NCG500602_Inspection_20180810

NORTH CAROLINA
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MICHAEL S. REGAL
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LINDA CULPEPPER
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10 August 2018
CERTIFIED MAIL #: 70161370 0000 25961211
RETURN RECEIPT REQUESTED
Mr. Bob Bauer, Facilities Manager
Dale Earnhardt, Inc.
1675 Dale Earnhardt Hwy. #3
Mooresville, North Carolina 28115
Subject: Notice of Violation
Compliance Evaluation Inspection
Dale Earnhardt, Inc.
NPDES General Permit No. NCG500602
Iredell County
Tracking #: NOV-2018-PC-0320
Dear Mr. Bauer:
Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the subject facility on
July 24, 2018, by Mr. Wes Bell of this Office.
This report is being issued as a Notice of Violation (NOV) due to the facility's failure to maintain three (3) years of
monitoring records which is a violation of the subject NPDES Permit and North Carolina General Statute (G.S.) 143-215.1 as
detailed in the Record Keeping Section of the attached report. Please be advised that G.S. 143-215.6A provides for 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, 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 violations.
It is requested that a written response be submitted to this Office by August 31, 2018, detailing the actions taken to address
the violation. In responding, please address your comments to the attention of Mr. Wes Bell.
EQ.:>
`_=r
North Carolina Department of Environmental Quality I Division of Water Resources
610 East Center Avenue I Suite 3011 Mooresville, North Carolina 28115
704.663.1699

Mr. Bob Bauer
Page Two
10 August 2018
Should you have any questions concerning this letter, please do not hesitate to contact Mr. Bell at [phone], or via
email at wes.bellkncdenr.gov.
Sincerely,
DocuSigned by:
A14CC681 AF27425...
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
Enclosures:
Inspection Report
NC Wastewater/Groundwater Laboratory Certification — Approved Procedure for the Analysis of pH

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 2 15 1 3 I NCG500602 111 12 I 18/07/24 I17 18 I S J 19 LG] 201 I
211111 1 1 1 1 1 111 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 111 1 1 1 1 1 166
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ----------------------Reserved-------------------
67 1.0 70 71 I„ I 72 n 73 � 74 751 I I I I I I I80
u u 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 oermit Number)
01:45PM 18/07/24
16/04/25
Dale Earnhardt, Inc.
1675 Hwy #3
Exit Time/Date
Permit Expiration Date
Mooresville NC 28115
02:40PM 18/07/24
20/07/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Bob Bauer/Facilities Manager/704-662-8000 ext 3311/7046628970
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Cindey Sims, 1675 Coddle Creek Hwy Mooresville NC 28115/Director of
Properties/704-662-8000/7046629158 No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit 0 Flow Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program 0 Facility Site Review Effluent/Receiving Waters 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
cuSigned by: 8/10/2018
Wes Bell MRO WQ//704-663-1699 Ext.2192/
Be&
E�:96D90=437...
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
W. Corey Basinger MRO WQ//704-235-2194/
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
DocuSigned by:
8/10/2018
AtaccsatAi=vazs... Page#

NPDES yr/mo/day Inspection Type
NCG500602 111 121 18/07/24 1 17 18 JCJ
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Page#

Permit: NCG500602 Owner - Facility: Dale Earnhardt, Inc.
Inspection Date: 07/24/2018 Inspection Type: Compliance Evaluation
Yes No NA NE
Are records kept and maintained as required by the permit?
❑
0
Permit
Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new
❑
❑
0
❑
application?
❑
0
❑
❑
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?
0
❑
❑
❑
Comment: The last compliance evaluation inspection was performed at the facility on 10/19/15 by DWR
staff.
Record Keeping
Yes No NA NE
Are records kept and maintained as required by the permit?
❑
0
❑
❑
Is all required information readily available, complete and current?
❑
0
❑
❑
Are all records maintained for 3 years (lab. reg. required 5 years)?
❑
0
❑
❑
Are analytical results consistent with data reported on DMRs?
❑
❑
0
❑
Is the chain -of -custody complete?
❑
❑
❑
Dates, times and location of sampling
❑
information for a period of
three (3) years. (Permit Condition Reference: Part II, Section D (6)
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?
❑
❑
0
❑
Is the ORC certified at grade equal to or higher than the facility classification?
❑
❑
0
❑
Is the backup operator certified at one grade less or greater than the facility classification? ❑
❑
0
❑
Is a copy of the current NPDES permit available on site?
❑
❑
❑
Facility has copy of previous year's Annual Report on file for review?
❑
❑
0
❑
Comment: The facility had not maintained three years of monitoring records.
Please be advised that
the subject permit requires the permittee to maintain all monitoring
information for a period of
three (3) years. (Permit Condition Reference: Part II, Section D (6)
Records Retentionl.
Laboratory
Yes No NA NE
Page# 3

