NC0021709_Pretreatment Audit Report_20190312

'r
K" 1; 0,
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: Jefferson
2. Control Authority Representative(s): Tim Church
3. Title(s): WWTP ORC/Pretreatment Coordinator
4. Address of POTW:
Mailing PO Box 67
City Jefferson Zip Code 28640
Phone Number 336-246-2165 Fax Number E-Mail ieffwns(&centurvlink.net
5. Audit Date 3/12/2019
6. Last Inspection Date: 2/20/2018 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. Copper NPDES violations in October.
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
INICI01012 I1 17 to I9 1
MM/DD/YY
I03I12I19
10.
.................................................................
Current Number of Significant. Industrial Users(SIUs)?...............................................................................................
1
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
14.
....................................................................................................................................................................................................................................................................................................
Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi -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?
1
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 suDDortina documents and PERCS ADDroval Letter. and dates consistent with Program Info:
Program Element
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
8/3/2018
® Yes ❑ No
8/7/2018
® Yes ❑ No
4/1/2022
Industrial Waste Survey (IWS)
5/27/2014
® Yes ❑ No
8/4/2014
® Yes ❑ No
5/1/2019
Sewer Use Ordinance (SUO)
11/2/2012
® Yes ❑ No
11/7/2012
® Yes ❑ No
Enforcement Response Plan (ERP)
2/27/2003
® Yes ❑ No
4/7/2003
® Yes ❑ No
Short Term Monitoring Plan (STMP)
3/16/2018
® Yes ❑ No
3/28/2018
® 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 12/19/2012
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 Following: S=Satisfactory M=Mareinal 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
pH meter, portable sampler.
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: 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. POTW keeps hard copies and checks reports manually.
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Utility bills.
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 would allow requester to review files.
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? POTW would honor the request.
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? Water bills, zoning applications, tax records.
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?) Volume of flow if <2% of WWTP, MSDS, product produced, etc.
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
®Yes ❑No If Yes, How many are there? Landfill leachate on occasion.
Please list each site and how it is permitted, if applicable. Follow requirements in SUO.
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) Samples & permission, designated point. SUO also has requirements for a local permit and
keeping of manifests that POTW should follow.
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? Paper overallocations for cyanide and silver, hoping to resolve with IUP
modifications (categorical standards applied to CIU but they don't discharge it so their limits can be lowered).
45. If yes to #44, What is being done to address the over allocations? (short-term IUPs, HWA to be revised, pollutant study, etc.)
IUP modification should be completed by April 15, 2019.
46. Does the POTW keep pollutant loading in reserve for future growth / safety? ® Yes ❑ No
If yes, what percentage of each parameter 5-10%
47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) ® Yes ❑ No
If yes, Explain. Overallocations discussed in 44 & 45.
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)
Categorical standards, pollutants listed in application, POC if necessary. Note that POTW only has a single CIU currently.
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
PERCS guidance.
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? ❑ 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. POTW uses a worksheet, which he tries to check when data is
received.
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?
Look at volumes of organics on hand and judge whether these could cause issues at the plant if spilled.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Plan should have notification and clean up procedures. Checked during inspections.
56. How does the POTW decide where the sample point for an SILT should be located?
Sample for categorical waste only if such waste is categorically regulated; otherwise PERCS guidance.
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. ORC of West Jefferson samples for SIU. Tim
Church trusts that he is doing it correctly based on experience.
58. Who performs sample analysis for the POTW for Metals Water Ouality Labs
Conventional Parameters Water Ouality Labs
Organics Water Quality Labs
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Use provided CoC forms.
Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis (HWA)
60a.
60b.
60c.
60d.
60e.
60f.
Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑ NO
Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ® YES ❑ NO
Is LTMP/STMP Data Maintained in Table or Equivalent? ® YES ❑ NO Is Table Adequate? ® YES ❑ NO
All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? ® YES ❑ NO Division Inspector, verify yourself!
If NO to any above, list violations
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? Michael Whittenburg, McGill Associates 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 05 year expiration ❑Other
Explain.
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. Possible to obtain more land for sludge disposal.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 4

