The URL can be used to link to this page

Home My WebLink AboutNC0020451_Pretreatment_PAI_Report_20240828 Docusign Envelope ID:7FF01 D79-DC82-485A-94B6-BC5F73ACD74A Eta`STATE ROY COOPER Governor ELIZABETH S.BISER Secretary *�Af QUAM W RICHAM E.ROGERS,JR. NORTH CAROLINA Director Environmental Quality 8/28/2024 Via Electronic Mail(w"t (ktownofwj.com) Mr.Brandon Patrick Pretreatment Coordinator Town of West Jefferson PO Box 490 West Jefferson,NC 28694 Subject: Pretreatment Audit Inspection Program: Town of West Jefferson Wastewater Treatment Plant: Town of West Jefferson WWTP NPDES#: NCO020451,Ashe County Dear Mr. Patrick: Enclosed is a copy of the Pretreatment Audit Inspection (PAI) Report for the inspection of the Town of West Jefferson's industrial pretreatment program on June 20, 2024, by Mr. Keyes McGee of the Division's Central Office. Background The Town of Jefferson has one significant industrial user (SIU) discharging effluent to the Town of West Jefferson Wastewater Treatment Plant. Publicly Owned Treatment Works(POTW)Interview Discussions with you indicate no POTW issues related to the pretreatment program at the time of this PAI. Pretreatment Program Elements Review The most recent Headworks Analysis (HWA) was submitted to the Division on March 21, 2024. The HWA is awaiting Division review. The Industrial Waste Survey(IWS)was approved on July 11,2019. The Sewer Use Ordinance(SUO)was approved on January 10,2013. The Enforcement Response Plan(ERP)was approved on February 13,2020. The Short Term Monitoring Plan(STMP)was approved on July 11,2019. D E Q�� North Carolina Department of Environmental Quality I Division of Water Resources 512 North Salisbury Street 1 1611 Mail Service Center I Raleigh,North Carolina 27699-1611 NORTH CAROLINA 919.707.9000 Uapad—t of E,,kon—tal Quay Docusign Envelope ID:7FF01 D79-DC82-485A-94B6-BC5F73ACD74A STMP File Review Findings The POTW is sampling as per the approved STMP at the appropriate PQLs. Industrial User Permit(IUP) File Review File review for Ashe County Cheese(0003)indicates well organized records and data. The SIU was fully compliant with the industrial user permit (IUP) for the last complete 6-month reporting. POTW Industrial Inspection Review The POTW annual on-site inspection of Ashe County Cheese was witnessed by the Division and it was completed as required. File No Action Items Necessary for the Pretreatment Program Final Comments The Town of West Jefferson's industrial pretreatment program is satisfactory. The POTW continues to administrate an adequate pretreatment program. Please inform the control authority's most senior management of our findings by forwarding a copy of this letter and the enclosed report. The report should be self-explanatory; however, should you have any questions, please do not hesitate to contact Mr. McGee at(919) 707-3636, email: ke, e�gee(&deq.nc.gov. Sincerely, tkm/west jefferson_pai_2024 Enclosure: 06/20/2024 Inspection Report DocuSigned by: Ec: Municipal Unit File EKfLj$dL6(� kh Jenny Graznak,WSRO C464531431644FE... Central Files(Laserfiche) Michael J. Montebello,NPDES Branch Chief Division of Water Resources D E Q North Carolina Department of Environmental Quality I Division of Water Resources vvv512 North Salisbury Street 11611 Mail Service Center I Raleigh,North Carolina 27699-1611 NORTH CAROLINA 919.707.9000 Depa"mem of Environmental Duality Docusign Envelope ID:7FF01 D79-DC82-485A-94B6-BC5F73ACD74A i a 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 West Jefferson 2. Control Authority Representative(s):Brandon Patrick 3. Title(s): ORC/Pretreatment Coordinator 4. Address of POTW: Mailing PO Box 490 City West Jefferson Zip Code 28694 Phone Number (336)977-6725 Fax Number E-Mail wwtp(a)townofwi.com 5. Audit Date 06/20/2024 6. Last Inspection Date: 12/06/2021 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. Currently landfilling sludge to resolve sludge compliance issues. 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 1014 15 11 1 1061201241 _10:.._Current Number of Significant.Industrial Users..(SIUS) ............................................................................................................................. I 11. Number of SIUs with No IUP,or with an Expired IUP?............................................................................................................................. 0 ................................................................................ . ............................................. 