NC0025496_Inspection_20190909

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
Mr. Robert Pearson
Water Resources Director
City of Lincolnton
Post Office Box 617
Lincolnton, North Carolina 28093-0617
Dear Mr. Pearson:
NORTH CAROLINA
Environmental Quality
9 September 2019
Subject: Pretreatment Audit Inspection
City of Lincolnton
Permit No. NCO025496
Lincoln County
Enclosed is a copy of the Pretreatment Audit Inspection Report for the inspection of the City of Lincolnton's
approved Industrial Pretreatment Program on September 5, 2019, by Mr. Wes Bell of this Office. Please inform the
City's Pretreatment Coordinator of our findings by forwarding a copy of the enclosed report.
The report should be self-explanatory; however, should you have any questions concerning this report, please do
not hesitate to contact Mr. Bell at [phone] or at [e-mail].
Sincerely,
Docu�Siilgnneed by:
A14CC681 AF27425...
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
Enclosure:
Inspection Report
D Q
� 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
NORTH CAROLINA
Da"MoM a enWmn�bl mwnq 704,663.1699

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT AUDIT REPORT
Background Information:
1. Control Authority (POTW) Name: City of Lincolnton
2. Control Authority Representative(s): Debra Tunstall
3. Title(s): Pretreatment Coordinator
4. Address of POTW:
Street/Post Office Box Post Office Box 617
City/State/Zip Code Lincolnton, NC 28093-0617
Phone Number: [phone] Fax Number: [phone] E-Mail: [e-mail]
5. Audit Date: 09/05/2019
6. Last Inspection Date: 12/12/2017 Inspection Type: ® PCI ❑ Audit
7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? ® Yes ❑ No
If No, Explain.
8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? ® Yes ❑ No
If Yes, Explain. An effluent fecal coliform weekly average violation was reported in January 2019.
9. Is POTW under an Order That Includes Pretreatment Conditions? ❑ Yes ® No
Order Type and Number: Are Milestone Dates Being Met? ❑ Yes ❑ No ® NA
Parameters Covered Under Order
ICIS Coding:
Main Program Permit Number MM/DD/YY
NCO025496 09/05/19
10. Current Number of Significant Industrial Users (SIUS)?
.....................................................................................................................................................................................................................................................................................................
7
SIUS
..........................
11. Current Number of Categorical Industrial Users (CIUS)?
.....................................................................................................................................................................................................................................................................................................
3
CIUS
....................
12. Number of SIUs Not Inspected by POTW in Last Calendar Year?
.....................................................................................................................................................................................................................................................................................................
0
......................
13. Number of SIUs Not Sampled by POTW in Last Calendar Year?
.....................................................................................................................................................................................................................................................................................................
0
.....................
14. Enter Higher Number of 12 or 13
.....................................................................................................................................................................................................................................................................................................
0
NOIN
..........................
15. Number of SIUs with No IUP, or with an Expired IUP
.....................................................................................................................................................................................................................................................................................................
0
NOCM
..........................
16. Number of SIUs in SNC for Either Reporting or Limits Violations During Either of Last 2
1
PSNC
Semi -Annual Periods (Total Number of SIUs in SNC)
.....................................................................................................................................................................................................................................................................................................
..........................
17. Number of SIUs in SNC for Reporting During Either of Last 2 Semi -Annual Periods
.....................................................................................................................................................................................................................................................................................................
1
MSNC
..........................
18. Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi -Annual Periods
.....................................................................................................................................................................................................................................................................................................
0
SNPS
..........................
19. Number of SIUs in SNC for Both Reporting and Limits Violations During Either of Last 2
0
Semi -Annual Periods
20. Number of SIUs in SNC for Self -Monitoring Reauirements that were Not Insnected or Sampled
0
SNIN
NC DWR Pretreatment Audit Form Revised: July 25, 2007 Page 1

