NC0021181_Inspection_20191119 (2)

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
Mr. Daniel Perry
Pretreatment Coordinator
City of Belmont
Post Office Box 431
Belmont, North Carolina 28012
Dear Mr. Perry:
NORTH CAROLINA
Environmental Quality
November 19, 2019
Subject: Pretreatment Audit Inspection
City of Belmont
NPDES Permit No. NCO021181
Gaston County
Enclosed is a copy of the Pretreatment Audit Inspection Report for the inspection of the City of Belmont's
approved Industrial Pretreatment Program on November 6, 2019, by Mr. Wes Bell of this Office.
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 wes.bell(cbncdenr.gov.
Sincerely,
DocuSigned by:
p 'i**' H NUft for
F161 F669A2D84A3...
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
Enclosure: Pretreatment Audit 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 Belmont
2. Control Authority Representative(s): Tanya Setzer, Daniel Perry
3. Title(s): WWTP Supervisor/ORC, Pretreatment Analyst/Coordinator
4. Address of POTW:
Street/Post Office Box 298 Parkdale Drive/Post Office Box 431
City/State/Zip Code Belmont, NC 28012
Phone Number: [phone] Fax Number: 704-825-6505 E-Mail: dperryncityofbelmont.org
tsetzer(& cityof belmont.or2
5. Audit Date: 11/06/2019
6. Last Inspection Date: 05/04/2018 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.
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
INIC10101211111811 I111061191
10.
....................................................................................................................................................................................................................................................................................................
Current Number of Significant Industrial Users (SIUS)?
1
11.
....................................................................................................................................................................................................................................................................................................
Number of SIUs with No IUP, or with an Expired IUP?
0
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.
....................................................................................................................................................................................................................................................................................................
Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi -Annual Periods?
0
15.
....................................................................................................................................................................................................................................................................................................
Number of SIUs in SNC for Reporting During Either of Last 2 Semi -Annual Periods?
0
16.
....................................................................................................................................................................................................................................................................................................
Number of SIUs in SNC with Pretreatment Schedule?
0
17.
....................................................................................................................................................................................................................................................................................................
Number of SIUs on Schedules?
0
18.
Current Number of Categorical Industrial Users (CIUS)?
0
19.
Number of CIUs in SNC?
0
NC DWR Pretreatment Audit Form Revised: December 2016 Page 1

20. PRETREATMENT PROGRAM ELEMENTS REVIEW
Program Element:
NCO021181
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
5/10/16
® Yes ❑ No
8/24/16
❑ Yes ❑ No
5/1/21
Industrial Waste Survey (IWS)
7/24/15
® Yes ❑ No
12/4/15
® Yes ❑ No
8/1/20
Sewer Use Ordinance (SUO)
5/20/13
® Yes ❑ No
5/28/13
® Yes ❑ No
Enforcement Response Plan (ERP)
11/5/19
® Yes ❑ No
1/10/08
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
1/18/19
® Yes ❑ No
2/26/19
® Yes ❑ No
Legal Authority (Sewer Use Ordinance-SUO)
21. 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.
22. 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.
23. If yes to #22, Have you had any trouble working with these towns or districts? ❑ Yes ❑ No ®NA
If yes, Explain.
24. Date of Last SUO Adoption by Local Council 5/6/13
25. Have you had any problems interpreting or enforcing any part of the SUO? ❑ Yes ® No
If yes, Explain.
Enforcement (Enforcement Response Plan-ERP)
26. Did you send a copy of the ERP to your industries? ❑ Yes ❑ No
If no, POTW must send copy within 30 days.
27. 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.
28. List Industries under a Schedule or Order and Type of Schedule or Order
None
Resources
29. Please Rate the Following: S=Satisfactory M=Marginal U=Unsatisfactory
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
®S ❑M ❑U
Access to POTW Vehicles for
Sampling, Inspections, and
®S ❑M ❑U
Emergencies
Access to Operable Sampling
Equipment
®S ❑ M 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: December 2016 Page 2

30. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No
Explain Yes or No. Excel
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain. The SIU is billed directly for
the sampling fees.
Public Perception/ Participation:
32. Are there any local issues affecting the pretreatment program (e.g.. odor, plant closing, new or proposed plants)?
❑ Yes ® No If yes, Explain. Note: The POTW's governing body has approved the elimination of the WWTP discharge
with all wastewater being conveyed to a Charlotte Water WWTP in the future.
33. 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? By appointment; files reviewed at the WWTP.
34. 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 request would be reviewed and approved by Public Utilities
Director, Superintendent and Pretreatment Coordinator. Confidential files would be secured in a locked storage area.
35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? ® Yes ❑ No
36. Is the public notified about changes in the SUO or Local Limits? ® Yes ❑ No
37. Were all industries in SNC published in the last notice? ❑ Yes ❑ No ®NA
Permitting (Industrial Waste Survey-IWS):
38. How does the POTW become aware of new or changed Users? POTW's Planning & Zoning Dept. contacts the
Pretreatment Staff.
39. 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
SILT?) Review information on IWS forms (Short/Long), flow volumes, type of industrial activity, categorical waste
streams, wastewater characteristics/loading and potential impacts to WWTP.
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) The POTW does not accept waste from septage haulers.
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.)
46. Does the POTW keep pollutant loading in reserve for future growth / safety? ® Yes ❑ No
If yes, what percentage of each parameter? 10 - 15%
47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) ❑ Yes ® No
If yes, Explain.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 3

