NC0024252_NOV-2022-PC-0016 PCI_20220531

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
CERTIFIED MAIL#: 7018 3090 0001 2319 0918
RETURN RECEIPT REQUESTED:
Brian Bradshaw
City of Conover
Post Office Box 549
Conover, North Carolina 28613
SUBJECT: Notice of Violation
Pretreatment Compliance Inspection
City of Conover
NPDES Permit No. NC0024252
Catawba County
Tracking #: NOV-2022-PC-0016
Dear Mr. Bradshaw:
NORTH CAROLINA
Environmental Quality
May 31, 2022
Enclosed is a copy of the Pretreatment Compliance Inspection (PCI) Report for the inspection of the City of Conover's
Industrial Pretreatment Program on January 11, 2022, by Mr. Wes Bell of this Office. Please advise the Pretreatment staff of
our findings by forwarding a copy of the enclosed report.
This report is being issued as a Notice of Violation (NOV) due to the City's failures to initiate enforcement according to
the Division -approved Enforcement Response Plan (ERP) and provide records required under the Division -approved Industrial
Pretreatment Program. These failures are violations of North Carolina General Statute (G.S.) 143-215.1, 15A North Carolina
Administrative Code (NCAC) 2H .0900 and subject NPDES Permit. Specifically, the City did not initiate enforcement on
Engineered Controls International's (ECI) failure to submit the TTO Certification during the second half of 2021 (by December
7, 2021 per IUP). In addition, the City failed to provide the permit application (ECI), slug spill control plan (Hickory
Springs), and Division approval letters for the ERP and ECI's IUP. The City's failure to maintain all required records was
noted in the previous PCI performed on June 23, 2021. Please be advised that in accordance with G.S. 143-215.6A, a civil
penalty assessment of not more than twenty-five thousand dollars ($25,000.00), or twenty-five thousand dollars ($25,000.00)
per day when the violation is of a continuing nature, may be assessed against any person who violates or fails to act in
accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S. 143-215.1.
It is requested that a written response be submitted to this Office by June 21, 2022, addressing the City's actions to
address all violations. In addition, the City must initiate enforcement to ECI for the failure to submit the TTO Certification by
June 10, 2022. In responding, please address your comments to the attention of Mr. Bell. The response should also include a
copy of the City's enforcement action to ECI.
D_E
o,.mworkt G.ed o �
North Carolina Department of Environmental Quality I Division of Water Resources
Mooresville Regional Office 1610 East Center Avenue. Suite 301 1 Mooresville. North Carolina 28115
704.663.1699

Should you have any questions concerning this report, please do not hesitate to contact Mr. Bell at [phone] or at
[e-mail].
Enclosure:
Inspection Report
Cc: NPDES Program Files - Laserfiche
Sincerely,
DocuSigned by:
A14CC681 AF27425...
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
North Carolina Department of Environmental Quality I Division of Water Resources
Mooresville Regional Office 1610 East Center Avenue. Suite 301 1 Mooresville. North Carolina 28115
704.663.1699

