NC0020737_Compliance Evaluation Inspection_20231109

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
CERTIFIED MAIL #: 7020 3160 0000 3283 0779
RETURN RECEIPT REQUESTED;
Rick Duncan, Water Resources Director
City of Kings Mountain
Post Office Box 429
Kings Mountain, NC 28086-0429
SUBJECT: Notice of Violation
NORTH CAROLINA
Environmental Quality
November 9, 2023
Compliance Evaluation Inspection
City of Kings Mountain -Pilot Creek WWTP
NPDES Permit No. NCO020737
Cleveland County
Tracking #: NOV-2023-PC-0555
Dear Mr. Duncan:
Enclosed is a copy of the Compliance Evaluation Inspection (CEI) Report for the inspection conducted at the subject
facility on October 30, 2023, by Mr. Wes Bell of this Office. This Office would like to thank all WWTP staff for their
cooperation and assistance that was provided throughout this inspection. Please advise the facility's Operator -in -Responsible
Charge (ORC) of our findings by forwarding the enclosed report.
This report is being issued as a Notice of Violation (NOV) due to the following:
- Unapproved effluent dissolved oxygen measurements were reported on the May and June 2023 monitoring reports;
- Flow proportional influent and effluent composite samples were not being collected.
Please be advised that the failures to properly sample the effluent dissolved oxygen and collect flow proportional influent
and effluent composite samples are violations of the subject NPDES Permit and North Carolina General Statute (G.S.)
143-215.1. Please note that G.S. 143-215.6A provides for a civil penalty 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, 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. Penalties may also be assessed for any damage to surface waters of the State that may result from the
violation.
North Carolina Department of Environmental Quality I Division of Water Resources
Mooresville Regional Office 1 610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115
704.663.1699

It is requested that a written response be submitted to this Office by November 30, 2023, detailing the actions taken to
address all violations as discussed in this report. In responding, please address your comments to the attention of Mr. Wes Bell.
As discussed in the inspection report, the City may submit a variance request to the Division to collect time -based (constant
time/constant volume) composite samples only if the daily flow rates do not vary by more than 15%. The request should
include a week's worth of daily flow charts, listing of any equalization facilities, flow description throughout the wastewater
facility and any other supplemental information that could assist in the Division's decision. Please submit the variance request
to the attention of Mr. Bell.
Should you have any questions concerning this Notice, please do not hesitate to contact Mr. Bell at [phone] or at
wes.bellkdeq.nc• gov.
Enclosure: Inspection Report
Cc: NPDES Program Files - Laserfiche
Sincerely,
Docu Signed by:
4d4tV i1 PU4,ti.
F161FB69A2D84A3...
Andrew H. Pitner, P.G.
Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
EQ;
North Carolina Department of Environmental Quality [ Division of Water Resources
Mooresville Regional Office 1 610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115
704.663.1699

United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040-0057
Water Compliance Inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 IN 1 2 u 3 I NC0020737 I11 121 23/10/26 I17 18I � I 19 I s I 201 I
211IIIII 111111III II III III1 I I IIIII IIIIIIIII II r6
Inspection
Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved -------------------
67
I 72 I n, I 71 I 74 79 I I I I I I I80
701LJ � I 71 [ LL -1 I I
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES permit Number)
09:25AM 23/10/26
20/02/01
Pilot Creek WWTP
200 Potts Creek Rd
Exit Time/Date
Permit Expiration Date
Kings Mountain NC 28086
03:OOPM 23/10/26
23/08/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Rickey Lee Bailey/ORC/704-739-7131/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Ricky Duncan,PO Box 429 Kings Mtn NC 280860429//704-734-4525/7047302152
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit 0 Flow Measurement Operations & Maintenar Records/Reports
Self -Monitoring Progran 0 Sludge Handling Dispo: Facility Site Review Effluent/Receiving Wate
Laboratory
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Wes Bell signedby: DWR/MROWQ/704-235-2192/ 11/8/2023
2 re&
E�Docu`,','�96D90=437
...
Signature of M r&AYReviewer Agency/Office/Phone and Fax Numbers Date
Andrew Pi 0""{'''�' H P'4"f"DWR/MRO WQ/704-663-1699 Ext.2180/ 11/9/2023
F161FB69A2D84A3...
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

