NC0020567_Pretreatment Complaince Inspection Audit_20211209

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT AUDIT REPORT
Water Resources
ENVIRONMENTAL QUALITY
Background Information [Complete prior to audit; review Program Info Database Sheet(s)]
1. Control Authority (POTW) Name: Yadkin Valley Sewer Authority
2. Control Authority Representative(s): Nicole Johnston, Dave Johnson, Portia Hayes, Nikki Hembree, Ron Lynn, Billy Stone,
Robert Smith
3. Title(s): Executive Director, Asst. Executive Director, Administrative Asst., Office Asst., Engineering Consultant (West
Engineers, PLLC, Utilities Maintenance, Utilities Maintenance
4. Address of POTW:
Mailing 500 HWY 268 West
City Elkin Zip Code 28621
Phone Number 336.835.9819 Fax Number 336.835.9840 E-Mail info@,,yvsa.org
5. Audit Date 12/9/2021
6. Last Inspection Date: 6/24/2021 Inspection Type: ® PCI ❑ Audit
7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s) ? ® Yes ❑ No
If No, Explain.
8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? ❑ Yes ® No
If Yes, Explain.
9. Is POTW under an Order That Includes Pretreatment Conditions? ❑ Yes ® No
Order Type and Number: Are Milestone Dates Being Met? ❑ Yes ❑ No ® NA
Parameters Covered Under Order
ICIS Coding
Main Program Permit Number
INICI0I0I2 Io 15 16 17 I
10. Current Number of Significant Industrial Users (SIUs)?
11. Number of SIUs with No IUP, or with an Expired IUP?
12. Number of SIUs Not Inspected by POTW in Last Calendar Year?
13. Number of SIUs Not Sampled by POTW in Last Calendar Year?
MM/DD/YY
08 01 20I
14. Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi -Annual Periods?
15. Number of SIUs in SNC for Reporting During Either of Last 2 Semi -Annual Periods?
16. Number of SIUs in SNC with Pretreatment Schedule?
1
0
0
0
0
1
1
17. Number of SIUs on Schedules?
1
18. Current Number of Categorical Industrial Users (CIUs)?
19. Number of CIUs in SNC?
0
0
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 1

20. PRETREATMENT PROGRAM ELEMENTS REVIEW- Review POTW files, verify POTW has copy of each Program Element
in their File, complete with all supporting documents and 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)
2/5/2015
A/ Yes ❑ No
6/12/2015
0 Yes ❑ No
9/1/2020
Industrial Waste Survey (IWS)
7/13/2018
A/ Yes ❑ No
12/3/2018
A/ Yes ❑ No
4/1/2023
Sewer Use Ordinance (SUO)
4/19/2013
0 Yes ❑ No
12/15/2011
A/ Yes ❑ No
*See Comments
Enforcement Response Plan (ERP)
6/1/2020
11 Yes ❑ No
6/1/2020
A/ Yes ❑ No
Long Term Monitoring Plan (LTMP)
2/12/2020
1 Yes ❑ No
2/12/2020
0 Yes ❑ No
Comments: Third Revision was completed 4/9/2013. Awaiting PERCS Approval Letter. Operating from 2013 SUO
Legal Authority (Sewer Use Ordinance-SUO)
21. Do you have any towns and/or areas from which you receive wastewater which are not in your annexed jurisdiction?
❑ Yes ® No If yes, Please list these towns and/or areas.
22. If yes to #21, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? ❑ Yes ❑ No ® NA
A copy, if not already submitted, should be sent to Division.
23. If yes to #21, Have you had any trouble working with these towns or districts? ❑ Yes ❑ No ® NA
If yes, Explain.
24. Date of Last SUO Adoption by Local Council04/19/2013
25. Have you had any problems interpreting or enforcing any part of the SUO? ❑ Yes ® No
If yes, Explain.
Enforcement (Enforcement Response Plan-ERP)
26. Did you send a copy of the ERP to your industries? ® Yes ❑ No
If no, POTW must send copy within 30 days.
27. Have you had any problems interpreting or enforcing any part of the ERP (i.e. any adjudication, improper enforcement, etc?
❑ Yes ® No If yes, Explain.
28. List Industries under a Schedule or Order and Type of Schedule or Order
VITRO (PGW, LLC)
Resources
29. Please Rate the Followine: S=Satisfacto
M=Mareinal
U=Unsatisfacto
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
OS ❑M ❑U
Access to POTW Vehicles for
Sampling, Inspections, and
Emergencies
CIS ❑M ❑U
Access to Operable Sampling
Equipment
E/ S ❑M ❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
1 S ❑M ❑U
Reference Materials
1S❑M❑U
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
1 S ❑M ❑U
Computer Equipment (Hardware and
Software)
OS ❑M ❑U
NC DWR Pretreatment Audit Form Revised: December 2016
Page 2

30. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No
Explain Yes or No.
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Charge back.
Public Perception/ Participation
32. Are there any local issues affecting the pretreatment program (e.g.. odor, plant closing, new or proposed plants)?
❑ Yes ® No If yes, Explain.
33. Has any one from the public ever requested to review pretreatment program files? ❑ Yes ® No
If yes, Explain procedure. If no, how would the request be addressed?
34. Has any industry ever requested that certain information remain confidential from the public? ❑ Yes ® No If yes, Explain
procedure for determining whether information qualified for confidential status, as well as procedure for keeping files confidential
from public. If no how would the request be addressed?
35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? ® Yes ❑ No
36. Is the public notified about changes in the SUO or Local Limits? ® Yes ❑ No
37. Were all industries in SNC published in the last notice? ® Yes ❑ No
Permitting (Industrial Waste Survey-IWS)
38. How does the POTW become aware of new or changed Users? Responses from mass mailing to all commercial users.
39. Once the POTW becomes aware of new or changed Users, how does the POTW determine which industries have the
reasonable potential to adversely impact the WWTP and therefore require a new permit or a permit revision? (Who is an
SIU?) IWS is sent to Users to fill out and return.
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
['Yes No If Yes, How many are there?
Please list each site and how it is permitted, if applicable.
41. Does the POTW accept waste by (mark if applicable) ❑ Truck ®Dedicated Pipe ❑ NA
42. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples drawn,
manifests required) Waste is placed on a drying bed (designated point).
43. How does the POTW allocate its loading to industries? Mark all that apply
Uniform Limits ❑ Historical Industry Need ❑ By Surcharge ❑ Categorical Limits ❑ Other
Explain Other:
44. Review POTW' s copies of current allocation tables for each WWTP. Are there any over allocations? ❑ Yes ® No
If yes, what parameters are over allocated?
45. If yes to #44, What is being done to address the over allocations? (short-term IUPs, HWA to be revised, pollutant study, etc.)
NA
46. Does the POTW keep pollutant loading in reserve for future growth / safety? ® Yes ❑ No
If yes, what percentage of each parameter %
47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) ❑ Yes ® No
If yes, Explain.
48. How does the POTW decide on which pollutants to limit in the permits? Monitor for? (for example: were only those pollutants
listed on the application limited; categorical parameters; NPDES Pollutants of Concern)
NPDES POC's along with User sampling and testing.
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Past monitoring occurrences.
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 3

Permit Compliance
50. Does the POTW currently have or during the past year had any permits under adjudication? ❑ Yes ® No
If yes, which industries? What was (will be) the outcome of the adjudication?
51. Demonstrate how the POTW judges compliance. This should include compliance judgment on all violations of limits, reporting
requirements, and permit conditions, as well as for SNC. Laboratory testing results, in addition to glass and garnet in the
POTW lines and pumps.
52. Does the POTW use the Division's model inspection form or equivalent? ® Yes ❑ No
If no, does the POTW form include all Division data? ❑ Yes ❑ No
53. Were all SIUs evaluated for the need of a slug/spill control plan during their most recent inspections? ® Yes ❑ No
If no, Explain.
54. What criteria are used to determine if a slug/spill control plan is needed?
Evaluation of waste product contents, how waste is stored, and the capability/possibility of all the avenues to which it can
enter POTW system.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Detailed protocols to intercept and contain spills, inhibiting them from reaching POTW. In addition to,
facility diagrams, material inventory, SDS data sheets, and information on spill prevention, reporting, and training.
56. How does the POTW decide where the sample point for an SIU should be located?
Accessibility of the sampling points at SIU and position in the waste flow system.
57. Has the POTW established a procedure to ensure that representative samples will be taken by the POTW or SIU each time?
(example: correct location; proper programming of sampler; clean equipment; swirling the sample bucket uniformly)
POTW: ® Yes ❑ No SIU: ® Yes ❑ No If yes, Explain.
58. Who performs sample analysis for the POTW for Metals Environmental 1, LLC
Conventional Parameters Environmental 1, LLC
Organics Environmental 1, LLC
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Pace lab picks up samples using their chain of custody.
Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis (HWA)
60a. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑ NO
60b. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ® YES ❑ NO
60c. Is LTMP/STMP Data Maintained in Table or Equivalent? ® YES ❑ NO Is Table Adequate? ❑ YES ❑ NO
60d. All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? ® YES ❑ NO Division Inspector, verify yourself!
60e. If NO to any above, list violations
60f. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? El YES ® NO
If yes, which ones? Eliminated: Added:
61. Do you complete your own headworks analysis (HWA) ? El Yes ® No
If no, who completes your HWA? West Consultants Phone [phone]
62. Do you have plans to revise your HWA in the near future? ® Yes El No
If yes, what is the reason for the revision? (mark all that apply) ❑Increased average flow ❑NPDES limits change
❑More LTMP data available ['Resolve over allocation ®5 year expiration ®Other
Explain. Dana Foley with NCDEQ requesting more information that we are addressing now for renewal.
63. In general, what is the most limiting criteria of your HWA? ❑Inhibition ® Pass Through ['Sludge Quality
64. Do you see any way to increase your loading in the future (Example: obtaining more land for sludge disposal)? ❑ Yes ® No
Explain. Not needed for present.
Summary
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
No
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 4

INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION
66. User Name
1. PGW (Vitro)
2.
3.
67. IUP Number
IWP001
68. Does File Contain Current Permit?
i1 Yes ❑ No
❑ Ycs ❑ No
❑ Yes ❑ No
69. Permit Expiration Date
12/31/2022
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
NA
71. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
/1 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
72. Does File Contain Inspection Completed Within Last Calendar Year?
i1 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
73. a. Does File Contain 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
74. 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
75. a. Does File Contain Original Permit Review Letter from Division?
b. All Issues Resolved?
a. Yes ■No
b.®Yes❑No❑N/A
a. •Yes ■No
b.❑Yes❑No❑N/A
a. ■Yes ■No
b.❑Yes❑No❑N/A
76. During Most Recent Semi -Annual Period, Did POTW Complete its
Sampling as Required by IUP, including Flow?
i1 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
/1 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
78. During Most Recent Semi -Annual Period, Did SIU Complete its
Sampling as Required by IUP, including Flow?
®Yes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
79. During Most Recent Semi -Annual Period, Did SIU submit all reports on
time?
®Yes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
80a. 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
80b. For categorical lUs 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
81. During Most Recent Semi -Annual Period, Did POTW Identify All
Limits Non -Compliance from Both POTW and SIU Sampling?
❑ Yes ❑ No
DN/A
❑ Yes ❑ No
❑ Yes ❑ No
82. During Most Recent Semi -Annual Period, Did POTW Identify All
Reporting Non -Compliance from SIU Sampling?
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
83. a. Was 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 and obtain results within 30 days of
becoming aware of SIU limit violations in the POTW's sampling of SIU?
a.❑Yes❑No®N/A
b.❑Yes❑NoDN/A
c.❑Yes❑NoDN/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
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
i1 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
Specified in POTW's ERP (NOVs, Penalties, timing, etc.)?
®Yes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
86. Does File Contain Penalty Assessment Notices?
®Yes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
87. Does File Contain Proof Of Penalty Collection?
®Yes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
88. a. Does 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
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
Information For You?
❑ Yes /1 No
❑ Yes ❑ No
❑ Yes ❑ No
FILE REVIEW COMMENTS:
All files are well organized, detailed and in compliance.
Other notes: In August of 2021, the notice to drop other industry was approved by NCDEQ, leaving PGW (Vitro) only SIU to monitor.
Received noticed in Feb 2020 that STMP was adequate. In 2022, YVSA will begin updating their SUO. They are currently using 3rd revision
dated 4/9/2013, to which they are still awaiting PERCS Approval Letter.
NC DWR Pretreatment Audit Form Revised: December 2016
Page 5

INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number
INICIO 10 12 In k 16 7
MM/DD/YY
12109121 I
1. Industry Inspected: PGW (Vitro)
2. Industry Address: 300 PGW Drive, Elkin, NC 28621
3. Type of Industry/Product: Automotive Glass
4. Industry Contact: Mark Patterson Title: Maintenance Engineering Manager Phone: [phone] Cell: 336.469.2955
Nadene Patterson EHS Manager 336.551.3902 Cell: 336.488.3375
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:
Industrial inspection was conducted by Nicole Johnston, Dave Johnson, Billy Stone, Robert Smith, and Ron Lynn. The inspection of
PGW was very thorough. Production rates (including labor issues, future projections and delivery of raw materials/effects on production),
employees training, sludge plan, calibration of meters, file reviews (COC's, sampling procedures, log books), permits, labor schedules,
and review of spill response plan were reviewed and documented during inspection. During the walk through of facility, all meters,
drains, wells, chemical storage, pumps, RO system, and piping were investigated. Any leaks, spills, or other concerns were immediately
examined and questioned. Detailed notes were taken by investigating crew. The inspection began shortly after 10:00am and was
completed around 12:45pm. Overall, YVSA conducted an excellent inspection of SIU.
Audit SUMMARY AND COMMENTS:
Audit Comments: See industrial inspection comments above
Requirements: none
Recommendations: none
NOD: ❑ Yes ® No
NOV: ❑ Yes ® No
QNCR: ❑ Yes ® No
POTW Rating:
Satisfactory
Marginal ❑ Unsatisfactory ❑
Audit COMPLETED BY: Tricia Lowery DATE: 12/10/2021
XXXX, PERCS, and XXXX, XXXX Regional Office
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 6