NC0020800_PTAudit_20180426

eater Resources
Environmental Quality
April 26, 2018
James Reid, Mayor
Town of Andrews
P.O. Box 1210
Andrews NC 28901
SUBJECT: Pretreatment Audit Inspection
Town of Andrews
Permit No: NC0020800
Cherokee County
Dear Mayor Reid:
ROY COOPER
Governor
MICHAEL S. REGAN
Secrelmy
LINDA CULPEPPER
Inlerim Direclor
Enclosed please find a copy of the Pretreatment Audit Inspection form from the inspection conducted
on April 19, 2018. The Pretreatment Audit Inspection was conducted by Deborah Gore, PERCS Unit
Supervisor, and Dan Boss, Environmental Specialist, of the Asheville Regional Office. Mr. Tim Wood, and
Mr. Mark Bentley were present for the inspection and their time and cooperation was much
appreciated.
The purpose of the pretreatment audit is to determine the effectiveness of the Pretreatment program
by reviewing the files, which include a review of POTW plant performance, sampling and compliance
judgment program, adherence to the enforcement response plan (ERP), and evaluating how the
program performs an industrial user inspection.
The audit report is attached with findings and observations made during the inspection. Please review
for more detail.
1. The Pretreatment Coordinator (Michael Ladd, contracted from EIS) for the Town of Andrews
passed away suddenly in January 2018. Mr. Bentley (EIS), who has been responsible for
sampling, has taken over the additional duties. Most of the program documents were not
available at the time of the inspection. Mr. Bentley believes that the documents are filed in Mr.
Ladd's office but was not able to locate them in advance of the inspection. Although, EIS is the
contractor, the Town is still the Control Authority and should maintain copies of all program
elements. Copies of the current headworks analysis (HWA), long term monitoring plan (LTMP),
sewer use ordinance (SUO), enforcement response plan (ERP) and industrial waste survey (IWS)
were sent via email to Mr. Wood and Mr. Bentley.
2. Town of Andrews has 1 significant industrial users (SIUs), which is categorical under 40 CFR 433.
3. The industrial user permit file was reviewed.
State of North Carolina � Environmental Quality
1617 Mai] Service Center � Raleigh, North Carolina 27699-1617
919-707-9000

a. The data for the first half of 2017 indicates that the SIU is in significant non-compliance
(SNC) for BOD, TSS and cyanide. The Town must judge compliance for the 2nd half of
2017, send out appropriate Notices of Violation and publish the required notice of SIUs
in SNC. This information must be summarized in the Pretreatment Annual Report and
submitted by June 25, 2018. Forms and detailed instructions were emailed to Mr.
Wood and Mr. Bentley.
b. Request copy of slug/spill plan.
c. Remind the SIU of the requirements in Part II, 2, b of their permit to report violations
occurring during self -monitoring events within 24 hours and to resample and submit the
results within 30 days.
4. The Industrial User Permit expires September 21, 2018. Team has submitted the permit
renewal application. Please submit the renewed permit to PERCS 30 days in advance of the new
effective date (August 22, 2018).
5. During the audit a thorough inspection was conducted at Team Industries.
a. Ensure the SIU has a copy of the ERP within 30 days.
6. Monitoring Plan. Andrews may consider implementing ashort-term monitoring plan instead of
a long-term monitoring plan and eliminating some pollutants of concern that are associated
with the land application of biosolids. Detailed explanation and examples were sent to Mr.
Wood and Mr. Bentley via email.
Please see the audit report form for more details.
Thank you for your continued cooperation with the Pretreatment Program. Please do not hesitate to
contact me at 919-807-6383 [[e-mail]], Monti Hassan at 919-807-6314
[[e-mail]] or Dan Boss at 828-296-4500 [[e-mail]] if you have any
questions or concerns.
S_ incerely,
Deborah Gore
PERCS Supervisor
cc: Tim Wood, ORC
Mark Bentley, EIS
Central Files
ARO Files
PERCS Files

Background Information [Complete prior to audit; review Program Info Database Sheet(s)]
1. Control Authority (POTW) Name: Town of Andrews
2. Control Authority Representative(s): Mark Bentley & Tim Wood
3. Title(s): Lab ORC
4. Address of POTW:
Mailing PO Box 1201
City Andrews Zip Code 28901-0217
Phone Number 828-557-8630 Fax Number 828-321-4159 E-Mail Twood312(n�yahoo.com
5. Audit Date 04/18/2018
6. Last Inspection Date: 06/26/2017 Inspection Type: PCI
7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheets) ? Yes
If No, Explain.