NPDES yr/mo/day Inspection Type
NCO020737 I11 12I 23/10/26 117 18 i c i
(Cont.)
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
On -site Representatives:
The following City staff were in attendance during the inspection: Mr. Donnie Spencer, Mr. Lee Bailey
and Mr. Kevin Hodges.
Record Keeping Section cont'd:
Several eDMRs will be revised and resubmitted to correct transcription errors in the following months:
- October 2022 (correct units of measurement for influent selenium and thallium);
- April 2023 [correct units of measurement for effluent selenium, thallium, and oil & grease (and
influent), zinc (and influent), correct ">" symbol to "<" for influent oil & grease, and remove one
effluent mercury value — 11th or 13th];
- May 2023 (correct units of measurement for effluent thallium);
- July 2023 [add effluent tox value and correct units of measurement for effluent arsenic (and result)
and cyanide].
Effluent temperature values should also be added on all eDMRs starting in May 2023. The facility
staff must ensure all units of measurement, sample types, etc. are correctly reported on all future
eDMRs.
Page#

Permit: NCO020737 Owner -Facility: Pilot Creek WWTP
Inspection Date: 10/26/2023 Inspection Type: Compliance Evaluation
Permit
Yes
No
NA
NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new
0
❑
❑
❑
application?
Is the facility as described in the permit?
0
❑
❑
❑
# Are there any special conditions for the permit?
0
❑
❑
❑
Is access to the plant site restricted to the general public?
0
❑
❑
❑
Is the inspector granted access to all areas for inspection?
❑
❑
❑
Comment: The Division received the City's permit renewal package on 3/7/2023.
The City implements a Division -approved Industrial Pretreatment Program.
The last compliance evaluation inspection at this facility was performed by
DWR staff
on 3/22/2022.
Record Keeping
Are records kept and maintained as required by the permit?
Is all required information readily available, complete and current?
Are all records maintained for 3 years (lab. reg. required 5 years)?
Are analytical results consistent with data reported on DMRs?
Is the chain -of -custody complete?
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
Are DMRs complete: do they include all permit parameters?
Has the facility submitted its annual compliance report to users and DWQ?
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified
operator on each shift?
Is the ORC visitation log available and current?
Is the ORC certified at grade equal to or higher than the facility classification?
Is the backup operator certified at one grade less or greater than the facility
classification?
Is a copy of the current NPDES permit available on site?
Facility has copy of previous year's Annual Report on file for review?
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
■ ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
■ ❑ ❑ ❑
■ ❑ ❑ ❑
❑ ❑ ■ ❑
■ ❑ ❑ ❑
■ ❑ ❑ ❑
■ ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Page# 3