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
BACKGROUND INFORMATION
1. Control Authority (POTW) Name: City of Conover
2. Control Authority Representative(s): Eric Williams
3. Title(s): WWTP ORC/Pretreatment Coordinator
4. Last Inspection Date: 6/23/21 Inspection Type: ® PCI ❑ Audit
5. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? ® YES ❑ NO
6. Is POTW under an Order That Includes Pretreatment Conditions? ❑ YES ® NO
Order Type, Number, Parameters: Are Milestone Dates Being Met? ❑ YES ❑ NO ® NA
ICIS CODING
Main Program Permit Number
NC0024252
MM/DD/YY
01/11/22
7. Current Number Of Significant Industrial Users (SIUs)?
2
8. Number of SIUs With No IUP, or With an Expired IUP?
0
9. Number of SIUs Not Inspected By POTW in the Last Calendar Year?
0
10. Number of SIUs Not Sampled By POTW in the Last Calendar Year?
0
11. Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi -Annual Periods?
0
12. Number of SIUs in SNC For Reporting During Either of the Last 2 Semi -Annual Periods?
0
13. Number of SIUs in SNC with Pretreatment Schedule?
0
14. Number of SIUs on Schedules?
0
15. Current Number Of Categorical Industrial Users (CIUs)?
2
16. Number of CIUs in SNC?
0
POTW INTERVIEW
17. Since the Last PCI, has the POTW had any NPDES Limits Violations?
If Yes, What are the Parameters and How are these Problems Being Addressed?
18. Since the Last PCI, has the POTW had any Problems Related to an Industrial
Discharge (Interference, Pass -Through, Blockage, Citizens' Complaints, Increased
Sludge Production, Etc.)?
If Yes, How are these Problems Being Addressed?
19. Which Industries have been in SNC for Limits or Reporting during
either of the Last 2 Semi -Annual Periods? Not Been Published for
Public Notice?(May refer to PAR if Excessive SIUs in SNC)
SNC for
SNC for
Not Pul
20. Which Industries are on Compliance Schedules or Orders? For all SIUs on an
Order, Has a Signed Copy of the Order been sent to the Division?
21. Are Any Permits Or Civil Penalties Currently Under Adjudication? If Yes, Which
Ones?
/1 YES ❑ NO; effluent pH
minimum not reached —
10/5/2021.
/1 YES ❑ NO
See Comments Section
Limits: N/A
Reporting: N/A
)lished: N/A
N/A
❑ YES /1 NO
LTMP/STMP FILE REVIEW: Not Applicable
22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ❑ YES
23. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ❑ YES ❑ NO
24. Is LTMP/STMP Data Maintained in a Table or Equivalent? ❑ YES ❑ NO Is Table Adequate? ❑ YES ❑ NO
25. All LTMP/STMP effluent data reported on Discharge Monitoring Report? ❑ YES ❑ NO
26. If NO to 23 - 26, list violations:
27. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ❑ NO
❑ NO
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1

28. PRETREATMENT PROGRAM ELEMENTS REVIEW:
Program Element
Last Submittal Received
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
N/A
❑ Yes ❑ No
N/A
❑ Yes ❑ No
N/A
Industrial Waste Survey (IWS)
1/24/18
/1 Yes ❑ No
3/9/18
a Yes ❑ No
10/1/22
Sewer Use Ordinance (SUO)
1/15/13
a Yes ❑ No
4/2/13
❑ Yes /1 No
Enforcement Response Plan (ERP)
7/2/15
❑ Yes ►1 No
8/19/15
❑ Yes /1 No
Long Term Monitoring Plan (LTMP)
N/A
❑ Yes ❑ No
N/A
❑ Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW
29. User Name II
1. Hickory Springs 2. Engineered Controls Int.
3.
30. IUP Number
101HS
101J
31. Does File Contain Current Permit?
/1 Yes ❑ No
/1 Yes ❑ No
❑ Yes ❑ No
32. Permit Expiration Date
11/13/22
5/1/23
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
433.17
433.17
34. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
/1 Yes ❑ No
❑ Yes /1 No
❑ Yes ❑ No
35. Does File Contain an Inspection Completed Within Last Calendar Year?
Al Yes ❑ No
/1 Yes ❑ No
❑ Yes ❑ No
36. a. Does the File Contain a Slug/Spill Control Plan?
b. If No, is One Needed? (See Inspection Form from POTW)
a. ■Yes eNo
b. Yes ■No
a. Yes •No
b. •Yes ■No
a. •Yes ■No
b. •Yes ■No
37. 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
38. a. Does File Contain Original Permit Review Letter from the Division?
b. All Issues Resolved?
a. Yes ■No
b.❑Yes❑No®N/A
a. •Yes VNo
b.❑Yes❑No❑N/A
a. •Yes ■No
b.❑Yes❑No❑N/A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
its Sampling as Required by IUP, including flow?
Al Yes ❑ No
/1 Yes ❑ No
❑ Yes ❑ No
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
/1 Yes ❑ NoJ
/1 Yes ❑ No
❑ Yes ❑ No
41a. During the Most Recent Semi -Annual Period, Did the SIU Complete its
Sampling as Required by IUP, including flow?
® Yes ❑No❑N/A
®Yes❑No❑N/A
❑Yes❑No❑N/A
41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports
on time?
❑Yes®No❑N/A
❑Yes®No❑N/A
❑Yes❑No❑N/A
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
file include process/dilution flows as Required by IUP?
❑Yes❑No®N/A
❑Yes❑NoNN/A
❑Yes❑No❑N/A
42b. For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
❑YesDNo®N/A
❑Yes❑NoON/A
❑Yes❑No❑N/A
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Limits Non -Compliance from Both POTW and SIU Sampling?
■ Yes •NoLNA
❑Yes❑NoNN/A
❑Yes❑No❑N/A
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Reporting Non -Compliance from SIU Sampling?
®Yes❑No❑N/A
❑Yes®No❑N/A
❑Yes❑No❑N/A
44. a. Was the 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. Did POTW resample within 30 days of knowledge of SIU limit
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
violations from the POTW sample event?
45. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
❑ Yes /1 No
❑ Yes r No
❑ Yes ❑ No
46. During the Most Recent Semi -Annual Period, Was Enforcement Taken
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
®Yes❑No❑N/A
❑Yes®No❑N/A
❑Yes❑No❑N/A
47. Does the File Contain Penalty Assessment Notices?
❑Yes❑No®N/A
❑Yes❑NoON/A
❑Yes❑No❑N/A
48. Does The File Contain Proof Of Penalty Collection?
❑Yes❑No®N/A
❑Yes❑NoNN/A
❑Yes❑No❑N/A
49. a. Does the 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
50. Did the POTW Representative Have Difficulty in Obtaining Any of This
Requested Information For You?
/1 Yes ❑ No
0 Yes ❑ No
❑ Yes ❑ No
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

