NC0021423_PCA_20210812

DocuSign Envelope ID: D356AB81-F264-4593-948F-D8DAE9570CE4
NCDENR
ENVRONME µu New REEWRCEs
NORTH CAROLINA DIVISION OF WATER QUALITY
PRETREATMENT AUDIT REPORT
Background Information [Complete prior to audit; review Program Info Database Sheet(s)]
1. Control Authority (POTW) Name: Town of Spruce Pine
2. Control Authority Representative(s): Darrell Graham
3. Title(s): ORC/Pretreatment Coordinator
4. Address of POTW:
Mailing PO Box 189
City Spruce Pine
Zip Code 28777
Phone Number 828-765-3007 Fax Number 828-765-3007 E-Mail [e-mail]
5. Audit Date 8/12/2021
6. Last Inspection Date: 9/10/2019 Inspection Type: ® PCI ❑ Audit
7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s) ? x 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. New NPDES Permit requires Bis (2-ethyhexyl) phthalate be monitored and reported at
WWTP effluent.
9. Is POTW under an Order That Includes Pretreatment Conditions? ❑ Yes ® No
Order Type and Number: Are Milestone Dates Being Met? ❑ Yes ❑ No x NA
Parameters Covered Under Order
PCS (WENDB)Coding
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac. Type
INI INICI0 I0 I2 I1 I4 I2 I3 I 1°81121211 IGI IS I 1 I
(DTIA) (TYPI) (1NSP) (FACC)
10. Current Number of Significant Industrial Users (SIUS)?
11. Current Number of Categorical Industrial Users (CIUS)?
12. Number of SIUs Not Inspected by POTW in Last Calendar Year?
13. Number of SIUs Not Sampled by POTW in Last Calendar Year?
14. Enter Higher Number of 12 or 13
15. Number of SIUs with No IUP, or with an Expired IUP
16. Number of SIUs in SNC for Either Reporting or Limits Violations Durin
Semi -Annual Periods (Total Number of SIUs in SNC)
17. Number of SIUs in SNC for Reporting During Either of Last 2 Semi -Annual Periods
18. Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi -Annual Periods
19. Number of SIUs in SNC for Both Reporting and Limits Violations Durin
Semi -Annual Periods
1
1
0
0
0
1
0
0
0
0
SIUS
CIUS
NOIN
NOCM
PSNC
MSNC
SNPS
20. Number of SIUs in SNC for Self -Monitoring Requirements that were Not Inspected or Sampled
0
SNIN
NC DWQ Pretreatment Audit Form Revised: July 25, 2007
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DocuSign Envelope ID: D356AB81-F264-4593-948F-D8DAE9570CE4
21. 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)
12/23/2020
/1 Yes ❑ No
CO reviewing
Yes ❑ No
Industrial Waste Survey (IWS)
10/17/2019
/1 Yes ❑ No
3/4/2020
a Yes ❑ No
Sewer Use Ordinance (SUO)
4/2/2013
/1 Yes ❑ No
4/22/2013
a Yes ❑ No
-
Enforcement Response Plan (ERP)
2/12/2019
x Yes No
2/22/2019
X Yes No
-
Short Term Monitoring Plan (STMP)
9/16/2019
/1 Yes ❑ No
12/13/2019
X Yes ❑ No
Legal Authority (Sewer Use Ordinance-SUO)
22. 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.
23. If yes to #22, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? ❑ Yes ❑ No ® NA
A copy, if not already submitted, should be sent to Division.
24. If yes to #22, Have you had any trouble working with these towns or districts? ❑ Yes ❑ No ® NA
If yes, Explain.
25. Date of Last SUO Adoption by Local Council 4/22/2013
26. Have you had any problems interpreting or enforcing any part of the SUO? ❑ Yes ® No
If yes, Explain.