12. Number of SIUs Not Inspected.by POTW in Last Calendar Year? 0 ................................................................................................................................................. 1.3. Number of SIUs Not Sampled by POTW in.Last Calendar Year? 0 ...................................................................................................................................................... 14. Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi-Annual Periods? 0 15. Number of SIUs in SNC for Reporting.During Either of Last 2 Semi-Annual Periods? 0 16. Number of SIUs in SNC with Pretreatment Schedule? 0 ...................................................................................................................................................................................................................................................................................................... 17. Number of SIUs on Schedules? 0 ...................................................................................................................................................................................................................................................................................................... _1$:.._Current Number of Categorical Industrial Users..(CIUs) .......................................................................................................................... 0 19. Number of C1IJs in SNC? 0 NC DWR Pretreatment Audit Form Revised: July 2024 Page 1 Docusign Envelope ID:7FF01D79-DC82-485A-94B6-BC5F73ACD74A 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 Last Approval Date Next Due, Date In file? Date In file If Applicable Headworks Analysis(HWA) 03/21/2024 ®Yes ❑ No 03/04/2019 ®Yes ❑ No Industrial Waste Survey(IWS) 03/25/2019 ®Yes ❑ No 07/11/2019 ®Yes ❑ No Sewer Use Ordinance(SUO) 12/19/2012 ®Yes ❑ No 01/10/2013 ®Yes ❑ No Enforcement Response Plan(ERP) 02/11/2020 ®Yes ❑ No 02/13/2020 ®Yes ❑ No Long Term Monitoring Plan(LTMP) 03/25/2019 ®Yes ❑ No 07/11/2019 ®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 Council 02/04/2013 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 N/A Resources 29. Please Rate the Following: S=Satisfacto M=Mar final 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: July 2024 Page 2 Docusign Envelope ID:7FF01D79-DC82-485A-94B6-BC5F73ACD74A 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. N/A—Rates are satisfactory to cover pretreatment costs. 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?The POTW will provide access to records(just as done during the audit). 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 *Not necessary(open door policy) 36. Is the public notified about changes in the SUO or Local Limits? ®Yes ❑ No *Posted in newspaper and on town website(link included for annual wastewater report in water bill) 37. Were all industries in SNC published in the last notice? ®Yes ❑ No Yes—the last time there was a SNC situation. Permitting(Industrial Waste Survey-IWS) 38. How does the POTW become aware of new or changed Users?Through the Town Hall Office(when an application for water service is submitted. 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?)Dependent upon the process wastewater activities of the facility. 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.No 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)N/A—no septic pumpers are allowed to discharge. 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?Hg and Se. 45. If yes to#44,What is being done to address the over allocations?(short-term IUPs,HWA to be revised,pollutant study,etc.) With no effluent violations—to be determined. 46. Does the POTW keep pollutant loading in reserve for future growth/safety? ®Yes ❑ No If yes,what percentage of each parameter 10% 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) Historical precedent due to no change at SIU. NC DWR Pretreatment Audit Form Revised: July 2024 Page 3 Docusign Envelope ID:7FF01D79-DC82-485A-94B6-BC5F73ACD74A 49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain. Historical precedent. 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.Reviewed the Industrial Data Summary Form. 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®N/A 53. Were all SIUs evaluated for the need of a slug/spill control plan during their most recent inspections? ❑Yes ❑ No If no,Explain.The only SIU has an approved spill plan. 54. What criteria are used to determine if a slug/spill control plan is needed? Historical precedent. 55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate? Requires periodic review for maintaining accurate information. 