NC0025496_Compliance Inspection_20171215

a'^
Water Resources
Environmental Qualiq
ROY COOPER
Governor
MICHAEL S. REGAN
.Secretary
LINDA CULPEPPER
Interim Director
December 15, 2017 RECEIVED/DENR/DWR
JAN 0 5 2017
Mr. Robert Pearson, Water Services Director
Water Resources
City of Lincolnton Permitting Section
P. O. Drawer 617
Lincolnton, North Carolina 28093-0617
Subject: Pretreatment Compliance Inspection
City of Lincolnton
NPDES Permit No. NCO025496
Lincoln County
Dear Mr. Pearson:
Enclosed is a copy of the Pretreatment Compliance Inspection Report for the inspection of the
City of Lincolnton's Industrial Pretreatment Program on December 12, 2017, by Mr. Wes Bell of this
Office.
Should you have any questions concerning this report, please do not hesitate to contact Mr. Bell
at [phone], or via email at wes.bell&cdenr.gov.
Enclosure:
Inspection Report
cc: Vivien Zhong, PERCS Unit
MSC -1617 Central -Basement
M
SincerelyJ�"I/ cf
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
State of North Carolina I Environmental Quality) Water Resources! Watet Quality Regional Operations
Mooresville Regional Office 1610 East Center Avenue, Suite 310 I Mooresville, North Carolina 28115
704-663-1699

K`ra NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
Yate+ Resources
LN VMO..MNTAL OV IL1Y Y
BACKGROUND INFORMATION 1Comulete Prior To PCI; Review Proeram Info Database Sheet(s)1
1. Control Authority (POTW) Name: City of Lincolnton
2. Control Authority Representative(s): Debra Tunstall
3 Title(s): Pretreatment Program Coordinator
4 Last Inspection Date: 9/21/16 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
Main Program Permit Number MM/DD/YY
NCO025496 12/12/17
7. Current Number Of Significant Industrial Users (SIUs)?
6
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
1
12. Number of SIUs in SNC For Reporting During Either of the Last 2 Semi -Annual Periods
0
13. Number of SlUs in SNC with Pretreatment Schedule?
0
14 Number of SIUs on Schedules?
1
15. Current Number Of Categorical Industrial Users (CIUs)?
3
16. Number of CIUs in SNC?
1
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 Addressed9
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 Addressed9
19. Which Industries have been in SNC for Limits or Reporting during SNC foi
either of the Last 2 Senn -Annual Periods? Not Been Published for Violatio
Public Notice?(May refer to PAR if Excessive SIUs in SNC) SNC foi
Not Pu
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
Ones9
❑ YES ® NO
❑ YES ® NO
Limits: KACO USA — Zinc TRC
is (July — December 2016)
Reporting: None
flished: None
VT LeeBoy, Yes
❑ YES ® NO
LTMP/STMP FILE REVIEW:
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 Report9 ® 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
NC DWR Pretreatment Compliance Inspection (PCI) Form updated December 2016 Page 1