Enforcement (Enforcement Response Plan-ERP)
27. Did you send a copy of the ERP to your industries? X Yes No
If no,
28. Have you had any problems interpreting or enforcing any part of the ERP (i.e. any adjudication, improper enforcement,
etc? X No If yes, Explain.
29. List Industries under a Schedule or Order and Type of Schedule or Order
Resources
30. Please Rate the Following: S=Satisfactory M=Marginal U=Unsatisfactory
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
1 S ❑M ❑U
Access to POTW Vehicles for
Sampling, Inspections, and
Emergencies
1 S ❑M ❑U
Access to Operable Sampling
Equipment
1/ S ❑M ❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
a S ❑M ❑U
Reference Materials
1/ S ❑M ❑U
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
X S ❑M U
Computer Equipment (Hardware and
Software)
// S ❑M ❑U
NC DWQ Pretreatment Audit Form
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DocuSign Envelope ID: D356AB81-F264-4593-948F-D8DAE9570CE4
31. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No
Explain Yes or No.
32. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Spruce Pine will reduce the POTW sampling at BHP. Refer to new CIU draft.
Public Perception/ Participation
33. Are there any local issues affecting the pretreatment program (e.g.. odor, plant closing, new or proposed plants)?
❑ Yes ® No If yes, Explain.
34. 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?
35. 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?. Info would probably be kept at Town Hall.
36. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? ® Yes ❑ No
37. Is the public notified about changes in the SUO or Local Limits? ® Yes ❑ No Through Board Mtg. Minutes.
38. Were all industries in SNC published in the last notice? ❑ Yes ❑ No Not applicable for 2020.
Permitting (Industrial Waste Survey-IWS)
39a...How does the POTW become aware of new or changed Users? Manager would notify WWTP staff.
39b. 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?) Based on IWS short form and Pretreatment regulations.
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 Septage
42. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples
drawn, manifests required) Designated point -Carters Ridge Pump Station. It was unclear what controls are
in place.
43. How does the POTW allocate its loading to industries? Mark all that apply
❑ Uniform Limits ❑ Historical Industry Need El By Surcharge ® Categorical Limits ❑ Other
Explain Other:
44. Review POTW's copies of current allocation tables for each WWTP. Are there any over allocations? El Yes ® No
If yes, What parameters are over allocated?
45. If yes to #43, What is being done to address the over allocations? (short-term 1UPs, HWA to be revised, pollutant study,
etc.)
46. Does the POTW keep pollutant loading in reserve for future growth / safety? ® Yes ❑ No
If yes, what percentage of each parameter 9% cyanide, 31% copper others >50% as noted in previous PCA.
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)
Categorical and pollutants of concern. Additions to the POTW's NPDES Permit.
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DocuSign Envelope ID: D356AB81-F264-4593-948F-D8DAE9570CE4
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits ?
Explain. Categorical limit requirements.
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. Date stamp needed on mail at Town Hall to assist in
judging reporting requirements.
52. Does the POTW use the Division's model inspection form or equivalent? ® Yes ❑ No
If no, does the POTW form include all DWQ 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?
Categorical and chemicals on site.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Review based on regulatory requirements.
56. How does the POTW decide where the sample point for an SIU should be located?
The sampling point was established prior to current Coordinator.
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 ETS
Conventional Parameters POTW
Organics ETS
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Normal approved procedures.
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 X NO Is Table Adequate? YES X NO
60d. All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? ® YES ❑ NO
60e. If NO to any above, list violations
60f. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ® NO
If yes, which ones? Eliminated: Added:
61. Do you complete your own headworks analysis (HWA) ? ❑ Yes ® No
If no, Who completes your HWA? Marty Groom Phone ( ) --
62. Do you have plans to revise your HWA in the near future? X Yes No
If yes, What is the reason for the revision? (mark all that apply) X Increased average flow
❑More LTMP data available ❑Resolve over allocation
Explain.
