NC0025534_Inspection_20190611

NC DWR Pretreatment Audit Form Revised: December 2016 Page 1

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT AUDIT REPORT

Background Information [Complete prior to audit; review Program Info Database Sheet(s)]
1. Control Authority (POTW) Name: Hendersonville WWTP
2. Control Authority Representative(s): Seth Goad, Scott Chovan
3. Title(s): Environmental Services Coordinator, Lab Manager
4. Address of POTW:
Mailing 305 Williams St
City Hendersonville Zip Code 28792
Phone Number 828-697-3057 Fax Number E-Mail [e-mail]
5. Audit Date 06/11/2019
6. Last Inspection Date: 09/04/2018 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 probl ems? Yes No
If Yes, Explain. 1 weekly BOD avg violation, 26% over the permit limit

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 MM/DD/YY
N C 0 0 2 5

5 3 4

06 11 19

10. Current Number of Significant Industrial Users (SIUs)? 3
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)? 2
19. Number of CIUs in SNC? 1

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NC DWR Pretreatment Audit Form Revised: December 2016 Page 2
20. PRETREATMENT PROGRAM ELEMENTS REVIEW- Review POTW files, verify POTW has copy of each Program
Element in their File, complete with all supporting documents and PERCS Approval Letter, and dates consistent with Progra m Info:
Program Element Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA) 5/16/2018 Yes No 6/28/2018 Yes No 3/31/2023
Industrial Waste Survey (IWS) 9/20/2018 Yes No 10/19/2018 Yes No 10/1/2023
Sewer Use Ordinance (SUO) 1/4/2013 Yes No 4/29/2013 Yes No
Enforcement Response Plan (ERP) 9/28/2016 Yes No 10/19/2016 Yes No
Long Term Monitoring Plan (LTMP) 9/28/2016 Yes No 10/19/2016 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.

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 12/06/2012

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

Resources

29. Please Rate the Following: S=Satisfactory M=Marginal 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
Emergencies

S M U

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

Computer Equipment (Hardware and
Software)

S M U

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NC DWR Pretreatment Audit Form Revised: December 2016 Page 3

30. Does the POTW have an adequate data management system to run the pretreatment program? Yes No
Explain Yes or No. Excel spreadsheets are used to manage data.

31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Surcharge data/costs.

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?

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 confi dential
from public. If no how would the request be addressed?

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? County permits, applications for sewer connections
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?) Conversation with User.

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) Each hauler is required to have a permit. Only waste from Henderson County is accepted.
Septage analysis is performed quarterly.

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.)

46. Does the POTW keep pollutant loading in reserve for future growth / safety? Yes No
If yes, what percentage of each parameter 50%

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)
By the type of industry, NPDES permit limits, and probable toxicity sources.

49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Historical data/violations.
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NC DWR Pretreatment Audit Form Revised: December 2016 Page 4

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, reporti ng
requirements, and permit conditions, as well as for SNC. Excel spreadsheets that use formulas.

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. They all have their own spill plans.

54. What criteria are used to determine if a slug/spill control plan is needed?
Determined by what is stored on site and in what quantities.

55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Determined by what is stored on site and in what quantities.

56. How does the POTW decide where the sample point for an SIU should be located?
The sampling point should be after the pretreatment process, but before any dilution.

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. In person training by Scott Chovan.

58. Who performs sample analysis for the POTW for Metals Pace Environmental
Conventional Parameters WWTP Lab
Organics Pace Environmental
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Two different forms are used, standard procedure.

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.

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.

