NC0041696_Inspection_20190711

Town of Valdese
PO Box 339
Valdese, NC 28690
Deborah Gore
PERCS Unit Supervisor
NCDEQ / DWR
1617 Mail Service Center
Raleigh, NC 27699-1617
Dear Ms. Gore,
In response to your request for comments, from the June 10, 2019 audit report, please find the
below information:
• As pointed out during the audit, copies of our ERP will be provided to all SIU's later this
year, during annual inspections. Furthermore, discharge permit applications will be
shared because current SIU permits expire 12/31/2020 and will ask for their submittal
by June 2020.
• A permit modification has been submitted to PERCS (Vivien Zhong) for Valdese Water
Recycling. In it, pH self -monitoring frequency has been added and the BOD limit
increased, to which we believe will satisfy VWR needs and allow a greater compliance
possibility. In addition, VWR submitted a revised pollutant checklist to the Town on
June 14, 2019.
• Regarding our actions in response to SNC status of VWR, we have increased our tracking
efforts of information primarily (dates received/submitted) and timeliness of delivering
NOV's. Continued dialogue with Mr. Leonhardt and providing suggestions about the
timing of samples (early part of the month and quarter) and effective, timely
communication and submittal of self -monitoring data, will allow ample opportunity to
re -sample (if needed) and aid in compliance efforts.
VWR indicated during their inspection, within your presence, that they have ceased
accepting waste from 2-3 customers because of misinformation or contrary product
profile by those customers, potentially leading to VWR non-compliance of NH3 and Sb
(SNC). Since VWR no longer transacts with those customers, violations with those
particular pollutants of concern have improved.

Although VWR will be in SNC again (second consecutive 6 month period), this time will
be for BOD. Therefore, their permit has been modified and explanation has been
discussed in the above bullet point. As a reminder, the first SNC period came from one
(1) quarters' worth of data; not a full 6-month timeframe. Original permit issued
October 2018.
• We will continue to closely monitor all factors relating to the permit of Valdese Water
Recycling and should dilemmas continue, elevated response and enforcement will
result. As with any SIU within our program, we strive for a positive working relationship
and seek to educate, remedy and solve compliance situations in a cooperative fashion.
Our hope is to see VWR become a stable entity regarding compliance. Although their operation
differs in style versus other industrial users in the Pretreatment Program and have
greater/detailed analytical requirements (categorical), does not relieve them of their
responsibility to comply. Yes, we anticipate "blips", as with any other SIU and will react
accordingly at the time data is submitted, compiled and evaluated.
We thank you for your time, feedback and assistance during the audit process. Should there be
a need for anything additional on our part, please notify us.
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Pretreatment Coordinator WWTP Superintendent / ORC