❑NPDES limits change
5 year expiration X Other
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. No real need to increase
NC DWQ Pretreatment Audit Form
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DocuSign Envelope ID: D356AB81-F264-4593-948F-D8DAE9570CE4
Summary
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
New WWTP Permit requires Bis (2-ethyhexyl) phthalate.
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION)
66. User Name 1. BRP 2.
3.
67. IUP Number
002
68. Does File Contain Current Permit?
// Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ NI
69. Permit Expiration Date
9/30/2020
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
464 & 433
71. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
@ Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ N(
72. Does File Contain Inspection Completed Within Last Calendar Year?
// Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ NI
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)? Sampling performed.
EYes No xN/A
❑Yes❑No❑N/A
❑Yes❑No❑N/,
75. a. Does File Contain Original Permit Review Letter from Division?
b. All Issues Resolved?
a. xYes No
b.®Yes❑No❑N/A
a. •Yes ■ No
b.❑Yes❑No❑N/A
a. •Yes ❑No
b.❑Yes❑No❑N/J
76. During Most Recent Semi -Annual Period, Did POTW Complete its
Sampling as Required by IUP, including Flow?
0 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ N(
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
// Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ NI
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/.
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/,
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/,
80b. 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/,
81. During Most Recent Semi -Annual Period, Did POTW Identify All Limits
L Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ NI
Non -Compliance from Both POTW and SIU Sampling?
82. During Most Recent Semi -Annual Period, Did POTW Identify All
Reporting Non -Compliance from SIU Sampling? Town Hall needs to
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/.
Track by Pace Cover Letter.
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 xN/A
b. Yes❑No xN/A
c. Yes❑No xN/A
a.❑Yes❑No❑N/A
b.❑Yes ❑No❑N/A
c.❑Yes ❑No❑N/A
a.❑Yes ❑No❑Nt
b.❑Yes❑No❑N/E
c.❑Yes❑No❑N//
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
❑ Yes // No
❑ Yes ❑ No
❑ Yes ❑ NI
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/.
86. Does File Contain Penalty Assessment Notices?
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/,
87. Does File Contain Proof Of Penalty Collection?
❑ Yes ❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/.
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❑Nt
b.❑Yes❑No❑N/J
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
Information For You?
x No
❑ Yes ❑ No
❑ Yes ❑ NI
FILE REVIEW COMMENTS: Town Hall needs to track reporting requirements with date stamp when Pace Cover
Letter is received.
NC DWQ Pretreatment Audit Form Revised: July 25, 2007
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DocuSign Envelope ID: D356AB81-F264-4593-948F-D8DAE9570CE4
INDUSTRY INSPECTION PCS CODING:
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac. Type
INI INICIO IO I2 I1 I4 I2 I3 I 1 I I I IU 1 Is I 12
(DTIA) (TYPI) (INSP) (FACC)
1. Industry Inspected: NA
2. Industry Address:
3. Type of Industry/Product:
4. Industry Contact: Title: Phone: Fax:
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 NA
B. Plant Tour Yes ❑ No NA
C. Pretreatment Tour Yes ❑ No NA
D. Sampling Review Yes ❑ No NA
E. Exit Interview Yes ❑ No NA
Industrial Inspection Comments: NA. BRP was closed during COVID.
Audit COMMENTS and REQUIREMENTS:
Audit Comments: Spruce Pine NC0021423 now has to monitor and report Bis (2-ethyhexyl) phthalate at their effluent. They
have drafted a CIU for BRP including this parameter.
Requirements: Spruce Pine needs to update/complete their STMP schematic. Date stamp may be needed on mail received at
Town Hall to judge reporting compliance.
NOD: ❑ Yes ® No
NOV: ❑ Yes ® No
QNCR: ❑ Yes ® No
POTW Rating:
Satisfactory x Marginal
DS
�10
Audit COMPLETED BY: Linda Wiggs DATE: August 30, 2021
Asheville Regional Office
Unsatisfactory ❑
NC DWQ Pretreatment Audit Form
Revised: July 25, 2007 Page 6