Permit: NCO020737
Inspection Date: 10/26/2023
Record Keeping
Owner -Facility: Pilot Creek WWTP
Inspection Type: Compliance Evaluation
Yes No NA NE
Comment: The records reviewed durinq the inspection were orqanized and well maintained.
Discharge Monitoring Reports (eDMRs) were reviewed for the period September 2022
through August 2023. A weekly average TSS effluent violation was reported in
February 2023. The Division has previously addressed this limit violation through the
issuance of a Notice of Violation (NOV).
See Summary Section for additional comments.
Laboratory
Yes
No
NA
NE
Are field parameters performed by certified personnel or laboratory?
0
❑
❑
❑
Are all other parameters(excluding field parameters) performed by a certified lab?
0
❑
❑
❑
# Is the facility using a contract lab?
0
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0
■
❑
❑
❑
degrees Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
❑
❑
❑
■
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
❑
❑
❑
■
Comment: Influent and effluent analyses (including filed) are performed under the City's
laboratory certification #222. Meritech. Inc. has also been contracted to provide
analytical support.
The 10.0 S.U. pH buffer had expired and should be discarded. The lab has an
additional 10.0 S.U. standard (not expired) that can be used for all future pH meter
calibrations.
Influent Sampling Yes No NA NE
# Is composite sampling flow proportional? ❑ 0 ❑ ❑
Is sample collected above side streams?
EIN
❑
❑
Is proper volume collected?
■
❑
❑
❑
Is the tubing clean?
■
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0
0
❑
❑
❑
degrees Celsius)?
Is sampling performed according to the permit?
❑
0
❑
❑
Comment: The subject permit requires influent composite BOD and TSS samples. The facilit
staff were collecting time -based (constant time/constant volume) composite influent
samples. Please be advised that flow proportional influent composite samples must be
collected as required by the by the subject Permit (Part II, Section A. Composite
Sample). The Division may grant a variance to collect time -based composite samples
only if the daily flow rates do not vary by more the 15%. A variance request has not
been submitted and/or received by the Division.
Effluent Sampling Yes No NA NE
Is composite sampling flow proportional? ❑ 0 ❑ ❑
Is sample collected below all treatment units? 0 ❑ ❑ ❑
Page# 4

Permit: NCO020737 Owner -Facility: Pilot Creek WWTP
Inspection Date: 10/26/2023 Inspection Type: Compliance Evaluation
Effluent Sampling Yes No NA NE
Is proper volume collected?
0
❑
❑
❑
Is the tubing clean?
■
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0
0
❑
❑
❑
degrees Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
❑
0
❑
❑
representative)?
Comment: The subiect permit requires composite and qrab effluent samples. The facilitv staff
were collecting time -based (constant time/constant volume) composite effluent
samples. Please be advised that flow proportional effluent composite samples must be
collected as required by the by the subject Permit (Part II, Section A. Composite
Sample). The Division may grant a variance to collect time -based composite samples
only if the daily flow rates do not vary by more the 15%. A variance request has not
been submitted and/or received by the Division.
In addition, facility staff had used the values from the in -line dissolved oxygen (DO)
monitoring system (continuous) to report the daily DO effluent values on the May and
June 2023 eDMRs instead of using a calibrated hand held meter. Please be advised
that daily grab samples must be collected and analyzed as required by the subject
Permit (Part I, A(1) Effluent Limitations & Monitoring Requirements).
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, 0 ❑ ❑ ❑
and sampling location)?
Comment:
Operations & Maintenance Yes No NA
Is the plant generally clean with acceptable housekeeping? 0 ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: The wastewater treatment facility appeared to be adequately treating wastewater at the
NE
❑
❑
time of the inspection. Process control measurements were being performed with the
documentation being maintained on -site. The facility is equipped
with a SCADA system
and the wastewater treatment plant is visited seven days
per week with staff on call for
any alarm/emergency conditions.
Pump Station - Influent
Yes
No
NA
NE
Is the pump wet well free of bypass lines or structures?
■
❑
❑
❑
Is the wet well free of excessive grease?
0
❑
❑
❑
Are all pumps present?
0
❑
❑
❑
Are all pumps operable?
0
❑
❑
❑
Are float controls operable?
0
❑
❑
❑
Page# 5

