NC0025496_Inspection_20230125

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Daniel Perry
Pretreatment Coordinator
City of Lincolnton
Post Office Box 617
Lincolnton, North Carolina 28093
NORTH CAROLINA
Environmental Quality
January 25, 2023
SUBJECT: Notice of Deficiency
Pretreatment Compliance Inspection
City of Lincolnton
NPDES Permit No. NC0025496
Lincoln County
Tracking No. NOD-2023-PC-0041
Dear Mr. Perry:
Enclosed is a copy of the Pretreatment Compliance Inspection (PCI) Report for the inspection of the City of Lincolnton's
approved Industrial Pretreatment Program on January 24, 2023, by Mr. Wes Bell of this Office.
This report is being issued as a Notice of Deficiency (NOD) due to the City's failure to properly implement the
Pretreatment Program. Specifically, the City failed to initiate enforcement according to the Division -approved ERP due to ST
Engineering, Inc.'s failure to submit the January — June 2022 TTO Certification by June 30, 2022 (IUP requirement). You had
submitted (via email) to this Office a copy of the NOV issued to ST Engineering for the reporting violation on January 24, 2023;
therefore, a response will not be required. If you choose to provide any additional comments to this violation and/or report,
please submit your response in writing to this Office by February 15, 2023.
The report should be self-explanatory; however, should you have any questions, please do not hesitate to contact Mr. Bell
at [phone] or at [e-mail].
Enclosure: Inspection Report
D_E
Sincerely,
Docu Signed by:
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F161 FB69A2D84A3...
Andrew H. Pitner, P.G.
Assistant 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 INFORMATION1
1. Control Authority (POTW) Name: City of Lincolnton
2. Control Authority Representative(s): Daniel Perry
3. Title(s): Pretreatment Program Coordinator
4. Last Inspection Date: 12/21/21 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
PCS CODING
Main Program Permit Number
NC0025496
MM/DD/YY
01/24/23
7. Current Number Of Significant Industrial Users (SIUs)?
5
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)?
3
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?
❑ YES aO
❑ YES /1 NO
Limits: None
Reporting: None
)lished: N/A
N/A
❑ YES /1 NO
LTMP/STMP FILE REVIEW:
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)
8/30/22
Yes ❑ No
9/15/22
r Yes ❑ No
11/30/26
Industrial Waste Survey (IWS)
7/13/22
/1 Yes ❑ No
8/10/22
r Yes ❑ No
8/9/27
Sewer Use Ordinance (SUO)
5/10/22
/1 Yes ❑ No
10/7/13
r Yes ❑ No
Enforcement Response Plan (ERP)
12/6/19
/1 Yes ❑ No
2/5/20
/1 Yes ❑ No
Long Term Monitoring Plan (LTMP)
8/30/22
/1 Yes ❑ No
9/26/22
/1 Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW
29. User Name 1. Cosette Pharmaceuticals 2. McMurray Fabrics
3. ST Engineering, Inc.
30. IUP Number
0012
0013
0020
31. Does File Contain Current Permit?
/1 Yes ❑ NoJ
/1 Yes ❑ No
/1 Yes ❑ No
32. Permit Expiration Date
6/30/24
6/30/24
6/30/23
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
439
410
433
34. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
A Yes ❑ No
/1 Yes ❑ No
A Yes ❑ No
35. Does File Contain an Inspection Completed Within Last Calendar Year?
/1 Yes ❑ No
/1 Yes ❑ No
1 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. AYes •No
b. •Yes ■ No
a. ► Yes ■No
b. A Yes ■ No
a. •Yes ANo
b. •Yes ►5 No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
Organic Management Plan (TOMP)?
❑ Yes ❑NoEN/A
❑Yes❑NoEN/A
®Yes❑No❑N/A
38. a. Does File Contain Original Permit Review Letter from the Division?
b. All Issues Resolved?
a. AYes •No
b.❑Yes❑NoEN/A
a. ► Yes •No
b.❑Yes❑No®N/A
a. AYes •No
b.❑Yes❑NoEN/A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
its Sampling as Required by IUP, including flow?
