NC0024147_Pretreatment Compliance Inspection_20221118

DocuSign Envelope ID: C4B124F8-F43D-496C-AA39-AC2A98418DA9
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Mr. Scott Siletzky
WWTP Superintendent
City of Sanford
P.O. Box 3729
Sanford, NC 27331-3729
NORTH CAROLINA
Environmental Quality
November 18, 2022
Subject: Pretreatment Compliance Inspection
City of Sanford
Big Buffalo WWTP - NPDES Permit No. NC0024147
Lee County
Dear Mr. Siletzky:
On August 24, 2022, Cheng Zhang of the Raleigh Regional Office conducted a Pretreatment
Compliance Inspection of City of Sanford's pretreatment program. The assistance given by Ms. Sarah
Jordan, the pretreatment coordinator, was greatly appreciated. The inspection report is attached.
Findings during the inspection were as follows:
1. There are eleven Significant Industrial Users (Sills) discharging, nine of which are also
Categorical Industrial Users (CIUs). It was noted that Chara and Arauco were in Significant
Non -Compliance (SNC) during the two most recent semi-annual periods.
2. The pretreatment inspection file review included Arauco (Permit No. 0042), Pfizer (Permit No.
0022) and Moen (Permit No. 0008). The files needed for review were available for inspection,
contained all the required elements and were in excellent condition. During the first semi-annual
period of 2012, Arauco had a copper and four Zinc violations and was late in submitting required
zinc resampling result, Arauco was in SNC for zinc violation. These violations were
appropriately addressed by the POTW per Enforcement Response Plan (ERP). Pfizer and Moen
were in compliance.
3. A review of the files containing the pretreatment program elements was conducted. All files
were up to date, available and well organized. It was noted that update of Headworks Analysis
was submitted in April 2022 and is in review by the Division. The City needs to update the
Long Term Monitoring Plan (LTMP) by using the NC DEQ Published Detection Limit
Values.
4. LTMP data for were reviewed, it was noted that all parameters were sampled at required
locations and analyzed with required detection levels. LTMP data was well organized and
maintained.
D.••=EQ
NORTH CAROLINA
DeperhneM of Environmental Oual�
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office I 3800 Barrett Drive I Raleigh, North Carolina 27609
919.791.4200

DocuSign Envelope ID: C4B124F8-F43D-496C-AA39-AC2A98418DA9
Thank you for your continued support of the Pretreatment Program. If you have any questions or
comments, please call Cheng Zhang at [phone] (or email: [e-mail]).
Enclosure: City of Sanford PCI Inspection Form
CC: Laserfiche
D_E
NORTH CARCLINA
gaparhnanl of Environmental quality
Sincerely,
DocuSigned by:
Ehuiu-ssa f. �4 ai in,ltit,(,
B2916E6AB32144F...
Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11611 Mail Service Center I Raleigh, North Carolina 27699-1611
919.707.9000

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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 Sanford
2. Control Authority Representative(s): Sarah Jordan
3. Title(s): Pretreatment Coordinator
4. Last Inspection Date: 9/17/2021 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
NICIO 10 12141114171
MM/DD/YY
L 08 124 1 22 I
7. Current Number Of Significant Industrial Users (SIUs)?
11
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?
2
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)?
9
16. Number of CIUs in SNC?
2
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
either of the Last 2 Semi -Annual Periods? Not Been Published for
Public Notice?(May refer to PAR if Excessive SIUs in SNC)
SNC for
SNC for
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? Chara is challenging the SNC status and penalty
❑ YES /1 NO
❑ YES A NO
Limits: Chara for Mo, Arauco for Zn
Reporting: None
lished: None
None
/1 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/ 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 ® NO
If yes, which ones? Eliminated: Added:
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1