Permit: NCO020737
Inspection Date: 10/26/2023
Owner -Facility: Pilot Creek WWTP
Inspection Type: Compliance Evaluation
Pump Station - Influent
Yes No
NA
NE
Is SCADA telemetry available and operational?
0 ❑
❑
❑
Is audible and visual alarm available and operational?
❑ ❑
0
❑
Comment: The telemetry type alarm system properly operated during
the on -site test on the high
water alarm.
Bar Screens
Yes
No
NA
NE
Type of bar screen
a.Manual
❑
b.Mechanical
Are the bars adequately screening debris?
0
❑
❑
❑
Is the screen free of excessive debris?
■
❑
❑
❑
Is disposal of screening in compliance?
0
❑
❑
❑
Is the unit in good condition?
0
❑
❑
❑
Comment: Screenings are disposed at a permitted landfill.
Chemical Feed
Yes
No
NA
NE
Is containment adequate?
0
❑
❑
❑
Is storage adequate?
■
❑
❑
❑
Are backup pumps available?
■
❑
❑
❑
Is the site free of excessive leaking?
0
❑
❑
❑
Comment: Sodium hydroxide is added to the influent (prior
to aeration basins) to maintain
appropriate alkalinity/pH levels.
Aeration Basins
Mode of operation
Type of aeration system
Is the basin free of dead spots?
Are surface aerators and mixers operational?
Are the diffusers operational?
Is the foam the proper color for the treatment process?
Does the foam cover less than 25% of the basin's surface?
Is the DO level acceptable?
Is the DO level acceptable?(1.0 to 3.0 mg/1)
Yes No NA NE
Ext. Air
Diffused
❑ ■ ❑ ❑
❑ ❑ ■ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Page# 6

Permit: NCO020737
Inspection Date: 10/26/2023
Aeration Basins
Owner -Facility: Pilot Creek WWTP
Inspection Type: Compliance Evaluation
Yes No NA NE
Comment: All three aeration basins were operational and in service. Wastewater staff have
initiated adjustments to the influent flow and air distribution sysems within the aeration
basins due to operational issues associated with the blowers. Dead spots were
observed due to the lack of proper aeration/mixing. The City has purchased three new
blowers with the first blower to be received on -site by December 2023.
Secondary Clarifier
Is the clarifier free of black and odorous wastewater?
Is the site free of excessive buildup of solids in center well of circular clarifier?
Are weirs level?
Is the site free of weir blockage?
Is the site free of evidence of short-circuiting?
Is scum removal adequate?
Is the site free of excessive floating sludge?
Is the drive unit operational?
Is the return rate acceptable (low turbulence)?
Is the overflow clear of excessive solids/pin floc?
Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth)
Yes
No
NA
NE
■
❑
❑
❑
■
❑
❑
❑
❑
■
❑
❑
■
❑
❑
❑
■
❑
❑
❑
■
❑
❑
❑
■
❑
❑
❑
■
❑
❑
❑
■
❑
❑
❑
■
❑
❑
❑
■
❑
❑
❑
Comment: All three secondary clarifiers (1,3,4) were operational and in service. Note: Afourth
clarifier was taken out of service several years ago. The weirs for clarifier #3 were
unlevel; however, no evidence of short-circuiting was observed. Plans should be made
to level the weirs in the tuture. The sludge blanket level in clarifier #4 was greater than
a quarter of the sidewall depth; however, wastewater staff have been wasting and
reducing the MLSS level in aeration basin #4.
Pumps-RAS-WAS
Yes
No
NA
NE
Are pumps in place?
0
❑
❑
❑
Are pumps operational?
■
❑
❑
❑
Are there adequate spare parts and supplies on site?
❑
❑
❑
■
Comment:
Disinfection -Gas
Yes
No
NA
NE
Are cylinders secured adequately?
■
❑
❑
❑
Are cylinders protected from direct sunlight?
0
❑
❑
❑
Is there adequate reserve supply of disinfectant?
0
❑
❑
❑
Is the level of chlorine residual acceptable?
0
❑
❑
❑
Is the contact chamber free of growth, or sludge buildup?
■
❑
❑
❑
Page# 7