Permit: NCG500602 Owner - Facility: Dale Earnhardt, Inc.
Inspection Date: 07/24/2018 Inspection Type: Compliance Evaluation
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
❑
❑
0
❑
Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
❑
❑
0
❑
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
❑
❑
0
❑
Comment: The facility staff must ensure that the contract company performing the analyses calibrates
the pH meter according to the NC Wastewater/Groundwater Laboratory Certification —
Approved Procedure for the Analysis of pH (attached to report).
Effluent Sampling
Is composite sampling flow proportional?
Is sample collected below all treatment units?
Is proper volume collected?
Is the tubing clean?
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
representative)?
Comment: The subiect aeneral Dermit reauires effluent arab samDles
MUM ►[•7►/_1111111►1M
❑ ❑ ■ ❑
❑ ❑ ■ ❑
❑ ❑ ■ ❑
❑ ❑ ■ ❑
❑ ❑ ■ ❑
■ ❑ ❑ ❑
The Facilities Manager indicated that the contracted company (Water Tech Solutions, Inc.)
that services the ozone/cooling tower system performs monthly sampling on the
non -contact cooling water and bi-monthly calibrations on the conductivity and temperature
in-line monitoring system. Please note that these records are required to be maintained for
a period of at least three (3) years as previously discussed in the Records Keeping Section.
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, and ❑ ❑ 0 ❑
sampling location)?
Comment: The non -contact coolina water is not discharaed into surface waters: therefore. no upstream
and downstream monitoring is required.
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? 0 ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑ 0 ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Page# 4

Permit: NCG500602
Inspection Date: 07/24/2018
Operations & Maintenance
Owner - Facility: Dale Earnhardt, Inc.
Inspection Type: Compliance Evaluation
Yes No NA NE
Comment: No biocides and/or corrosion/scale inhibitors are added to the cooling tower system.
Yes No NA NE
Is right of way to the outfall properly maintained?
❑
Potable water (City of Mooresville) is used for make-up water. Disinfection is
performed by
Are the receiving water free of foam other than trace amounts and other debris?
❑
an ozone system.
0 ❑
If effluent (diffuser pipes are required) are they operating properly?
❑
❑
Flow Measurement - Effluent
Yes No NA NE
# Is flow meter used for reporting?
❑
❑
0
❑
Is flow meter calibrated annually?
❑
❑
0
❑
Is the flow meter operational?
❑
❑
0
❑
(If units are separated) Does the chart recorder match the flow meter?
❑
❑
0
❑
Comment: The discharae of the non -contact coolina water (bleed -off) is based on the conductivit
levels. The cooling tower system discharges approximately two to three times per day
during the summer months at less than one hundred gallons per day (based on bucket and
stop watch instantaneous flow measurements). The cooling tower system does not
discharae durina the winter months.
Effluent Pipe
Yes No NA NE
Is right of way to the outfall properly maintained?
❑
❑
0 ❑
Are the receiving water free of foam other than trace amounts and other debris?
❑
❑
0 ❑
If effluent (diffuser pipes are required) are they operating properly?
❑
❑
0 ❑
Comment: The non -contact cooling water is discharged into a wooded area.
Page# 5

