NC0041696_PAR Inspection_20190610

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
[e-mail]
Chris Bortnick, Superintendent
Town of Valdese
P.0 Box 339
Valdese NC 28690
NORTH CAROLINA
Enviromnental QuaUty
June 10, 2019
SUBJECT: Pretreatment Audit ,Inspection & Pretreatment Annual Report
Town of Valdese
Permit No: NCO041696
Burke County
Dear Mr. Bortnick:
Enclosed please find a copy of the Pretreatment Audit Inspection form from the inspection conducted
on May 7, 2019. The Pretreatment Audit Inspection was conducted by Deborah Gore, PERCS Unit
Supervisor, and Linda Wiggs, Environmental Specialist. Mr. Chris Bortnick and Ms. Candace Cox were
present for the inspection and your 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.
Background
The Town of Valdese has (8) significant industrial users (SIU), two are considered categorical and is 3.5
MGD permitted facility.
Legal Authority
The Town receives wastewater from the towns of Rutherford College and Drexel. There are agreements
in place that allow the Town to perform industrial waste survey activities within those towns. To date
no SIUs have been identified.
North Carolina Department of Environmental Quality I Division of Water Resources
R E • IJ 512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1617
NOFMICAFKXM
919.707.9000

Enforcement Response Plan
Ensure that each SIU has a copy of the enforcement response plan next time inspections are conducted.
Industrial User Permit (IUP) File Review
The pretreatment audit file review included Valdese Water Recycling. The SIU was in significant non-
compliance during the second half of 2018 for titanium and ammonia. A public notice was placed in the
local paper as required.
In the future, document that SIUs have contacted you within 24 hours of becoming aware of a self -
monitoring violation and ensure that re -sampling occurs within 30 days (IUP condition Part II, 2, b).
Modify the Valdese Water Recycling permit to include a monitoring frequency for pH. Submit
modified permit to PERCS by July 12, 2019. Also, provide the pollutant checklist if available or
comment on when it will be completed (see Division letter dated 1/25/19)
Industrial Inspection
A thorough inspection was conducted at Valdese Water Recycling. All components of the inspection
form were covered. The waste manifests were reviewed. The information provided on the
manifests was inconsistent. A copy of special conditions for a CWT permitted by the City of
Winston-Salem is attached for your information.
Pretreatment Annual Report
The PAR noted that Valdese Water Recyclers was in significant non-compliance (SNC) during the
second half of 2018 for titanium and ammonia and that a public notice was placed. Please provide a
narrative detailing the actions taken by the Control Authority. Include the response from the SIU
describing the cause of the non-compliance, actions taken by the SIU to resolve the non-compliance
and the NOVs sent to the SIU documenting the non-compliance. A response to this item is due July
12, 2019.
Thank you for your continued cooperation with the Pretreatment Program. Please do not hesitate to
contact me at (919) 707--3624 [[e-mail]] or Linda Wiggs at 828-296-4500
[[e-mail]] if you have any questions or concerns.
Sincerely,
Deborah Gore, PERCS Supervisor
Division of Water Resources
Enclosures: audit form, example Special Conditions
cc: Candace Cox, via email
Central Files
ARO Files
PERCS Files

a NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT AUDIT REPORT
Water Resources
ENVIRONMENTAL QUALITY
Background Information jComplete prior to audit; review Program Info Database Sheet(s)]
1. Control Authority (POTW) Name: Town of Valdese
2. Control Authority Representative(s): Candace Cox / Chris Bortnick
3. Title(s): Pretreatment Coordinator / WWTP Superintendent
4. Address of POTW:
Mailing PO Box 339
City Valdese Zip Code 28690
Phone Number 828-879-2131 Fax Number 828-874-5915 E-Mail CCox(&—,valdesenc.sov
5. Audit Date 05/07/2019
6. Last Inspection Date: 08/28/2018 Inspection Type: PCI
7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s) ? Yes
Meridian removed sink. Program elements up-to-date.
8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? Yes
If Yes, Explain. pH violations in February and April. Unclear if industry related.
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 Coding
Main Program Permit Number
INIC1010I4 I1 16 19 I6 I
MM/DD/YY
I05I07I19I
_lo:.._Current.Number of Significant Industrial Users(SILTs)�............................................................................................................................. 8
11. Number of SIUs with No IUP, or with an Expired IUP?............................................................................................................................ 0
......................................................................................
12. Number of 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? 2
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)? VWR & By Design 2
19. Number of CIUs in SNC? VWR 1
14 . Bimbo on border for pH — purchased new equip and trained staff to use properly. 3 pH violations, 1 good last week.
