NC0020338_Inspection_20190410

ROY COOPER
Governor
NCHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
Mr. Grant Trivette
Town of Yadkinville
P.O. Box 816
Yadkinville, North Carolina 27055
NORTH CAROLINA
Environmental Quality
April 10, 2019
SUBJECT: Pretreatment Audit Inspection (PAI)
Town of Yadkinville
NPDES# NCO020338
Yadkin County
Dear Mr. Trivette:
RECEIVE;DIDENR/DWR
APR 2 3 2019
Water Rezourcez
ftrmiit,inq Section
On March 20, 2019 a Pretreatment Audit Inspection (PAI) was performed by Jim Gonsiewski of
the Winston-Salem Regional office and Monti Hassan of the Raleigh Central office. Mr. Grant
Trivette, operator in responsible charge and pretreatment coordinator for the Town of Yadkinville
was present. The purpose of this inspection was to determine the effectiveness of the pretreatment
program, which included: a detailed file review, review of the POTW plant performance, sampling,
and compliance judgement program, adherence to the enforcement response plan (ERP), and
observing an industrial user inspection. Additionally, an inspection of the Unifi #2 facility was
conducted in conjunction with an inspection by the Town of Yadkinville.
Background
This is a 2.5 MGD permitted facility.. The City has four (4) Significant Industrial Users and one
(1) Categorical Industrial User regulated per CFR 433.
Pretreatment Program Element Review
The Headworks Analysis (HWA) renewal was submitted on August 18, 2017. The HWA was
approved on October 31, 2017. The next HWA is due on September 1, 2022.
The last Industrial Waste Survey (IWS) was submitted on January 11, 2017. The IWS was
approved on April 7, 2017. The next IWS is due on January 31, 2022.
The Sewer Use Ordinance (SUO) was approved on January 2, 2012.
The Enforcement Response Plan (ERP) was approved on January 19, 2010.
b E Q North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1 450 Hanes Mill Road Suite 3001 Winston-Salem. North Carolina 27105
voanacu+ouaa
336.776.9800

LTMP File Review
The Long Term Monitoring Plan (LTMP) was approved on March 16, 2016 and is being conducted
at the proper locations and frequencies.
Industrial User Permit (IUP) File Review
A review of the file for Unifi #2 (#0002) revealed that the monitoring data was well organized and
compliant.
A review of the file for Austin (#0006) revealed that the monitoring data was well organized and
compliant.
A review of the file for B&G Food Snacks Inc. (40004) revealed that the monitoring data was well
organized and compliant.
The slug control plans for Unifi #2 (#0002) was in good order.
The slug control plans for Austin (#0006) was in' good order.
The slug control plans for B&G Food Snacks, Inc. (#0004) was in good order.
Action Items
No other action items were noted.
The pretreatment program is considered satisfactory. Mr. Trivette maintains an excellent program.
If you have any questions please contact Jim Gonsiewski or me at [phone].
Sincerely,
oocusgnea by:CLoti T 15.2"
145B49m5C84EA..
Lon T. Snider
Assistant Regional' Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
cc: P. M- ni — W-wj aW
Central Files
WSRO Files

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 Yadkinville
2. Control Authority Representative(s): Grant Trivette
3. Title(s): WWTP ORC/Pretreatment Coordinator
4. Address of POTW:
Mailing P.O. Box 816
City Yadkinville, NC Zip Code 27055
Phone Number 336-679-2184 Fax Number 336-677-1199 E-Mail Strivettenn,yadkinville.ore
5. Audit Date 03/20/2019
6.• Last Inspection Date: 02/26/2019 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.
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
INIC101012 In I3 13 I8 1
MM/DD/YY
103 120119I
10:...Cu. Number...............of........................ .
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
.....................................................................................................................................................
13. Number of.SIUs Not Sampled by. POTW in Last Calendar Year? 0
..........................................................................................................................................................
ring of Last 2 Semi-
14. Number of SIUs in SNC for Limits Violations DuEither Annual Periods? 1
........................................................................................................................................................................................................................................................................................
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
.............................................. :....................................................................................... ....................................................................................................... ...........................................
18. Current Number of Categorical Industrial Users(CIUs)....................................................................................... 1
19. Number of CIUs in SNC? 0
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_ cmmnlete with all cnnnnrtino rdnnnments anrd PF.R("R Annrnval T.etter And rlates ennsistent with Prnaram Tnfn-
Program Element
Last Submittal
Date In file? -
Last Approval
Date In file
Date Negt Due,
If Applicable
Headworks Analysis (HWA)
08/18/2017
® Yes ❑ No
10/31/2017
® Yes ❑ No
09/01/2022
Industrial Waste Survey (IWS)
01/11/2017
® Yes ❑ No
04/07/2017
® Yes ❑ No
01/31/2022
Sewer Use Ordinance (SUO)
12/02/2011
® Yes ❑ No
01/02/2012
® Yes ❑ No
Enforcement Response Plan (ERP)
01/13/2010
® Yes ❑ No
01/19/2010
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
03/16/2016
® Yes ❑ No
03/16/2016 ,
® 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. The county is tied into the collection system and the county
reimburses the town for the maintenance cost. (Two lines)
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. Copy sent via email 3/22/2019.
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 01/ 09 / 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=Marainal 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
E
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. Data monitoring for tracking and compliance entered at POTW.
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Charge back lab costs, sampling costs, personnel time costs, permit renewal fees, permit fees.
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? POTW personnel go before the city board.
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? Check with the SIU on how much, if any, information can be
released.
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? Town manager will notify POTW.
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
SILT?) The POTW will take the short form to the user, then the user will fill out the long form if necessary.
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
®Yes ❑No If Yes, How many are there? One
Please list each site and how it is permitted, if applicable. Lydall, a general local permit that can pump up the 10,000
gpd.
41. Does the POTW accept waste by (mark if applicable) ❑ Truck ®Dedicated Pipe ❑ NA The facility does not
normally accept hauled waste.
42. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples drawn,
manifests required) Septic haulers have a specific area on the plant site to dispose of waste each time. Haulers fill
out manifests and submit them to the POTW. Haulers"are monitored entering and leaving the facility.
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 944, What is being done to address the over allocations? (short-term IUDs, 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. BOD 55.3%, Flow 61.2%, TSS 79%, Ammonia 80.6%, Arsenic 59.5%, Cadmium
68.8%, Chromium 88.3%, Copper 50.9%, Cyanide 64.4%, Lead 57.1%, Mercury 94.9%, Molybdenum 85.8%, Nickel
48.3%, Selenium 66.3%, Silver 99.1 Zinc 21.5%.
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 data, allocation limits.
Sludge is a major restrictor. _
NC DWR Pretreatment Audit Form Revised: December 2016 Page 3