21. PRETREATMENT PROGRAM ELEMENTS REVIEW
Program Element:
NCO025496
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
5/8/17
® Yes ❑ No
8/3/17
® Yes ❑ No
6/1/22
Industrial Waste Survey (IWS)
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
Enforcement Response Plan (ERP)
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
Legal Authority (Sewer Use Ordinance-SUO)
22. Do you have any towns and/or areas from which you receive wastewater which are not in your annexed jurisdiction?
❑ Yes ® No If yes, Please list these towns and/or areas.
23. If yes to #22, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? ❑ Yes ❑ No ® NA
A copy, if not already submitted, should be sent to Division.
24. If yes to #22, Have you had any trouble working with these towns or districts? ❑ Yes ❑ No ®NA
If yes, Explain.
25. Date of Last SUO Adoption by Local Council 7/10/14
26. Have you had any problems interpreting or enforcing any part of the SUO? ❑ Yes ® No
If yes, Explain.
Enforcement (Enforcement Response Plan-ERP)
27. Did you send a copy of the ERP to your industries? ® Yes ❑ No
If no, POTW must send copy within 30 days.
28. Have you had any problems interpreting or enforcing any part of the ERP (i.e. any adjudication, improper enforcement, etc?
❑ Yes ® No If yes, Explain.
29. List Industries under a Schedule or Order and Type of Schedule or Order. None
Resources
30. Please Rate the Followins: S=Satisfactory M=Marsinal U=Unsatisfactory
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
®S ❑M UK
Access to POTW Vehicles for
-
Sampling, Inspections, and
®S ❑M ❑U
Emergencies
Access to Operable Sampling
Equipment
®S Elm Flu
Availability of Funds if Needed for
Additional Sampling and/or Analysis
®S ❑M ❑U
Reference Materials
®S ❑M ❑U
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
❑S ❑M ❑U
Computer Equipment (Hardware and
Software)
®S ❑M ❑U
NC DWR Pretreatment Audit Form Revised: July 25, 2007 Page 2

31. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No
Explain Yes or No. Excel
32. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
POTW bills SIUs for sampling costs.
Public Perception/ Participation:
33. Are there any local issues affecting the pretreatment program (e.g.. odor, plant closing, new or proposed plants)?
® Yes ❑ No If yes, Explain. The POTW is in the process of permitting a new metal finisher/CIU (Bosch Tools).
34. Has any one from the public ever requested to review pretreatment program files? ❑ Yes ® No
If yes, Explain procedure. If no, How would the request be addressed? All requests would be referred to the Water Resources
Director. The Water Resources Director would coordinate with the Pretreatment Coordinator for a time and location for
the file review.
35. Has any industry ever requested that certain information remain confidential from the public? ❑ Yes ® No If yes, Explain
procedure for determining whether information qualified for confidential status, as well as procedure for keeping files confidential
from public. If no. how would the request be addressed? The Water Resources Director and Pretreatment Coordinator would
review information requested to be confidential. Any confidential information would be secured in a locked file cabinet.
36. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? ® Yes ❑ No
37. Is the public notified about changes in the SUO or Local Limits? ® Yes ❑ No
38. Were all industries in SNC published in the last notice? ® Yes ❑ No ❑ NA
Permitting (Industrial Waste Survey-IWS):
39a... How does the POTW become aware of new or changed Users? The POTW's Economic Development personnel
would contact the Pretreatment Coordinator of any new users. The Pretreatment Coordinator also performs site
visits to new and/or Non-SIUs to verify manufacturing products/processes.
39b. Once the POTW becomes aware of new or changed Users, how does the POTW determine which industries have the
reasonable potential to adversely impact the WWTP and therefore require a new permit or a permit revision? (Who is an
SIU?) The Pretreatment Coordinator would evaluate the manufacturing processes (per site visit), IWS Short/Long
Form information, any categorical waste streams, pollutant loading, and flow.
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
❑Yes ®No If Yes, How many are there?
Please list each site and how it is permitted, if applicable.
41. Does the POTW accept waste by (mark if applicable) ❑ Truck ❑Dedicated Pipe ® NA
42. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples drawn,
manifests required) N/A. The POTW does not accept septage and/or industrial waste.
43. How does the POTW allocate its loading to industries? Mark all that apply
❑ Uniform Limits ® Historical Industry Need ❑ By Surcharge ® Categorical Limits ❑ Other
Explain Other:
44. Review POTW's copies of current allocation tables for each WWTP. Are there any over allocations? ❑ Yes ® No
If yes, What parameters are over allocated?
45. If yes to #44, What is being done to address the over allocations? (short-term IUPs, HWA to be revised, pollutant study, etc.)
N/A.
46. Does the POTW keep pollutant loading in reserve for future growth / safety? ® Yes ❑ No
If yes, what percentage of each parameter? 15 - 20%
47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) ❑ Yes ® No
If yes, Explain.
48. How does the POTW decide on which pollutants to limit in the permits? Monitor for? (for example: were only those pollutants
listed on the application limited; categorical parameters; NPDES Pollutants of Concern) Categorical parameters and NPDES
POCs.
NC DWR Pretreatment Audit Form Revised: July 25, 2007 Page 3

