difficul in Obtainin An of This
El
® No
El Yes
0 Lo_j
❑
Yes ®No
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

Requested Information For You?
FILE REVIEW COMMENTS:
Well organized files. All information was readily available. One SIU (Copland Industries, Inc.) close 1/19.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
I 1 I I
1. Industry Inspected:
2. Industry Address:
3. Type of Industry/Product:
4. Industry Contact:
Phone: Fax:
Title:
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 ® NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ® NO
POTW Rating:
Satisfactory X Marginal Unsatisfactory
PCI COMPLETED BY: Jim Gonsiewski DATE: 07/30/2019
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3