NORTH CAROLINA WASTEWATER/GROUNDWATER LABORATORY CERTIFICATION
APPROVED PROCEDURE FOR THE ANALYSIS OF pH
This document provides an approved procedure for the analysis of pH per 15A NCAC 2H .0805 (a) (6) (F) and (g) (3).
HOLDING TIME:
• Samples must be analyzed within 15 minutes of collection (40 CFR Part 136 Table II).
METER CALIBRATION:
• Use a pH meter accurate and reproducible to 0.1 S.U. (as demonstrated daily by acceptable performance of a
check standard buffer) with a range of 0 to 14 S.U. and equipped with temperature -compensation adjustment.
• Instruments are to be calibrated according to the manufacturer's calibration procedure prior to analysis of
samples each day compliance monitoring is performed. Calibration must include at least two buffers. The meter
calibration must be verified with a third standard buffer solution (i.e., check buffer) prior to sample analysis. The
calibration and check standard buffers must bracket the range of the samples being analyzed. A portion of the
buffer solutions should not be used for more than one calibration. Discard any used buffer portions. Do not pour
unused portions back into the original bottle.
• All check standard buffers must read within ±0.1 S.U. to be acceptable. If the meter verification does not read
within ±0.1 S.U., corrective actions must be taken before any samples are analyzed. Possible corrective actions
may be found at the end of this document.
• When performing analyses at multiple sample sites, a post -analysis calibration verification using the check
standard buffer must be analyzed at the end of the run. It is recommended that a mid-day check standard buffer
be analyzed when samples are analyzed over an extended period of time. The post -analysis check standard
buffer(s) must read within ±0.1 S.U. or corrective actions must be taken. If recalibration is necessary, all samples
analyzed since the last acceptable calibration verification must be reanalyzed, if possible. If samples cannot be
reanalyzed, the data must be qualified.
GENERAL INFORMATION:
• The pH probe must be stored and operated according to manufacturer's instructions (e.g., open or loosen the fill
hole cap during measurement, ensure electrolyte fill solution is at the proper level, etc.).
• Samples shall be gently stirred during measurement. The pH sensing portion and the reference junction must be
completely immersed. Steps must be taken to eliminate cross contamination between measurements (e.g.,
rinsing and blotting the electrode dry, dipping the electrode in stream multiple times, etc.).
• The units of measure for pH analyses are Standard Units (S.U.). It is recommended that pH be read and
documented in one -hundredths (0.01). Values must be reported in tenths (0.1). It should be noted that many
Proficiency Testing (PT) providers require samples be reported to one -hundredths.
• Sample duplicates are not a required quality control element for Field parameters.
• If more than one pH concentration has been taken for a particular day, these values cannot be averaged due to
the logarithmic nature of pH concentration. All values must be reported on the eDMR, either in the daily cell or the
comments section. The following convention must be followed when deciding which value to report in the daily
cell:
o Any value in violation of permit limits must be reported in the daily cell. If multiple samples yielded
noncompliant results, the most extreme noncompliant value must be reported in the daily cell.
o If all values taken during the day were compliant with the permit limits, the value closest to the bounds of
the limit range (high or low) must be reported in the daily cell.

Approved Procedure for Analysis of pH
Page 2 of 2
DOCUMENTATION:
The following must be documented in indelible ink whenever sample analysis is performed.
1. Date and time of sample collection
2. Date and time of sample analysis to verify the 15 -minute holding time is met [Alternatively, one time may be
documented for collection and analysis with the notation that samples are measured in situ or immediately at
the sample site.]
3. Facility name, sample site (ID or location), and permit number
4. Collector's/analyst's name or initials
5. Meter calibration and meter calibration time(s)
6. True values of buffers used for calibration
7. True value for the check standard buffer
8. Value obtained for the check standard buffer (verification of ± 0.1 S.U.)
9. True value and value obtained for the post -analysis calibration verification (s), where applicable
10. Indication of when the post -analysis calibration verification was performed (e.g., time of analysis, end -of -day
analysis, etc.)
11. Units of measure
12. Report all data values to the nearest 0.1 S.U.
13. Traceability for chemicals, reagents, standards and consumables
14. Instrument identification (serial number preferred)
15. Parameter analyzed
16. Method reference
17. Data qualifier(s), when applicable
18. Equipment maintenance (recommended)
Refer to Quality Assurance Policies for Field Laboratories (at http://deg.nc.gov/about/divisions/water-resources/water-
resources-data/water-sciences-home-page/laboratory-certification-branch/technical-assistance-policies) for additional
quality assurance and quality control requirements.
TROUBLESHOOTING:
If the check buffer does not read within ±0.1 S.U., the lab should first try pouring a new aliquot of the check buffer and
reading it again. If it still does not read within ±0.1 S.U., the meter must be recalibrated. Possible corrective actions
include: check the meter calibration procedure, refer to the trouble shooting section in the instrument manual, and
check the buffers. If, after recalibration, the check buffer does not read within ±0.1 S.U., the meter and/or probe
operation may be suspect and may require servicing. If the laboratory does not have a back-up meter/electrode, or
another meter/electrode cannot be procured, it is recommended that the lab report the measured pH results with a
qualifier that indicates the value is estimated.
The true values of buffers are temperature dependent. Check the manufacturer's label on the bottle for the true value.
This document was prepared using Standard Methods 4500-H' B — 2011 as a reference Rev. 11/2017