NC0020621_Compliance Report_20211215

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
Mr. John A. Ward III
Town of Boone
P.O. Box 192
Boone, North Carolina 28607
NORTH CAROLINA
Environmental Quality
December 15, 2021
SUBJECT: Pretreatment Compliance Inspection (PCI)
Jimmy Smith WWTP
NPDES Permit No. NC0020621
Watauga County
Dear Mr. Ward:
On December 6, 2021, a Pretreatment Compliance Inspection (PCI) was performed by Alex Lowe of
the Winston-Salem Regional Office. Ms. Karen Reece, Pretreatment Coordinator 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, Charleston Forge, was conducted (previously permitted
SIU Hospitality Mints closed in May of 2020, and their permit has since been removed from the
program). Charleston Forge is a batch -release wastewater producer, and their sampling practices align
with requirements in 40 CFR 433.17. The IUP is set to expire on December 31, 2021, and Ms. Reece
was able to show Mr. Lowe a copy of the replacement permit to be issued on January 1, 2022.
Ms. Reece noted that there have been some recent issues with copper exceedances showing up in the
pre -discharge testing, but since no wastewater is released from the SIU until the testing shows
compliance with their permit, no NOV has been issued. The SIU was able to determine the source of
the excess copper and is in the process of pumping out the affected holding tanks. All required pollutant
sampling by the POTW was confirmed to be of the proper frequency according to the LTMP. No
concerns were uncovered in reviewing this SIU file.
D_E
NORTH CAROLINA ` �{
Ilwaeimen1 of EmImnmGMdl WIZ
North Carolina Department of Environmental Quality 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)
09/28/2020
/1
Yes
•
No
In Review
•
Yes
//
No
Industrial Waste Survey (IWS)
2/12/2019
►1
Yes
•
No
03/01/2019
//
Yes
•
No
04/01/2024
Sewer Use Ordinance (SUO)
11/06/2012
1
Yes
•
No
11/07/2012
►/
Yes
•
No
Enforcement Response Plan (ERP)
01/30/2020
LI
Yes
•
No
2/13/2020
1
Yes
•
No
Long Term Monitoring Plan (LTMP)
08/29/2017
11
Yes
•
No
09/19/2017
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,
Deo�„cu��Si''gn�ned"w by: ei
OD2D3CED3F1E7456... ((JJ
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
NORTH cto
DewhmaM or fnvIri�onmeirtai (Imlay
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 300 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: Jimmy Smith WWTP (Boone)
2. Control Authority Representative(s): Karen Reece
3. Title(s): Lab Supervisor/Pretreatment Coordinator
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 1 0 10 1 2 1 016 1 2 1 1[ J 12 I06 121 1
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)?
1
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)
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 El 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 El NO
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)
09/28/2020
/1 Yes ❑ No
In Review
❑ Yes /1 No
Industrial Waste Survey (IWS)
2/12/2019
/1 Yes ❑ No
03/01/2019
/1 Yes ❑ No
04/01/2024
Sewer Use Ordinance (SUO)
11/06/2012
/1 Yes ❑ No
11/07/2012
/1 Yes ❑ No
Enforcement Response Plan (ERP)
01/30/2020
/1 Yes ❑ No
2/13/2020
Cl Yes ❑ No
Long Term Monitoring Plan (LTMP)
08/29/2017
a Yes ❑ No
09/19/2017
Cl Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION
29. User Name 1. Charleston Forge 2.
3.
30. IUP Number
0004
31. Does File Contain Current Permit?
/1 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
32. Permit Expiration Date
12/31/2021
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
433.17
34. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
/1 Yes ❑ No
08/10/2021
❑ Yes ❑ No
❑ Yes ❑ No
35. Does File Contain an Inspection Completed Within Last Calendar Year?
/1 Yes ❑ No
05/25/2021
❑ 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. LYes •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)?
SYes❑No❑N/A
Last certified
08/11/2021
❑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. ►SYes •No
b.❑Yes❑NoSN/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
10/21/2021
❑ 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?
SYes❑No❑N/A
09/14/2021
❑Yes❑No❑N/A
❑Yes❑No❑N/A
41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports
On time?
❑YesSNo❑N/A
Tox. Cert was late,
so NOV was issued;
also day late on
flow data for
October 2020
❑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❑NoSN/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❑NoSN/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?
/1 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?
SYes❑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 awarec.
of SIU limit violations in the POTW's sampling of the SIU?
a.❑Yes❑No®N/A
b.❑Yes❑No®N/A
❑yes❑No®N/A
a.❑Ycs❑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 /1 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.)?
SYes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
48. Does the File Contain Penalty Assessment Notices?
❑Yes❑NoSN/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
49. Does The File Contain Proof Of Penalty Collection?
❑Yes❑NoSN/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❑NoON/A
a.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
a.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
NC DWR Pretreatment Compliance Inspection (PCI) Form
Updated December 2016 Page 2

51. Did the POTW Representative Have Difficulty in Obtaining Any of This
Requested Information For You?
❑ Yes I No
❑ Yes ❑ No
❑ Yes ❑ No
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 Jimmy Smith WWTP in Boone. Lab Supervisor/Pretreatment Coordinator Karen Reece was
present for the inspection.
Lowe reviewed the pretreatment program elements and found that 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, Charleston Forge, was conducted (previously permitted SIU Hospitality Mints
closed in May of 2020, and their permit has since been removed from the program). Charleston Forge is a batch -release
wastewater producer, and their sampling practices align with requirements in 40 CFR 433.17. The IUP is set to expire on
December 31, 2021, and Ms. Reece was able to show Mr. Lowe a copy of the replacement permit to be issued on January 1,
2022.
Ms. Reece noted that there have been some recent issues with copper exceedances showing up in the pre -discharge testing,
but since no wastewater is released from the SIU until the testing shows compliance with their permit, no NOV has been
issued. The SIU was able to determine the source of the excess copper and is in the process of pumping out the affected
holding tanks. All required pollutant sampling by the POTW was confirmed to be of the proper frequency. No concerns were
uncovered in reviewing this SIU file.
This program is found to be 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