VWR SNC for titanium, NH3: 2018.2 violations for BOD, NH3, Zn and Sb in 2019.1 (not SNC at this time).
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 sunnortine documents and PERCS Annroval Letter_ and dates consistent with Pmvram Tnfre
Program Element
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
5/2/18
Yes
5/30/18
Yes
8/1/2023
Industrial Waste Survey (IWS)
10/22/15
Yes
1/6/16
Yes
11/1/2020
Sewer Use Ordinance (SUO)
1/2/13
Yes
1/3/13
Yes
N/A
Enforcement Response Plan (ERP)
10/26/16
Yes
11/29/16
Yes
N/A
Long Term Monitoring Plan (LTMP)
12/6/18
Yes
12/12/18
Yes
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? Yes
If yes, Please list these towns and/or areas. Rutherford College, Drexel
22. If yes to #21, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? Yes
A copy, if not already submitted, should be sent to Division. Agreement in place that allows Valdese to include in IWS.
23. If yes to #21, Have you had any trouble working with these towns or districts? No
If yes, Explain.
24. Date of Last SUO Adoption by Local Council 11/5/2012
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? Unsure — will provide copies at inspection.
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
29. Please Rate the Following: S=Satisfactory M=Marginal U=Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
Access to POTW Vehicles for
Sampling, Inspections, and
Access to Operable Sampling
Equipment
Availability of Funds if Needed for
Additional Sampling and/or Analys
Reference Materials
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
Computer Equipment (Hardware and
Software)
-Rating
Explanation, if Unsatisfactory
S
S
S
S
S
S
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
Explain Yes or No. Excel spreadsheet. Data is entered as it is received
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Monthly fee based on flow rate to system
Public Percention/ Particination
32. Are there any local issues affecting the pretreatment program (e.g.. odor, plant closing, new or proposed plants)?
No. Nothing upcoming. VWR fairly new.
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? Requestor would have to set up appointment to come to
plant to review files.
34. Has any industry ever requested that certain information remain confidential from the public? No
If no how would the request be addressed? Information would be labeled Confidential.
35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? No. Usually only if
there is a problem. Sets up samplers on unannounced basis.
36. Is the public notified about changes in the SUO or Local Limits? Yes. On Council agenda.
37. Were all industries in SNC published in the last notice? Yes
Permitting (Industrial Waste Survey-IWS)_
38. How does the POTW become aware of new or changed Users? Planning Dept informs of new businesses; awareness of
sites; uses short form or long form as appropriate and Manufacturer's Guide to determine who to survey. -
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?) Based on nature of business, flow, SIC code
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
No, do not accept hauled wastewater.
41. Does the POTW accept waste by (mark if applicable) N/A
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 have been used for textiles. Historical Industry Need trying to go more to historical need in the
future. Categorical Limits as appropriate.
44. Review POTW's copies of current allocation tables for each WWTP. Are there any over allocations? No
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
If yes, what percentage of each parameter 10 %
47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) No
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)
A lot already established: Historical data, NPDES limited, nutrients are a big issue. Annually do all POCs
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
POTW does all monitoring on a quarterly basis, except VWR. Since new SIU, POTW 1/qtr and VWR 2/qtr.
NC DWR Pretreatment Audit Form Revised: December 2016 Paee 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. Enters data in spreadsheet, compares to permit limits, makes any
violations red. Reports are stamped with date received.
52. Does the POTW use the Division's model inspection form or equivalent? Yes
53. Were all SIUs evaluated for the need of a slug/spill control plan during their most recent inspections? Yes. Everyone has one.
54. What criteria are used to determine if a slug/spill control plan is needed?
Nature of waste, floor drains > where it is going, storage or production areas.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate? Cursory review
56. How does the POTW decide where the sample point for an SIU should be located?
Most have been established: not high traffic area (safety), accessible, captures all process flows.
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: composite sampler, use sample probe appropriate for the flow. Mix well, avoid cross contamination.
SIU: Yes: only 1 SIU does self -monitoring. They contract with Prism Labs.
58. Who performs sample analysis for the POTW for Metals Blue Ridge
Conventional Parameters In -House
Organics Blue Ridge
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Sample tech takes out sampler. Fills out with sample analysis, times, preservation, etc; appropriate signatures — sometimes
person collecting samples is same person receiving samples in lab. 2 Rivers does low level mercury — sent via UPS with
CoC properly completed. Merritech picks up chronic toxicity.
