NC0020737_SOC Status Report_20200630

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June 30, 2020
City of Kings Mountain WWTP
Pilot Creek
'• -e7 •
Kings Mountain, NC 28086
Derek Denard
North Carolina Department of Environmental Quality
Water Quality Division
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: July 2020 Status Report for Pilot Creek WWTP
Mr. Denard,
The City of Kings Mountain holds NPDES Permit NC0020737. After receipt of the extended
Special Order of Consent (SOC) by the Environmental Management Commision, Pilot Creek has
submitted quarterly Status Reports; informing the State, of ongoing efforts made to reduce
thallium in the collection system for the City of Kings Mountain. According to Scheduled
Activity section, Section 2. (b); this will be the final report for this SOC. If further information is
needed, please contact me for that information.
Coremetech and City of KM TI data to date:
The following chart consists of monthly data from January 2016 until May 2020 regarding
testing results for Cormetech and the POTW's effluent sampling events. These results are the
monthly average for each entity:
s
6
5
J
bao 4
E
3
2
1
0
0 0
0
0
0 0
C
T
a+ >
U1
N Z
2016-2020 TI Data
0 0
0
0
0 0
C
T
?
a+ >
U1 O
N Z
0 0
0
0
0 0
C
T
a+ >
U1
N Z
0 0
0
0
0 0
C
T
a+ >
U1
N Z
0 0 0
0 0 0
C T
Co rmetec h
Co KM

Coremetech SOC info:
Cormetech was put on a Consent Order and Complaince Schedule on December 20, 2019.
Cormetech was put under this order due to falsifying flow data during 2016-2017 timeframe in
order to avoid non-complaince with the City. On June 6, 2020 the SOC for Cormetech expired.
Cormetech submitted a letter of completion with the order on June 5, 2020. In this letter
Cormetech stated the company has taken additional steps on their own to enhance procedures,
training and equipment to ensure compliance with IUP#032. These steps include:
1. Detailed training on all permit conditions provided by the Director of Environmental
Health & Safety to all employees who might impact permit compliance in any manner.
This training was provided in two sessions on January 6, 2020; two sessions on January
8, 2020; and a makeup session on January 22, 2020. Multiple sessions of the training
were completed to ensure coverage of all shifts at the facility.
2. Increased wastewater sampling by utilizing ICP equipment relocated from the
Cormetech Steele Creekfacilityto the Kings Mountain facility. This equipment lab
technicians are currently covering the three production shifts.
3. Additional laboratory technician positions created and filled to allow around -the -clock
wastewater sampling analysis whenever the facilty is operational and discharging
wastewater to the City of Kings Mouintain. Three trained labtechnicians are currently
covering the three production shifts.
4. Additional equipment to better control industrial wastewater. The Cityof Kings
Mountain approved our March 5, 2020 request for Authorization to Construct for the
installation of wastewater control panel, two inline effluent line pH meter, and an
additional tandem flow meter. Although not directly required for compliance with
permitted parameters, this equipment will increase the facility's ability to better control
batch treatment operations, to better control effluent pH, and to ensure that the main
flow meter is operating and recording accuratelyat all times. Installation of the tandem
flow meter is completed. However, efforts for installation of the remaining equipment
have been delayed by the Covid-19 situation. Contractors have not been available to
complete necessary electrical installation work.

The following information was provided to the City regarding compliance activities Cormetech
took pursuant to the Consent Order:
Consent
Activity Description
Deadline
Date
Documentation Submitted to
Ordcr
for
Complated
City of Kings Mvunlailn
Activity
Completion
Number
01114/2020
0111012020
Completed.
4.b.i.
Prepare and submit a
plan of action to
See January 10, 2020 letter to City
achieve conVnuvua
of Kings Mountain that detalic the
compliance flow
following actions taken:
monitoring and
1. Different, approved flowmeter
reporting.
and recorder installed
October S. 2019 and utilized
since November 2019
discharge monitoring report;
2. Additional, back-up f€owmetera
purchased to ensure
compliance; and
3. Third party contracted to
maintain tlowmeter and
recorders stern.
4.b.iv
Increase monitoring
1212012019
06/05/2020
Completed.
for Thallium and
—
Increased monitoring occurred and
Arsenic for the
06106/2020
results submitted with the monthly
duration of the
wastewater monitoring results for
Consent Order.
December 2019 through June
Submit results with
2020. All increased monitoring
monthly report.
samples in compliance with the
Consent Order limits. Results for
the May 2020 sampling will be
submitted no later than June 20,
2020; and results for the ,bane
2020 sampling will be submitted no
later than July 20 2020.
4_b_iii_
Complete and submit
02i0712020
02/0&2020
Completed.
Pilot Studies and
See February B, 2020 letter to City
identify alternatives
of Kings Mountain that details
chosen to achieve
response and fallowing actions
compliance.
taken:
1, Identified areas to increase
control of industrial
wastewater; and
2. Researched additional
e ui meat.
4.b.iv.
Begin construction
03/0612020
03106/2020
Completed.
(upon approval)
See March 6, 2020 letter to City of
and/or implement
Kings Mountain that details
identified process
response, including request to
alternatives .
install additional equipment.
4.b.v.
Achieve compliance
06i061202G
0513112020
Completed.
with final (lUP #032),
All May 2020 sampling results in
with all requirements
compliance with Permit limits. The
in Permit No. 032.
report detailing these results will
be submitted as required no later
than June 20, 2020_ Additionally,
during the Consent Order period,
CORMETECN complied with all
applicable Permit and Consent
Order limits.

