NC0021717_202309PAI_20230928

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Town of Wilkesboro
Kenneth Noland
Town Manager
PO Box 1056
Wilkesboro, NC 28697
NORTH CAROLINA
Environmental Quality
September 26, 2023
SUBJECT: Pretreatment Audit Inspection (PAI)
Wilkesboro / Cub Creek WWTP
Main Program Permit (NPDES) #NC0021717
Wilkes County
Dear Mr. Noland:
On 9/8/2023 a Pretreatment Audit Inspection (PAI) was performed by Tricia Lowery of the Winston-
Salem Regional Office. Amber Garwood and Glenn Clark were present for the inspection. The purpose of
this audit was to determine the effectiveness of the Control Authority's pretreatment program regarding
SILT inspections., which includes the initial interview, tour of SILT facility, sampling review, and an exit
interview.
Background
This is a 4.9 MGD permitted facility. The Town has 3 Significant Industrial Users (SIUs), none of which
are categorical. The publicly owned treatment works (POTW) had 3 violations in July, August and
September of 2022 for Ammonia.
POTW Interview
The POTW is in the process of upgrading. The POTW has many issues removing solids, obtaining proper
DO levels in aeration basin and many components in the facility are out of service. Once upgrades are
complete, this will improve many elements of the pretreatment program.
Pretreatment Program Elements Review
The Headworks Analysis (HWA) was last approved on 4/27/2020. The next HWA is due 4/1/2024.
The IWS was last approved on 3/27/2020. The next IWS is due 12/1/2024.
The Sewer Use Ordinance (SUO) was approved on 1/2/2013.
The Enforcement Response Plan (ERP) was submitted on 2/24/2020 and approved on 3/14/2020.
The Long -Term Monitoring Plan (LTMP) was submitted 9/29/2020 and approved on 3/11/2021.
DffNorth Carolina Department of Environmental Quality I Division of Water Resources
oan caaouNn
Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105
M336.776.9800
oep.m.m or em�nmen� Qualm

LTMP File Review
The Long -Term Monitoring Plan (LTMP) is being conducted at the proper locations and frequencies
(2/year).
Industrial User Permit (IUP) File Review
A review of the file for Tyson (IU#1003) revealed that the monitoring data was well organized and
compliant.
The slug control plan for Tyson (IU#1003) was in good order.
Action Items
No other action items were noted.
The pretreatment program is considered satisfactory. Ms. Garwood runs an adequate pretreatment program.
If you have any questions, please contact Tricia Lowery or me at [phone].
Sincerely,
I D-ocu Siiggned by:
•n. l Jn,lAtf
145B49E225C94EA...
Lon T. Snider
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
Attachment:
NC DWR Pretreatment Audit Inspection (PAI) Report
REQ� North Carolina Department ofEnvironmental Quality I Division ofWater Resources
Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Raleigh, North Carolina 27105
NORTH CAROLINA 336.776.9800
naparMeM of EmironmanW 9uallly