Long/Short Term Monitor' Plan STMP) and Headworks Analysis (WA)
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 Is Table Adequate? N/A
60d. All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? YES
60e. If NO to any above, list violations _
60f. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? NO
Added: Recently added CWT parameters (Co, Sb, Sn, Ti, Vn) 3/5years. Done 4/2019. Next one in 1/2020.
61. Do you complete your own headworks analysis (HWA) ? Yes
62. Do you have plans to revise your HWA in the near future? No, last approved 5/2018
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? Sludge Quality
64. Do you see any way to increase your loading in the future (Example: obtaining more land for sludge disposal)? No
Explain. Not necessary at this time.
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. Valdese Water Recycling,
LLC
2.
3.
67.
IUP Number
27
-711
68.
Does File Contain Current Permit?
Yes
❑ Yes ❑ No
❑Yes No
69.
Permit Expiration Date
12/31/2020
70.
Cate orical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
437.47
71.
Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
Yes
❑ Yes ❑ No
❑ Yes ❑ No
72.
Does File Contain Inspection Completed Within Last Calendar Year?
L Yes
❑ Yes ❑ No 11
❑ Yes ❑ No
73.
a. Does File Contain Slug/Spill Control Plan?
b. If No, is One Needed? See Inspection Form from POTW
a. No
b. Yes
a. ❑Yes ❑No
b. ❑Yes ❑No 11
a. ❑Yes ❑No
b. ❑Yes ❑No
74.
For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
Organic Management Plan (TOMP ?
N/A
❑Yes❑NoON/A
11
❑Yes❑NoON/A
75.
a. Does File Contain Original Permit Review Letter from Division?
b. All Issues Resolved?
a. Yes
b. No
a. []Yes ❑No
b.OYesONoON/A
a. []Yes []No
b.❑YesMo❑N/A
76.
During Most Recent Semi -Annual Period, Did POTW Complete its
Sampling as Required by IUP, includingFlow?
Yes ::]Fr�
ElNo
❑ Yes ❑ No
77.
Does File Contain POTW Sampling Chain -Of -Custody Forms?
Yes
❑ Yes ❑ No ❑ Yes ❑ No
78.
During Most Recent Semi -Annual Period, Did SIU Complete its
Sampling as Required by IUP, including Flow?
Yes
11
OYes❑NoON/A
❑YesONoON/A
79.
During Most Recent Semi -Annual Period, Did SIU submit all reports on
Yes
❑Yes❑No❑N/A
❑Yes❑No❑N/A
time?
80a. For categorical IUs with Combined Wastestream Formula (CWF), does
N/A
❑YesONoON/A
❑Yes❑No❑N/A
file includeprocess/dilution flows as Required by IUP?
80b. For categorical IUs with Production based limits, does file include
N/A
❑YesONoON/A
❑YesONo❑N/A
production rates and/or flows as Required by IUP?
81.
During Most Recent Semi -Annual Period, Did POTW Identify All
Yes
❑ Yes ❑ No
❑ Yes ❑ No
Limits Non -Compliance from Both POTW and SIU Sampling?
82.
During Most Recent Semi -Annual Period, Did POTW Identify All
N/A
❑Yes❑No❑N/A
OYes❑No❑N/A
R ortm , Non-CoM21iance from SIU Sampling?
83.
a. Was POTW Notified by SIU (Within 24 Hours) of All Self-
a. No
a.OYesONoON/A
a.OYesONoON/A
Monitoring Violations?
b. Did Industry Resample and submit results to POTW within 30 Days?
b. No
b.OYesONo❑N/A
b.OYesONoON/A
c. If applicable, did POTW resample and obtain results within 30 days of
becomingaware of SIU limit violations in the POTW's sampling of SIU?
c. N/A
c.OYesONo❑N/A
c.OYesONoON/A
84.
During Most Recent Semi -Annual Period, Was SIU in SNC?
Yes (2018.2)
❑ Yes
❑ No
❑ Yes ❑
No
85.
During Most Recent Semi -Annual Period, Was Enforcement Taken as
Yes
❑Yes❑NoO
❑YesONoON/A
Specified in POTW's ERP OVs, Penalties, timing, etc.)?
86.
Does File Contain Penalty Assessment Notices?
N/A
❑YesONo❑N/A ❑Yes❑NO❑N/A
87.
Does File Contain Proof Of Penalty Collection?
N/A
❑Yes❑NoON/A ❑Yes❑No❑N/A
88.
a. Does File Contain Any Current Enforcement Orders?
a. N/A
a.❑YesONo❑N/A
a.OYesONoON/A
b. Is SIU in Compliance with Order?
b. N/A
b.❑Yes❑No❑N/A
b.❑Yes❑Nn❑N/A
89.