DocuSign Envelope ID: C4B124F8-F43D-496C-AA39-AC2A98418DA9
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 Approva 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 (HWA)
4/2022
@ Yes ❑ No
2/22/2018
@ Yes ❑ No
5/1/2022
Industrial Waste Survey (IWS)
6/30/2018
/1 Yes ❑ No
8/10/2018
/1 Yes ❑ No
8/1/2023
Sewer Use Ordinance (SUO)
12/20/2011
a Yes ❑ No
1/25/2012
r Yes ❑ No
Enforcement Response Plan (ERP)
4/20/2009
a Yes ❑ No
7/17/2009
r Yes ❑ No
Long Term Monitoring Plan (LTMP)
12/22/2014
/1 Yes ❑ No
3/12/2015
r Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION
29. User Name 1. Arauco 2. Pfizer
3. Moen
30. IUP Number
0042
0022
0008
31. Does File Contain Current Permit?
/1 Yes ❑ No
/1 Yes ❑ No
/1 Yes ❑ No
32. Permit Expiration Date
9/30/2024
9/30/2024
9/30/2024
429
439
433
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
34. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
i1 Yes ❑ No
@ Yes ❑ No
/1 Yes ❑ No
35. Does File Contain an Inspection Completed Within Last Calendar Year?
/1 Yes ❑ No
/1 Yes ❑ No
1 Yes ❑ No
36. a. Does the File Contain a Slug/Spill Control Plan?
b. If No, is One Needed? (See Inspection Form from POTW)
a. AYes •No
b. •Yes •No
a. ► Yes •No
b. •Yes •No
a. AYes •No
b. •Yes •No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
Organic Management Plan (TOMP)?
❑ Yes ❑No®N/A
❑Yes❑No ON/A
®Yes❑No❑N/A
38. a. Does File Contain Original Permit Review Letter from the Division?
b. All Issues Resolved?
a. AYes •No
b.❑Yes❑No❑N/A
a. ► Yes •No
b.❑Yes❑No❑N/A
a. AYes •No
b.❑Yes❑No❑N/A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
its Sampling as Required by IUP, including flow?
/1 Yes ❑ No
/1 Yes ❑ No
❑ Yes I No
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
A Yes ❑ No
/1 Yes ❑ No
A Yes ❑ No
41. During the Most Recent Semi -Annual Period, Did the SIU Complete its
Sampling as Required by IUP, including flow?
®Yes❑No❑N/A
®Yes❑No❑N/A
®Yes❑No❑N/A
41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports
on time?
®Yes❑No❑N/A
NYes❑No❑N/A
®Yes❑No❑N/A
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
file include process/dilution flows as Required by IUP?
111Yes®NoE1N/A
❑Yes❑NoON/A
❑Yes❑No®N/A
42b. For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
❑Yes❑No®N/A
❑Yes❑NoNN/A
❑Yes❑No®N/A
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Limits Non -Compliance from Both POTW and SIU Sampling?
® Yes ❑No❑N/A
❑Yes❑No ON/A
III Ycs❑No®N/A
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Reporting Non -Compliance from SIU Sampling?
❑Yes❑No®N/A
❑Yes❑NoON/A
❑Yes❑No®N/A
44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
Monitoring Violations?
b. Did Industry Resample and submit results to POTW Within 30 Days?
c. If applicable, Did POTW resample within 30 days of becoming awarec.
of SIU limit violations in the POTW's sampling of the SIU?
a.❑Yes❑NoNN/A
b.®Yes❑No❑N/A
❑yes❑NoNN/A
a.❑Yes❑NoEIN/A
b.❑Yes❑NoEIN/A
c.❑Yes❑No®N/A
a.❑Yes❑No®N/A
b.❑Yes❑No®N/A
c.❑Yes❑No®N/A
46. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
/1 Yes ❑ No
❑ Yes 0 No
/1 Yes ❑ No
47. During the Most Recent Semi -Annual Period, Was Enforcement Taken
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
®Yes❑No❑N/A
❑Yes❑NoON/A
®Yes❑No❑N/A
48. Does the File Contain Penalty Assessment Notices?
® Yes ❑No❑N/A
❑Yes❑No ON/A
® Yes ❑No❑N/A
49. Does The File Contain Proof Of Penalty Collection?
®Yes❑No❑N/A
❑Yes❑NoON/A
®Yes❑No❑N/A
50. a. Does the File Contain Any Current Enforcement Orders?
b. Is SIU in Compliance with Order?
a.❑Yes❑No®N/A
b.❑Yes❑NoEIN/A
a.❑Yes❑NoEIN/A
b.❑Yes❑No®N/A
a.❑Yes❑No®N/A
b.❑Yes❑NoEIN/A
51. Did the POTW Representative Have Difficulty in Obtaining Any of This
Requested Information For You?
❑ Yes /1 No
❑ Yes r No
❑ Yes I No
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

DocuSign Envelope ID: C4B124F8-F43D-496C-AA39-AC2A98418DA9
FILE REVIEW COMMENTS:
41— Arauco had multiple four zinc violations and one copper violation.
46 — Arauco was in SNC for zinc violations.
47 — POTW issued two NOVs to Arauco limit violations and SNC.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
J I I I I I I I JL1 1 I 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 El YES E NO
B. Plant Tour El 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: The program is well managed.
Requirements: LTMP needs to be updated by using the NC DEQ Published Detection Limit Values
Recommendations: None
NOD: ❑ YES ® NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ® NO
POTW Rating:
® Satisfactory ❑ Marginal ❑ UnSatisfactory
PCI COMPLETED BY: Cheng Zhang, Raleigh Regional Office DATE: August 24, 2022
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3