NC0020567_Pretreatment Annual Report_20220225

EXECUTIVE DIRECTOR CHAIR
Nicole Johnston sawn Vaii@y Woody Faulk
* VICE-CHAIR
SECRETARY *
Anita Darnell
Anita Darnell
tit 119
,�� BOARD OF DIRECTORS
{ Rheajean Benge
TREASURER 02' Autin0 Wayne V. Moore
Wayne V.Moore Tommy Wheeler
February 21, 2022
Mr. Michael Montebello
NC Division of Water Quality RECEIVED
PERCS Unit
1617 Mail Service Center FEB 2 5 Z022
Raleigh, NC 27699-1617
RE: 2021 Pretreatment Annual Report NCDEQIDWRINPDES
Yadkin Valley Sewer Authority (YVSA)
NPDES Permit No. NC0020567
Dear Mr. Montebello:
Enclosed are an original and one copy of the Yadkin Valley Sewer Authority's Pretreatment
Annual Report (PAR) for the period of January 1, 2021 through December 31, 2021.
I certify, under penalty of law, that this document and all attachments were prepared under my
direction, or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate,
and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fines and imprisonment for knowing violations.
Please contact me at [phone], or Benjie Thomas of West Consultants at [phone]
with any questions.
Sincerely,
Nicole Johnston
Executive Director
cc: Benjamin B. Thomas, PE
500 NC Hwy 268 W — Elkin,NC 28621
Phone: [phone] - www.yvsa.org — Fax: [phone]

General Information:
This is the seventh PAR submitted and the following IUP is in YVSA's pretreatment program:
• Pittsburgh Glass Works, LLC (PGW)which began operation in early March 2013
The AT, STMP, HWA, SUO, ERP, IWS and permits are up to date. The Division's Pretreatment
Program Info Database was updated and is enclosed. The updated items are highlighted on the
info database (note that the HWA was submitted on 11/6/20 and is currently being reviewed).
The received SNC Report is correct as received.
Site inspections of the PGW facility were completed by the YVSA staff on 2/1/21, 5/25/21, and
12/9/21 (with NC inspector).
IU Information:
PGW's IUP renewal effective and expiration dates are 10/1/21 and 12/31/22,respectively.
The attached notice of violation(NOV) and civil penalty assessment letter was issued to PGW
on June 22, 2021, which included a penalty of$20,000. The primary reason for the NOV and
penalty was because PGW used a non-approved chemical treatment to address the severe
biological growth in their reverse osmosis and/or washer system(s). However, the enclosed
signed Consent Order and Compliance Schedule was agreed upon, so the penalty was reduced to
$10,000.
The following are enclosed:
• PAR Tables
• Updated Pretreatment Program Info Database
• Notice of Violation(NOV) and Civil Penalty Assessment Letter
• Public Notice of IUP Violation
• Consent Order and Compliance Schedule
• Civil Penalty Invoice (9/3/21) & Check Receipt
500 NC Hwy 268 W — Elkin,NC 28621
Phone: [phone] — www.yvsa.org — Fax: [phone]

Pretreatment Performance Summary (PPS)
1. Pretreatment Town Name: Yadkin Valley Sewer Authority
2. "Primary" NPDES Number NCO() 20567
or Non Discharge Permit#if applicable =>
3. PAR Begin Date,please enter O1/Ol/yyyy 3.=> 1/1/2021
4. PAR End Date, please enter 12/31/yyyy 4.=> 12/31/2021
5. Total number of SIUs, includes CIUs 5.=> 1
6. Number of CIUs 6.=> 0
7. Number of SIUs with no IUP, or with an expired IUP 7.=> 0
8. Number of SIUs not inspected by POTW 8.=> 0
9. Number of SIUs not sampled by POTW 9.=> 0
10. Number of SIUs in SNC due to IUP Limit violations lo.=> 1
11. Number of SIUs in SNC due to Reporting violations 11.=> 0
12. Number of SIUs in SNC due to violation of a Compliance Schedule,CO,AO or si 12._> 0
13. Number of CIUs in SNC 13.=> 0
14. Number of SIUs included in Public Notice 14.=> 1
15 Total number of SIUs on a compliance schedule, CO, AO or similar 15.=> 0
16. Number of NOVs,NNCs or similar assesed to SIUs 1
17. Number of Civil Penalties assessed to SIUs 17.=> 1
18. Number of Criminal Penalties assessed to SIUs 18.=> 0
19. Total Amount of Civil Penalties Collected 19._> $ 10,000
20. Number of IUs from which penalties collected 20.=> 0
Foot Notes: AO Administrative Order IUP Industrial User Pretreatment Permit POTW Publicly Owned Treatment Works
CIU Categorical Industrial User NNC Notice of Non-Compliance SIU Significant Industrial User
CO Consent Order NOV Notice of Violation SNC Significant Non-Compliance
IU Industrial User PAR Pretreatment Annual Report
Form name: PAR,SNCR,2001
Date Revised: 1/4/2001