FILE REVIEW COMMENTS:
17. The POTW has been addressing significant oil & grease accumulations at the WWTP headworks from an industrial user's (Star Snax)
discharge. The industry produces tortilla chips. The POTW has approved a permanent grease reduction/removal system at the industry. The
industry will also be permitted under a local permit.
28. The approval letter for the Enforcement Response Plan (ERP) could not be found during the inspection. Note: A Copy of the approval letter
was emailed to the POTW on 1/12/2022.
35. The POTW performed the SIU inspections on 9/8/2021 (Hickory Springs) and 9/13/2021 (Engineered Controls Int.).
36. Engineered Controls Int. (ECI) will need to update the slug/spill control plan (POTW's contacts need to be updated at a minimum)
39. POTW contracts Water Tech Labs (Pace Analytical Services subcontracted) for Industrial User Permit (IUP) sampling analyses.
41 a. Hickory Springs and ECI contract Pace Analytical Services to perform IUP analyses.
46. The POTW issued a Notice of Violation to Hickory Springs for the failure to submit (and sample) the November 2021 monitoring data
according to the IUP. The POTW failed to initiate enforcement according to the Division approved ERP for ECI's failure to submit the TTO
Certification by 12/7/21 (per IUP). In addition, the POTW failed to collect TTO samples due to ECI's failure to submit the TTO Certification
as required in the IUP.
50. In addition to the ERP approval letter, the POTW's pretreatment staff could not provide the following documentation during the inspection:
Division approval letters for ECI; slug/spill control plan for Hickory Springs and permit application for ECI. Note: The slug/spill control plan
for ECI and the Division approval letters (ERP and SIU IUPs) were available for review during the previous compliance inspection performed
on 9/12/2019. The Division approval letters for the SIU IUPs and permit application (ECI) were emailed to the POTW on 1/12/2022.
SUMMARY AND COMMENTS:
The POTW's record keeping system continues to need improvement. Note: Record Keeping deficiencies were noted in the previous PCI
performed on 6/23/2021. All Pretreatment files must be properly maintained and accessible for review.
The POTW must initiate an enforcement action according to the Division approved ERP for ECI's failure to submit a TTO Certification by
12/7/2021 (second half of 2021). The enforcement action must be issued by June 10, 2022.
The POTW must ensure all pH calibrations (IUP sampling) during first half of 2021 are documented and are accessible for review.
The Industrial Waste Survey is due 10/1/2022. The POTW staff should contact the Pretreatment staff in the Central Office (contacts were
emailed to POTW on 1/11/2022) to obtain the Manufacturer's Registry and updated IWS form for the initiation (and documentation) of the
industrial surveys.
NOD: ❑ YES ® NO
NOV: ® YES ❑ NO
QNCR: ❑ YES ® NO
POTW Rating:
Satisfactory ❑ Marginal ® Unsatisfactory_ ❑
DocuSigned by:
PCI COMPLETED BY: EIle* Bch DATE: 5/31/2022
A61696D90CC3437...
Wes Bell, Environmental Specialist II, MRO/WQROS, DWR
-DocuSigned by:
PCI REVIEWED BY:
-A14CC681AF27425...
DATE:
5/31/2022
W. Corey Basinger, Regional Supervisor, MRO/WQROS, DWR
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3

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