49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits ? Explain.
New SIUs — three sampling events per six months with a potential reduction in monitoring based on sampling results.
Active SIUs — typically two sampling events per six months.
Permit Compliance:
50. Does the POTW currently have or during the past year had any permits under adjudication? ❑ Yes ® No
If yes, which industries? What was (will be) the outcome of the adjudication?
51. Demonstrate how the POTW judges compliance. This should include compliance judgment on all violations of limits, reporting
requirements, and permit conditions, as well as for SNC. Compliance Judgement Worksheet - SNC determinations; violations
(limit, monitoring, reporting, etc.) based on approved ERP.
52. Does the POTW use the Division's model inspection form or equivalent? ® Yes ❑ No
If no, does the POTW form include all DWQ data? ❑ Yes ❑ No
53. Were all SIUs evaluated for the need of a slug/spill control plan during their most recent inspections? ® Yes ❑ No
If no, Explain.
54. What criteria are used to determine if a slug/spill control plan is needed? Chemical storage practices, presence and locations of
floor drains and secondary containment, potential impacts to WWTP.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate? Emergency contacts kept
current, proper storage practices and secondary containment, adequate spill response equipment.
56. How does the POTW decide where the sample point for an SIU should be located? Pretreatment system effluent and/or
regulated waste streams prior to comingling with domestic wastewater.
57. Has the POTW established a procedure to ensure that representative samples will be taken by the POTW or SIU each time?
(example: correct location; proper programming of sampler; clean equipment; swirling the sample bucket uniformly)
POTW: ® Yes ❑ No SIU: ® Yes ❑ No If yes, Explain. POTW — Laboratory and sampling manuals/SOPS;
SIUs contract commercial laboratory to perform sampling and analyses.
58. Who performs sample analysis for the POTW for Metals — Blue Ridge Labs; Two Rivers Utilities — Low level mercury
Conventional Parameters — Prism Labs
Organics —_Blue Ridge Labs
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
POTW uses internal COC and the contracted laboratory's COC; SIUs use contracted laboratory's COC.
Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis (HWA):
60a.
60b.
60c.
60d.
60e.
60f.
Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑ NO
Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ® YES ❑ NO
Is LTMP/STMP Data Maintained in Table or Equivalent? ® YES ❑ NO Is Table Adequate? ® YES ❑ NO
All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? ® YES ❑ NO
If NO to any above, list violations
Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ® NO
If yes, which ones? Eliminated: Added:
61. Do you complete your own headworks analysis (HWA) ? ® Yes ❑ No
If no, Who completes your HWA? Phone:
62. Do you have plans to revise your HWA in the near future? ❑ Yes ® No
If yes, What is the reason for the revision? (mark all that apply) ❑Increased average flow ❑NPDES limits change
❑More LTMP data available ❑Resolve over allocation 05 year expiration ❑Other, explain.
63. In general, what is the most limiting criteria of your HWA?
❑Inhibition ❑ Pass Through ®Sludge Quality
64. Do you see any way to increase your loading in the future (Example: obtaining more land for sludge disposal)? ❑ Yes ❑ No
Explain. N/A. Reserve capacity is available at the WWTP.
NC DWR Pretreatment Audit Form Revised: July 25, 2007 Page 4