Pretreatment Annual Report (PAR) Yadkin Valley Sewer Authority=YVSA
Industrial Data Summary Form (IDSF) Control Authority=> YVSA Industry Name PGW,LLC
Use separate forms for each industry/pipe WWTP Name=> YVSA WWTP IUP# IWP001
Enter BDL values as<(value) NPDES#_> NC0020567 Pipe# 001
1st 6 months,dates=> 1/1/21 to 6/30/21
2nd 6 months,dates=> 7/1/21 to 12/31/21
Flow, mgd* pH* Grit** Oil & Grease**
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 6 6 6 6 6 6 1 1
* Maximum (mg/1)=>
* or Maximum (lb/d)_>
* 6 Month Average(mg/1)=> 0.085 mgd 0.157 mgd 8.2 7.8 ND ND <5.6 <5.6
* rr Average Loading(lb/d)=>
%violations,(chronic SNC is>=66%)=> 0 0 0 0 0 0 0 0
%TRC violations,(SNC is>=33%)_> _
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=>
* Maximum (mg/1)_>
* or Maximum (lb/d)=>
* 6 Month Average(mg/1)=>
* rr Average Loading(lb/d)_>
%violations,(chronic SNC is>=66%)=>
%TRC violations,(SNC is>=33%)=>
*Monitoring Frequency: Continuous/Daily.
**Monitoring Frequency:once per 6 month
BDL=>Below Detection Limit mg/1=>milligrams per liter
* POTW must enter at least one of these RIP=>Industrial User Permit lb/d=>pounds per day
four rows, Please indicate how averages were calculated SNC=>Significant Non-Compliance mgd=>million gallons per day
Avg period could be month,Qtr,or 6-month&if BDL,1/2BDL,or zero values used. TRC=>Technical Review Criteria WWTP=>wastewater treatment plant
Form name: PAR,SNCR,2001
Date Revised: 1/4/2001

Pretreatment Annual Report (PAR) Yadkin Valley Sewer Authority=YVSA
Significant Non-Compliance Report (SNCR) PAR Covers This Calendar Year=> 1/1/21-12/31/21
Control Authority => YVSA
WWTP =Wastewater Treatment Plant, use separate form for each WWTP. WWTP Name => YVSA WWTP
SIU= Significant Industrial User NPDES # => NC0020567
SNC = Significant Non-Compliance
A SNCR Form must be submitted with every PAR, please write "None" if you had No SIUs in SNC during calendar year
SNC ? (Yes/No)
for each 6-month period.
IUP# Pipe# Industry Name Parameter or "Reporting" Jan. - June July - Dec.
In violation of Part 2 (II) Section 25 (Reports of
Changed Conditions) of the IUP &in violation of the
IWP001 001 Pittsburgh Glass Works (PGW), LLC Yadkin Valley Sewer Use Ordinance (use of non- Yes No
approved chemical treatment(see the 6/22/21 NOV for
more detailed information)
Attach a copy of the Division's "SIUs in SNC Historical Report" for your POTW's SIUs behind this page .
Is the database correct ? Notify the Division of any errors ! Database indicates SNC history for previous years.
EVERY SNC MUST be explained in the Narrative, How was, is, or will it be resolved?
REPEAT SNCs are serious matters that MUST be explained in the Narrative.
Form name: PAR,SNCR,2001
Date Revised: 1/4/2001

•
YADKIN VALLEY SEWER AUTHORITYSIU REPORTING FORM
IUP DMR SUMMARY
IUP NO. IWP001 YEAR 2021
FACILITY NAME PGW LOCATION ELKIN
50050 00400 00540 00556
EFF. FLOW 3 c GRIT ui
LU
c0 a
>- O U F- 0 W
-I a 3 = - z - e!
LU H a H X c� °- V } _J O >- j C7
a 05
p WCe a c a) Q1Qa >- Qa _,
3 >. z a z
a eca a a o
MGD MGD MGD SU mg/L mg/L mg/L
January-21 0.095 0.120 9.93 9.1 ND
February-21 0.084 0.104 0.092 8.54 9.5 ND
March-21 0.082 0.112 0.092 7.86 ND
April-21 0.081 0.113 0.092 7.40 ND
May-21 0.094 0.118 0.009 7.69 ND < 5.6
June-21 0.072 0.091 0.092 7.77 ND
July-21 0.141 0.160 0.092 7.77 ND
August-21 0.155 0.188 0.110 7.85 ND < 5.6
September-21 0.144 0.186 0.114 7.97 ND
October-21 0.153 0.193 0.118 8.04 ND
November-21 0.167 0.195 0.122 7.78 ND
December-21 0.181 0.225 0.127 7.62 ND
Limits 0.245 0.319 0.210 6-10 5.0 mg/L
Average 0.121 8.02 ND
Ave 1st6 Months 0.085 8.20 ND
Ave 2nd 6 Months 0.157 7.84 ND
Maximum 0.225 9.93 ND
Minimum 0.072 7.40 ND
Running Annual Avg 0.127
Collection Method
Continuous (C) C .
Grab (G) G G G G
Frequency Cont./Daily Every Sample Monthly Monthly Every 6-Mon

