NC0020184_Regional Office Historical File Pre 2018

ROY COOPER
Governor
MICHAEL S.REGAN
Secretary
S.JAY ZIMMERMAN
Water Resources Director
Environmental Quality
July 13, 2017
Ms. Stephanie Scheringer
Division Manager Wastewater Treatment
Two Rivers Utilities
Post Office Box 1748
Gastonia,North Carolina 28053-1748
Subject: Pretreatment Audit Inspection
Two Rivers Utilities
NPDES Permit No.NC0020184
Gaston County
Dear Ms. Scheringer:
Enclosed is a copy of the Pretreatment Audit Inspection Report for the inspection of the Two
Rivers Utilities' Industrial Pretreatment Program on July 7,2017,by Mr. Wes Bell of this Office. Please
inform the Pretreatment Supervisor of our findings by forwarding a copy of the enclosed report.
Should you have any questions concerning this report,please do not hesitate to contact Mr. Bell
at(704)235-2192,or via email at [e-mail].
Sincerely,
W. Corey Basinger,Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources,NCDEQ
Enclosure:
Inspection Report
cc: Deborah Gore,PERCS Unit
MSC-1617 Central-Basement
WB
State of North Carolina I Environmental Quality'Water Resources I Water Quality Regional Operations
Mooresville Regional Office 1610 East Center Avenue,Suite 310 I Mooresville,North Carolina 28115
704-663-1699

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT AUDIT REPORT
Background Information:
1. Control Authority(POTW)Name: Two Rivers Utilities
2. Control Authority Representative(s):Janet Maddox,Brian Ramsey,Chad Ledford
3. Title(s):Pretreatment Supervisor,Industrial Chemist,Industrial Chemist
4. Address of POTW:
Street/Post Office Box Post Office Box 1748
City/State/Zip Code Gastonia,NC 28053-1748
Phone Number: [phone] Fax Number: (704)-922-0619 E-Mail: [e-mail]
5. Audit Date:7/7/2017
6. Last Inspection Date:3/22/2016 Inspection Type: ®PCI 0 Audit
7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? ®Yes 0 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? 0 Yes 0 No ® NA
Parameters Covered Under Order
PCS(WENDB)Codina:
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac.Type
U INICIO 10 1210111814 I I07(D0 )17I �YPI) Lai
(FACC)
10. Current Number of Significant Industrial Users(SIUS)? 25 SIUS
11. Current Number of Categorical Industrial Users(CIUS)? 9 CIUS
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. Enter Higher Number of 12 or 13 0 NOIN
15. Number of SIUs with No IUP,or with an Expired IUP 0 NOCM
16. Number of SIUs in SNC for Either Reporting or Limits Violations During Either of Last 2 3 PSNC
Semi-Annual Periods(Total Number of SIUs in SNC)
17. Number of SIUs in SNC for Reporting During Either of Last 2 Semi-Annual Periods 0 MSNC
18. Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi-Annual Periods 3 SNPS
19. Number of SIUs in SNC for Both Reporting and Limits Violations During Either of Last 2 0
Semi-Annual Periods
20. Number of SIUs in SNC for Self-Monitoring Requirements that were Not Inspected or Sampled 0 SNIN
-- POOP 1

21. PRETREATMENT PROGRAM ELEMENTS REVIEW
Program Element: Last Submittal Last Approval Date Next Due,
NC0020184 Date In file? Date In file If Applicable
Headworks Analysis(HWA) 6/27/17 ®Yes 0 No 12/20/15 ®Yes 0 No 9/1/20
Industrial Waste Survey(IWS) 6/11/15 Z Yes❑ No 8/3/15 ®Yes❑ No 6/20/20
Sewer Use Ordinance(SUO) 12/6/12 ®Yes 0 No 12/27/12 ®Yes❑ No
Enforcement Response Plan(ERP) 6/23/16 IZ Yes❑ No 9/13/16 ®Yes❑ No
Long Term Monitoring Plan(LTMP) 5/26/17 ®Yes 0 No 2/20/17• ®Yes 0 No
Program Element: Last Submittal Last Approval Date Next Due,
NC0074268 Date In file? Date In file If Applicable
Headworks Analysis(HWA) 3/29/17 ®Yes❑ No 4/18/17 ®Yes❑ No 11/1/19
Industrial Waste Survey(IWS) 6/11/15 ®Yes❑ No 8/3/15 ®Yes❑ No 6/20/20
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 2/20/17 ®Yes❑ No
Legal Authority(Sewer Use Ordinance-SUO)
22. Do you have any towns and/or areas from which you receive wastewater which are not in your annexed jurisdiction?
®Yes 0 No If yes,Please list these towns and/or areas.High Shoals,Stanley,Clover(S.C.),Ranlo,Bessemer City,Lowell,
Kings Mountain,Cramerton,Gaston County.
23. 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.
24. If yes to#22,Have you had any trouble working with these towns or districts? ❑Yes® No ❑NA
If yes,Explain.
25. Date of Last SUO Adoption by Local Council. 12/4/12
26. Have you had any problems interpreting or enforcing any part of the SUO? ❑Yes® No
If yes,Explain.
Enforcement(Enforcement Response Plan-ERP)
27. Did you send a copy of the ERP to your industries? Z Yes❑ No
If no,POTW must send copy within 30 days.
28. 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.
29. List Industries under a Schedule or Order and Type of Schedule or Order
None;however,two compliance schedules were completed in January 2017(Town of Clover)and June 2017(Bessemer
City).
NC 1lWR Pretreatment Audit Fnrm Reviced• Tilly 75 7nn7 Pave