8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? Yes
If Yes, Explain. Not related to industrial discharge. WWTP undergoing upgrades.
9. Is POTW under an Order That Includes Pretreatment Conditions? No
Order Type and Number: Are Milestone Dates Being Met? NA
Parameters Covered Under Order
ICIS Codins
Main Program Permit Number
INlclolol2 l0 18 to to
MM/DD/YY
10:....Current Number of.Significant Industrial.Users..(SIiJS)�.............................................................................................................................. 1
.11.:...Number of S1Us.with.No.lUP or with an ExpiredaUP?.............................................................................................................................. 0
12.. Number.of.S1Us Not Inspected,by.POTW.in Last Calendar Year? 0
...............................................................................................................................................................
13:.Number,of S1Us.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? 1
15. Number of SNs in SNC for. Reporting During Either.of Last 2SemrAnnual Periods? 0
16. Number of SlUs in SNC with Pretreatment Schedule? 0
....................................................................................................................................................................................................................................................................................................
17. Number of S1Us on Schedules?
................................................................................................................................................................................................................................................................................................... 0
18:....Current Number.of.Categorical Industrial Users..�CNs)?........................................................................................................................... 1
19. Number of C1Us in SNC? 1
14. Team in SNC for BOD 1st half of 2017. All of S1U data not in POTW files, so unsure if SNC for 2nc half.
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 supportine 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 A licable
Headworks Analysis (HWA)
9/7/15
No
12/4/15
No
9/30/20
Industrial Waste Survey (IWS)
5/8/17
No
6/14/17
No
4/30/20
Sewer Use Ordinance (SUO)
1/14/13
No
1/17/13
No
N/A
Enforcement Response Plan (ERP)
10/29/08
No
11/19/08
No
N/A
Long Term Monitoring Plan (LTMP)
12/17/08
No
12/18/08
No
N/A
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? No
22. If yes to #21, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? 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? NA
If yes, Explain.
24. Date of Last SUO Adoption by Local Council 2/12/2013
25. Have you had any problems interpreting or enforcing any part of the SUO? No
If yes, Explain.
Enforcement (Enforcement Response Plan-ERP)
26. Did you send a copy of the ERP to your industries? Not sure
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? No
28. List Industries under a Schedule or Order and Type of Schedule or Order
None
Resources
2�
>. Please Rate the Following: S=Satisfacto M=Mar final
Ratin
U=Unsatisfacto
Ex lanation, if Unsatisfactor
Personnel Available for Maintaining
POTW's Pretreatment Pro ram
S
Access to POTW Vehicles for
Sampling, Inspections, and
S
Emer encies
Access to Operable Sampling
multiple
Equipment
S
Availability of Funds if Needed for
Additional Sam lip and/or Anal sis
S
Reference Materials
S
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
S
Computer Equipment (Hardware and
Software)
S
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
Microsoft Office suite
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
No additional fees are assessed to the SIU
Public Perception/ Participation
32.Are there any local issues affecting the pretreatment program (e.g.. odor, plant closing, new or proposed plants)? No
33. Has any one from the public ever requested to review pretreatment program files? No
If yes, Explain procedure. If no, how would the request be addressed? Town understands that the files are public records
34. Has any industry ever requested that certain information remain confidential from the public? 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? Confirm information is confidential
35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? No
36. Is the public notified about changes in the SUO or Local Limits? Yes public agenda
37. Were all industries in SNC published in the last notice? N/A
Permitting (Industrial Waste Survey-IWS)
38. How does the POTW become aware of new or changed Users? Would come from Town Administrator
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?) cursory inspection; anticipated flow or pollutants, processes used
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate? Yes
If Yes, How any are there?