Pretreatment Program Info Database printed on: 01r1812022
for Program Name Yadkin Valley Sewer Authority 0 lwc% at 7010 0.87
WWTP Name Yadkin Valley Sewer Authority WWTP Stream Information
Program Approval Date 03/07/2013 7010 Flow cfs/ mgd 317 / 204.78
1Q10 Flow cfs/ mgd 256.67 / 165.89
Pretreatment Status Modified
Stream Classification C
Region WSRO Basin Number YADO2
County Surry Receiving Stream Name Yadkin River
NPDES Number NC0020567 •
NPDES Effective Date Last PAR Rec 02/28/2021 PAR Due Date 03/01/2022 mercury
08/01/2020 1631
NPDES Expire Date Current Fiscal 06/24/2021 required
P 01/31/2024 Year PCI Done
POTW is Primary WWTP TRUE Last Audit on 12/09/2021 Audit Year Next21/22 yes
Design Flow mgd 1.8000 % Design mgd is SIU permitted 11.67 Permitted SIU flow(mgd) [Pt_SIU) 0.21
WWTP SIU's 1 Program Sills 1 -
WWTP CIU's 0 Program CIUs 0 HWA LTMP IWS SUO ERP
date Inactive Date Next Due 09/01/2020 04/01/2023
Date Received by DWR 11/06/2020 10/17/2019 07/13/2018 12/15/2011 06/01/2020
Date Approved Pending 02/12/2020 12/03/2018 01/06/2012 09/02/2020
Adopt Date Required
Date Adopted 04/09/2013
r
Info in this Box from Pt_Contacts Date Date Date
PT_Pro Attended Attended Attended
Formal Name g.Prime Phonel Ext Fax HWA Wksp IUP Wksp PAR Wksp
Ms. Nicole Johnston Primary 336-835-9819 336-835-9840 4/13/05 6/11/12 1/27/05
[e-mail] Executive Director P.O. Box 828 Elkin, NC 28621
Mr. Benjamin Thomas 828.522.4728 6/13/12
[e-mail]
Mr. Ron Lynn 828.522.4724 1/30/20 6/11/17
[e-mail]
Mr. Dave Johnson 336-835-9819
[e-mail] 1/30/20 1/29/20
Pretreatment Related NOVs from DWQ DWR Central Office Contact McGee&Miller
DWR Regional Contact Tricia Lowery

EXECUTIVE DIRECTOR Va' CHAIR
Nicole Johnston yad � Woody Faulk
* MI*
SECRETARY * * VICE-CHAIR
Anita Darnell IMP* "f Anita Darnell
A. BOARD OF DIRECTORS
O{ Wayne V.Moore
TREASURMooreER
t � ;W Victor Varela
WayneTommy Wheeler
June 22nd, 2021
CERTIFIED MAIL
Mr. James Clark
Plant Manager
Pittsburgh Glass Works, LLC
300 PGW Drive
Elkin, NC 28621
Subject: NOTICE OF VIOLATION & CIVIL PENALTY ASSESSMENT (NOV &CPA)
Pittsburgh Glass Works, LLC
Pretreatment Permit # IWP001
Dear Mr. Clark:
Pittsburgh Glass Works, LLC has been found to be in violation of Part 2 (II) Section 25 of the
IUP which provides that the permittee(PGW)shall not begin any changes with their wastewater
stream and pretreatment system until receiving written approval from the Authority. These
"Significant changes may include but are not limited to:
(a) Increases or decreases to production;
(b) Increases in discharge of previously reported pollutants;
(c) Discharge of pollutants not previously reported to the Authority;
(d) New or changed product lines;
(e) New or changed manufacturing processes and/or chemicals."
The facility is found to be particularly in violation of section `e' above of the IUP, which
provides that written approval must be provided before use of new chemicals with regards
to the permittee's operations and pretreatment system.
The facility is also in violation of the Yadkin Valley Sewer Use Ordinance (SUO) as
described in Chapter 4—Wastewater Discharge Permit Application and Issuance under
Section 4.2 —Wastewater Permit (i) Permit Conditions (2) (L) -"Requirements for prior
notification and approval by the Director of any new introduction of wastewater pollutants
or of any significant change in the volume or character of the wastewater prior to
introduction in the system."
500 NC Hwy 268 W- Elkin,NC 28621
Phone: [phone] -www.vvsa.org-Fax:[phone]

Please note that YVSA was notified by Mr.Ted Huyett, Corporate EHS Director for Vitro,
of the noncompliance on April 1, 2021 via email about the usage of Chemical Treatment
CL206 since"on or about October 27, 2020" due to severe biological growth in the RO
and/or washer system(s). Further correspondence was received from a conference call on
April 28, 2021 with Vitro staff as well as from a letter from Mr. James Clark, Plant
Manager for Vitro, dated May 3, 2021.
Due to this violation of the industrial user permit, Yadkin Valley Sewer Authority is issuing
this Notice of Violation (NOV) to Pittsburgh Glass Works, LLC along with a civil penalty
assessment(CPA) for$20,000.00 (Invoice# 21-1023).
Although YVSA understands that corrective action steps have been implemented to correct for
this violation of the permit, a civil penalty assessment has been issued to Pittsburgh Glass
Works, LLC, in accordance with our `Enforcement Response Plan' (ERP):
$20,000.00 1 TOTAL CIVIL PENALTY
YVSA requests that Pittsburgh Glass Works, LLC, submit payment of this penalty within thirty
(30) days of receipt of this notice. This violation is considered an "Unpermitted Discharge
Aware of Requirement" under the ERP, and the action to be completed must be "Notice of
Violation with Penalty Assessed."
Please note that remedial actions, as implemented and provided in the email response by
Mr. Ted Huyett on April 1, 2021 as well as the letter dated May 3, 2021 from you, should
continue to assure that the noncompliance problem does not occur again. Should
Pittsburgh Glass Works, LLC fail to maintain compliance, then additional actions,
including additional enforcement may be assessed in accordance with the Yadkin Valley
Sewer Authority ERP.
In addition, Federal regulations found in 40 CFR 403.8 (f) (2) (viii) requires that a Public Notice
of industrial users in significant noncompliance be published annually. Pittsburgh Glass will be
included in that notice.
Per Section 10 of the Sewer Use Ordinance, any user issued a civil penalty assessment has the
right to an adjudicatory hearing upon making written demand to the POTW Director within thirty
(30) days of receipt of the civil penalty assessment.
Thank you for your cooperation with the YVSA Pretreatment Program. Please feel free to call
me if you have any questions.
Sincerely,
Nicole Johnston
YVSA Executive Director
Cc: Benjie Thomas, West Consultants, PLLC
Ted Huyett, Director, EHS Director, Vitro Automotive Glass
500 NC Hwy 268 W - Elkin,NC 28621
Phone: [phone]-- www.yvsa.ore Fax: [phone]

