NC0020451_Pretreatment Audit Report_20190312

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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: West Jefferson
2. Control Authority Representative(s): Brandon Patrick
3. Title(s): WWTP ORC/Pretreatment Coordinator
4. Address of POTW:
Mailing PO Box 490
City West Jefferson Zip Code 28694
Phone Number 336-246-3558 Fax Number E-Mail wwtp(&townofwi.com
5. Audit Date 3/12/2019
6. Last Inspection Date: 1/24/2017 Inspection Type: ® PCI ❑ Audit
7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s) ? ® Yes ❑ No
If No, Explain. Previous inspection noted to update ERP and ensure resampling completed within 30 days.
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 Io 14 Is I1 I
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?
0
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)?............................................................................................
0
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. 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)
2/6/2019
® Yes ❑ No
3/4/2019
® Yes ❑ No
4/1/2024
Industrial Waste Survey (IWS)
3/31/2014
® Yes ❑ No
6/23/2014
® Yes ❑ No
4/1/2019
Sewer Use Ordinance (SUO)
12/19/2012
® Yes ❑ No
1/10/2013
® Yes ❑ No
Enforcement Response Plan (ERP)
5/24/2017
® Yes ❑ No
5/26/2017
® Yes ❑ No
Short Term Monitoring Plan (STMP)
7/21/2014
® Yes ❑ No
8/21/2014
® Yes ❑ No
4/1/2019
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 2/4/2013
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
Composite sampler, pH meter.
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 currently relies on hard copies, though Mr. Patrick said he hoped to move to a digital system.
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Water 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 said they would let the person examine the 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? Mr. Patrick said he would talk to the town manager and town lawyer.
We discussed some procedures PERCS uses to handle confidential information.
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
Ordinances on website.
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? Through planning discussions.
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?) Survey forms, sampling if needed.
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
❑Yes ®No If Yes, How many are there?
Please list each site and how it is permitted, if applicable.
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) N/A
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? Silver and mercury — both seemed to be paper over allocations due to
differences in detection levels and uncontrollable loading.
45. If yes to #44, What is being done to address the over allocations? (short-term IUPs, HWA to be revised, pollutant study, etc.)
Use lower detection limits. Otherwise nothing, as both are due to uncontrollable loading.
46. Does the POTW keep pollutant loading in reserve for future growth / safety? ® Yes ❑ No
If yes, what percentage of each parameter N/A%
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)
Pollutants of concern.
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Based on potential to impact.
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. Mr. Patrick completes a compliance judgement worksheet when he
receives 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?
Potential for a spill to impact the plant.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
According to the requirements in the SUO.
56. How does the POTW decide where the sample point for an SILT should be located?
Just before entering the sewer system for local limits SIUs, categorical only for CIUs.
57. Has the POTW established a procedure to ensure that representative samples will be taken by the POTW or SILT 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. Tim Church @ Jefferson samples for SIU; trusts
That he is doing it properly based on his experience.
58. Who performs sample analysis for the POTW for Metals Water Ouality Labs
Conventional Parameters Water Ouality Labs
Organics Water Ouality 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: TP, Silver, due to no NPDES or SIU requirements 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.
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 obtainable if needed. Also planning to get a new belt press.
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
Town may be adding an industrial park — currently in very early planning stages.
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. Ashe County Cheese
2.
3.
67. IUP Number
0003
68. Does File Contain Current Permit?
® Yes ❑ No
❑ Yes ❑ No
[—]Yes ❑ No
69. Permit Expiration Date
6/30/2019
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
N/A
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 ❑
I ❑ 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❑NoON/A
F
❑Yes❑No❑N/A
❑Yes❑No❑N/A
Organic Management Plan (TOMP)?
1
75. a. Does File Contain Original Permit Review Letter from Division?
a. ®Yes []No
I
a. ❑Yes ❑No
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
FMTeT ❑
❑ Yes ❑ No
Sampling as Required by IUP, including Flow?
1
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
® Yes ❑ No
❑ Yes ❑ No 11
❑ Yes ❑ No
78. During Most Recent Semi -Annual Period, Did SIU Complete its
®Yes❑No❑N/A
F
❑Yes❑No❑N/A
❑Yes❑No❑N/A
1
Sam lin as Required b IUP, includin Flow?
1
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❑No®N/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
❑ 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 -Compliance from SIU Sampling?
83. a. Was POTW Notified by SIU (Within 24 Hours) of All Self-
amYes❑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 and obtain results within 30 days of
c.®Yes❑No❑N/A
becomingaware of SIU limit violations in the POTW's sampling of SIU?
c.❑Yes❑No❑N/A
c.❑Yes❑No❑N/A
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
❑
Yes
®
No
❑
Yes
❑
No
❑
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?
OYes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/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
® No
❑ Yes ❑ No
❑ Yes ❑ No
I[E]Yes
Information For You?
FILE REVIEW COMMENTS:
11/2018 sampling read pH of 2.28 at grab and 5.40 in composite sampler (likely read in composite sample due to temperature
probe also reading pH). However, no NOV was sent for the low pH of 2.28. Both NOVs that POTW sent last year were for BOD (1 in each
6 month period). The grab pH should have been used to judge compliance.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 5

INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
I N I C 1 0 10 12 10 14 15 11 I Io-31121191
1. Industry Inspected: Ashe County Cheese
2. Industry Address: 106 E. Main Street, West Jefferson
3. Type of Industry/Product: Cheese
4. Industry Contact: Title:
Phone: [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:
None.
Audit SUMMARY AND COMMENTS:
Audit Comments: Please see the file review comments noted Previously.
Requirements: _
Recommendations:
NOD: ❑ Yes ® No
NOV: ❑ Yes ® No
QNCR: ❑ Yes ® No
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory ❑
Docu Signed by:
Audit COMPLETED BY: DATE: 3/22/2019
Vivien Zh�ong,Z 'ft, and Paul DiMatteo, Winston-Salem Regional Office
NC DWR Pretreatment Audit Form Revised: December 2016 Page 6