NC0020567_Pretreatment Compliance Inspection Report_20210708

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
Ms. Nicole Johnston
Yadkin Valley Sewer Authority
P.O. Box 828
Elkin, North Carolina 28621
NORTH CAROLINA
Environmental Quality
July 8, 2021
SUBJECT: Pretreatment Compliance Inspection (PCI)
Yadkin Valley Sewer Authority
NPDES# NC0020567
Surry County
Dear Ms. Johnston:
On June 24, 2021 a Pretreatment Compliance Inspection (PCI) was performed by Jim Gonsiewski
and Tricia Lowery of the Winston-Salem Regional Office. Ms. Nicole Johnston, Executive
Director of the Yadkin Valley Sewer Authority was present for the inspection along with Mr. Dave
Johnson (Assistant Executive Director), Ms. Portia Hayes (Administrative Assistant), and Ms.
Nicki Hembree (Office Assistant) of the Yadkin Valley Sewer Authority. Mr. Ron Lynn of West
Consultants participated by telephone. The purpose of this inspection was to determine the
effectiveness of the 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 1.8 MGD permitted facility. The POTW has one (1) Significant Industrial User (SIU)
(PGWNitro Auto Glass) which is non -categorical. Weyerhaeuser was an SIU until December 31,
2020 when they allowed their permit to expire. Weyerhaeuser installed a new pretreatment system
that enabled them to reuse all process water.
POTW Interview
There are no plant problems related to pretreatment issues and there are no NPDES permit limit or
monitoring violations recorded from December 2019 through May 2021. The facility is very well
operated.
Pretreatment Program Elements Review
The Headworks Analysis (HWA) renewal was submitted on November 6, 2020. The HWA is
currently under review.
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105
336.776.9800

The last Industrial Waste Survey (IWS) was submitted on July 13, 2018. The IWS was approved
on December 3, 2018. The next IWS is due on April 1, 2023.
The Sewer Use Ordinance (SUO) was approved on January 6, 2012.
The Enforcement Response Plan (ERP) was approved on September 2, 2020.
The Short Term Monitoring Plan (STMP) was approved on February 12, 2020.
STMP File Review
The Short Term Monitoring Plan (STMP) is being conducted at the proper locations and
frequencies.
Industrial User Permit (IUP) File Review
The SIU was in significant noncompliance (SNC) for garnet in August 2020. The SIU was also
in SNC for using a biocide (CL-206) without permission from July 24, 2020 to April 28, 2021.
Fines totaling $20,000 were assessed.
A review of the file for PGW/Vitro Auto Glass (IWP 001) revealed that the monitoring data was
well organized and compliant.
The slug control plan for PGW/Vitro Auto Glass (IWP 001) was in good order.
Action Items
No other action items were noted.
The pretreatment program is considered satisfactory. Ms. Johnston maintains an excellent
pretreatment program. If you have any questions please contact Jim Gonsiewski or me at (336)
776-9800.
Sincerely,
DocuSipned by:
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0D2D3CE3F1B7458...
Jennifer F. Graznak
Assistant Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
Encl: PCI Report
cc: PERCS Unit — Michael Montebello (Electronic Copy)
WSRO Electronic Files
Laserfiche Files
Dcyarwun a Dmevmeuw aai` /W°
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105
336.776.9800

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)l
1. Control Authority (POTW) Name: Yadkin Valley Sewer Authority WWTP
2. Control Authority Representative(s): Nicole Johnston„ Dave Johnson, Portia Hayes, Nikki Hembree, Ron Lynn
3. Title(s): Executive Director, Assistant Executive Director, Administrative Assistant, Engineering Consultant (West Engineers, PLLC)
4. Last Inspection Date: 01/17/19 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
f NI CIO 10 1 21 0 1 5 1 61 7I J 06 J 24 I 21 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?
1
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?
1
12. Number of SIUs in SNC For Reporting During Either of the Last 2 Semi -Annual Periods?
1
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?
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
either of the Last 2 Semi -Annual Periods? Not Been Published for
Public Notice?(May refer to PAR if Excessive SIUs in SNC)
❑ YES ® NO
❑ YES ®NO
SNC for Limits: 1
SNC for Reporting: 1 (ChemTreat CL-206) YES
Not Published: Will publish in July 2021
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?
None
❑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. If NO to 23 - 26, list violations
27. 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