YADKIN VALLEY SEWER AUTHORITY -kb con
Vab_
611. s
t
INVOICE Sr$atb°
Bill To
Pittsburgh Glass Works (Vitro) Invoice# 21-1023
Attn: James Clark Account#
300 PGW Drive Invoice Date 6/22/2021
Elkin, NC 28621 Terms Due Upon Receipt
SEE REVISED 9/3/21 INVOICE DUE TO
CONSENT ORDER & COMPLIANCE SCHEDULE
LINE .
1 Civil Penalty-Violation of Industrial 1 N 20,000.00 $20,000.00
2 User Permit
3
4
5
6
7
8
9
10
Notes: Subtotal $20,000.00 1
Sales Tax
TOTAL DUE $20,000.00
Please return bottom portion of page w th your payme•t
Remit Payment
to:
Yadkin Valley Sewer Authority Invoice # 21 1023
500 NC Hwy 268W Account#
Elkin, NC 28621 DUE DATE Upon Receipt
AMOUNT DUE $20,000.00
yer
4 Phone [phone] Paid b
( ) v
• FAX [phone] Pittsburgh Glass Works (Vitro)
♦r Email [e-mail]
"*Ut Website www yvsa.org Total Amount Enclosed $

RECEIVED
JUL 1 9 LULI PUBLIC NOTICE
OF SIGNIFICANT
NORTH CAROLINA INDUSTRIAL
SURRY COUNTY WASTEWATER VIOLATIONS PERMIT
The Yadkin Valley Sewer Au-
AFFIDAVIT OF PUBLICATION thority,in accordance with
Federal and State Regulations,
is hereby giving Public Notice
of Significant Industrial Users
Before the undersigned, a Notary Public of said County and State, duly that were in Significant Non-
commissioned, qualified and authorized by law to administer oaths, compliance(SNC)with nation-
al pretreatment regulations 40
personally appeared Sandra Hurley who being first duly CFR Part 403,and state pre-
, sworn,deposes and says:that he(she) is Regional Publisher treatment regulations 15
NCAC2H.0900,as well as loc-
(Publisher or other officer or employee authorized to make affidavit) of al pretreatment regulations
ADAMS PUBLISHING GROUP, LLC, engaged in thepublication of a during the 31,2 2s of July 1 -
December 31,2020 and Janu-
newspaper known as THE TRIBUNE, published, issued, and entered as ary 1 -June 30,2021.Vitro
periodicals class mail in the cityof Elkin in said Countyand State; that he (formerly Pittsburgh Glass
Works(PGW),LLC),was in
(she) is authorized to make this affidavit and sworn statement; that the violation to Permit General
Condition Part li,Section 25-
notice or other legal advertisement,a true copy of which is attached hereto, "The permittee shall give no-
was published in THE TRIBUNE on the following dates: tice to the Authority of any
planned significant changes to
I
j zl the pemtittee's operations or
t -t system which might alter the
nature,quality,or volume of its
wastewater at least 180 days
before the change.The permit-
I tee shall not begin the chances
until receiving written approval
from the Authority."The facility
isand that the said newspaper in which such notice, paper, document or Section specificallye)- Si violationifcat of
(e)-"Significant
CO legal advertisement was published was,at the time of each and every such changes may include but are
publication, a newspaper all of the requirements and not limited n new or changed
pmeeting q manufacturing processes I
qualifications of Section 1-597 of the General Statutes of North Carolina and/or chemicals."
and was a qualified newspaper within the meaning of Section 1-597 of the The facility is also in violation
General Statutes of North Carolina. of the Yadkin Valley Sewer
Use Ordinance(SUO)as de-
scribed in Chapter 4-
This is day of ,2021 Wastewater Discharge Permit
I Application and Issuance un-
der1 Permit Section -
Wastewater Pe (i)Permit
Conditions(2)(L)-"Require-
Signature of person making affidavit merits for prior notification and
approval by the Director of any
Sworn to and subscribed before me, this / new introduction s on ofo awny signitic-
`V ) / ,2021 ant change in the volume or
character of the wastewater
prior to introduction in the sys-
tem."
______ _e_..4....,tiAsi____ .* >let74.0.45._r A continuing effort is being
Notary Public made by the industry to pre-
vent further violations through
implementation of monthly in-
spections and/or other correct-
My Commission expires: January 18, 2023 ive action measures.
Yadkin Valley Sewer Authority _
FERRIS W. SIMPSON Direect Johnston,Executive
NOTARY PUBLIC Julys,2021
SURRY COUNTY, N.C. Publish:7-14-21 70051008
0

