NC0020800_Compliance Evaluation Inspection_20211123

DocuSign Envelope ID: B94966FB-23FE-48B8-B96B-07E97FA9FF30
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Qualify
SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED.
November 23, 2021
Sandy Dobson, Town Administrator
Town of Andrews
E-mail: [e-mail]
SUBJECT: Pretreatment Compliance Inspection Report
Andrews WWTP
NPDES WW Permit No. NC0020800
Cherokee County
Dear Permittee:
The North Carolina Division of Water Resources conducted an inspection of the Andrews WWTP on
11/09/2021. This inspection was conducted to verify that the facility is operating in compliance with the
conditions and limitations specified in NPDES WW Permit No. NC0020800. The findings and comments
noted during this inspection are provided in the enclosed copy of the inspection report entitled
"Compliance Inspection Report".
Please respond via e-mail to this office within 30 days of your receipt of this letter regarding your plans
or measures to be taken to address the following issues:
Explain via written communication how the SIU industry (TEAMS, Inc) has ceased categorical discharge and the
WWTP's intent to have an inactive pretreatment program. The industry must request rescission of the
categorical permit in writing. The WWTP shall include a final inspection report of the SIU.
If you should have any questions, please do not hesitate to contact Timothy Heim with the Water
Quality Regional Operations Section in the Asheville Regional Office at 828-296-4500 or via email at
[e-mail].
ATTACHMENTS
Sincerely,
-DocuSigned by:
Sri 4
'-E39 19 ABFB4FF..
Daniel Boss, Asst. Keglonal Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ
Ec: LF, Mark Bentley — Pretreatment Coordinator, Tim Wood - WWTP ORC
North Carolina Department of Environmental Quelfy I DIvtslon of Water Resources
Asheville Regional Office 12090 O.S. Highway 70 I Swannanoa, Noah Carolina 28778
828.290 4500

DocuSign Envelope ID: B94966FB-23FE-48B8-B96B-07E97FA9FF30
United States Environmental Protection Agency
EPA Washington, D.C. 20460
Water Compliance Inspection Report
Form Approved.
OMB No. 2040-0057
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction
1 IN
Code
I 2
IL
NPDES yr/mo/day Inspection Type Inspector Fac
I 3 I NC0020800 111 121 21/11/09 117 181 D I 19I S I 2011
Type
21IIIIII
IIIIIIIIIII
IIIIIII
I
IIIIII
IIIIIIIIIII
P6
Inspection
671
Work Days
Facility Self -Monitoring
I 7°
I
Evaluation Rating
I 711
B1
1
72
QA
I N I
731
I
I I
Reserved
74 71
I
I I
I
I
I
180
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
Andrews WWTP
Reagan Ave
Andrews NC 28901
Entry Time/Date
10:OOAM 21/11/09
Permit Effective Date
19/09/01
Exit Time/Date
01:OOPM 21/11/09
Permit Expiration Date
23/08/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Mark Christopher Bentley/ORC/828-360-3966/
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Michael Ladd,PO Box 1210 Andrews NC 289011210//828-321-3113/
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Self -Monitoring Progran Pretreatment Other
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Timothy H Heim DWR/ARO WQ/828-296-4665/ 7
DocuSigned by: 11/2 3/2021
FIIKAO tkt,ik
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
[__DocosnedbY
.�1 : 11/23/2021
Kin22
E397192DABFB4FF...
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page# 1

DocuSign Envelope ID: B94966FB-23FE-48B8-B96B-07E97FA9FF30
31
NPDES yr/mo/day
NC0020800 111 121 21 /11 /09
117
Inspection Type
18H
(Cont.)
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Tim Heim of the Asheville Regional Office performed a Pretreatment Compliance Inspection on
November 9th, 2021, and follow-up file review on November 18th, 2021. Tim Wood (Andrews WWTP
ORC) & Mark Bentley (Earth Environmental Pretreatment Coordinator) assisted with the inspection
and with records and sampling results review.
The pretreatment program, associated record keeping, and the relationship with the IU were
generally in good order at the time of the inspection and compliant with permit conditions.
The single Industrial User: (IU) in the program, TEAM Industries, Inc. (IUP # 0004) removed their paint
line and chromate drag line in 2018 and is understood to no longer produce industrial wastewater.
A revision of the Industrial User permit for this facility and suspension of the Andrews WWTP
pretreatment program may be appropriate and is being pursued through Central Office Permitting
(Keyes McGee).
To proceed with suspension of the pretreatment program, the following actions should be initiated:
Explain via written communication how the industry has ceased categorical discharge and the POTW
desires to have an inactive pretreatment program. The industry must request rescission of the
categorical permit in writing. The WWTP shall include a final inspection report of the SIU.
The Pretreatment Annual Report is still due in March, and the pretreatment permit remains in effect
until it is rescinded.
See attached NC DEQ Pretreatment Compliance Inspection form for details.
Page# 2