resources
30. 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 ZS❑M❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis ZS❑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
31. Does the POTW have an adequate data management system to run the pretreatment program?®Yes❑ No
Explain Yes or No. Hach WIMS.
32. How does the POTW recover the cost of the Pretreatment Program from their industries?Explain.
Surcharges,penalties for violations,permitting fees,annual maintenance fee,SIUs directly billed for sampling costs.
Public Perception/Participation:
33. Are there any local issues affecting the pretreatment program (e.g..odor,plant closing,new or proposed plants)?
❑Yes® No If yes,Explain.
34. 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?A written request would be reviewed by the
Pretreatment Supervisor and City Attorney. Copies of the information would be provided or files would be reviewed at the
Long Creek WWTP with the Pretreatment staff in attendance.
35. 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 written request would be reviewed and approved by the
Pretreatment Supervisor and City Attorney. All confidential information would be kept in a locked file cabinet.
36. In addition to annual inspection,does the POTW periodically meet with industries to discuss pretreatment? ®Yes❑ No
37. Is the public notified about changes in the SUO or Local Limits? ®Yes❑ No
38. Were all industries in SNC published in the last notice? ®Yes❑ No ❑NA
Permitting(Industrial Waste Survey-IWS):
39a...How does the POTW become aware of new or changed Users?All new non-residential sewer connections are
reviewed on the City's database(Cayenta). The Pretreatment Group also reviews(monthly)all new business
licenses and permits maintained by the City's Planning Department.
39b.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
SIU?)IWS/Short Form is reviewed and a site visit is performed. A full permit application is required based on the
information in the IWS/Short Form and site visit. SIC Code,categorical processes,flow volumes,discharge
characteristics,and potential impacts to WWTP are also evaluated during these determinations.

40. Does the POTW receive waste from any groundwater remediation projects(petroleum,CERCLA)or landfill leachate?
®Yes❑No If Yes,How many are there? 1
Please list each site and how it is permitted,if applicable.Gaston County Landfill/SIU
41. Does the POTW accept waste by(mark if applicable) Z 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)No septage is accepted at any of the WWTPs.A designated point(manhole at Crowders Creek
WWTP)for one industrial user(<5,000 gallons per week),manifests for each load are maintained and each load is
sampled.
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%
47. Has the POTW experienced any difficulty in allocation?(for example: adjudication by an industry) ❑Yes® No
If yes,Explain.
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)Categorical parameters,NPDES POCS,
>5%MAHL a limit will be issued.
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Monthly monitoring for twelve months(minimum)if no historical data for baseline,monitoring may be reduced based on
sampling results,semi-annual monitoring minimum monitoring frequency.
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.Compliance Judgement Worksheet for SNC determinations;ERP
followed for limit,monitoring,reporting,and/or permit condition violations.
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.
54. What criteria are used to determine if a slug/spill control plan is needed?
EPA checklist used as a guide; presence of floor drains;chemical storage/secondary containment.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Adequate chemical storage and secondary containment;emergency contacts kept up to date; presence of spill response
equipment.
56. How does the POTW decide where the sample point for an SIU should be located?
Sampling preferred following all treatment processes for regulated waste streams.
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—Sampling SOP;POTW evaluates SIU
sampling procedures during inspections.
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8. Who performs sample analysis for the POTW for Metals—Certified In-house Lab
Conventional Parameters—Certified In-house Lab
Organics—Shealy Environmental Services
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
POTW uses internal and contracted lab's COCs. Sills use contracted lab's COCs.
Long/Short Term Monitoring Plan(L/STMP)and Headworks Analysis(HWA):
60a. Is LIMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ®YES ❑NO
60b. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ®YES ❑NO
60c. Is LTMP/STMP Data Maintained in Table or Equivalent? Z YES ❑NO Is Table Adequate? ®YES 0 NO
60d. All LTMP/STMP effluent data on Discharge Monitoring Report(DMR)?®YES❑NO DWQ Inspector,verify yourself!
60e. If NO to any above,list violations
60f. 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)? Z 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 LIMP data available ❑Resolve over allocation 05 year expiration ®Other,explain. Remove total
phosphorus.
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. NA—Sufficient capacity in all WWTPs.
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.Cornell Cookson 2.Valley Proteins 3.Owens Corning
67. IUP Number 1065 1047 1068
68. Does File Contain Current Permit? ®Yes ❑ No ®Yes ❑ No ®Yes ❑ No
69. Permit Expiration Date 12/31/20 8/31/21 I 12/31/19
70. Categorical Standard Applied(I.E.40 CFR,Etc.)Or N/A 433.17 NA NA
71. Does File Contain Permit Application Completed Within One Year Prior ®Yes ❑ No ®Yes ❑ No ®Yes ❑ No
to Permit Issue Date?
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. ®Yes ONo a. EYes ONo a. ®Yes ONo
b.If No,is One Needed?(See Inspection Form from POTW) b. ❑Yes ONo b.['Yes ONo b. ❑Yes ONo
74. For 40 CFR 413 and 433 TTO Certification,Does File Contain a Toxic ®Yes❑No❑N/A ❑Yes❑No®N/A ❑Yes❑NoEN/A
Organic Management Plan(TOMP)?
75. a.Does File Contain Original Permit Review Letter from Division? a. EYes ONo a. EYes ONo a. EYes ONo
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 by IUP,including Flow?
77. Does File Contain POTW Sampling Chain-Of-Custody Forms? ®Yes ❑ No ®Yes ❑ No I ®Yes ❑ No
78. During Most Recent Semi-Annual Period,Did SIU Complete its I ®Yes❑No❑N/A II ®Yes❑No❑N/A II ®Yes❑No❑N/A I
Sampling as Required by IUP,including Flow?
- - - - -- ----