North Carolina
County of Surry
In the matter of Yadkin Valley Sewer Authority
Pretreatment Permit No. IWP001
held by Pittsburgh Glass Works, Inc. (Vitro)
CONSENT ORDER AND COMPLIANCE SCHEDULE — to end at same time
for IWP001 Permit Renewal (December 31, 2022)
Pursuant to provisions of the Sewer User Ordinance of the Yadkin Valley Sewer Authority, this
Consent Order is made effective the 1st day of October, 2021, between Pittsburgh Glass Works
(PGW), Inc. (hereinafter the "User") and the Yadkin Valley Sewer Authority (hereinafter the
"Authority").
The User and Authority hereby stipulate and agree as follows:
1. User holds Yadkin Valley Sewer Authority Pretreatment Permit No. IWP001 (hereinafter
the "Permit", which shall refer to User's existing permit and any subsequent renewals or
modifications thereof)for the operations of existing pretreatment units and discharges from
said treatment works into the Authority's sewer system.
2. User has provided the usage of ChemTreat CL206 (hereinafter "CL206") to treat reverse
osmosis return water on or about October 27, 2020 due to several biological growth in the
Reverse Osmosis (RO) and/or washer system(s). Usage of CL206 was stopped on April
28, 2021 after it was made clear by the Authority that the usage must stop until and if
approval for use is provided by the Authority. Based upon this CL206 usage, the Authority
has issued a Notice of Violation & Civil Penalty Assessment for the period July 2020
through December 2020 as well as for the period January 2021 through June 2021 in a
letter dated from the Authority on June 22nd, 2021.
3. User hereby agrees to do and perform all of the following:
a. Meet and comply with all terms and conditions of the Permit(except as modified
by the Order) provided, however, subject to the terms and conditions of the
Consent Order, the following shall apply:
*There will be no usage of CL206 along with ChemTreat CL427 (hereinafter
"CL427")or ChemTreat C2198T(hereinafter"C2198T")during the terms of the
Consent Order(and as provided by IWP001). For this to be completed for the
interim, a modification for the Permit must be completed to show no usage for
the usage of these ChemTreat chemicals during this Consent Order timeline
(which will also correspond with the expiration of IWP001).
*Additionally, no biocides or other chemical additives are allowed in the
discharge without first obtaining permission from the Authority. The biocides
CL206, CL427, and C2198T are specifically prohibited. (Biocides ChemTreat
CL49, ChemTreat CL2250, and ChemTreat CL6859 have previously been
approved.) If the User requests the approval of a biocide or other chemical
deemed toxic, User is to submit information showing the expected
concentration of the biocidal components in the discharge at average and
maximum conditions. Also, User shall submit information showing that the
expected concentrations of the biocidal components will not inhibit the
biological treatment process of the POTW and will not be toxic to aquatic life
in the receiving stream. Such information will need to be based on published
data for each proposed biocide and shall use evaluation methodologies
1

widely accepted by wastewater treatment professionals. Before
approving any new biocide or chemical additive,the data source and the
dolo must be acceptable to the Authority.
evaluation methodology p y
*In summary, there shall be no usage of CL206, CL427, and C2198T (or any
other biocides or other chemicals) without first getting permission from the
Authority even after the expiration of this Consent Order or the expiration of
the Permit.
b. Unless and until compliance is achieved/maintained, the User will undertake
activities necessary to ensure that User is in compliance in accordance with the
following schedule:
COMPLIANCE SCHEDULE
Activities Deadline for Completion
(i) Provide monthly documentation about the Monthly through end of
non-usage of CL206, CL427, and C2198T via consent order
the cover letter of the DMR(which is due the (December 31, 2022)
20th day of the month following the month in
which normal samples were taken.
c. User shall perform each of the activities set forth in subparagraph (b)on or before
the dates established thereby unless such dates are extended by agreement of User and
the Authority may request such extensions for good cause, and the Authority will not
unreasonably withhold its consent to such extensions.
All reports required by the Consent Order shall be submitted to the Authority by Certified
Mail, Return Receipt Requested, addressed to:
Nicole Johnston
Executive Director
Yadkin Valley Sewer Authority
PO Box 828
Elkin, NC 28621
d. The User shall pay the Authority the sum of $10,000, no later than October 31,
2021,for the apparent Significant Non-Compliance during the July through December 2020
and January through June 2021 reporting periods (which is a reduction of the original civil
penalty assessment of$20,000).
4 Any violation of the terms of this Consent Order shall subject the User to the enforcement
authority outlined in the Sewer Use Ordinance and according to the Enforcement
Response Plan. Such action may include, but is not limited to such fines, penalties and
assessments as may be set forth in the Enforcement Response Plan of the Yadkin Valley
Sewer Authority, as amended from time to time.
In lieu of other penalties, the User acknowledges that the Authority has the right under the
Ordinance to impose civil penalties for violations of the User's limits or failure to meet a
milestone date under this Consent Order, or failure to achieve full compliance with Consent
Order
Violation of limits **Up to $25,000 per day, per violation
Failure to collect required samples, meet
compliance schedule deadlines,
required reports, or other milestones
dates contained herein **Up to $10,000 per day, per violation
2

5. Once Compliance is achieved, this Consent Order shall terminate and all obligations
hereunder except any obligation to pay identified moneys to the Authority shall expire.
Upon termination of this Order, the User shall be subject to all terms of the Permit.
6. In the performance of activities under this Consent Order, User must otherwise follow the
procedures, rules, regulations, ordinances, and statutes of the Authority, State, and
Federal governments as they may apply to User. Nothing contained herein shall be
construed as a waiver thereof by the Authority.
Signed on this ,30 day of September 2021.
USER: PittsbuurrjhhGlasss Works Inc.
BY: ��X
TITLE: I"GAi1/7— /1%1.r/A,C.�Ie
AUTHORITY: Yadkin Valley Sewer Authority
BY: Nicole Johnston
TITLE: Executive Director
This Order expires December 31, 2022, which will correspond to the permit
expiration date as well.
3