Additional Information reeardine Cormetech:
Cormetech requested an flow reduction to 0.125MGD which would also include the City's new
NPDES permitted limits. This modification was received by the Division on February 19, 2020.
Approval letter from the Division was received on March 25, 2020. This permit became
effective on April 1, 2020.
An additional modification was made with effective date May 15, 2020 to include changes to
the limit sheet and Cormetech's permit. These modifications include:
• Changed pH to grab
• Flow method to continuous
• Revised continuous flow monitoring and pH grab definitions
• Added pH calibration requirements
• Added email to reporting monitoring results
Another permit modification took place that will become effective on July 1, 2020. These
modifications were approved by the Division and the approval letter was issued on June 3,
2020. Modifcations for this IUP were as follows:
• Changed 40 CFR type on limit page due to typographical error
• Added foot note to limit page stating monitoring frequency by POTW
• Removed email from section 2a. Reporting monitoring results.
• Added 40CFR433 to Specific conditions Part III, 11.
The Director of Water Resources required the Pretreatment Coordinator to monitor flow and
collect samples at Cormetech at a minimum of monthly. No violation occurred during these
unknown sampling events. No additional monthly flow checks or sampling will take place unless
the POTW seems necessary.
Cormetech's status report information:
March: (received on 3/19/20)
Cormetech engaged a wastewater consulting company, Civil & Environmental Consultants, Inc.
to review their current system. Cormetech stated they have completed their onsite visit
consisting of two days observing their process, reviewing standard operating procedures, and
interviewing wastewater operators. During the visit close out meeting, they did suggest a
couple of minor adjustments in their process but reported that they are following best known
industry practices. The company now has a better understanding on their catalyst regeneration
process and wastewater process so now they are going to do some research on final filtration
options and provide a quote to determine the best practice for managing a filter press cloth
failure. The work will be completed in the coming months pending their availability and
workload.

April: (received on 4/17/20)
This report stated Civil & Environmental Consultants, Inc. submitted the draft report of findings
from their site visit for Cormetech review and comment. The final report will be issued after
receiving and responding to Cormetech's questions, comments, and requests for clarification.
Due to the Covid-19 pandemic, the consultant's office is closes, therefore the path forward for
further researching final filtration options is on hold. The company did mention in the closing
meeting for the site visit that use of total suspended solids or turbidity probe after the filter
presses might be a better solution in the application than installing a "safety" filter.
May: (received 5/15/20)
In the May report, Cormetech stated they are still in the process of reviewing the final report
from Civil & Environmental Consultants, Inc. and working on comments. Their report did not
find any immediate issues that needed to be corrected. Due to the closing of the office, the
path forward for further researching final filtration is still on hold. They also said this work will
continue as soon as possible.
June: (received on 6/18/20)
Civil & Environmental Consultants, Inc. submitted the draft report to Cormetech, after their
review, Cormetech noted there were no major recommendations for improvements to their
system. Cormetech is reviewing their recommendations to see if they can implement them in
their system. Civil & Environmental Consultants, Inc. has begun to work remotely and they all
will begin discussing next steps with the company during the next several weeks.
Cormetech will no longer submit monthly reports unless a change takes place that the POTW
must be notified on. In the event the POTW sees a rise in thallium results submitted by the
company, Cormetech will be required to start sending those reports again.
Improvements to the POTW
The POTW has purchased DO and pH monitors for our three aeration basin. This will give the
ORC around -the -clock reports on the process of the facility. In the event these readings are out
of range, an alarm will sound and send notification of the issue. Due to Covid-19 restrictions,
these monitors have not been installed at this time. Once the restrictions are lifted within the
City, we will proceed with the installation and monitoring.
The Huffstetler Group has been hired by the Cityto rehab our #3 & #4 clarifiers. This project
begin on March 91", 2020. The project has yet to be completed. The scope of work for this
project includes:
#4 Clarifier Replacing the following clarifier mechanism parts:
• Influent well
• Scum trough/beach (includes all rubber)
• Skimmer arm

• Skimmer assembly
• Tie bars
Additional repairs:
• Coat all items above in epoxy paint
#3 Clarifier:
• Remove all weirs and baffles
• Replace new weirs, baffles, supports and hardware
All main components in the #4 clarifier have been installed. Delivery of the new weirs for #4
arrived today (6/29/20) and the Huffstetler employees are installing these currently. Once all
repairs to #4 are completed, #3 system will betook down, cleaned and ready for repair. #3
clarifier will receive all new weirs.
Final Notes:
As shown in the data provided, Cormetech and the City of Kings Mountain have both diligently
reduced the amounts of thallium in our effluent discharges dating back to January 2016. At this
time, the Citydoes not feel as though we will have an issue meeting the required NPDES permit
limitsfor thallium.
According to the City's Special Order by Consent (SOC) EMC SOC WQS16-001 Ad I, the order is
set to expire on August 31, 2020, therefore this is the last construction status report that will be
submitted unless otherwise required and/or notified by the Division. If additional information
is needed, please contact me directly.
As always, it is the City's number one priorityto maintain a compliant effluent at the Pilot Creek
facility. We will continue to operate our Klampress to remove solids from the facility in order to
produce the highest possible quality effluent and work diligentlyto improve the plants overall
performance.
Sincerely,
Richelle Meek
City of Kings Mountain
WWTP Superintendent/ORC
[e-mail]
Office #: [phone]