NC0020451_Pretreatment Compliance Inspection_20170125

Water Resources
Environmental Quality
January 25, 2017
Mr. Charles Call
Town of West Jefferson
P.O. Box 490
West Jefferson, NC 28694
SUBJECT: Pretreatment Compliance Inspection
West Jefferson
NPDES Permit #NC0020451
Ashe County
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. JAY ZB4MERMAN
Director
JAN 31 2017
Water Quality
permitting Section
A Pretreatment Compliance Inspection (PCI) was performed by April Norton of the Division of Water
Resources (Division) Winston-Salem Regional Office; on the subject facility on January 24, 2017. The
Pretreatment Coordinator, Charles Call, was present for the inspection. The purpose of this inspection was to
determine the effectiveness of the pretreatment program, which included a review of pretreatment program
elements, publicly owned treatment works (POTW) plant performance, industry monitoring data, and
adherence to the enforcement response plan (ERP).
The Town currently has one (1) Significant'Industrial Users (SIU), which is not categorical. The user name
is Ashe County Cheese, and the industrial user permit number is 0003. The SIU was not in significant non-
compliance during the previous semi-annual period. However, there were permit limit violations during
January 2016, February 2016 and March 2016 for zinc, biochemical oxygen demand, and pH, respectively.
Program Elements Review
1. Headworks Analysis (HWA) — The purpose of the HWA is to determine the maximum allowable
headworks loading, the uncontrollable loading, and the maximum allowable industrial loading the
publically owned treatment works (POTW) can receive from its SIU's without failing a NPDES permit
limit, interfering with the POTW, restricting the beneficial use of sludge, or impacting worker safety and
health. The HWA was approved on June 20, 2014 and due for renewal on April 1, 2019. There were no
errors noted with the HWA at the time of the inspection.
2. Industrial Waste Survey (IWS) — The purpose of the IWS is to identify new and existing Industrial Users
and their pollutants of concern that require_ permitting either as Siu's or Non-SIU's. The IWS was
approved on June 23, 2014 and due for renewal on April 1, 2019. There were no errors noted with the
IWS at the time of the inspection.
3. Sewer Use Ordinance (SUO) — The purpose of the SUO is to develop, and enact a SUO that provides the
local government the legal authority to implement the pretreatment program and protects the POTW,
POTW workers, the public, surface waters of the State and sludge. The SUO was approved on January
10, 2013; an update is not required unless significant changes take place.
r
¢- �Notl' lnq Compares!:__,
State of North Carolina I Environmental Quality
450 West Hanes Mill Road, Suite 300 1 Winston-Salem, North Carolina 27105
336-776-9800

Enforcement Response Plan (ERP) — The ERP is created by the POTW, and is used to provide fair and
equitable treatment in initial and escalating enforcement actions. The ERP was last approved on August
18, 2005. The ERP should be updated to accurately reflect actions which will be taken by the POTW to
address violations. Specifically, the ERP must: describe how the POTW will investigate instances of SIU
non-compliance, cover all anticipated types of SIU violations, describetypes of escalating enforcement
responses the POTW will take for each type of violation including time frames, and identify by title the
official(s) responsible for each type of response.
5. Short Term Monitoring Plan (STMP) — The purpose of the STMP is to gather POTW data for completion
of a site-specific headworks analysis. The data is to be collected over an extended period. Please ensure
that the STMP quarterly sampling period begins in 2018 (calendar year) for the next HWA renewal.
During the time of the inspection, the STMP contained a site map which did not represent the current
POTW. A more accurate map was placed in the STMP at the time of inspection.'
The next Pretreatment Annual Report (PAR) is due March 1, 2017. Please refer to the attached inspection
report for further detail. If you have any questions, please contact April Norton at [phone].
Sincerely,
rOherri V Knight, PE, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
cc: WSRO Files
Central Files
CNLonti Hass aur PERC_S�CTnit

NORTH CAROLINA DIVISION OF WA'T'ER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
BACKGROUND INFORMATION [Complete Prior To PCI• Review Program Info Database Sheet(s)]
1. Control Authority (POTW) Name: West Jefferson
2. Control Authority Representative(s): Charles McCall
3. Title(s): Pretreatment Coordinator
4. Last Inspection Date: 10 /08 /2015 Inspection Type: ® PCI ❑ Audit
5. Has Program Completed All Requirements from the Previous Inspection or 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
PCS CODING
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector
n INI CIO 10 12101415 111 O1 417 IT EU
Fac. Type
(FAC
(DTIA) (TYPI (INSP)
7. Current Number Of Significant Industrial Users (SATs)? I
SIUS
8. Current Number Of Categorical Industrial Users (CIUs)?
0
CATS
9. Number of SATs 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 ]UP
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 POTW Permit Limits Violations? ❑ Yes E No
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 ❑ Yes ® No
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 during either of the Last 2 Semi- SNC for Limits: N/A
Annual Periods? Have any Industries in SNC (During Either of the Last SNC for Reporting: N/A
2 Semi -Annual Periods) Not Been Published for Public Notice? Not Published: N/A
(May refer to PAR if Excessive SIUs in SNC)
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? N/A
21. Are Any Permits Or Civil Penalties Currently Under Adjudication? If Yes, Which ❑ Yes ® No
Ones?
LTMP/STMP FILE REVIEW:
22. Is the LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® Yes El No
23. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ® Yes [I No
24. Is the LTMP/STMP Data Maintained in a Table or Equivalent? ® Yes El No Is the Table Adequate? ® Yes ❑ No
25. All LTMP/STMP effluent data reported on Discharge Monitoring Report? ® YES El NO DWQ Inspector, please verify!
26. If NO to 23 - 26, list violations
27. Should any Pollutants of Concern be Eliminated from or Added to the LTMP/STMP? [-]Yes ® No
If yes, which ones? Eliminated: Added:
NC DWQ Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 1