Pccv
Nadene Patterson T: [phone] 1110.11.°—
Vitro Automotive Glass M: [phone] eAltra,
300 Pc.3.N.v ive
Elkin, NC, 28621. USA Automotive Glass
www.vitro.com
October 20th, 2021
RECEIVED
Nicole Johnston
Executive Director OCT 21 2021
Yadkin Valley Sewer Authority
PO Box 828
Elkin, NC 28621
RE: Pittsburgh Glass Works, LLC
300 PGW Drive, Elkin, NC 28621
Permit IWP001
Remittance
Dear Ms. Johnston:
Enclosed please find remittance for the following:
1. Compliance Violation Fee$10,000
2. Industrial Permit Renewal Fee$500.00
3. Public Notice Cost$197.60
4. Costs Incurred Due to Violation $584.50
I've also enclosed a new cover letter for the September DMR as we had the date in the title RE line wrong.
Please do not hesitate to contact me at 336-551-3902, on my cell at 724-771-1163, or via email at
npatterson n,vitro.com if you have any questions or require additional information
EHS Manager
Vitro Automotive Glass

Vitro Automotive Glass
300 PGW Drive
t} �4 Elkin,North Carolina 28621 USA
` Telephone[phone]
fi Fax[phone]
James Clark
Plant Manager
May 3,2021
Nicole Johnston
Executive Director
Yadkin Valley Sewer Authority
500 NC Hwy 268 W
Elkin,NC 28621
RE: Pittsburgh Glass Works, LLC(PGW)
300 PGW Drive
Elkin, NC 28621
IUP No. IWP001
Dear Ms. Johnston:
This correspondence is in follow-up to a telephone conversation on April 28, 2021 with Nicole Johnston
(Executive Director YVSA), Benjie Thomas(YVSA Consultant), Mark Patterson (PGW Manager,
Engineering& Maintenance),Ted Huyett(PGW Director, EHS), and me. The call was requested by
Benjie Thomas and focused on PGW's use of a reverse osmosis micro-biocide, ChemTreat CL206.
As we discussed, the PGW Elkin,NC facility started using ChemTreat CL206 (CL206)to treat reverse
osmosis return water on or about October 27,2020 due to severe biological growth in the RO and/or
washer system(s). You were first notified about this via telephone call and email on April 1,2021 by
Ted Huyett. Use of CL206 was stopped on April 28, 2021 after it was made clear by YVSA usage must
stop until/if approval for use is obtained from YVSA.
This correspondence outlines known timelines associated with CL206 use, causes and contributing causes
of CL206 use, and corrective actions PGW has implemented, or will implement, to ensure this issue does
not occur in the future.
Known Timeline Associated with CL206 Use.
1. September 9, 2020: PGW wastewater permit IWP001 renewal application submitted to YVSA on
behalf of PGW by Austin Meyer of One Environmental Group of Carolina, PLLC. The
application requests a new method for grit analysis along with a request for new chemicals,
including CL206, to remove biological/bacteria growth in the RO system.
2. October 12,2020: New PGW Elkin,NC EHS Manager starts.
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3. October 27, 2020 (on or about): Use of CL206 in reverse osmosis system begins due to severe
biological growth in the RO and/or washer system(s). Decision to implement was made without
knowledge that the use of CL206 had not been approved by YVSA.
4. January 4, 2021 (on or about): YVSA letter to PGW Elkin, NC EHS Manager requesting
additional information regarding biocides, including CL206)proposed for use in the wastewater
permit IWP001 renewal application. Requested information included the expected concentration
of the biocidal components discharged at average and maximum concentrations, and a pilot-scale
or full-scale study showing the expected concentrations of the biocidal components will not inhibit
the YVSA biological treatment process and will not be toxic to aquatic life in the YVSA discharge
receiving stream.
5. March 12, 2021: PGW Elkin,NC EHS Manager terminates employment without giving 2-week
notice.
6. March 17, 2021: Dave Johnson emails Ted Huyett and Nadene Patterson(PGW EHS Contractor)
requesting Page 10 of the PGW wastewater permit IWP001 renewal application submitted on
9/9/2021 be modified to remove biocides, including CL206, which" . . . are not approved at this
time".
7. March 24,2021: One Environmental pulls sample from pipe 001 to analyze for 2-2-dibromo-3-
nitrilopropionamide(DBNPA), the active ingredient in CL206.
8. March 31 (on or about): Use of CL206 confirmed by PGW Director, EHS during on-site visit to
the PGW Elkin facility.
9. April 1, 2021: Nicole Johnston notified by telephone call and email that use of CL206 started on
or about October 27, 2020 due to severe biological growth in the RO and/or washer system(s).
10.April 20, 2021: Page 10 of IWP001 resubmitted by PGW listing CL206 use in the reverse osmosis
system.
11. April 26, 2021: Benjie Thomas (YVSA) email to Ted Huyett questioning listed use of CL206.
Huyett responds reaffirming use of CL206.
12. April 27, 2021: Benjie Thomas (YVSA)email to Ted Huyett indicating YVSA was under the
impression that the CL206 was no longer being used and requesting conference call to discuss.
13. April 28, 2021: Call with PGW and YVSA to discuss CL206 use. Use of CL206 was stopped on
April 28, 2021 after it was made clear by YVSA usage must stop until/if approval for use is
obtained from YVSA.
14. April 28, 2021: Meeting follow-up email provided to Nicole Johnston and Benjie Thomas by Ted
Huyett. Email included DBNPA analysis for a sample taken at WW001 on March 24, 2021 (no
DBNPA was detected), confirmation PGW stopped using the ChemTreat CL-206 effective
4/28/2021, and an updated/resubmitted page 10 of the Pittsburgh Glass Works LLC Elkin,NC
IWP application for the new back light production line(ChemTreat CL-206 was removed from
Section E 2 a requested by YVSA).
2