Did POTW Representative Have Difficulty in Obtaining Any Requested
No
❑ Yes ❑ No
❑ Yes ❑ No
Information For You?
FILE REVIEW COMMENTS:
71. Signed 2016. IUP 2019. New facility; additional comments/updates included and initialed as recently as 10/2018.
72. Certified operator
73. has been requested (rec'd during inspection)
75. SIU must complete pollutant checklist when data is available.
NC DWR Pretreatment Audit Form Revised: December 2016 Pane 5

INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
INIClo 10 14 11 16 19 16 I 1051071191
1. Industry Inspected: Valdese Water Recy cling
2. Industry Address:
3. Type of Industry/Product: Centralized waste treater
4. Industry Contact: Derr Leonhardt 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 Will control plan rec'd. Reviewed manifests/acceptance rocedures
B. Plant Tour ❑ Yes Landfill leachate clients. Not runnine ever►• day.
C. Pretreatment Tour ❑ Yes SBRs — aeration and mixing. Chem ppct. Added mixer, aeration on 2 batch tanks.
Slud a solidification done off -site. Establishin on -site lab capabilities
D. Sampling Review ❑ Yes March violation due to not enoueh aeration. NH3 hi her than usual,• zot a better
screening method.
E. Exit Interview ❑ Yes
Industrial Inspection Comments:
Audit SUMMARY AND COMMENTS:
Audit Comments:
Requirements: Provide copies of ERP to SIUs at next inspection.
Make sure SIUs inform POTW within 24 hours of becoming aware of a self -monitoring violation and repeat samoline is done
within 30 da► s IIUP PART II, 2, bl.
Include a sampling free uencv for pH in the Valdese Water RecN-clingVWRpermit.
Have VWR complete pollutant checklist when data is available (review letter from Division dated 1/25/19).
Provide a narrative of actions taken by the POTW regardin , the status of SNC for VWR
Recommendations: Enter LTMP data into sureadsheets as received.
NOD: No
NOV: No
QNCR: No
POTW Rating:
Satisfactory X
Audit COMPLETED BY: Deborah Gore and Linda Wiggs DATE: May 7,201
Supervisor, PERCS, and Environmental Specialist H, Asheville Regional Office
NC DWR Pretreatment Audit Form Revised: December 2016 Page 6

HOH
Permit No.: 1998
Pipe #: 01
40 CFRP 437
C. PROHIBITIONS
HOH shall not accept the following pollutants for treatment: dioxins/furans, solvents,
pesticides/herbicides, radioactive waste, infectious waste, PCB's, tributyltin, or triclosan,
D. WASTE PROFME/MANIMT
As part of the required monthly report, HOH shall provide written documentation of all wastes received
and treated during the calendar month. This documentation shall include origin of waste, date received,
type and volume of waste, method of treatment, and method and date of disposal.
E. TREATMENT REQUIREMENTS
At a minimum, HOH shall follow the Treatment Procedures for the Organic Subcategory, Metals
Subcategory and Oils Subcategory as submitted by HOH in the CWT initial certification statement dated
May 21, 2002. Should HOH decide to modify any of these treatment procedures, written approval must
be obtained from the Industrial Waste Control Section prior to the initiation of said procedures.
F. ANNUAL CERTIFICATION STATEMENT
The permittee shall submit a written certification statement annually which certifies that HO.H is
operating its treatment systems to provide treatment as set forth in Section I above. This certification
statement must be on letterhead and signed by the responsible corporate officer as defined in 40 CFR
403.12(l). The certification statement is due January 311 of each calendar year.
G. ON -SITE COMPLIANCE PAPERWORK
All data and/or information which supports this permit shall be retained in the offices located at 1701
Vargrave Street. This paperwork must:
1. List and describe the subcategory wastes being accepted for treatment
2. List and describe the treatment systems in -place, modifications to the treatment systems and
the conditions which the systems are operated for the subcategories of wastes accepted for
treatment
3. Provide information and supporting data establishing that these treatment systems will
achieve equivalent treatment
4. Describe the procedures the permittee follows to ensure that the treatment systems are well
operated and maintained
5. Explain why the procedures the permittee has adopted will ensure the treatment systems are
well -operated and maintained.
H. SLUG/SPILL CONTROL PLAN
The permittee shall implement the approved Slug/Spill Control Plan on file with the City of Winston-
Salem. If the Slug/spill plan is modified or updated, a copy of the plan shall be submitted to the City
within 30 days of implementation.
17