NC0020451_Inspection_20200407

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
April 7, 2020
Mr. Brandon Patrick, Pretreatment Coordinator
PO Box 490
West Jefferson, NC 28694
SUBJECT: Pretreatment Compliance Inspection Report
Town of West Jefferson
NPDES# NCO020451
Ashe County
Dear Mr. Patrick:
On March 24, 2020, Paul DiMatteo of the Division of Water Resources, Winston-Salem
Regional Office conducted a Pretreatment Compliance Inspection at the above referenced
wastewater treatment system. The purpose of this inspection was to determine the effectiveness
of the Town's pretreatment program, which included: reviewing the files, POTW plant
performance, sampling and compliance judgement program, and adherence to the Enforcement
Response Plan.
Background
The Town operates one 0.5 MGD facility and has 1 significant industrial user (SIU).
POTW Interview
There was one NPDES permit limit violation for copper in October 2019. Mr. Patrick indicated
that he was concerned about illegal dumping and noted that there was a hit for the same
parameter at the same time the year before. Mr. Powell said he has not had issues implementing
the pretreatment program.
Pretreatment Program Elements Review
The Headworks Analysis (HWA) renewal was submitted for on February 6, 2019 and approved
on March 4, 2019. The next HWA is due on April 1, 2024.
The City's last Industrial Waste Survey (IWS) was submitted on March 25, 2019 and was
approved on July 11, 2019. The next IWS is due April 1, 2024.
The last Short -Term Monitoring Plan (STMP) was submitted on March 25, 2019 and approved
on July 11, 2019.
D � North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office [ 450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105
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The Sewer Use Ordinance (SUO) was approved on January 10, 2013.
The ERP was approved on May 26, 2017.
STMP Review
The STMP is not currently being conducted.
Industrial User Permit (IUP) File Review
A review of the files for Ashe County Cheese (#0003) revealed that monitoring data was well
organized and violations were addressed in a timely manner consistent with the ERP. The slug
control plan was in good order.
If you have any questions, please contact Paul DiMatteo at [phone] or
Paul.Dimatteo(&ncdenr.aov; or our office at [phone].
Sincerely,
DocuSigned by:
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Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
cc: DWR Laserfiche Files

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
Waterkesaurces
ENVIRONMENTAL OVAL I TY
BACKGROUND INFORMATION 1Comnlete Prior To PCI: Review Program Info Database Sheets
1. Control Authority (POTW) Name: West Jefferson
2. Control Authority Representative(s): _Brandon Patrick
3. Title(s): WWTP ORC/Pretreatment Coordinator
4. Last Inspection Date: 3/12/2019 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
N I C 1 0 1 0 1 2 10 1 4 1 5 1 1 103 124 120 J
7. Current Number Of Significant Industrial Users SIUs ?
1
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 ?
0
16. Number of CIUs in SNC? 11
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?
Concerned about illegal dumping, but Mr. Patrick also noted that there was a
hit the same time last year.
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 Pul
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?
EYES ❑ NO
Copper, 10/2019
❑ YES ® NO
Limits: None
Reporting: None
dished: N/A
None
❑ YES ® NO
LTMP/STMP FILE REVIEW: STMP Monitoring is not currently being conducted.
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.
27.
If NO to 23 - 26, list violations
Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ®NO
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1

If yes, which ones? Eliminated: Added:
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

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 (HWA)
2/6/2019
® Yes ❑ No
3/4/2019
® Yes ❑ No
4/1/2024
Industrial Waste Survey IWS
3/25/2019
® Yes ❑ No
7/11/2019
® Yes ❑ No
4/1/2024
Sewer Use Ordinance SUO)
12/19/2012
® Yes ❑ No
1/10/2013
® Yes ❑ No
Enforcement Response Plan (ERP)
1 3/8/2017
® Yes ❑ No
5/6/2017
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
1 3/25/2019
® Yes ❑ No
7/11/2019
® Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name
1. Ashe County Cheese 2.
3.
30. IUP Number
0003
31. Does File Contain Current Permit?
® Yes ❑ No
❑ Yes ❑
I❑ Yes ❑ No
32. Permit Expiration Date
6/30/2024
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
N/A
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 11
❑ 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 ❑No
b. ❑Yes ON-
b. ❑Yes ❑No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
❑Yes❑No[D
71
❑Yes❑No❑N/A
❑Yes❑No❑N/A
Organic Management Plan TOMP ?
38. a. Does File Contain Original Permit Review Letter from the Division?
®Yes ❑No
ROYesONoIR
a. ❑Yes ❑No
a. ❑Yes ❑No
b. All Issues Resolved?
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❑No[D
❑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❑N/A
production rates and/or flows as Required b 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?
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
All Re porting_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❑No❑N/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 J1
❑
Yes
❑
No
I
❑
Yes
❑
No
47. During the Most Recent Semi -Annual Period, Was Enforcement Taken
®Yes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/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❑NoON/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[9
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
ElYes [_1 No
Requested Information For You?
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3

FILE REVIEW COMMENTS:
Industry had a silver violation in September, but did extra sampling to stay out of SNC. They don't have any monthly average
limits.
Files were well organized and readily available.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
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: None. A well run program.
Requirements:
Recommendations:
NOD: ❑ YES ® NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ® NO
POTW Rating:
Satisfactory XXXX Marginal UnSatisfactory
Docu Signed by:
PCI COMPLETED BY: �� DATE: 3/24/2020
F10C7C2E5BB34D4...
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 4