/1 Yes ❑ No
/1 Yes ❑ No
1 Yes ❑ No
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
A Yes ❑ No
/1 Yes ❑ No
A 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
NYes❑No❑N/A
❑YesENo❑N/A
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
file include process/dilution flows as Required by IUP?
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑NoEN/A
42b. For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑NoEN/A
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Limits Non -Compliance from Both POTW and SIU Sampling?
❑Yes❑NoEN/A
❑Yes❑NoEN/A
■ Yes •No0NA
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Reporting Non -Compliance from SIU Sampling?
❑ Yes ❑NoEN/A
❑Yes❑NoEN/A
❑YesENo❑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
violations from the POTW sample event?
a.❑Yes❑NoEN/A
b.❑Yes❑NoEN/A
c.❑Yes❑NoNN/A
a.❑Yes❑NoEN/A
b.❑Yes❑NoEN/A
c.❑Yes❑No®N/A
a.❑Yes❑NoEN/A
b.❑Yes❑NoEN/A
c.❑Yes❑No®N/A
45. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
❑ Yes /1 No
❑ Yes L No
❑ Yes /1 No
46. During the Most Recent Semi -Annual Period, Was Enforcement Taken
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
❑ Yes ❑NoEN/A
❑Yes❑NoEN/A
❑YesENo❑N/A
47. Does the File Contain Penalty Assessment Notices?
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑NoEN/A
48. Does The File Contain Proof Of Penalty Collection?
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑NoEN/A
49. a. Does the File Contain Any Current Enforcement Orders?
b. Is SIU in Compliance with Order?
a.❑Yes❑NoEN/A
b.❑Yes❑NoEN/A
a.❑Yes❑NoEN/A
b.❑Yes❑NoEN/A
a.❑Yes❑NoEN/A
b.❑Yes❑NoEN/A
50. Did the POTW Representative Have Difficulty in Obtaining Any of This
Requested Information For You?
❑ Yes /1 No
❑ Yes r No
❑ Yes I No
NC DWR Pretreatment Compliance Inspection (PCI) Form
Updated December 2016 Page 2

FILE REVIEW COMMENTS:
22. The POTW's on -site certified laboratory performs BOD, TSS, ammonia and field analyses for LTMP sampling events. Statesville
Analytical has been contracted to perform the remaining LTMP analyses.
35. SIU inspections were performed on 11/15/22 (Cosette Pharmaceuticals), 12/6/22 (McMurry Fabrics) and 12/2/22 (ST Engineering).
39. POTW only performs field analyses during SIU sampling events. Statesville Analytical (all remaining IUP analyses except low level
mercury) and Two Rivers Utilities/Crowders Creek Laboratory (low level mercury) have been contracted to perform analyses during SIU
sampling events.
41b. ST Engineering failed to submit the January — June 2022 TTO Certification by June 30, 2022, as required by the SIU's IUP. The POTW
did not receive this TTO Certification until 12/5/22.
46. The POTW failed to initiate enforcement according to the Division -approved ERP for the late reporting of ST Engineering's TTO
Certification for the January — June 2022 monitoring period.
SUMMARY AND COMMENTS:
The POTW must initiate enforcement according to the Division approved ERP due to ST Engineering's failure to submit the January - June
2022 TTO Certification by June 30, 2022 (IUP requirement). Note: The POTW had emailed a copy of the NOV being issued to ST
Engineering for the reporting violation to the DWR/Mooresville Regional Office on 1/24/23.
The records reviewed during the inspection were organized and well maintained. Overall, the POTW's Industrial Pretreatment Program was
being properly implemented.
NOD: ® YES ❑ NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ®NO
POTW Rating:
Satisfactory ❑ Marginal ❑ Unsatisfactory ❑
PCI COMPLETED BY:
PCI REVIEWED BY:
DocuSigned by:
[We* Bell
DATE: 1/25/2023
A61696D90CC3437...
Wes Bell, Sr. Environmental Specialist, MRO/WQROS, NC DWR
DocuSigned by:
14.1444i,HNut4
F161 FB69A2D84A3...
DATE:
Andrew H. Pitner, Acting Regional Supervisor, MRO/WQROS, NC DWR
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3