DocuSign Envelope ID: B94966FB-23FE-48B8-B96B-07E97FA9FF30
Permit: NC0020800
Inspection Date: 11/09/2021
Owner - Facility: Andrews WWTP
Inspection Type: Pretreatment Compliance
Other
Comment: Reference attached PCI Report form.
Yes No NA NE
Page# 3

DocuSign Envelope ID: B94966FB-23FE-48B8-B96B-07E97FA9FF30
NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
Water Resources
ENVIRONM ENTAL QUALITY
BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)1
1. Control Authority (POTW) Name: Town of Andrews
2. Control Authority Representative(s): Mark Bentley, Earth Environmental
3. Title(s):Pretreatment Coordinator (Contractor)
4. Last Inspection Date: 06/26/2017 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 NA
PCS CODING
Trans.Code
IN
Main Program Permit Number
MM/DD/YY
NICIo 10 12 101810 101 J11109I21
DTIA
Inspec.Type
J P
(TYPI)
Inspector Fac. Type
J S J 1
INSPI (FACC
7. Current Number Of Significant Industrial Users (SIUs)?
1
SIUS
8. Current Number Of Categorical Industrial Users (CIUs)?
1
CIUS
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. Enter the Higher Number of 9 or 10
0
NOIN
12. Number of SIUs With No IUP, or With an Expired IUP
0
NOCM
13. Number of SIUS in SNC for Either Reporting or Limits Violations During Either of the Last 2
Semi -Annual Periods (Total Number of SIUs in SNC)
0
PSNC
14. Number of SIUs in SNC For Reporting During Either of the Last 2 Semi -Annual Periods
0
MSNC
15. Number of SIUS In SNC For Limits Violations During Either of the Last 2 Semi -Annual Periods
0
[ SNPS
16. Number of SIUs In SNC For Both Reporting and Limits Violations During Either of the Last 2
Semi-annual Periods
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?
a YES ❑ NO
BOD, TSS (Not PT Related)
❑ YES /1 NO
Limits: N/A
Reporting :N/A
lished:N/A
N/A
❑ YES 11 NO
(*Draft SA in progress)
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 DWQ 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
If yes, which ones? Eliminated: Consider suspending PT program Added: None
NC DWQ Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1
❑ NO

DocuSign Envelope ID: B94966FB-23FE-48B8-B96B-07E97FA9FF30
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 Approva 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)
09/07/2015
0 Yes ❑ No
12/04/15
❑ Yes ❑ No
DUE
Industrial Waste Survey (IWS)
05/29/13
' Yes ❑ No
06/14/17
/1 Yes ❑ No
DUE
Sewer Use Ordinance (SUO)
01/14/13
/1 Yes ❑ No
1/17/13
/1 Yes ❑ No
-
Enforcement Response Plan (ERP)
2/27/2020
/1 Yes ❑ No
2/27/2020
/1 Yes ❑ No
-
Long Term Monitoring Plan (LTMP)
12/17/08
a Yes ❑ No
2/27/2020
/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. Team Industries 2.
3.
30. IUP Number
0004
31. Does File Contain Current Permit?
/1 Yes ❑ No_
❑ Yes ❑ No
❑ Yes ❑ No
32. Permit Expiration Date
12/31/2020
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
433 /
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. ►1Yes •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
2010
❑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. AYes •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?
/1 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
A 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?
11 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❑NOON/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 /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.)?
❑ Yes ❑NoON/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❑NoEIN/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 DWQ Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

DocuSign Envelope ID: B94966FB-23FE-48B8-B96B-07E97FA9FF30
FILE REVIEW COMMENTS:
File review performed remotely with Mark Bentley, Earth Environmental.
INDUSTRY INSPECTION PCS CODING:
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac. Type
N1 1N ICI 010 1 2 1 01 81 01 01 1 111 09 1 211 1 I 1 1 S 1 1 2 1
(DTIA) (TYPI) (INSP) (FACC)
1. Industry Inspected: TEAM Industries Andrews, Inc.
2. Industry Address: 3750 Airport Road; Andrews, NC 28901
3. Type of Industry/Product: Metal Finishing: (gear cases) electroplating & ancillary processes no longer generate process
Wastewater.
Typical domestic flow is below 10,000 GPD
4. Industry Contact: Title: Terry Younce Phone: [phone]
Pretreatment Contractor: Earth Environmental - Contact: Mark Bentley Phone: [phone]
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 El NO
Industrial Inspection Comments:
The paint line and chromate drag line were removed in 2018. A revision of the Industrial User permit for this facility
and suspension of the Andrews WWTP pretreatment program may be appropriate and is being pursued through Central
Office Permitting (Keyes McGee).
OVERALL SUMMARY AND COMMENTS:
Comments: The Andrews WWTP ORC, PT Coordinator, ARO Inspector and CO staff are coordinating to request suspension of the PT
program.
Requirements: NA
Recommendations: _Proceed with request to suspend PT program.
NOD: ❑ YES ® NO
NOV: ❑ YES ® NO
QNCR: El YES ® NO
POTW Rating:
Satisfactory X Marginal UnSatisfactory
PCI COMPLETED BY: Tim Heim DATE: 11/22/2021
/
--irigneg by:
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NC DWQ Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3