28. PRETREATMENT PROGRAM ELEMENTS REVIEW— Please review POTW files, verify POTW has copy of Program Element in
their files. complete with sutmortine documents and cony of PERCS Approval Letter, and dates consistent with Program Info:
Program Element
Last Submittal Received
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis A
5/8/17
® Yes ❑ No
8/3/17
® Yes ❑ No
6/1/22
Industrial Waste Survey S
1/26/15
® Yes ❑ No
4/6/15
® Yes ❑ No
10/1/19
Sewer Use Ordinance (SUO)
10/2/13
® Yes ❑ No
10/7/13
® Yes ❑ No
® Yes ❑ No
Enforcement Response Plan RP
7/31/08
® Yes ❑ No
10/29/08
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
12/29/16
® Yes ❑ No
3/30/17
® Yes ❑ No
a. ®Yes ❑No 1[a.
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR I FILE REVIEW AND 1 IU INSPECTIO
29. User Name
1. Cataler North America
2. South Fork Industries
3. G&W Laboratories
30. IUP Number
10021
0004
0012
31. Does File Contain Current Permit?
I ® Yes ❑ NoI
® Yes ❑ No
® Yes ❑ No
32. Permit Expiration Date
6/30/18
6/30/19
6/30/19
33. Categorical Standard Applied I.E. 40 CFR, Etc. Or N/A
4151
410
439
34 Does File Contain Permit Application Completed Within One Year Prior
® Yes ❑ No
❑ Yes ®No
® Yes ❑ No
to Permit Issue Date
35 Does File Contain an Inspection Completed Within Last Calendar Year?
I ®Yes ❑ NoI
® Yes ❑ No 11
® Yes ❑ No
36. a. Does the File Contain a Slug/Spill Control Plan
a. ®Yes ❑No 1[a.
❑Yes ®No
a. ®Yes []Nob.
If No, is One Needed? (See Inspection Form from POTW)
b ❑Yes ❑No
b. ❑Yes ®No
b. ❑Yes ❑No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑No®N/A
Organic Management Plan (TOMP)9
38 a. Does File Contain Original Permit Review Letter from the Division?
a. ®Yes ❑No
a. ®Yes []No
a. ®Yes ❑No
11
b All Issues Resolved?
b ❑Yes❑No®N/A
b ❑Yes❑No®N/A
b ❑Yes❑No®N/A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
® Yes El No
® Yes [I No
®Yes El No
its Sam lin as Re uired b lUP, includin flow
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
® Y
I ® Yes ❑ No -11
® Yes ❑ No
41a During the Most Recent Semi -Annual Period, Did the SILT Complete its
®Yes❑No❑N/A
®Yes❑No❑N/A
®Yes❑No❑N/A
Sampling as Required by IUP, including flow?
41b. During the Most Recent Semi -Annual Period, Did SILT submit all reports
OYes❑No❑N/A
®Yes❑No❑N/A
®Yes❑No❑N/A
on time
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑NoON/A
file includeprocess/dilution flows as Required by IUP?
42b. For categorical IUs with Production based limits, does file include
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑No®N/A
pr duction rates and/or flows as Required b IUPC
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑No®NA
❑Yes❑No®N/A
®Yes❑No❑N/A
All Limits Non -Compliance from Both POTW and SIU Sampling?
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑No®N/A
❑Yes❑NoON/A
❑Yes❑NoON/A
All Reporting Non -Compliance from SIU Sampling?
44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
a.❑Yes❑No®N/A
a ❑Yes❑No®N/A
a ®Yes❑No❑N/A
Monitoring Violations9
b. Did Industry Resample and submit results to POTW Within 30 Days9
b ❑Yes❑No®N/A
b ❑Yes❑No®N/A
b ®Yes❑No❑N/A
c. Did POTW resample within 30 days of knowledge of SIU limit
c ❑Yes❑No®N/A
c ❑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 ® No
1 ❑ Yes ® No❑
Yes ® No
46. During the Most Recent Semi -Annual Period, Was Enforcement Taken
❑Yes❑No®N/A
❑Yes❑No®N/A
®Yes❑No❑N/A
as Specified in the POTW's ERP OVs, Penalties, timing, etc )9
47 Does the File Contain Penalty Assessment Notices?
❑Yes❑NoEN/A
I ❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑No®N/A
48. Does The File Contain Proof Of Penalty Collection?
❑Yes❑NoON/A
❑Yes❑NoON/A
49. a. Does the File Contain Any Current Enforcement Orders?
a.❑Yes❑No®N/A
a.❑Yes❑No®N/A
a.❑Yes❑No®N/A
b. Is SIU in Compliance with Order?
b ❑Yes❑No®N/A
b ❑Yes❑No®N/A
b ❑Yes❑No®N/A
50 Did the POTW Representative Have Difficulty in Obtaining Any of This
❑ Yes ® No
❑ Yes ® No
❑ Yes ® No
Requested Information For You?
NC DWR Pretreatment Compliance Inspection (PCI) Form updated December 2016 Page 2

FILE REVIEW COMMENTS:
14. VT LeeBoy has been on a Consent Order since 6/7/16 to address zinc limit violations. The Consent Order is scheduled to expire on
1/1/18.
28. The SUO was adopted on 7/10/14.
34. South Fork Industries' failure to submit a renewal application within 180 days of permit expiration has been previously addressed
by the POTW (NOV issuance).
35. POTW Inspections: Cataler North America -12/7/17, South Fork Industries -11/29/17, G&W Laboratories -12/1/17.
39. POTW only analyzes conventional parameters at the on-site lab during LTMP sampling events. Blue Ridge Labs (metals, cyanide,
oil & grease), Prism Laboratories (conventional parameters, total phosphorus, total nitrogen), and Two Rivers Utilities Laboratory
(low level mercury) are contracted to perform analyses during LTMP and/or SIU sampling events.
41a. Cataler North America, South Fork Industries, and G&W Laboratories all contract NC certified commercial labs (Blue Ridge
Labs and/or Prism Laboratories) for analyses.
46. The POTW issued a NOV to G&W Laboratories for a daily maximum oil & grease limit violation (SIU sampling event) in April
2017.
SUMMARY AND COMMENTS:
The required IUP detection levels for copper (2 ug/L), ethyl acetate (5 ug/L), acetone (15 ug/L), and isopropyl acetate (5 ug/L) were not
being met by G&W Laboratories' contracted labs (Prism and sub -contracted Analytical Environmental Services, Inc). The POTW
must ensure that all required IUP detection levels are being met.
The POTW pretreatment staff use a field notebook to document field measurements during SIU sampling events. The pretreatment
staff must ensure that all data is complete (sampling times, units of measurement, etc.) and legible.
The records reviewed during the inspection were organized and well maintained. Overall, the City's Industrial Pretreatment Program
appeared to be properly implemented.
NOD: ❑ YES ® NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ® NO
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory ❑
/I
PCI COMPLETED BY: ��r tet" DATE: December 14, 2017
Wes Bell, Mooresville Regional Office
NC DWR Pretreatment Compliance Inspection (PCI) Form t;pdated December 2016 Page 3