Summary
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
AEV's sister company in town may start using the same categorical process. Mr. Church wasn't sure whether they would
switch all of this process to the other location or if they would maintain two permits.
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION)
66. User Name
1. American Emergency Veh. 2.
3.
67. IUP Number
004
68. Does File Contain Current Permit?
® Yes
❑ No
❑ Yes ❑
I ❑ Yes ❑ No
69. Permit Expiration Date
7/31/2021
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
433.17
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 11
❑ 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 POTW)
b. [-]Yes [-]No
b. []Yes ❑No I
b. ❑Yes ❑No
74. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
®Yes❑No❑N/A
F
❑Yes❑No❑N/A
❑Yes❑No❑N/A
Organic Management Plan (TOMP)?
75. a. Does File Contain Original Permit Review Letter from Division?
®Yes []No
RoYesoNoON/A
a. []Yes❑No
a. ❑Yes []Nob.
All Issues Resolved?
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 11
❑ Yes ❑ No
❑ 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 by IUP, including Flow?
79. During Most Recent Semi -Annual Period, Did SIU submit all reports on
®Yes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
time?
80a. 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 IUP?
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 IUP?
81. During Most Recent Semi -Annual Period, Did POTW Identify All
Yes ® No
F
ElYes ❑ 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
Reporting_Non-Compliance from SIU Sampling?
83. a. Was POTW Notified by SIU (Within 24 Hours) of All Self-
a.mYes❑No❑N/A
a.❑Yes❑No❑N/A
a.❑Yes❑No❑NSA
Monitoring Violations?
b. Did Industry Resample and submit results to POTW within 30 Days?
b.❑YesmNo❑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
becoming aware of SIU limit violations in the POTW's sampling of SIU?
c.❑YesmNo❑N/A
c.❑Yes❑No❑N/A
c.❑Yes❑No❑N/A
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
❑
Yes
®
No 11
❑
Yes
❑
No 11
❑
Yes
❑
No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
❑Yes®No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
Specified in POTW's ERP (NOVs, Penalties, timing, etc.)?
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❑No❑N/A
❑Yes❑No❑N/A
88. a. Does File Contain Any Current Enforcement Orders?
a.❑Yes❑NomN/A
a.❑Yes❑No❑N/A
a.❑Yes❑No❑N/A
b. Is SIU in Compliance with Order?
b.❑Yes❑NomN/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:
Industry had some recent issues with low pH. We discussed potentially changing the sampling point for that parameter, or adding some pH
adjustment before discharge. The latter was recommended as this would also help protect the industry's storage and piping system.
In a recent email exchange, Tim Church said he recently determined that their SIU was in SNC for the first semiannual period of 2018.
However, Mr. Church had not sent any notices or required resampling for this as is required in the ERP. POTW's current ERP also sets a
14 day turn around time for identifying violations which Mr. Church has consistently exceeded.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 5

INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
INIC10 10 12 11 17 10 19 I 1031121191
1. Industry Inspected: American Emergency Vehicles
2. Industry Address: 165 American Way, Jefferson
3. Type of Industry/Product: Ambulances
4. Industry Contact: Mike Absher
Title:
Compliance Manager 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:
Audit SUMMARY AND COMMENTS:
Audit Comments:
Requirements: 1. Take action on violations as specified in the ERP. 2. Submit a modified IUP to address overallocations by April
15, 2019.
Recommendations: Update the ERP as discussed during the inspection. Current model ERP includes a 30 day time frame for
taking action on violations; POTW's current ERP uses the old 14 day time frame.
NOD: ❑ Yes ® No
NOV: ® Yes ❑ No
QNCR: ❑ Yes ® No
POTW Rating:
Satisfactory ❑ Marginal ® Unsatisfactory ❑
Docu Signed by:
Audit COMPLETED BY: �°''" 4` m tt''O' DATE: 3/12/2019
F10C7C2E5BB34D4...
Vivien Zhong, PERCS, and Paul DiMatteo, Winston-Salem Regional Office
NC DWR Pretreatment Audit Form Revised: December 2016 Page 6