NC0023884_Inspection_20200124

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
Stephanie Scheringer, Division Manager
Two Rivers Utilities
Post Office Box 1748
Gastonia, North Carolina 28053
Dear Ms. Scheringer:
NORTH CAROLINA
Environmental Quality
24 January 2020
Subject: Pretreatment Compliance Inspection
Two Rivers Utilities
NPDES Permit No. NCO020184
Gaston County
Enclosed is a copy of the Pretreatment Compliance Inspection Report for the inspection of the Two Rivers Utilities'
approved Industrial Pretreatment Program on January 15, 2020, 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(cr�,ncdenr.gov.
Sincerely,
DocuSigned 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 COMPLIANCE INSPECTION (PCI) REPORT
BACKGROUND INFORMATION:
1. Control Authority (POTW) Name: Two Rivers Utilities
2. Control Authority Representative(s): David Shellenbarger, Michael Alexander, Chris English, Cody Austin
3. Title(s): Assistant Division Manager/Compliance, Pretreatment Supervisor, Pretreatment Coordinators
4. Last Inspection Date: 1/18/19 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
ICIS CODING
Main Program Permit Number MM/DD/YY
NCO020184 01/15/2020
7. Current Number Of Significant Industrial Users (SIUs)?
1 25
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?
1 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
0
12. Number of SIUs in SNC For Reporting During Either of the Last 2 Semi -Annual Periods
0
13. Number of SIUs in SNC with Pretreatment Schedule?
0
14. Number of SIUs on Schedules?
0
15. Current Number of Categorical Industrial Users CIUs ?
8
16. Number CIUs in SNC? 11
0
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 Addressed?
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 Addressed?
19. Which Industries have been in SNC for Limits or Reporting during N/A
either of the Last 2 Semi -Annual Periods? Not Been Published for Not Pu
Public Notice?(May refer to PAR if Excessive SIUs in SNC)
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
Ones?
® YES ❑ NO; Long Creek
WWTP — weekly and monthly
average effluent BOD violations
— April 2019.
❑ YES ®NO
dished: N/A
N/A
77ES ®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 Report? ® 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
If yes, which ones? Eliminated: Added:
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 1

28. PRETREATMENT PROGRAM ELEMENTS REVIEW:
Program Element
Long Creek WWTP (NC0020184)
Last Submittal Received
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
5/26/17
® Yes ❑ No
8/28/17
® Yes ❑ No
9/1/2020
Industrial Waste Survey (IWS)
6/11/15
® Yes ❑ No
8/3/15
® Yes ❑ No
6/20/2020
Sewer Use Ordinance (SUO)
12/6/12
® Yes ❑ No
12/27/12
® Yes ❑ No
Enforcement Response Plan (ERP)
6/23/16
® Yes ❑ No
9/13/16
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
7/30/19
® Yes ❑ No
9/6/19
® Yes ❑ No
Program Element
Crowders Creek WWTP (NC0074268)
Last Submittal Received
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
10/31/19
® Yes ❑ No
4/18/17
® Yes ❑ No
In Review
Industrial Waste Survey (IWS)
6/11/15
® Yes ❑ No
8/3/15
® Yes ❑ No
6/20/2020
Sewer Use Ordinance (SUO)
12/6/12
® Yes ❑ No
12/27/12
® Yes ❑ No
Enforcement Response Plan (ERP)
6/23/16
® Yes ❑ No
9/13/16
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
5/26/17
® Yes ❑ No
8/25/17
❑ Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW:
29. User Name
F. Lubrizol
2. Gaston Co. Landfill
3. Daimler Trucks NA
30. IUP Number
1053
1051
1 1023
31. Does File Contain Current Permit?
® Yes ❑
I ® Yes ❑
I ® Yes ❑
No
32. Permit Expiration Date
8/31/2021
12/31/2020
12/31/2020
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
414.85
N/A
433.17
34. Does File Contain Permit Application Completed Within One Year Prior
® Yes ElNo
FffVTE:] No
® Yes ❑ No
to Permit Issue Date?
35. Does File Contain an Inspection Completed Within Last Calendar Year?
I ® Yes ❑ No
® Yes ❑ No 11
® Yes ❑ No
36. a. Does the File Contain a Slug/Spill Control Plan?
a. ®Yes ❑No
a. ®Yes []No
a. ®Yes ❑No
b. If No, is One Needed? (See Inspection Form from POTW)
b. El es ❑No
b. ❑Yes ❑No
b. ❑Yes ❑No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
❑Yes❑NoNN/A
❑Yes❑NoNN/A
®Yes❑No❑N/A
Organic Management Plan (TOMP)?
11
38. a. Does File Contain Original Permit Review Letter from the Division?
a. ®Yes ❑No
a. ®Yes []No
a. ®Yes ❑No
b. All Issues Resolved?
b.❑Yes❑No®N/A
b.❑Yes❑NoNN/A
b.❑Yes❑No®N/A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
its Sampling as Required by IUP, including flow?
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
® Yes ❑
I
®
Yes ❑ No
®Yes
❑ No
41a. During the Most Recent Semi -Annual Period, Did the SIU Complete its
NYes❑No❑N/A
NYes❑No❑N/A
NYes❑No❑N/A
Sampling as Required by IUP, including flow?
41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports
NYes❑No❑N/A
NYcs❑No❑N/A
NYes❑No❑N/A
on time?
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑NoNN/A
❑Yes❑NoNN/A
❑Yes❑NoNN/A
file includeprocess/dilution flows as Required by IUP?
42b. For categorical IUs with Production based limits, does file include
❑Yes❑NoNN/A
❑Yes❑NoNN/A
❑Yes❑NoNN/A
production rates and/or flows as Required by IUP?
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑NoNNA
❑Yes❑NoNN/A
❑Yes❑NoNN/A
All Limits Non -Compliance from Both POTW and SIU Sampling?
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑NoNN/A
❑Yes❑NoNN/A
❑Yes❑NoNN/A
All Reporting Non -Compliance from SIU Sampling?
44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
a.❑Yes❑NoNN/A
a.❑Yes❑No®N/A
a.❑Yes❑NoNN/A
Monitoring Violations?
b. Did Industry Resample and submit results to POTW Within 30 Days?
b.❑Yes❑NoNN/A
b.❑Yes❑No®N/A
b.❑Yes❑NoNN/A
c. Did POTW resample within 30 days of knowledge of SIU limit
c.❑Yes❑NoNN/A
c.❑Yes❑No®N/A
c.❑Yes❑NoNN/A
violations from the POTW sample event?
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 2

45. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
❑
Yes
®
No
❑
Yes
®
No
❑
Yes
®
No
46. During the Most Recent Semi -Annual Period, Was Enforcement Taken
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
❑Yes❑No®N/A
❑Yes❑No[D
❑Yes❑No®N/A
47. Does the File Contain Penalty Assessment Notices?
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑No®N/A
48. Does The File Contain Proof Of Penalty Collection?
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑NoON/A
49. a. Does the File Contain Any Current Enforcement Orders?
b. IS SIU in Compliance with Order?
a.❑Yes❑No®N/A
b.❑Yes❑No®N/A
a.❑Yes❑No®N/A
b.❑Yes❑No®N/A
a.❑Yes❑No®N/A
b.❑Yes❑No®N/A
50. Did the POTW Representative Have Difficulty in Obtaining Any of This
Requested Information For You?
❑ Yes ® No
❑ Yes ®No
❑ Yes ®No
FILE REVIEW COMMENTS:
35. The POTW performed the SIU inspections on 10/28/19 (Lubrizol), 12/13/19 (Gaston Co. Landfill), and 10/10/19 (Daimler Trucks NA).
39. The POTW's on -site lab performs all analyses except for cyanide, oil & grease, phenols, organics and chronic toxicity. Shealy
Environmental Services is contracted to perform these analyses (and selected metals if needed) and Meritech is contracted to perform
toxicity analyses (if required).
41 a. The POTW performs IUP monitoring for the SIUs; however, Lubrizol and Daimler Trucks both contract Prism Laboratories, Inc. during
split sampling events (with the POTW).
SUMMARY AND COMMENTS:
The records reviewed during the inspection were organized and well maintained. The POTW must ensure that the contracted lab for Lubrizol
and Daimler Trucks adheres to the required IUP detection levels for copper, lead, zinc, nickel, TSS, oil & grease and total phosphorus. In
addition, if the POTW will continue to perform sampling in lieu of the Gaston Co. Landfill, then the applicable monitoring requirements (under
the Industry column) should be removed during the next permit renewal process (permit expires on 12/31/2020).
NOD: ❑ YES ® NO
NOV: ❑ YES ® NO
QNCR: [—]YES ® NO
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory_ ❑
DcuDATE:
Signed
by:
PCI COMPLETED BY:
E—',,96D90CC3437
23PAi(i... 1/ 2 4/ 2 0 2 0
Wes Bell, Environmental Specialist II
Doccu//Signed by:
PCI REVIEWED BY: A14CC681AF27425... DATE: 1/24/2020
W. Corey Basinger, Regional Supervisor
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 3