56. How does the POTW decide where the sample point for an SIU should be located? Point of entry into sewer. 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.Tim Church samples the SIU. 58. Who performs sample analysis for the POTW for Metals: Statesville Analytical POTW Lab: Statesville Analytical Conventional Parameters: Statesville Analytical Organics: Statesville Analytical 59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples. Both the POTW's CoC procedure and the SIU's CoC procedure(with Water Quality Lab of Banner Elk)are the same. 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? ❑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?N/A Phone O -- 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. The HWA was recently revised. 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.Available capacity still exists. Summary NC DWR Pretreatment Audit Form Revised: July 2024 Page 4 Docusign Envelope ID:7FF01D79-DC82-485A-94B6-BC5F73ACD74A 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: July 2024 Page 5 Docusign Envelope ID:7FF01D79-DC82-485A-94B6-BC5F73ACD74A INDUSTRIAL USER PERMIT IUP FILE REVIEW 3 IUP FILE REVIEWS AND 1 IU INSPECTION 66. User Name 1,Ashe County Cheese 2. 11 3. 67. IUP Number 0003 68. Does File Contain Current Permit? ®Yes ❑ No ❑Yes ❑ No ❑Yes ❑ No 69. Permit Expiration Date 06/30/2024 70. Categorical Standard Applied I.E.40 CFR,Etc. Or N/A N/A 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? I ®Yes ❑ No ❑Yes ❑ No ❑Yes ❑ No 73. a.Does File Contain Slug/Spill Control Plan? a. ®Yes❑No a. ❑Yes ❑No a. ❑Yes❑No b.If No,is One Needed? See Inspection Form from POT b. ❑Yes ❑No b. ❑Yes ❑No b. ❑Yes ❑No 74. For 40 CFR 413 and 433 TTO Certification,Does File Contain a Toxic ❑Yes❑No®N/A ❑Yes❑No❑N/A ❑Yes❑No❑N A Organic Management Plan TOMP ? 75. a.Does File Contain Original Permit Review Letter from Division? a. ®Yes❑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 ❑Yes ❑ No ❑Yes ❑ No 78. During Most Recent Semi-Annual Period,Did SIU Complete its ®Yes❑No❑N/A ❑Yes❑No❑A ❑Yes❑No❑N/ Sampling as Required b IUP,includingFlow? 79. During Most Recent Semi-Annual Period,Did SIU submit all reports on ®Yes❑No❑N/ ❑Yes❑No❑N/A ❑Yes❑No❑N/ time? 80a.For categorical IUs with Combined Wastestream Formula(CWF),does ❑Yes❑No®N/ ❑Yes❑No❑N/ ❑Yes❑No❑N/ file include process/dilution flows as Required b IUP? 80b.For categorical IUs with Production based limits,does file include ❑Yes❑No®N/ ❑ Yes❑No❑N/A ❑Yes❑No❑N/ 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❑No❑N/ ❑Yes❑No❑N/A ❑Yes❑No❑N/A Reporting-Non-Compliance 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 c.❑Yes❑No®N/A c.❑Yes❑No[]N/A c.❑Yes[]No❑N/A becoming aware of SIU limit violations in the POTW's sampling of SIU? 84. During Most Recent Semi-Annual Period,Was SIU in SNC? I ❑Yes ® No 11 ❑ Yes ❑ No I ❑Yes ❑ No 85. During Most Recent Semi-Annual Period,Was Enforcement Taken as ®Yes❑No ❑Yes❑No ❑Yes❑No Specified in POTW's ERP OVs,Penalties,timing,etc.)? ❑N/A ❑N/A ❑N/A 86. Does File Contain Penalty Assessment Notices? ❑Yes❑No N/ ❑Yes❑No N/ F❑Yes❑No❑N/ 87. Does File Contain Proof Of Penalty Collection? ❑Yes❑No N/ ❑Yes❑No N/ ❑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: Ashe County Cheese's IUP file is in good order. NC DWR Pretreatment Audit Form Revised: July 2024 Page 6 Docusign Envelope ID:7FF01D79-DC82-485A-94B6-BC5F73ACD74A INDUSTRY INSPECTION ICIS CODING: Main Program Permit Number MM/DD/YY N I C 1 0 I O 12 1 0 1 4 1 5 1 1 06 120 124 1.Industry Inspected: Ashe County Cheese 2.Industry Address: 106 East Main Street,West Jefferson,NC 28694 3. Type of Industry/Product: Cheese Making 4.Industry Contact: Brandon Hardin Title: Manager Phone: (336)246-2501 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 Very brief—no longer than necessary. B. Plant Tour ®Yes ❑ No Looked at all drains in facility. C. Pretreatment Tour ®Yes ❑ No D. Sampling Review ®Yes ❑ No Brandon Patrick verified sampling data. E. Exit Interview ®Yes ❑ No Spoke briefly about upcoming season. Industrial Inspection Comments: Met with Brandon Hardin. Only wash water is discharged—no changes planned at Ashe County Cheese Flow measurement is the watermeter. Audit SUMMARY AND COMMENTS: Audit Comments: Well run pretreatment program. Requirements: None Recommendations: None NOD: ❑ Yes ® No NOV: ❑ Yes ® No QNCR: ❑ Yes ® No POTW Rating: Satisfactory ® Marginal ❑ Unsatisfactory❑ Audit COMPLETED BY: Keyes McGee DATE: 06/20/2024 XXXX,PERCS,and XXXX, XXXX Regional Office NC DWR Pretreatment Audit Form Revised: July 2024 Page 7