Please list each site and how it is permitted, if applicable. Cherokee County Landfill via pipe
41. Does the POTW accept waste by (mark if applicable) Truck
42. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples drawn,
manifests required) 1 septage hauler. Introduced slowly into system at point about a mile away from plant during
"off hours" to minimize impact to WWTP
43. How does the POTW allocate its loading to industries? Mark all that apply
❑ Uniform Limits El Historical Industry Need ❑ By Surcharge X Categorical Limits ❑Other
Explain Other:
44. Review POTW's copies of current allocation tables for each WWTP. Are there any over allocations? 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? No, not necessary at this time
If yes, what percentage of each parameter
47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) 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)
Industry POCs and potential to impact
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Based on risk, amount of flow, POCs
NC DWR Pretreatment Audit Form Revised: December 2016 Page 3

Permit Compliance
50. Does the POTW currently have or during the past year had any permits under adjudication? No
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. Compliance judgement had been performed by previous coordinator.
52. Does the POTW use the Division's model inspection form or equivalent? Yes
53. Were all S1Us evaluated for the need of a slug/spill control plan during their most recent inspections? Not sure
54. What criteria are used to determine if a slug/spill control plan is needed? Not sure
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate? Not sure
56. How does the POTW decide where the sample point for an SIU should be located?
After process but before mixing with other wastewaters
57. Has the POTW established a procedure to ensure that representative samples will be taken by the POTW or S1U each time?
(example: correct location; proper programming of sampler; clean equipment; swirling the sample bucket uniformly)
POTW: Yes SN: Not sure. SIU employs a contract lab to perform sampling and analysis
58. Who performs sample analysis for the POTW for Metals Environmental TestinE Solutions
Conventional Parameters EIS
Organics Environmental TestinE Solutions
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Standard COC procedures; record pH. temperature, requested analysis, preservatives, proper signatures. Separate COC
for Environmental Testing Solutions
Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis (HWA)
60a.Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? Yes
60b.Are Correct Detection Levels being used for all LTMP/STMP Monitoring? Yes
60c. Is LTMP/STMP Data Maintained in Table or Equivalent? NO
60d.
60e.
60f.
All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? YES
If NO to any above, list violations
Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP?
If yes, which ones? Eliminated: Arsenic molybdenum and selenium can be eliminated since the Town disposes of sludue to
the landfill.
61. Do you complete your own headworks analysis (HWA) ? No
If no, who completes your HWA? Mark Bentley, EIS Phone () --
62. Do you have plans to revise your HWA in the near future? No, next due in 2020
63. In general, what is the most limiting criteria of your HWA? Inhibition
64. Do you see any way to increase your loading in the future (Example: obtaining more land for sludge disposal)? ❑Yes ❑ No
Explain. WWTP currently undergoing upgrade which will improve plant efficiency and increase allowable loads
Summary
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment? '
Plant upgrade currently underway.
NC DWR Pretreatment Audit Form Revised: December 201(i Page 4

INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IIJP FILE REVIEWS AND 1 IU INSPECTION)
66. User Name 1. Team Industries 2.
67. lUP Number 0004
68. Does File Contain Current Permit? Yes
69. Permit Ex iration Date 9/21/18
70. Cate orical Standard A lied LE. 40 CFR, Etc. Or N/A 433
71. Does File Contain Permit Application Completed Within One Year Prior No
to Permit Issue Date?
3.
❑Yes ❑ No
�
�❑ Yes ❑ No�
�-�
❑Yes ❑ No
❑Yes ❑ No
72. Does File Contain Ins ection Com leted Within Last Calendar Year?
73. a. Does File Contain Slug/Spill Control Plan?
b. If No, is One Needed? See Ins ection Form from POTW
Yes
❑Yes
❑
No
❑Yes ❑
No
a. 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
Or anic Mana ement Plan TOMP ?
N/A
❑Yes❑No❑N/A
❑YespNo❑N/A
75. a. Does File Contain Original Permit Review Letter from Division?
b. All Issues Resolved?
a. No
b. N/A
a. ❑Yes ❑No
b.❑Yes❑No❑N/A
a. ❑Yes ❑No
b.❑Yes❑No❑N/A
76. During Most Recent Semi -Annual Period, Did POTW Complete its
Sam lin as Re uired b IUP, includin Flow?
Yes
❑Yes ❑ No
❑Yes ❑ No
77. Does File Contain POTW Sam lin Chain-Of-Custod Forms?
78. During Most Recent Semi -Annual Period, Did SILT Complete its
Sam lin as Re uired b IUP, includin Flow?