Summary

65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that ma y affect pretreatment?
No
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NC DWR Pretreatment Audit Form Revised: December 2016 Page 5
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION)
66. User Name 1. Coats America Current Lighting Solutions 3. Kimberly Clark
67. IUP Number 003 001 002
68. Does File Contain Current Permit? Yes No Yes No Yes No
69. Permit Expiration Date 12/13/2023 12/31/2023 12/31/2023
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A 414.55 433.15 Na
71. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
Yes No Yes No Yes No
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?
b. If No, is One Needed? (See Inspection Form from POTW )
a. Yes No
b. Yes No
a. Yes No
b. Yes No
a. Yes No
b. Yes No
74. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
Organic Management Plan (TOMP)?
Yes No N/A Yes No N/A Yes No N/A
75. a. Does File Contain Original Permit Review Letter from Division?
b. All Issues Resolved?
a. Yes No
b.Yes No N/A
a. Yes No
b.Yes No N/A
a. Yes No
b.Yes No N/A
76. During Most Recent Semi-Annual Period, Did POTW Complete its
Sampling as Required by IUP, including Flow?
Yes No Yes No Yes No
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
Sampling as Required by IUP, including Flow?
Yes No N/A Yes No N/A Yes No N/A
79. During Most Recent Semi-Annual Period, Did SIU submit all reports on
time?
Yes No N/A Yes No N/A Yes No N/A
80a. For categorical IUs with Combined Wastestream Formula (CWF), does
file include process/dilution flows as Required by IUP?
Yes No N/A Yes No N/A Yes No N/A
80b. For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
Yes No N/A Yes No N/A Yes No N/A
81. During Most Recent Semi-Annual Period, Did POTW Identify All
Limits Non-Compliance from Both POTW and SIU Sampling?
Yes No Yes No

Yes No
X-NA
82. During Most Recent Semi-Annual Period, Did POTW Identify All
Reporting Non-Compliance from SIU Sampling?
Yes No N/A Yes No N/A Yes No N/A
83. a. Was POTW Notified by SIU (Within 24 Hours) of All Self-
Monitoring Violations?
b. Did Industry Resample and submit results to POTW within 30 Days?
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?
a.Yes No N/A

b.Yes No N/A

c.Yes No N/A
a.Yes No N/A

b.Yes No N/A

c.Yes No N/A
a.Yes No N/A

b.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
Specified in POTW's ERP (NOVs, Penalties, timing, etc.)?
Yes No N/A Yes No N/A Yes No N/A
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?
b. Is SIU in Compliance with Order?
a.Yes No N/A
b.Yes No N/A
a.Yes No N/A
b.Yes No N/A
a.Yes No N/A
b.Yes No N/A
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
Information For You?
Yes No Yes No Yes No
FILE REVIEW COMMENTS:

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NC DWR Pretreatment Audit Form Revised: December 2016 Page 6
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
N C 0 0 2 5 5

3 4 6 11 19

1. Industry Inspected: Coats America
2. Industry Address: 1710 Brevard Rd, Hendersonville NC
3. Type of Industry/Product: Different types of thread
4. Industry Contact: Danny Fulcher Title: Maintenance Mngr 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:

This facility is having difficulty getting an accurate flow measurement when they take composite samples. The draw tube for
the sampler collects rags in the effluent channel and backs up the channel. This results in a falsely high flow reading from the
transducer. The facility would like to replace the sampler setup, but they have not yet found a contractor able and available to
do the work.

Audit SUMMARY AND COMMENTS:
Audit Comments: Mr. Goad has only been in this pretreatment position for 4 months and so it was understandable that he had
some difficulty answering all the audit questions and locating some documents.
Required Actions: 1. Send the Enforcement Response Plan to all your industries by 7/19/2019. 2. Send an ownership change
IUP modification for GE Lighting to Vivien Zhong by 7/19/2019. 3. Update your LTMP to reevaluate the ammonia detection
level and SIU sampling frequency, then send it to Vivien Zhong for approval by 7/19/2019. 4. Request a copy the TOMP from
GE Lighting. 5. Send GE Lighting an NOV for their March 2018 sample by 7/19/2019. 6. Request a copy of the SSCP from
Kimberly-Clark.
Recommendations:

NOD: Yes No
NOV: Yes No
QNCR: Yes No

POTW Rating:
Satisfactory Marginal Unsatisfactory

Audit COMPLETED BY: Daniel Boss DATE: 06/11/2019
PERCS and Asheville Regional Office
DocuSign Envelope ID: 26617FFB-CED0-4CA3-9791-CDB46E8AD4C3