NC0020184_Pretreatment_IUP_Renewal_Letter_20191125

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
NORTH CAROLINA
Environmental Quality
November 25, 2019
Via Electronic Mail ([e-mail])
Chris English
Pretreatment Coordinator
Two Rivers Utilities
P.O. Box 1748
Gastonia, NC 28053
Subject: Pretreatment Review of Industrial User Pretreatment Permit (IUP)
Two Rivers Utilities; Gaston County
WWTP: Long Creek, NPDES#: NCO020184
Dear Mr. English:
The Pretreatment, Emergency Response and Collection Systems (PERCS) Unit of the Division of Water
Resources has reviewed the Industrial User Pretreatment Permit (IUP) renewal submitted by Two Rivers
Utilities for the following Significant Industrial User (SIU). The IUP was received by the Division on
November 1, 2019.
IUP # SIU NAME
1068 OC Comp Non -Woven Tech
The review indicates that with the following comments, the IUP is adequate and meets the minimum
requirements of 15A NCAC 2H .0905 and .0916 and 40 CFR 403.8(f)(1)(iii). The allocation table maintained
in the Division's database has been updated.
1. Please submit a copy of transmittal letter to PERCS for our records once it is available.
2. It is noted during the review that the flow limit was changed to a monthly average from a daily
maximum limit. Monthly average limits can be a very effective SIU control tool. However, they do
not provide as much control as a daily maximum limit in preventing hydraulic surges and shock
pollutant loads at the WWTP. If the POTW chooses to continue without daily limits, the Division
expects the POTW to closely review this SIU's data as well as the POTW data, to be able to
document slug loads, to take immediate action to stop slug loads, and promptly modify the IUP
to reinstate daily maximum limits as needed.
Federal and State pretreatment regulations require the local delegated pretreatment program to
effectively control and document the discharge of wastewater from Significant/Categorical Industrial
Users to the POTW. It is the POTW's responsibility to ensure that these objectives are consistently met.
Thank you for your continued cooperation with the Pretreatment Program. If you have any questions or
comments, please contact me at 919-707-3627 [email: [e-mail]].
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617
Noana GwauNn �
919.707.9000

Sincerely,
DocuSigned by:
Vivien Zhong, PERCS Unit
vz/Two Rivers_long_iup_123 E42E88CDBD404A7...
Ec: PERCS Unit File
Mike Alexander, Two Rivers Utilities
Wes Bell, Mooresville Regional Office
Central Files (Laserfiche)