NC0020621_Pretreatment Audit Report_20190311

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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: Boone
2. Control Authority Representative(s): Karen Reece
3. Title(s): Pretreatment Coordinator
4. Address of POTW:
Mailing P.O. Drawer 192
City Boone Zip Code 28607
Phone Number 828-268-6272 Fax Number E-Mail karen.reece(&townofboone.net
5. Audit Date 3/11/2019
6. Last Inspection Date: 4/9/2018 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.
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 1016 12 I1 I
MM/DD/YY
I03 I11 I19
10.
.................................................................
Current Number of Significant Industrial Users(SIUs)?...............................................................................................
2
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?
1
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. 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)
5/1/2017
® Yes ❑ No
10/26/2017
® Yes ❑ No
10/1/2020
Industrial Waste Survey (IWS)
2/12/2019
® Yes ❑ No
3/1/2019
® Yes ❑ No
4/1/2024
Sewer Use Ordinance (SUO)
11/6/2012
® Yes ❑ No
11/7/2012
® Yes ❑ No
Enforcement Response Plan (ERP)
2/22/2013
® Yes ❑ No
5/13/2013
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
8/29/2017
® Yes ❑ No
9/19/2017
® 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 12/13/2013
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
Portable ISCO Samplers
Equipment
®S ❑M ❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
®S ❑M ❑U
Reference Materials
Standard methods, materials available online
®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. They enter data into a spreadsheet.
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Regular utility bills and fines when issued. No 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. New water intake/capacity upgrade at WTP. Anticipate more flow/growth from expansion.
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? Goes through town clerk, then sent to POTW.
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 keeps any requested information, except effluent data,
confidential. Confidential information is locked in a folder.
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? Meter connection reports, water use reports, regular
planning reports.
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?) Professional judgement — send short forms to manufacturers.
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. They're sampled quarterly and have a letter of permission.
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) Designated discharge point, manifests, sampling, camera surveillance.
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 #44, What is being done to address the over allocations? (short-term IUPs, HWA to be revised, pollutant study, etc.)
N/A
46. Does the POTW keep pollutant loading in reserve for future growth / safety? ® Yes ❑ No
If yes, what percentage of each parameter N/A%
Try to keep flow and conventional pollutants about equal.
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)
Monitor POCs annually, then decide if there's anything that might adversely affect the plant.
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.
Flow volume/pattern, potential for impact, how much MAHL it's using, controls.
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. Look at monthly reports as they come in, send acknowledgement
letter with compliance sampling, follow ERP.
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. Both have a plan.
54. What criteria are used to determine if a slug/spill control plan is needed?
Potential for spills and what can be spilled.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
State checklist, make sure any specific concerns are included.
56. How does the POTW decide where the sample point for an SILT should be located?
Try to get only regulated wastewater for CIUs; for others try to get a point representative of the entire discharge.
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. Discuss sampling at inspections. Hospitality Mints
uses a contract lab.
58. Who performs sample analysis for the POTW for Metals R&A
Conventional Parameters POTW except nutrients. Nutrients R&A
Organics R&A
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Chain of custody forms, locking of samples, etc.
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? Phone ( i --
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. NPDES permit renewal.
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.
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?
May update ERP.
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION)
66. User Name
1. Hospitality Mints 2. Charleston Forge IF
3.
67. IUP Number
0003
0004
68. Does File Contain Current Permit?
® Yes ❑ No
® Yes ❑
I ❑ Yes ❑ No
69. Permit Expiration Date
5/31/2023
12/31/2021
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
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
® 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❑NoEN/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❑NomN/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
® 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
11
Sampling as Required by IUP, including Flow?
79. During Most Recent Semi -Annual Period, Did SIU submit all reports on
OYesONoO
FE77ETooN/A
❑Yes❑No❑N/A
time?
80a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑NoEN/A
❑Yes❑NoEN/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❑NoEN/A
❑Yes❑NoEN/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
EYes❑No❑N/A
EYes❑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.❑Yes❑NomN/A
b.❑Yes❑NomN/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.❑Yes❑NomN/A
c.mYes❑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
EYes❑No❑N/A
EYes❑No❑N/A
❑Yes❑No❑N/A
Specified in POTW's ERP (NOVs, Penalties, timing, etc.)?
86. Does File Contain Penalty Assessment Notices?
EYes❑No❑N/A
❑Yes❑NoEN/A
❑Yes❑No❑N/A
87. Does File Contain Proof Of Penalty Collection?
❑YesENo❑N/A
❑Yes❑NoEN/A
❑Yes❑No❑N/A
88. a. Does File Contain Any Current Enforcement Orders?
a.❑Yes❑NomN/A
a.❑Yes❑NomN/A
a.❑Yes❑No❑N/A
b. Is SIU in Compliance with Order?
b.❑Yes❑NomN/A
b.❑Yes❑NomN/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:
Charleston Forge is a batch discharger, so if their sampling results in a violation the POTW requires them to take it somewhere else. If
POTW sampling is in violation then they'll do resampling.
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 16 12 11 I 103111 1191
1. Industry Inspected: Charleston Forge
2. Industry Address: 251 Industrial Park Drive, Boone
3. Type of Industry/Product: Metal Furniture
4. Industry Contact: David Kiker Title: Plant Manager 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: Well run program.
Requirements: None.
Recommendations: None.
NOD: ❑ Yes ® No
NOV: ❑ Yes ® No
QNCR: ❑ Yes ® No
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory ❑
/D�ocuSigned by:
Audit COMPLETED BY: lo`'M°=`O- DATE: 3/11/2019
F=7UE5BB34D4...
Vivien Zhong, PERCS, and Paul DiMatteo, Winston-Salem Regional Office
NC DWR Pretreatment Audit Form Revised: December 2016 Page 6