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) NPDES POCs, categorical parameters,
wastewater characteristics including flow.
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
New SIUs - monthly monitoring for baseline, reduce monitoring based on loading/sample results; Quarterly monitoring
would be required at a minimum.
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. SNC determinations based on Compliance Judgement Worksheet;
Violations (limit, monitoring, reporting, permit conditions, 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. Only SIU required to have slug/spill control plan.
54. What criteria are used to determine if a slug/spill control plan is needed? Presence of floor drains, chemical storage practices,
secondary containment.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate? Emergency contacts kept
current, adequate secondary containment, spill response equipment on -site.
56. How does the POTW decide where the sample point for an SIU should be located? Pretreatment system effluent prior to
combining with domestic waste stream.
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 has sampling SOP, POTW samples for the
SIU via contract lab (Shealy Environmental).
58. Who performs sample analysis for the POTW for Metals — Shealy Environmental Services
Conventional Parameters — Shealy Environmental Services
Organics - Shealy Environmental Services
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Contract lab's (Shealy Environmental Services) COC is used for the POTW/SIU sampling events.
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?
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.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 4

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 in WWTP.
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. Spartan Dyers
2.
3.
67. IUP Number
0009
68. Does File Contain Current Permit?
® Yes ❑ No
❑ Yes ❑
I ❑ Yes ❑ No
69. Permit Expiration Date
11/5/24
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
1 410.70
71. Does File Contain Permit Application Completed Within One Year Prior
® Yes ❑ No
F
❑ Yes ❑ No
❑ Yes ❑ No
to Permit Issue Date?
1
72. Does File Contain Inspection Completed Within Last Calendar Year?
® Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
73. a. Does File Contain Slug/Spill Control Plan?
a. EYes ❑No
Eb.
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❑MON/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. EYes ❑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 b IUP, includingFlow?
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
I ® Yes ❑ No7j
❑ 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 by IUP, including Flow?
79. During Most Recent Semi -Annual Period, Did SIU submit all reports on
®Yes❑No❑N/A
F
❑Yes❑No❑N/A
❑Yes❑No❑N/A
time?
80a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑MEN/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
file include process/dilution flows as Required b IUP?
80b. For categorical IUs 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
es❑No❑N/A
F5Y
❑Yes❑No❑N/A
❑Yes❑No❑N/A
Limits Non -Compliance from Both POTW and SIU Sam lin ?
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-Com liance 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❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
87. Does File Contain Proof Of Penalty Collection?
❑Yes❑MSN/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❑NoIR
b.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
Yes ®
ElNo
❑ Yes ❑
❑ No
Information For You?
!oFMTeT
NC DWR Pretreatment Audit Form Revised: December 2016 Page 5

FILE REVIEW COMMENTS:
72. POTW performed the inspection at Spartan Dyers on 11/6/18.
76. The POTW samples the SIU on a monthly basis.
85. The POTW issued a NOV on 7/16/19 for multiple temperature violations (daily maximum) in June 2019.
INDUSTRY INSPECTION PCS CODING:
Trans.Code Main Program Permit Number MM/DD/YY Inspection type Inspector Facility Type
❑N N C 0 0 2 1 1 111 106 19 U❑ =S 2❑
(DTIA) (TYPI) (INSP) (FACC)
1. Industry Inspected: Spartan Dyers
2. Industry Address/Mailing: Post Office Box 790, Belmont, NC 28012 Physical: 217 Sterling Street, Belmont, NC 28012
3. Type of Industry/Product: Textile
4. Industry Contact: Peter Stroupe Title: Plant Engineer Phone: [phone]
Fax: [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:
Spartan Dyers employs approximately sixty-five personnel and operates two production shifts, twenty-four hours per day five days per
week. The facility is currently producing over 3.6 million pounds of dyed yarn per year. The pretreatment system consists of pH
adjustment, aerated lagoon, and continuous pH/flow/temperature measurement system. The POTW is automatically notified if the flow,
pH and/or temperature levels fall outside the established set points from the SIU's continuous measurement system.
SUMMARY AND COMMENTS:
The records reviewed during the inspection were organized and well maintained. The POTW's Industrial Pretreatment Program was
being properly implemented.
NOD: ❑ Yes ® No
NOV: ❑ Yes ® No
QNCR: ❑ Yes ® No
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory ❑
NC DWR Pretreatment Audit Form Revised: December 2016 Page 6

a—"96D90CC3437
cuSignedd by:
AUDIT COMPLETED BY: ... DATE: 11/18/2019
Wes Bell, Env. Specialist II, Mooresville Regional Office
EDocuSigned by:
F161FB69A2D84A3
a 44W H P44-f. 11.18.19
AUDIT REVIEWED BY: . DATE:
for W. Corey Basinger, Regional Supervisor, Mooresville Regional Office
NC DWR Pretreatment Audit Form Revised: December 2016 Page 7