Summary:
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment? No
INDUSTRIAL USER PERMIT IUP FILE REVIEW:
66. User Name
1. Cataler NA
2. Celadon
3. FMS Enterprises USA
67. IUP Number
1 0021
0028
1 0027
68. Does File Contain Current Permit?
I
®
Yes ❑ No
® Yes ❑ NoI
® Yes
❑ No
69. Permit Expiration Date
1 6/30/23
2/28/23
4/30/23
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
I N/A
N/A
N/A
71. Does File Contain Permit Application Completed Within One Year Prior
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
to Permit Issue Date?
72. Does File Contain Inspection Completed Within Last Calendar Year?
I ® Yes ❑ No
® Yes ❑ NoI
® Yes ❑ No
73. a. Does File Contain Slug/Spill Control Plan?
. ®Yes ❑No
Fb.
a. []Yes ®No
a. ❑Yes ®No
b. If No, is One Needed? (See Inspection Form from POTW
❑Yes []No
b. ❑Yes ®No
b. []Yes ®No
74. 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)?
75. a. Does File Contain Original Permit Review Letter from Division?
a. ®Yes ❑No
a. ®Yes []No
a. ®Yes [-]No
b. All Issues Resolved?
b.❑Yes❑No®N/A
b.❑Yes❑No®N/A
b.❑Yes❑No®N/A
76. During Most Recent Semi -Annual Period, Did POTW Complete its
® Yes ❑ No
®Yes ❑ No
® Yes ❑ No
Sampling as Required by IUP, including Flow?
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
❑
Yes
❑ No
® Yes ❑ No
® Yes ❑ No
78. During Most Recent Semi -Annual Period, Did SIU Complete its
®Yes❑No❑N/A
®Yes❑No❑N/A
®Yes❑No❑N/A
Sampling as Required b IUP, includingFlow?
11
79. During Most Recent Semi -Annual Period, Did SIU submit all reports on
®Yes❑No❑N/A
®Yes❑No❑N/A
®Yes❑No❑N/A
time?
80a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑NOON/A
file include process/dilution flows as Required b IUP?
80b. For categorical lUs with Production based limits, does file include
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑No®N/A
production rates and/or flows as Required by IUP?
81. During Most Recent Semi -Annual Period, Did POTW Identify All
❑Yes❑NOON/A
❑Yes❑No®N/A
❑Yes❑No®N/A
Limits Non -Compliance from Both POTW and SIU Sampling?
82. During Most Recent Semi -Annual Period, Did POTW Identify All
❑Yes❑NOON/A
❑Yes❑No®N/A
❑Yes❑No®N/A
Re ortin Non -Compliance from SIU Sampling?
83. a. Was 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 Violations?
b. Did Industry Resample and submit results to POTW within 30 Days?
b•❑Yes❑No®N/A
b.❑Yes❑No®N/A
b.❑Yes❑No®N/A
c. If applicable, did POTW resample and obtain results within 30 days of
becoming aware of SIU limit violations in the POTW's sampling of SIU?
c.❑Yes❑No®N/A
c.❑Yes❑No®N/A
c.❑Yes❑No®N/A
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
I
❑
Yes
®No
11
❑
Yes
®
No
❑ Yes
® No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
❑Yes❑No®N/A
®Yes❑No❑N/A
❑Yes❑No®N/A
Specified in POTW's ERP (NOVs, Penalties, timing, etc.)?
86. Does File Contain Penalty Assessment Notices?
❑Yes❑NOON/A
®Yes❑No❑N/A
❑Yes❑No®N/A
87. Does File Contain Proof Of Penalty Collection?
❑Yes❑No®N/A
®Yes❑No❑N/A
❑Yes❑No®N/A
88. a. Does 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
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
❑ Yes ®
®
❑ Yes ® No
Information For You?
!]FM77Ts
!j
FILE REVIEW COMMENTS:
16. Kaco was in SNC during second half of 2018 for reporting violations.
72. SIU inspections were performed by the POTW on 12/6/18 (Cataler), 2/28/18 (Celadon), and 12/20/18 (FMS Enterprises).
78. Cataler, Celadon, and FMS Enterprises all contract Blue Ridge Labs to perform sampling and analyses.
85. The POTW issued NOVs (dated 4/22/19 and 6/14/19) to Celadon for the discharges of unauthorized process water. A civil penalty
of $1500.00 was assessed with the second NOV (issued in June 2019).
NC DWR Pretreatment Audit Form Revised: July 25, 2007 Page 5

INDUSTRY INSPECTION PCS CODING:
Trans.Code Main Program Permit Number MM/DD/YY Inspection type Inspector Facility Type
0 N C 0 0 2 5 4 log IOS 19 0 ]KI 20
(DTIA) (TYPI) (INSP) (FACC)
1. Industry Inspected: McMurray Fabrics
2. Industry Address: 1140 Flint Street, Lincolnton, N.C. 28092
3. Type of Industry/Product: Textile/Fabric Dyeing and Finishing
4. Industry Contact: Mike Mills Title: Plant Engineer Phone: [phone]
5. Does the POTW Use the Division Model Inspection Form or Equivalent? ® Yes ❑ No
6. Did the POTW Contact Conduct the Following Parts of the Industrial Inspection Thoroughly?
Comments:
A. Initial Interview
® Yes
❑ No
B. Plant Tour
® Yes
❑ No
C. Pretreatment Tour
® Yes
❑ No
D. Sampling Review
® Yes
❑ No
E. Exit Interview
® Yes
❑ No
Industrial Inspection Comments:
The manufacturing facility has approximately 100 employees and operates two shifts, twenty-four hours per day, three to four days per
week for the dye house and one shift four to five days per week for the frames. The facility produces approximately 44,000 pounds of
product per week. The pretreatment facility includes the following: collection pits, pump systems, screening, pH adjustment (56%
acetic acid), and aerated holding pond. Discharge flows are based on the water usage readings. The holding pond is lowered twice per
year (during July and December shut down periods) to remove any sludge if needed. Heritage -Crystal Clean (HCC) has been contracted
to remove any accumulated sludge/debris in the holding pond along with all used oils, oily rags, etc.
The facility's records were organized and well maintained.
SUMMARY AND COMMENTS:
The records reviewed during the inspection were organized and well maintained. The City's Industrial Pretreatment Program was being
well managed and properly implemented.
NOD: ❑ Yes
® No
NOV: ❑ Yes
® No
QNCR: ❑ Yes
® No
POTW Rating:
Satisfactory
AUDIT COMPLETED BY:
Marginal ❑
a��D/ocuSignedd by:
WPiY �Gui
A61696D90CC3437...
Wes Bell, Environmental Specialist II
Unsatisfactory ❑
TE: 9/9/2019
Doccu/'Signed by:
AUDIT REVIEWED BY: AUCCWAF27425... DATE: 9/9/2019
W. Corey Basinger, Regional Supervisor
NC DWR Pretreatment Audit Form Revised: July 25, 2007 Page 6