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)
11/06/20
// Yes ❑ No
In Review
❑ Yes ❑ No
In review
Industrial Waste Survey (IWS)
07/13/18
/1 Yes ❑ No
12/03/18
' Yes ❑ No
04/01/23
Sewer Use Ordinance (SUO)
12/15/11
/1 Yes ❑ No
01/06/12
/1 Yes ❑ No
Enforcement Response Plan (ERP)
06/01/20
a Yes ❑ No
09/02/20
/1 Yes ❑ No
Short Term Monitoring Plan (STMP)
10/17/19
/1 Yes ❑ No
02/12/20
/1 Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION
29. User Name
1. PGWNitro Auto Glass
2.
3.
30. IUP Number
001
31. Does File Contain Current Permit?
/1
Yes ❑ No
❑ Yes ❑
No
❑
Yes
❑ No
32. Permit Expiration Date
09/30/21
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?
/1 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
35. Does File Contain an Inspection Completed Within Last Calendar Year?
/1 Yes
❑ No
❑ Yes ❑ No
❑ 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. Yes •No
b. •Yes ■ No
a. ■Yes •No
b. •Yes ■ No
a. ■Yes 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❑N/A
❑Yes❑No❑N/A
38. a. Does File Contain Original Permit Review Letter from the Division?
b. All Issues Resolved?
a. ►0Yes •No
b.❑Yes❑No®N/A
a. •Yes ■No
b.❑Yes❑No❑N/A
a. ■Yes •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?
' Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
/1 Yes ❑ No
❑ Yes ❑ No
❑
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
❑Yes❑No❑N/A
❑Yes❑No❑N/A
42a. For categorical lUs with Combined Wastestream Formula (CWF), does
file include process/dilution flows as Required by IUP?
❑Yes❑NoON/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
42b. For categorical His with Production based limits, does file include
production rates and/or flows as Required by IUP?
❑Yes❑No®N/A
❑Yes❑No❑N/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?
/5 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Reporting Non -Compliance from SIU Sampling?
®Yes❑No❑N/A
❑Ycs❑No❑N/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 aware
of SIU limit violations in the POTW's sampling of the SIU?
a.®Yes❑No❑N/A
b.®Yes❑No❑N/A
c.®Yes❑No❑N/A
a.❑Yes❑No❑N/A
b.❑Yes❑No❑N/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
❑
No
❑
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❑No❑N/A
❑Yes❑No❑N/A
48. Does the File Contain Penalty Assessment Notices?
®Yes❑No❑N/A
❑Yes❑No❑N/A
I ❑Yes❑No❑N/A
49. Does The File Contain Proof Of Penalty Collection?
®Yes❑No❑N/A
❑Yes❑No❑N/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❑No®N/A
a.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
a.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
51. Did the POTW Representative Have Difficulty in Obtaining Any of This
Requested Information For You?
❑ Yes ►1 No
❑ Yes ❑ No
❑ Yes ❑ No
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

FILE REVIEW COMMENTS:
The expiration date for the PGWNitro Auto Glass permit was extend from 03/06/21 to 09/30/21. The POTW and PGW entered into a
Consent Order and Compliance Schedule with PGWNitro Auto Glass on March 10, 2020. The order expired on July 31, 2020. The
SIU was in SNC for garnet in August 2020. A biocide (CL-206) was used from 07/24/20 to 4/28/21 to prolong the life of membranes in
use at the SIU. The POTW previously directed PGWNitro Auto Glass not to use the biocide. A fine of $20,000 was issued.
Weyerhaeuser was permitted as an SIU from March 2018 until December 31, 2020. However, only sanitary wastewater was sent to the
POTW for treatment. Average flow was approximately 150,000 gallons per month. Weyerhaeuser is permitted for300,000 gallons per
month. No process water was ever sent to the POTW. Weyerhaeuser purchased a new pretreatment system that allows them to recycle
all their process water. The permit expired on December 31, 2020.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
1. Industry Inspected:
2. Industry Address:
1 1 1 1
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 LINO
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: An extremely well run program
Requirements: None.
Recommendations: None
NOD: ❑ YES ® NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ® NO
POTW Rating:
Satisfactory X Marginal
PCI COMPLETED BY: Jim Gonsiewski
Unsatisfactory
DATE Jt y 8, 2021
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3