NC0020621_Pretreatment Compliance Inspection_20170407

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;lw — ROY COOPER
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Governor
, MICHAEL S.REGAN
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Secretary
Water Resources S.JAY ZIMMERMAN
Environmental Quality Director
April 7,2017
Ms.Karen Reece n'�,no�
Town of Boone cM11% n�O 11
P.O.Drawer 192 � CL vv��
Boone,NC 28607PR 1'l 7.017
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SUBJECT: Pretreatment Compliance Inspection Few n95e011011
Town of Boone
NPDES Permit#NC0020621
Watauga County
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 March 30, 2017. The
Pretreatment Coordinator,Karen Reece,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 two (2) Significant Industrial Users (SIU), one of which is categorical. The user
names are Hospitality and Charleston Forge, and the industrial User permit numbers are 0003 and 004,
respectively. Hospitality was in significant non-compliance during the previous semi-annual period for
reporting. Permit limit violations include BOD and TSS. Penalties were issued in the amounts of$2,161,
$9,100, and$6,800 for the months of June,October, and November 2016,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 October 2015 and due for renewal October 2020. 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 SIB's or Non-SIU's. The IWS was
approved May 2014 and due for renewal April 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 November
6,2012, an update is not required unless significant changes take place.
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State of North Carolina 1 Environmental Quality
450 West Hanes Mill Road,Suite 3001 Winston-Salem,North Carolina 27105
336-776-9800

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4. 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 May 13,
2013. 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, describe types 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. Long Term Monitoring Plan(STMP)—The purpose of the LTMP is to gather POTW data for completion
of a site-specific headworks analysis. The was approved on September 6, 2013 and due for renewal on
March 30,2017. The LTMP has been submitted to the Central office for review.
The next Pretreatment Annual Report(PAR)is due March 1, 2018. The Pretreatment Program at the Town
of Boon is exceptional. Please refer to the attached inspection report for further detail. If you have any
questions,please contact April Norton at(336)776-9692.
Sincerely,
(o'sherri V Knight,PE,Regional Supervisor
Water Quality Regional Operations Section
• Division of Water Resources,NCDEQ
cc: WSRO Files
Central Files
�1Vlonti Hassan—PERCS-Unit

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION(PCI)REPORT
BACKGROUND INFORMATION[Complete Prior To PCI;Review Program Info Database Sheet(s)1
1. Control Authority(POTW)Name: Town of Boone
2. Control Authority Representative(s): Karen Reece
3. Title(s): Pretreatment Coordinator
4. Last Inspection Date: 05/28/2015 Inspection Type: ®PCI ❑Audit
5. Has Program Completed All Requirements from the Previous Inspection or Program Info Sheet(s)? L 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 Fac.Type
N N C 0 0 2 0 6 2 1 03 30 17 P , S 1
(DTIA) (TYPI) (INSP) (FACC)
7. Current Number Of Significant Industrial Users(SIUs)? 2 SNS
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) 1 PSNC
14.Number of SIUs in SNC For Reporting During Either of the Last 2 Semi-Annual Periods 1 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 ® 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: 0
Annual Periods?Have any Industries in SNC(During Either of the Last SNC for Reporting: 1
2 Semi-Annual Periods)Not Been Published for Public Notice? Not Published: 0
(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 ❑ No
• 23. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ®Yes ❑ No
24. Is the LTMP/STMP Data Maintained in a Table or Equivalent? ®Yes ❑ No Is the Table Adequate? ❑Yes ❑ No
25. All LTMP/STMP effluent data reported on Discharge Monitoring Report? ®YES❑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:

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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 Approval Letter,and dates consistent with Program Info:
Program Element Last Approval Date Next Due,If Applicable
Date In file
Headworks Analysis(IIWA) 10/20/15 ®Yes❑ No October 1,2020
Industrial Waste Survey(IWS) 5/1/2014 ®Yes❑ No April 1,2019
Sewer Use Ordinance(SUO) 11/7/2012 ®Yes❑ No
Enforcement Response Plan(ERP) 2/13/2013 ®Yes❑ No
Long Term Monitoring Plan(LTMP) 9/6/2013 ®Yes❑ No March 31,2017(Submitted)
INDUSTRIAL USER PERMIT(IUP)FILE REVIEW(3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name 1. Hospitality 2. Charleston Forge 3.
30. IUP Number 0003 _ 0004
31. Does File Contain Current Permit? ®Yes ❑ No ►/ Yes ❑ No ❑Yes ❑ No
32. Permit Expiration Date 6/30/2018 12/31/2021 / /
33. Categorical Standard Applied(I.E.40 CFR,Etc.)Or N/A N/A 433
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 ❑Yes ❑ No
36. a.Does the File Contain a Slug/Spill Control Plan? a. ®Yes ONo a. ®Yes ONo a. ❑Yes ONo
b.If No,is One Needed?(See Inspection Form from POTW) b. ❑Yes ONo b. ❑Yes ONo b. ❑Yes❑No
37. For 40 CFR 413 and 433 TTO Certifiers,Does File Contain a Toxic ❑Yes❑NoON/A ®YesONo❑N/A ❑Yes❑No❑N/A
Organic Management Plan(TOMP)?
38. a.Does File Contain Original Permit Review Letter from the Division? a. EYes ONo a. @ Yes ONo a. ❑Yes ONo
b.All Issues Resolved? b.❑Yes❑No®N/A b.❑YespNo®N/A b.❑Yes❑No❑N/A
39. During the Most Recent Semi-Annual Period,Did the POTW Complete ®Yes❑No❑N/A DYes❑No❑N/A ❑Yes❑NoCIN/A
its Sampling as Required by IUP,including flow?
40. Does File Contain POTW Sampling Chain-Of-Custodies? ®Yes ONo❑N/A ®Yes ONo❑N/A ON/A
41. During the Most Recent Semi-Annual Period,Did the SIU Complete its ElYes❑No❑N/A DYes❑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 include process/dilution flows as Required by IUP?
42b.For categorical IUs with Production based limits,does file include ❑Yes❑No®N/A ❑Yes ONo®N/A ❑YespNo❑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❑NooN/A ❑Yes❑No❑N/A
All Reporting Non-Compliance from SIU Sampling?
44. a.Was the POTW Notified by SIU(Within 24 Hours)of All Self- a.®Yes❑No❑N/A a.❑YespNo®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.❑YespNo❑N/A
45. During the Most Recent Semi-Annual Period,Was the SIU in SNC? ®Yes ❑'No ❑Yes ® No ❑Yes ❑ No
46. During the Most Recent Semi-Annual Period,Was Enforcement Taken ®Yes❑No❑N/A ❑Yes❑NoON/A ❑Yes❑No❑N/A
as Specified in the POTWs ERP(NOVs,Penalties,timing,etc.)?
47. Does the File Contain Penalty Assessment Notices? ®Yes❑No❑N/A ❑Yes❑NoON/A ❑Yes❑No❑N/A
48. Does The File Contain Proof Of Penalty Collection? ®Yes❑No❑N/A ❑YespNo®N/A ❑Yes❑No❑N/A
49. a.Does the File Contain Any Current Enforcement Orders? a. ❑Yes ONo a. ❑Yes ENo a. ❑Yes ONo
b.Is SIU in Compliance with Order? b. ❑Yes ENo b. ❑Yes ENo b. ❑Yes ONo
50. Did the POTW Representative Have Difficulty in Obtaining Any of This ❑Yes /1 No ❑Yes No ❑Yes Cl No
Requested Information For You?
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FILE REVIEW COMMENTS:
The files are very organized.
INDUSTRY INSPECTION PCS CODING:
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac.Type
N I S 2
(DTIA) (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?
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:
OVERALL SUMMARY AND COMMENTS:
Comments: The Pretreatment Program at the Town of Boone is exceptional.
Requirements:
Recommendations:
NOD: ❑Yes ® No
NOV: ❑Yes ® No
QNCR: ❑Yes ® No
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory ❑
PCI COMPLETED BY: April Norton ��1� DATE: April 7,2017