Additional CL206 Usage Information
While used, the CL206 feed into the reverse osmosis water return line was set to maintain a concentration
of 25 ppm CL206 while the reverse osmosis system was in operation. If the reverse osmosis water
system operated 24/7 that would amount to approximately 40 pounds/day,or 1.67 pounds/hour of CL206
usage. However, the reverse osmosis water system does not operate 24/7. Based on the ordering
frequency information provided by ChemTreat, actual CL206 usage was approximately 16 pounds/day or
0.7 pounds/hour. The active ingredient in CL206, 2-2-dibromo-3-nitrilopropionamide (DBNPA), is
present at a concentration of 20%according to the safety data sheet provided by ChemTreat.
Information provided by ChemTreat indicated DBNPA would not persist in reverse osmosis water used at
the temperature required in the PGW glass washing process, therefore the CL206 was continuously fed
into the system while it operated.
No DBNPA was detected in a water sample taken from pipe 001 on March 24,2021 while the reverse
osmosis system was in operation. The sample was taken by One Environmental and analysis was
performed by Eurofins.
Issue: CL206 Was Used Without Prior YVSA Approval
Causes/Contributing Causes:
1. Severe biological growth in the reverse osmosis and/or glass washer water system(s)was causing
damage and/or plugging to system membranes and filtration systems. The damage and plugging
caused damage estimated at$100,000 annually and significant production downtime while repairs
and filter cleaning/replacement activities took place. Plant Maintenance and Engineering worked
with water treatment vendors to find a solution to the severe biological growth problem. The most
effective solution to the problem was determined to be the ChemTreat CL206 micro-biocide.
2. Ineffective communication between plant EHS, plant Maintenance and Engineering,PGW
Director EHS and YVSA.
a. The plant EHS Manager started more than 1 month after the wastewater permit IWP001
renewal application was submitted to YVSA requesting approval to use CL206 in the
reverse osmosis system. Shortly after starting work, the plant EHS Manager started a brief
discussion occurred between the EHS Manager and the Manager Maintenance and
Engineering regarding the status of permit renewal and CL206 approval. The Manager
Maintenance and Engineering interpreted the discussion as it was OK to use CL206 while
the permit renewal application was being reviewed by YVSA. The interpretation was also
partly based on information provided by ChemTreat which indicated DBNPA is not
persistent in reverse osmosis water used at the temperature required in the PGW glass
washing process. The plant EHS Manager terminated employment with PGW on March
12 and we are unable to obtain further information regarding the discussion.
b. Weekly environmental,health and safety orientation/training of the plant EHS Manager
began in mid-October 2020, however, focus on environmental topics did not begin until
December 22, 2020(orientation was being completed in weekly 1.5-hour segments
remotely via Microsoft Teams vs. face-to-face over 3-4 days due to COVID-19 pandemic
and desire to avoid non-essential business travel). Full review of the facility Industrial
User Permit No. 1WP001, Part II, General Conditions did not occur with the new EHS
3

Manager until January 2021. There was no communication to the PGW Director, EHS
indicating CL206 was being used during this detailed permit review.
c. On April 1,2021 YVSA was notified by telephone call and email that use of CL206 started
on or about October 27, 2020 due to severe biological growth in the RO and/or washer
system(s). YVSA provided clear direction to PGW to stop using CL206 during the April
28, 2021 conference call. PGW stopped use of CL206 on April 28, 2021.
3. Ineffective change management. The facility management of change system identified the use of
new water treatment chemicals as a significant change to operations or systems which might alter
the nature, quantity or volume of wastewater. This is evidenced by inclusion of the CL206 and
other proposed water treatment chemicals in the wastewater permit IWP001 renewal application
submitted to YVSA on September 9, 2020 and the accompanying request for approval for their
use. The PGW Manager, Maintenance and Engineering was aware CL206 could not be used in
the wastewater pretreatment system. However, they were not fully aware approval was required
prior to using CL206 in the reverse osmosis system because it was thought DBNPA would not be
persistent in reverse osmosis water and none would be released to YVSA.
Corrective Action(s):
1. Stop use of CL206.
[Responsibility: Mark Patterson/Jim Clark; COMPLETE: April 28, 2021]
2. Address the communication and management of change breakdowns. Complete full review of the
facility Industrial User Permit No. IWP001 with the Manger Engineering& Maintenance,Plant
Manager and the new PGW EHS Manager(new PGW Elkin EHS Manager, Al Douglas, started
on May 3, 2021). Focus on changes to operations or systems which might alter the nature,
quantity or volume of wastewater discharged to YVSA, water treatment chemical changes, and/or
other changes which require YSVA notification and approval before the change is implemented.
a. Inform the new EHS Manager of the requirement to notify YVSA of the new Plant
Manager via letter before he/she signs the facility DMR for the first time.
b. Inform YVSA the new EHS Manager, Al Douglas,or Nadene Patterson,will be submitting
monthly DMRs for the PGW Elkin,NC facility.
[Responsibility: Ted Huyett; Complete by: May 14,2021]
3. Investigate cost effective alternatives for a pilot-scale study to determine if CL206 use will inhibit
the YVSA biological treatment process and or be toxic to aquatic life in the YVSA discharge
receiving stream. The initial proposal obtained by PGW for a 30-day pilot-scale study was
$40,700.
[Responsibility: Ted Huyett; Complete By: May 31, 2021]
4. Investigate if CL206 is used at other North Carolina industrial facilities which discharge
wastewater to a POTW or directly to a receiving outfall. Provide information to YVSA if found.
[Responsibility: Ted Huyett/Mark Patterson; Complete By: May 31, 2021]
Vitro Automotive is strongly committed to environmental compliance and and we are genuinely
concerned about the communication and management of change breakdowns described herein. There was
no malicious intent to circumvent the YVSA approval process or cause environmental harm. We will
work to prevent similar issues form recurring.
4