49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Historical data, initial testing.
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. Historical calculation of data.
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?
Possible POC on site and flow to POTW.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate? SDS contact information and
training if required. Possible impact to the POTW.
56. How does the POTW decide where the sample point for an SIU should be located? At the end of the process at the SIU.
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. Observation of the industry collecting samples.
58. Who performs sample analysis for the POTW for Metals Pace Analytical
Conventional Parameters POTW
Organics Pace Analytical
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
The Chains of Custody (COCs) are filled out each sample day and relinquished to the lab.
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? 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. Increased acreage.
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. More land on which to land apply.
Summary
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: December 2016 Page 4

INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION)
66. User Name
1. Unifi #2 2. Austin
3. B&G Food Snacks, Inc.
67. IUP Number
0002
IF0006
0004
68. Does File Contain Current Permit?
® Yes ❑ No
® Yes ❑ No
11 ®Yes ❑ No
69. Permit Expiration Date
03/31/2024
03/31/2024
05/31/2020
70. Categorical Standard Applied .E. 40 CFR, Etc. Or N/A
---
433
---
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
11 ® 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 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❑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 E]Nc,7
I 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?
I ® Yes ❑ No
11 ® Yes ❑ Rol
® 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
Sampling as Required b IUP, includingFlow?
79. During Most Recent Semi -Annual Period, Did SIU submit all reports on
®Yes❑No❑N/A
®Yes❑No❑N/A
OYes❑No❑N/A
time?
80a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑NoON/A
. file includeprocess/dilution flows as Required by JUP?
80b. For categorical IUs with Production based limits, does file include
❑Yes❑NoON/A
❑Yes❑No®N/A
❑Yes❑No®N/A
production rates and/or flows as Required by lUP?
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/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
aaYes❑NopN/A
a.❑YesONo®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
becomingaware of SIU limit violations. in the POTW's sam lin of SIU?
c.❑Yes❑No®N/A
c.❑Yes❑No®N/A
c.❑Yes❑No®N/A
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
I
❑ Yes
® No
❑ Yes ® No 11
❑ Yes ® No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
❑Yes❑No®N/A
❑Yes❑No ON/A
❑Yes❑No®N/A
Specified in POTW's ERP (NOVs, Penalties, timing, etc.)?
11
86. Does File Contain Penalty Assessment Notices?
®Yes❑No❑N/A
❑Yes❑No®N/A
❑Yes❑No®N/A
87. Does File Contain Proof Of Penalty Collection?
®Yes❑No❑N/A
❑Yes❑NoON/A
❑Yes❑NoON/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?
11
FILE REVIEW COMMENTS: Well organized file. ORC is very proactive with the SIUs.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 5

INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
INICIO IO 17 10 13 13 IR I I'03I20I19I
1. Industry Inspected: Unifi IUP #002 (Plant 2).
2. Industry Address: 601 East Main Street Yadkinville, NC 27055
3. Type of Industry/Product: Fabric/paper for the automotive industry.
4. Industry Contact: Lisa Haynes Title: Environmental Manager Phone: [phone] Fax: [phone]
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 N/A
E. Exit Interview ® Yes ❑ No
Industrial Inspection Comments:
Water use is approximately 10,000'to 20,000 gpd. Any spills in the manufacturing area are cleaned up. The facility is clean and
very well 'run. 10 to 15 individuals work at the facility in three shifts. The facility produces fabric sheets for the automotive
industry by wrapping and beaming. In addition to Ms. Haynes, Richard Reavis (Site Coordinator) and Tom Sawyer
(Maintenance Supervisor) were present for the inspection.
Audit SUMMARY AND COMMENTS:
Audit Comments: Mr. Trivette runs an excellent pretreatment program. His interaction with the SIUs helps the operation run
smoothly.
Requirements:
Recommendations:
NOD: ❑ Yes ® No
NOV: ❑ Yes ® No
QNCR: ❑ Yes ® No
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory ❑
Dmuftned by:
Audit COMPLETED BY: DATE: 04/10/2019
Monti Has 9,9fffif-Winston-Salem Regional Office
NC DWR Pretreatment Audit Form Revised: December 2016 . Page 6