Yes
Yes
❑
No
�❑ Yes ❑
No
Yes
❑Yes❑No❑N/A
❑Yes❑No❑N/A
79. During Most Recent Semi -Annual Period, Did SILT submit all reports on
time?
Yes
❑Yes❑No❑N/A
❑Yes❑NopN/A
80a. For categorical Ns with Combined Wastestream Formula (CWF), does
file include rocess/dilution flows as Re uired b I[JP?
N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
80b. For categorical Ns with Production based limits, does file include
roduction rates and/or flows as Re uired b I[JP?
N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
81. During Most Recent Semi -Annual Period, Did POTW Identify All
Limits Non-Com liance from Both POTW and SIU Sam lin ?
No
❑Yes ❑ No
❑Yes,_ ❑ No
82. During Most Recent Semi -Annual Period, Did POTW Identify All
Re ortin Non-Com liance from SN Sam lin ?
N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
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
becomin aware of SIU limit violations in the POTW's sam lin of SN?
a. No
b. No
c. NIA
a.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
c.❑Yes❑No❑N/A
a.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
c.❑Yes❑No❑N/A
84. Durin Most Recent Semi -Annual Period, Was SN in SNC?
Yes
❑Yes
❑
No
❑Yes
❑ No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
S ecified in POTW's ERP OVs, Penalties, timin ,etc. ?
No
❑Yes❑No❑N/A
❑Yes❑No❑N/A
86. Does File Contain Penalt Assessment Notices?
87. Does File Contain Proof Of Penalt Collection?
88. a. Does File Contain Any Current Enforcement Orders?
b. Is SILT in Com liance with Order?
N/A
N/A
❑Yes❑No❑N/A
❑Yes❑No❑NIA
❑Yes❑No❑N/A
❑Yes❑No❑N/A
a. N/A
b. N/A
a.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
a.❑YespNo❑N/A
b.❑Yes❑No❑N/A
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
Information For You?
Yes
❑Yes ❑ No
❑Yes ❑ No
FILE REVIEW COMMENTS:
71. Does not have for the currently permit, but Team has submitted the application for renewal
74. Performs TTO sampling
78. Town did not have copy of sampling results, but Team had copy and will re -send to Town
79. Team did submit report, Town was unable to locate.
81. It appears that the SN is in SNC for BOD, TSS and cyanide during the first half of 2017. The data from the SN was not available during
the inspection so SNC for the second half of 2017 was not able to be determined. PAR forms and instructions sent via separate email.
83. Remind S1U of condition Part II, 2, b.
84. Results of 2°d half of 2017 compliance judgment not known as of today (4/26/18), but were SNC in first half of 2017.
85. NOVs for violations in first half of 2017 were not sent. Town will complete compliance judgement for 2017 and send appropriate NOVs.
Public Notice of SNs in SNC will be done.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 5

INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number
MM/DD/YY
1. Industry Inspected: Team Industries
2. Industry Address:
3. Type of Industry/Product: Steel and aluminum parts
4. Industry Contact: Title: Phone: Fax:
5. Does the POTW Use the Division Model Inspection Form or Equivalent? Yes
6. Did the POTW Contact Conduct the Following Parts of the Industrial Inspection Thoroughly?
Comments:
A. Initial Interview Yes
B. Plant Tour Yes
C. Pretreatment Tour Yes operator knowledEeable
D. Sampling Review Yes explained about SNC
E. Exit Interview Yes
Industrial Inspection Comments:
First inspection by Mark Bentley. Went over all questions. Discussed SNC status. Requested copy of spill plan
Audit SUMMARY AND COMMENTS:
Audit Comments: Due to sudden, unexpected passing of the previous pretreatment coordinator it is unclear if the proSram
element documents are in the files somewhere. Copies from PERCS files emailed to Mark and Tim (HWA, LTMP, SUO, ERP,
IWS1•
Requirements: Ensure Team Industries has a copy of the ERP. Request copy of spill/slus control plan. PAR, including
enforcement actions, due 6/25/2018.
Recommendations: Review monitoring plan and make revisions if necessary/desired.
NOD: No
NOV: No
QNCR: No
POTW RatinE:
Marginal
Audit COMPLETED BY: Deborah Gore &Dan Boss DATE: Auril 19, 2018
PERCS and Asheville Regional Office
NC DWR Pretreatment Audit Form Revised: December• 2016 Pale 6