•
We believe that the nature of CL206 results in the chemical dissipating after it is introduced into the
reverse osmosis system to an extent that it was undetectable in the sample taken by One Environmental.
We do not believe that CL206 was discharged into the YVSA system, and if it was, we have seen no
evidence that it had any adverse effect on the system. This is not to excuse the issues addressed above,
but to simply note that, to our knowledge,the errors did not result in harm to the system or the
environment.
We trust the actions taken, actions planned, and response provided via this correspondence have
sufficiently addressed both issues. Should you have any questions or need further information, please
contact me at(336) 551-3925 or iaclark(avitro.com,or contact Ted Huyett, Director EHS at(414) 839-
9813 or thuyett(avitro.com.
Sincerely,
/ames
Plant Manager, Vitro Automotive
5

AEYNARD1E Joseph H. Nanney
& [e-mail]
RECEIVED
JUL 21 2021
July 19, 2021
VIA U.S. MAIL And E-MAIL
Nicole Johnston
Director
Yadkin Valley Sewer Authority
500 NC Hwy 268 West
Elkin, NC 28621
Re: Notice of Violation and Civil Penalty Assessment
Pittsburgh Glass Works, LLC
Pretreatment Permit#IWP001
Dear Ms. Johnston:
As you may recall, this firm represents Pittsburgh Glass Works, LLC ("PGW").
Pursuant to section 10 of the Sewer Use Ordinance, we write to request an Initial
Adjudicatory Hearing to contest the notice of violation and civil penalty assessment
contained in your letter of June 22, 2021 to PGW.
We look forward to working with your office to schedule the hearing at a
mutually convenient time. Thank you for your time and consideration.
Sincerely,
. EYNARDIE &NANNEY, PLLC
.10
o•ep H. ey
cc: James Freeman, Esq. (via e-mail only)
5700 Six Forks Road,Suite 201
Raleigh,North Carolina 27609
P 919.747.7374• 919.891.0006
Creative Legal Solutions, Aggressive Advocacy

YADKIN VALLEY SEWER AUTHORITY yodnVaii6)`
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INVOICE
Bill To:
Pittsburgh Glass Works (Vitro) Invoice# 22-1028
Attn: James Clark Account#
300 PGW Drive Invoice Date 9/3/2021
Elkin, NC 28621 Terms Due by 10/31/2021
LINE DESCRIPTION U/M QTY TAXABLE UNIT PRICE AMOUNT
1 Civil Penalty-Violation of Industrial 1.00 10,000.00 $10,000.00
2 User Permit
3
4 Reduced for Consent Order and
5 Compliance Schedule that
6 expires December 31, 2022
7
9
10
Notes: Subtotal $10,000.00
Sales Tax
TOTAL DUE $10,000.00
Please return bottom portion of page with your payment
Remit Payment to:
Yadkin Valley Sewer Authority Invoice # 22-1028
S00 NC Hwy 268W Account#
Elkin, NC 28621 DUE DATE 10/31/2021
AMOUNT DUE $10,000.00
A.„601 ye/4.„ Phone [phone] Paid by:
R FAX [phone] Pittsburgh Glass Works (Vitro)
"` 41. Email [e-mail]
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PITTSBURGH GLASS WORKS LLC 10927
YADKIN VALLEY SEWER AUTHORITY Date: 10/11/21
Inv. No. Date Description Assignment Gross Amount Discount Net Amount
COMPLIANCE 10/11/21 Compliance Fees 20211011 10,000.00 0.00 10,000.00
Total: 10,000.00 0.00 10,000.00
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001 10927
6.9/430
11213
L litro Pittsburgh Glass Works LLC
30 Isabella Street,Pittsburgh,PA 15212
DATE CHECK NO. AMOUNT
10/11/21 0010927 ********10,000.00*
PAY * TEN THOUSAND DOLLARS AND 00/100 *******************************************************
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PITTSBURGH GLASS WORKS LLC 10927
YADKIN VALLEY SEWER AUTHORITY Date: 10/11/21
Inv. No. Date Description Assignment Gross Amount Discount Net Amount
COMPLIANCE 10/11/21 Compliance Fees 20211011 10,000.00 10,000.00
Total: 10,000.00 0 .00 10,000.00
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