Permit: NCO020737
Inspection Date: 10/26/2023
Disinfection -Gas
Owner -Facility: Pilot Creek WWTP
Inspection Type: Compliance Evaluation
Is there chlorine residual prior to de -chlorination?
Does the Stationary Source have more than 2500 Ibs of Chlorine (CAS No.
7782-50-5)?
If yes, then is there a Risk Management Plan on site?
If yes, then what is the EPA twelve digit ID Number? (1000- - )
If yes, then when was the RMP last updated?
Comment:
Flow Measurement - Effluent
# Is flow meter used for reporting?
Is flow meter calibrated annually?
Is the flow meter operational?
(If units are separated) Does the chart recorder match the flow meter?
Yes
No
NA
NE
■
❑
❑
❑
❑
❑
❑
■
❑
❑
❑
■
Yes
No
NA
NE
■
❑
❑
❑
■
❑
❑
❑
■
❑
❑
❑
❑
❑
■
❑
Comment: The facility is equipped with a flow meter (and V-notch weir) at the outlets of the three
chlorine contact chambers. All flows from the three flow meters are totalized
(automated system) and reported on the eDMRs. All flow meters are calibrated
annually (at a minimum) and were last calibrated on 3/8/2023 by Laboratory Instrument
Services, LLC. The ORC and staff must ensrue the contracted company that performs
the calibrations provides all calibration data including instantaneous confirmation
measurements.
De -chlorination
Yes
No
NA
NE
Type of system ?
Gas
Is the feed ratio proportional to chlorine amount (1 to 1)?
0
❑
❑
❑
Is storage appropriate for cylinders?
■
❑
❑
❑
# Is de -chlorination substance stored away from chlorine containers?
0
❑
❑
❑
Comment:
Are the tablets the proper size and type? ❑ ❑ 0 ❑
Are tablet de -chlorinators operational? ❑ ❑ ■ ❑
Number of tubes in use?
Comment:
Effluent Pipe
Yes
No
NA
NE
Is right of way to the outfall properly maintained?
❑
❑
❑
Are the receiving water free of foam other than trace amounts and other debris?
❑
❑
❑
If effluent (diffuser pipes are required) are they operating properly?
❑
❑
0
❑
Page# 8

Permit: NC0020737 Owner -Facility: Pilot Creek WWTP
Inspection Date: 10/26/2023 Inspection Type: Compliance Evaluation
Effluent Pipe Yes No NA NE
Comment: The effluent appeared clear with no floatable solids or foam.
Aerobic Digester
Yes
No
NA
NE
Is the capacity adequate?
0
❑
❑
❑
Is the mixing adequate?
0
❑
❑
❑
Is the site free of excessive foaming in the tank?
■
❑
❑
❑
# Is the odor acceptable?
■
❑
❑
❑
# Is tankage available for properly waste sludge?
0
❑
❑
❑
Comment: Both aerobic diqesters were operational and in service.
Solids Handling Equipment
Yes
No
NA
NE
Is the equipment operational?
0
❑
❑
❑
Is the chemical feed equipment operational?
0
❑
❑
❑
Is storage adequate?
■
❑
❑
❑
Is the site free of high level of solids in filtrate from filter presses or vacuum filters?
❑
❑
❑
■
Is the site free of sludge buildup on belts and/or rollers of filter press?
❑
❑
❑
Is the site free of excessive moisture in belt filter press sludge cake?
❑
❑
❑
The facility has an approved sludge management plan?
0
❑
❑
❑
Comment: The belt press was operation; however, the unit was not in service at the time of the
inspection. Dewatered bio-solids are transported and disposed at a permitted landfill
by City staff.
Standby Power
Yes
No
NA NE
Is automatically activated standby power available?
0
❑
❑
❑
Is the generator tested by interrupting primary power source?
0
❑
❑
❑
Is the generator tested under load?
0
❑
❑
❑
Was generator tested & operational during the inspection?
0
❑
❑
❑
Do the generator(s) have adequate capacity to operate the entire wastewater site?
■
❑
❑
❑
Is there an emergency agreement with a fuel vendor for extended run on back-up
0
❑
❑
❑
power?
Is the generator fuel level monitored?
0
❑
❑
❑
Comment: The facility is equipped with two generators (1 — aeration basin #3 blowers and 1 — rest
of WWTP) that are serviced twice per year by Carolina Power Solutions.
Page# 9