NC0024945_Pretreatment_Annual_Report_2018updates_20200513

CHARLOTTE
W4)TER
May 11, 2020
Vivien Zhong
NC Division of Water Resources
Water Quality Permitting Section
Wastewater Branch - PERCS Unit
1617 Mail Service Center
Raleigh, NC 276994617
Subject: Addendum to 2018 Pretreatment Annual Report
Dear Ms. Zhong,
This letter is an update to Charlotte Water's (CLTWater) 2018 Pretreatment Annual Report. Due to investigations that
were ongoing at the time of the 2018 PAR submittal and appeals of the NOVs issued as a result of those investigations,
publishing was delayed for some instances of Significant Non -Compliance (SNC) which occurred in calendar year 2018
and some instances of SNC were not included on the Significant Non -Compliance Report (SNCR) for 2018. As a result
of the completion of the investigations, enforcement and subsequent appeals, updates to the SNCR, Narratives and
Pretreatment Performance Summary for the 2018 PAR have also been made.
Haz�Mat Environmental Services was in SNC in 2018 for Manipulation of Sampling, Monitoring, and Reporting
Requirements. The Notice of Violation (NOV) for this violation was issued in 2019 and the appeal process was
completed in 2020. CLTWater has taken the appropriate steps as required in 40 CFR 403.8(f)(2)(viii), A Public
Notice was published in The Charlotte Business Journal on 04/24/2020 for Haz�Mat Environmental Services
(Haz�Mat) for SNC that occurred in 2018. This information was also posted on Charlotte Water's website for from
April 24-27, 2020. The SNCR for the Sugar Creels WWTP submitted with the 2018 PAR did not include Haz- Mat. The
SNCR for the Sugar Creek WWTP has been updated and is attached. The Narrative for the SIU has also been updated
and is attached.
AERC Acquisition Corporation d/b/a DART, A Clean Earth Company was in SNC in 2018 for failing to ensure self -
monitoring was representative of prevailing conditions. The NOV for this violation was issued in 2019 and the appeal
process was completed in 2020. CLTWater has taken the appropriate steps as required in 40 CFR 403.8(f)(2)(viii),
A Public Notice was published in The Charlotte Business Journal on 04/24/2020 for AERC Acquisition Corporation
d/b/a DART, A Clean Earth Company for SNC that occurred in 2018. This information was also posted on Charlotte
Water's website from April 24-27, 2020. The SNCR submitted with the 2018 PAR did not include this violation
committed by AERC Acquisition Corporation d/b/a DART, A Clean Earth Company. AERC Acquisition Corporation
d/b/a DART, A Clean Earth Company was also in SNC in 2018 for slug discharges of p-cresol. This violation was
inadvertently omitted from the original 2018 SNCR for the Irwin Creels WWTP included with the PAR.
The SNC report for the Irwin Creek WWTP has been updated and is attached. The Narrative for AERC Acquisition
Corporation d/b/a DART, A Clean Earth Company has also been updated and is attached.
As a result of the settlement of both cases it was necessary to update the 2018 Pretreatment Performance Summary.
The number of SIUs in SNC for reporting violations (Item 11) changed from 0 to 2. The updated Pretreatment
Performance Summary is attached.
Charlotte Water 4222 Westmont Drive, Charlotte, NC 28217 charlottewater.org
((n') Operated by the City of Charlotte

CHARLOTTE
W4)TER
If you have any questions regarding these updates, please call Sarah Daley at 704-3364729. In Sarah's absence, you
may also contact me at 704-3364636.
Resi
Bill Gmtert
Environmental Compliance Manager
Charlotte Water
System Protection
Enclosures: 2018 Significant Non -Compliance Report revised April 2020
2018 Narratives for Haz- Mat and Dart revised April 2020
2018 PPS revised April 2020
2018 Additional Public Notice 04/24/2020
Charlotte Water 4222 Westmont Drive, Charlotte, NC 28217 charlottewater.org
((� Operated by the City of Charlotte