28. PRETREATMENT PROGRAM ELEMENTS REVIEW - Please review POTW files, verify POTW has copy of Program Element in
their files, complete with supporting documents and CODY of PERCS Approval Letter, and dates consistent with Program Info:
Program Element
Last Approval Date Next Due, If Applicable
Date In file
Headworks Analysis (HWA)
6-20-14
® Yes ❑ No 4-1-19
Industrial Waste Survey (IWS)
6-23-14
® Yes ❑ No 4-1-19
Sewer Use Ordinance SUO
01-10-13
® Yes ❑ No
Enforcement Response Plan (ERP)
8-18-05
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
8-21-14
® Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW(3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name
1. Ashe County Cheese 2.
3.
30, IUP Number
0003
31. Does File Contain Current Permit?
I ® Yes ❑ No 11
❑ Yes ❑ Rol
❑ Yes ❑ No
32. Permit Expiration Date
6 /30 / 19
/
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
N/A
34. Does File Contain Permit Application Completed Within One Year Prior
Yes. ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
to Permit Issue Date?
35. Does File Contain an Inspection Completed Within Last Calendar Year?
® Yes ❑ No
❑ Yes ❑. No 11
❑ Yes ❑ No
36. a. Does the File Contain a Slug/Spill Control Plan?
a. ❑Yes NNo
a. ❑Yes ❑No
a. ❑Yes []No
b. If No, is One Needed? (See Inspection Form from POTW)
b. ❑Yes NNo
b. ❑Yes ❑No
b. []Yes []No
37. For 40 CFR 413 and 433 TTO Certifiers, Does File Contain a Toxic
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
Organic Management Plan (TOW)?
38. a. Does File Contain Original Permit Review Letter from the Division?
a. ❑Yes NNo
a. ❑Yes ONO
a. ❑Yes ❑No
b. All Issues Resolved?
b.❑Yes❑No❑N/A
I b.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
®Yes❑No❑N/A❑Yes❑No❑N/A
❑Yes❑No❑N/A
its Sampling as Required by IUP, including flow?
40. Does File Contain POTW Sampling Chain -Of -Custodies?
®Yes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
41. During the Most Recent Semi -Annual Period, Did the SIU Complete its
®Yes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
Sampling as Required by IUP, including flow?
41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports
®Yes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
on time?
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
file includeprocess/dilution flows as Required by NP?
42b. For categorical IUs with Production based limits, does file include
❑Yes❑No®N/A
❑Yes❑No❑N/A 1[❑Yes❑No❑N/A
production rates and/or flows as Required by IUP?
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
®Yes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
All Limits Non -Compliance from Both POTW and SIU Sampling?
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
All Re ortin Non -Com liance from SIU Sampling?
44. a. Was the 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 within 30 days of becoming aware
c.❑Yes❑No®N/A
of SIU limit violations in the POTW's sampling of the SIU?
c.❑Yes❑No❑N/A
c.❑Yes❑No❑N/A
45. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
I ❑ Yes ®No1
❑ Yes ❑ Nol
❑ Yes ❑ No
46. During the Most Recent Semi -Annual Period, Was Enforcement Taken
❑Yes®No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
as Specified in the POTWs ERP (NOVs, Penalties, timing, etb.)?
47. Does the File Contain Penalty Assessment Notices?
❑Yes®No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
48. Does The File Contain Proof Of Penalty Collection?
I ❑Yes❑NoNN/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
49. a. Does the File Contain Any Current Enforcement Orders?
a. ❑Yes NNo
a. ❑Yes ❑No
a. ❑Yes ❑No
b. Is SIU in Compliance with Order?
b. []Yes NNo
b. ❑Yes []No 11
b. []Yes []No
50. Did the POTW Representative Have Difficulty in Obtaining Any of This
❑ Yes ® No
❑Yes ❑ No
❑ Yes ❑
Requested Information For You?
!11
NC DWQ Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 2

y ;TILE REVIEW COMMENTS:
Please ensure that the SIU resubmits any sample results within 30 -days. Please update the ERP as stated in the PCI letter dated
January 25, 2017.
INDUSTRY INSPECTION PCS CODING: N/A
Trans.Code Main Program Permit Number MM/DD/YY
(DTIA)
Inspec.Type
Inspector
Fac. Type
0
0
0
(TYPI)
(INSP)
(FACC)
1. Industry Inspected:
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?
Continents:
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: '
OVERALL SUMMARY AND COMMENTS:
Comments:
Requirements: ERP update
Recommendations:
NOD: ❑ Yes ® No
NOV: ❑ Yes ❑ No
QNCR: [:]Yes ® No
POTW Rating:
Satisfactory Z Marginal ❑ Unsatisfactory ❑
PCI COMPLETED BY: April Norton DATE: January 25, 2017
NC DWQ Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 3