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: Town of Wilkesboro
2. Control Authority Representative(s): Amber Garwood, Glenn Clark
3. Title(s): Pretreatment Coordinator, ORC
4. Address of POTW: 700 Snyder St
Mailing PO Box 1056
City Wilkesboro Zip Code 28697
Phone Number 336-981-1078 Fax Number E-Mail agarwood(d,)wilkesboronc.org
5. Audit Date 09/08/2023
6. Last Inspection Date: 07/08/2022 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. In July, August, and September noncompliant due to NH3 limit exceedance. No NPDES compliance
issues have occurred since.
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 MM/DD/YY
INIC101012 11 17 11 17 I 19 130119I
**renewal application submitted on time. Still awaiting new permit.
10: Current Number of Significant Industrial Users (SIUs)?
.11... .Num..ber...of..SIUs....w.ith..No I.UP, 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?
..................................................................................................
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?
................................................................................................................................................................................................... .
17. Number of SIUs on Schedules?
................................................................................................................................................................................................... .
18: Current Number of Categorical Industrial Users (CIUs)?
19. Number of CIUs in SNC?
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)
10/12/2019
® Yes ❑ No
4/27/2020
® Yes ❑ No
4/01/2024
Industrial Waste Survey (IWS)
2/24/2020
® Yes ❑ No
3/27/2020
® Yes ❑ No
12/01/2024
Sewer Use Ordinance (SUO)
12/27/2012
® Yes ❑ No
1/02/2013
® Yes ❑ No
Enforcement Response Plan (ERP)
2/24/2020
® Yes ❑ No
3/14/2020
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
9/29/2020
® Yes ❑ No
3/11/2021
® Yes ❑ No
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 Counci112/03/2012
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
None
Resources
29. Please Rate the Followine: S=Satisfactory M=Mareinal U=Unsatisfactory
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
®S ❑M ❑U
Access to POTW Vehicles for
Sampling, Inspections, and
®S ❑M ❑U
Emergencies
Access to Operable Sampling
Equipment
®S ❑M ❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
®S ❑M ❑U
Reference Materials
®S ❑M ❑U
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
®S ❑M ❑U
Computer Equipment (Hardware and
Software)
®S ❑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.
Through rates and fees received from Pretreatment Permittees and septic haulers
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 anyone 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? Review policies around confidential information with industry.
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? Through IWS, Town Council Meeting, reviewing
customers with utility billing, look out for new, changing, or closing businesses in area.
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?) This would be determined by what type of business it is (categorical), how much waste and what type of
waste they would be discharging.
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
®Yes ❑No If Yes, How many are there? 2
Please list each site and how it is permitted, if applicable. Wilkes County Landfill in Roaring River, NC and Ashe
County Landfill in Crumpler, NC. Both have an active SIU Permit.
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) The trucks have a designated discharge point. POTW analyses samples at their very minimum
for what is required by their SIU Permit. Will occasionally sample more if there is a concern or need.
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.)
46. Does the POTW keep pollutant loading in reserve for future growth / safety? ® Yes ❑ No
If yes, what percentage of each parameter TSS has the lowest at 5.8% following at flow at 18.5% MAHL available. POTW
currently in design phase of a plant upgrade.
47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) ❑ Yes ® No
If yes, Explain.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 3

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)
Historical considerations and the NPDES Pollutants of Concern
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Tyson's sampling is much more frequent due to the industry being considered a separate influent and a large contributor.
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. Follow the permit conditions and ERP.
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?
Inspection of the industry's engineering controls and production processes.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Use State's guidelines as a minimum.
56. How does the POTW decide where the sample point for an SIU should be located?
Based on its discharge before entering the plant but after its process.
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. POTW collects all samples
58. Who performs sample analysis for the POTW for Metals Meritech
Conventional Parameters The POTW
Organics Meritech
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
They are filled out at the time of sampling by the person retrieving samples and with the carrier at the time of pickup.
Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis (HWA)
60a.
60b.
60c.
60d.
60e.
60f.
Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑ NO
Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ® YES ❑ NO
Is LTMP/STMP Data Maintained in Table or Equivalent? ® YES ❑ NO Is Table Adequate? ❑ YES ❑ NO
All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? ® YES ❑ NO Division Inspector, verify yourself.
If NO to any above, list violations
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? Phone (_) --
62. Do you have plans to revise your HWA in the near future? ® Yes ❑ 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.
63. In general, what is the most limiting criteria of your HWA? ®Inhibition ❑ Pass Through ❑Sludge Quality
NC DWR Pretreatment Audit Form Revised: December 2016 Page 4

64. Do you see any way to increase your loading in the future (Example: obtaining more land for sludge disposal)? ® Yes ❑ No
Explain. POTW is almost to the 90% Design phase for a plant upgrade which will increase the flow from 4.9 MGD to 8
MGD.
Summary
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
The plant upgrade should positively impact the pretreatment program.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 5

INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION)
66. User Name IF
-Tyson
2.
3.
67. IUP Number
1003
68. Does File Contain Current Permit?
® Yes ❑ No
❑ Yes ❑ No
❑
Yes
❑
No
69. Permit Expiration Date
12/11/2026
70. Categorical Standard Applied I.E. 40 CFR, Etc. Or N/A
NA
71. Does File Contain Permit Application Completed Within One Year Prior
® Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
to Permit Issue Date?
72. Does File Contain Inspection Completed Within Last Calendar Year?
® Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
73. a. Does File Contain Slug/Spill Control Plan?
a. NYes ❑No
a. ❑Yes ❑No
a. ❑Yes ❑No
b. If No, is One Needed? See Inspection Form from POTW
b. ❑Yes ❑No
b. ❑Yes ❑No
b. ❑Yes ❑No
74. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
Yes❑NoEN/A
P
❑Yes❑No❑N/A
❑Yes❑No❑N/A
Organic Management Plan TOMP ?
75. a. Does File Contain Original Permit Review Letter from Division?
a. NYes ❑No
a. ❑Yes ❑No
a. ❑Yes ❑No
b. All Issues Resolved?
b.❑Yes❑No®N/A
b.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
76. During Most Recent Semi -Annual Period, Did POTW Complete its
® Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
Sampling as Required by IUP, including Flow?
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
® Yes ❑ No 11
❑ Yes ❑ Kol
❑ Yes ❑ No
78. During Most Recent Semi -Annual Period, Did SIU` Complete its
®Yes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
]j
Sampling as Required by IUP, including Flow?
79. During Most Recent Semi -Annual Period, Did SIU submit all reports on
EYes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
time?
80a. For categorical users with Combined Wastestream Formula (CWF), does
❑Yes❑NoEN/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
file include process/dilution flows as Required b IUP?
80b. For categorical users with Production based limits, does file include
❑Yes❑NoEN/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
production rates and/or flows as Required by IUP?
81. During Most Recent Semi -Annual Period, Did POTW Identify All
® Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
Limits Non -Compliance from Both POTW and SIU Sampling?
82. During Most Recent Semi -Annual Period, Did POTW Identify All
❑Yes❑NoEN/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
Re ortin Non-Com liance from SIU Sampling?
83. a. Was POTW Notified by SIU (Within 24 Hours) of All Self-
a.❑Yes❑No®N/A
a.❑Yes❑No❑N/A
a.❑Yes❑No❑N/A
Monitoring Violations?
b. Did Industry Resample and submit results to POTW within 30 Days?
b.❑Yes❑No®N/A
b.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
c. If applicable, did POTW resample and obtain results within 30 days of
❑Yes❑No®N/A
becomingaware of SIU limit violations in the POTW's sam lingof SIU?
c.❑Yes❑No❑N/A
c.❑Yes❑No❑N/A
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
I ❑
Yes
®
No 11
❑
Yes
❑
No 11
❑
Yes
❑
No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
❑Yes❑NoEN/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
Specified in POTW's ERP OVs, Penalties, timing, etc.)?
86. Does File Contain Penalty Assessment Notices?
❑Yes❑NoEN/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
87. Does File Contain Proof Of Penalty Collection?
❑Yes❑NoEN/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
88. a. Does File Contain Any Current Enforcement Orders?
a.❑Yes❑No®N/A
a.❑Yes❑No❑N/A
a.❑Yes❑No❑N/A
b. Is SIU in Compliance with Order?
b.❑Yes❑No®N/A
b.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
❑ Yes ® No
❑ Yes ❑ No
❑ Yes ❑ No
Information For You?
FILE REVIEW COMMENTS:
Files are in good order. No issues found.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 6

INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
INIC10 In 12 I1 17 I1 17 I
**See above concerning date
1. Industry Inspected: Tvson
2. Industry Address: 704 S Factory Street, Wilkesboro NC 28697
3. Type of Industry/Product: Poultry processing facility
4. Industry Contact: James Brown Title: Environmental Manager Phone: [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
B. Plant Tour ® Yes ❑ No
C. Pretreatment Tour ® Yes ❑ No
D. Sampling Review ® Yes ❑ No
E. Exit Interview ® Yes ❑ No
Industrial Inspection Comments:
Avery detailed and informative plant tour. The pretreatment process was covered thoroughly with no issues found. Engineering
controls are in place to prevent slug discharges to POTW, in addition to stormwater protection measures.
Interview covered changes in production and/or personnel, with a detailed review of records, operations & management, and
sampling protocols.
Audit SUMMARY AND COMMENTS:
Audit Comments:
Requirements:
Recommendations:
NOD: ❑ Yes
NOV: ❑ Yes
QNCR: ❑ Yes
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory ❑
Audit COMPLETED BY: Tricia Lowery DATE: 9/8/2023
XXXX, PERCS, and XXXX, XXXX Regional Office
NC DWR Pretreatment Audit Form Revised: December 2016 Page 7