NC0024252_NOD2017PC0217_20170817

Water Resources
Environmental Quality
August 4, 2017
Mr. Michael Fox
Wastewater Treatment and Collection Supervisor
City of Conover
Post Office Box 549
Conover, North Carolina 28613
Dear Mr. Fox:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. JAY ZIMMERMAN
Director
RECEAVEDINCDEWWR
AUG 14 2017
Water Quality
Permitting Section
Subject- Notice of Deficiency
Pretreatment Compliance Inspection
City of Conover
NPDES Permit No. NCO024252
Catawba County
Tracking #: NOD -2017 -PC -0217
.it,"1)1NCDENWR
Enclosed is a copy of the Pretreatment Compliance Inspection Report for the inspecti6u 6fhA 2017
City of Conover's Industrial Pretreatment Program on July 27, 2017, by Mr. Wes Bell of this Office. �i Jailty
Please inform the City's Pretreatment Coordinator of our findings by forwarding a copy of,t%jpeslection
report.
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 on a reporting violation (chromium) from the April 24, 2017 sampling event.
The Town must initiate an enforcement action on the reporting violation within fourteen (14) days of
receipt of this report. In addition, it is requested that a written response be submitted to this Office by
August 25, 2017, addressing the actions taken to prevent the recurrence of this noncompliant finding. In
responding, please address your comments to Mr. Bell. Should you have any questions concerning this
report, please do not hesitate to contact Mr. Bell at [phone], or via email at wes [e-mail].
Enclosure:
Inspection Report
cc: Deborah Gore, PERCS Unit
Sincerely,
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
MSC -1617 Central -Basement
State of North Carolina I Environmental Quality) Water Resources I Water Quality Regional Operations
Mooresville Regional Office 1 610 East Center Avenue, Suite 310 1 Mooresville, North Carolina 28115
704-663-1699

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
BACKGROUND INFORMATION [Complete Prior To PCI• Review Program Info Database Sheet(s)]
1. Control Authority (POTW) Name: City of Conover
2. Control Authority Representative(s): Evan Rubins
3. Title(s): Pretreatment Program Coordinator
4. Last Inspection Date: 5/25/16 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
Trans.Code Main Program Permit Number MM/DD/YY Inspec Type Inspector Fac. Type
N NCO024252 7/27/17 P S 1
(DTrA) (TVPT) (INSP) (FACC)
7. Current Number Of Significant Industrial Users SIUs)?
2
SIUS
8. Current Number Of Categorical Industrial Users CIUs)?
2
CNS
9. Number of SIUs Not Inspected By POTW in the Last Calendar Year?
0
10. Number of SlUs Not Sampled By POTW in the Last Calendar Year?
0
11. Enter the Higher Number of 9 or 10
0
NOIN
12. Number of SIUs With No IUP, or With an Expired IUP
0
NOCM
13. Number of SIUs in SNC for Either Reporting or Limits Violations During Either of the Last 2
0
PSNC
Semi -Annual Periods (Total Number of SIUs in SNC)
14. Number of SI[Js in SNC For Reporting Durin Either of the Last 2 Semi -Annual Periods
0
MSNC
15. Number of SILTS In SNC For Limits Violations During Either of the Last 2 Semi -Annual Periods
0
SNPS
16. Number of SIUs In SNC For Both Reporting and Limits Violations During Either of the Last 2
0
Semi-annual Periods
POTW INTERVIEW
17. Since the Last PCI, has the POTW had any NPDES Limits Violations? ❑ YES ® NO
If Yes, What are the Parameters and How are these Problems Being Addressed? 11
18. Since the Last PCI, has the POTW had any Problems Related to an Industrial L YES Q9 NO
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 SNC for Limits: None
either of the Last 2 Semi -Annual Periods? Not Been Published for SNC for Reporting: None
Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not Published: None
20. Which Industries are on Compliance Schedules or Orders? For all SIUs onan
Order, Has a Signed Copy of the Order been sent to the Division N/A
21. Are Any Permits Or Civil Penalties Currently Under Adjudication? II LJ YES I2�1 NO
LTMP/STMP FILE REVIEW: NOT APPLICABLE TO THIS POTW
22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ❑ YES ❑ NO
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/STMT? ❑ YES ❑ NO
If yes, which ones? Eliminated: Added:
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 1

FILE REVIEW COMMENTS:
28. SUO was adopted on 7/1/13.
35. POTW performed SIU inspections on 7/13/17 (ECI) and 6/21/17 (Hickory Springs).
37. POTW received TTO Certifications from ECI on 6/9/17 and 12/16/16 and Hickory Springs on 7/5/17 and 12/8/16.
39. The POTW contracts Water Tech Labs to perform analyses.
41a. ECI contracts Pace Analytical Services, Inc. to perform analyses. Hickory Springs contracts Blue Ridge Labs to perform analyses.
43b. The POTW did not receive ECI's monitoring data for the follow-up chromium sampling event (4/24/17) within the required time period.
46. The POTW failed to initiate enforcement according to the Division approved ERP for ECI's reporting violation (follow-up chromium
sampling event). The POTW did issue a NOV to ECI for a chromium limit violation (3/31/17 SILT sampling event) and the failure to notify the
POTW within 24-hrs. of first knowledge of the chromium violation.
SUMMARY AND COMMENTS:
Comments:
The records were organized and well maintained.
Requirements:
The POTW must initiate enforcement according to the Division approved ERP to ECI for the reporting violation (4/24/17 sampling event)
within fourteen (14) days of receipt of this report.
NOD: ® YES ❑ NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ®NO
POTW Rating:
Satisfactory ® Marginal ❑atisfactory_ EJ COMPLETED BY: ly-,"/ DATE: August 3, 2017.
Wes Bell, Mooresville Regional Office
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 3