NC0020451_Compliance Report_20211215

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
Mr. Brantley Price
Town of West Jefferson
P.O. Box 490
West Jefferson, NC 28694
NORTH CAROLINA
Environmental Quality
December 15, 2021
SUBJECT: Pretreatment Compliance Inspection (PCI)
West Jefferson WWTP
NPDES Permit No. NC0020451
Ashe County
Dear Mr. Price:
On December 6, 2021, a Pretreatment Compliance Inspection (PCI) was performed by Alex Lowe
of the Winston-Salem Regional Office. Mr. Brandon Patrick, ORC, was present for the
inspection. The purpose of this inspection was to determine the effectiveness of the pretreatment
program, which includes reviewing the program element files, POTW plant performance,
industry monitoring data, and adherence to the enforcement response plan (ERP).
POTW Interview and Industrial User Permit (IUP) File Review
A file review of the only SIU in the program, Ashe County Cheese, was conducted. This SIU is a
non -categorical industrial user which passes cheese production wash water onto the POTW. Mr.
Patrick stated that the SIU has maintained satisfactory communication and delivers permit -
required data in a timely manner. Lowe confirmed that all data appears to have been collected and
reported properly, both by the SIU and by the POTW. This SIU has received notice of violation in
the last semi-annual period for limit exceedances of BOD, TSS, silver, and cyanide. This
violation did not result in the user being placed in SNC per the ERP.
Mr. Patrick was particularly helpful in accessing and sharing this information with Mr. Lowe. No
areas of concern were uncovered during this inspection
1:1E
NORTH CAROLINA
OeprAnert of FmlmemeW OwNry`
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

Pretreatment Program Elements Review
Lowe reviewed the pretreatment program elements and found that all were up to date and
properly documented with letters from the DWR. See table below for dates of latest element
approvals and dates of required renewal.
Program Element
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
2/6/2019
►1
Yes
•
No
3/4/2019
/1
Yes
•
No
4/1/2024
Industrial Waste Survey (IWS)
3/25/2019
►1
Yes
•
No
7/11/2019
Yes
•
No
4/1/2024
Sewer Use Ordinance (SUO)
12/19/2012
/1
Yes
•
No
01/10/2013
Yes
•
No
Available on
TWJ website
Enforcement Response Plan (ERP)
2/11/2020
/1
Yes
•
No
2/13/2020
A
Yes
•
No
Long Term Monitoring Plan (LTMP)
3/25/2019
/1
Yes
•
No
7/11/2019
/1
Yes
•
No
Action Items
No other action items were noted. The pretreatment program is considered satisfactory. If you
have any questions, please contact Alex Lowe or me at [phone].
Sincerely,
(-DocuSigned by:
-0D2D3CE3F1B7456...
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
D_E _
Deparirnertofemronme,,aI /110'.1
NORTH CAROLINA
North Carolina Department of Environmental Quality 1 Division of Water Resources
Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105
336.776.9800

NCNORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
W ¢.X,rf
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BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)1
1. Control Authority (POTW) Name: West Jefferson WWTP
2. Control Authority Representative(s): Brandon Patrick
3. Title(s): ORC
4. Last Inspection Date: February 23, 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
ICIS CODING
Main Program Permit Number
MM/DD/YY
J N I C I 0 10 12 I 0 I 4 I 5 I 1[ J 12 I 06 121
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?
N/A
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 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?
❑ YES /1 NO
❑ YES /1 NO
Limits: N/A
Reporting: N/A
lished: N/A
None
❑ YES 1 NO
LTMP/STMP FILE REVIEW:
22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES
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
❑ 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)
2/6/2019
/1 Yes ❑ No
3/4/2019
/1 Yes ❑ No
4/1/2024
Industrial Waste Survey (IWS)
3/25/2019
/1 Yes ❑ No
7/11/2019
/1 Yes ❑ No
4/1/2024
Sewer Use Ordinance (SUO)
/1 Yes ❑ No
/1 Yes ❑ No
Available on
town website
Enforcement Response Plan (ERP)
2/11/2020
// Yes ❑ No
2/13/2020
/1 Yes ❑ No
Long Term Monitoring Plan (LTMP)
3/25/2019
II Yes ❑ No
7/11/2019
/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. Ashe County Cheese 2.
3.
30. IUP Number
0003
31. Does File Contain Current Permit?
/1 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
32. Permit Expiration Date
6/30/2024
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
NA
34. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
/1 Yes ❑ No
2/12/2019
❑ Yes ❑ No
❑ Yes ❑ No
35. Does File Contain an Inspection Completed Within Last Calendar Year?
/1 Yes ❑ No
10/19/2021
❑ 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. L Yes ■ No
b.❑Yes ❑No ON/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?
/1 Yes ❑ No
April and July
❑ 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 IUs with Combined Wastestream Formula (CWF), does
file include process/dilution flows as Required by IUP?
❑Yes❑No®N/A
❑Yes❑No❑N/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❑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?
i1 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
BOD, TSS, Ag,
and Cyanide
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Reporting Non -Compliance from SIU Sampling?
❑Yes❑No®N/A
❑Yes❑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?
❑ Yes 0 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
❑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
❑ Yes /1 No
❑ Yes ❑ No
❑ Yes ❑ No
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

Requested Information For You?
OVERALL SUMMARY AND COMMENTS:
On Monday, December 6, 2021, Alex Lowe of the Winston-Salem Regional Office conducted a routine Pretreatment
Compliance Inspection at the Town of West Jefferson WWTP. ORC Brandon Patrick was present for the inspection.
Lowe reviewed the pretreatment program elements and found all were up to date and properly documented with letters from
the DWR. See table (item number 28 on PCI Report) for dates of latest element approvals and dates of required renewal.
A file review of the only SIU in the program, Ashe County Cheese, was conducted. This SIU is a non -categorical industrial
user which passes cheese production wash water onto the POTW. Mr. Patrick stated that the SIU has maintained satisfactory
communication and delivers permit -required data in a timely manner. Lowe confirmed that all data appears to have been
collected and reported properly, both by the SIU and by the POTW. This SIU has received notice of violation in the last semi-
annual period for limit exceedances of BOD, TSS, silver, and cyanide. This violation did not result in the user being placed in
SNC per the ERP.
Mr. Patrick was particularly helpful in accessing and sharing this information with Mr. Lowe. No areas of concern were
uncovered during this inspection, and the program should be considered satisfactory.
NOD: ❑ YES ® NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ® NO
POTW Rating:
Satisfactory X Marginal
UnSatisfactory
PCI COMPLETED BY: Alex Lowe, DWR, WQROS WSRO DATE: December 6, 2021
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3