79. During Most Recent Semi-Annual Period,Did SIU submit all reports on ®Yes❑No❑N/A ®Yes❑No❑N/A ®Yes❑No❑N/
time?
80a.For categorical Ws with Combined Wastestream Formula(CWF),does ❑Yes❑No®N/A ❑Yes❑No®N/A ❑Yes❑No®N/A
file include process/dilution flows as Required by 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 ❑Yes❑No®N/A ❑Yes❑No®N/A ®Yes❑No❑N/A
Limits Non-Compliance from Both POTW and SIU Sampling?
82. During Most Recent Semi-Annual Period,Did POTW Identify All ❑Yes❑No®N/A ❑Yes❑No®N/A ❑Yes❑No®N/A
Reporting Non-Compliance from SIU Sampling?
83. a.Was POTW Notified by SIU(Within 24 Hours)of All Self- a.❑Yes❑No ON/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 ❑c. Yes❑No®N/A
becoming aware of SIU limit violations in the POTW's sampling of SIU?
c.❑Yes❑No®N/A c.❑Yes❑No®N/A
84. During Most Recent Semi-Annual Period,Was SIU in SNC? El Yes ® No ❑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❑No®N/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❑No®N/A b.❑Yes❑NooN/A b.❑Yes❑No®N/A
89. Did POTW Representative Have Difficulty in Obtaining Any Requested ❑Yes ® No ❑Yes ® No ❑Yes Z No
Information For You?
FILE REVIEW COMMENTS:
16/18. SNC totals are based on 2016. Town of Clover/Pipe 001 (organic nitrogen)and City of Bessemer City/Pipe 002 (TKN)were in
SNC for the first half of 2016 and Industrial Fabricators/Pipe 001 (zinc and TSS)was in SNC for the second half of 2016.
66.Cornell Cookson ceased discharging in January 2017 and shut down in April 2017.
76. All sampling results had not been received for the SIU sampling events during first half of 2017; therefore, the SIU file reviews
were performed for the second half of 2016. An oil& grease sample for Cornell Cookson(semi-annual)was not collected during the
second half of 2016. The POTW was not able to collect an additional oil&grease sample during first half of 2017 due to SIU ceasing
the discharge in January 2017.
74.Cornell Cookson submitted TTO Certifications in May 2016 and November 2016.
78.POTW performs sampling for Cornell Cookson,Valley Proteins,and Owens Corning. Valley Proteins and Owens Corning contract
Prism Laboratories to perform analyses on split samples.
85.POTW issued a NOV(dated 1/17/17)to Owens Corning for a flow permit limit violation that occurred in December 2016.
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INDUSTRY INSPECTION PCS CODING::
Trans.Code Main Program Permit Number MM/DD/YY Inspection type Inspector Facility Type
N N C 0 0 2 0 1 8 4 07 07 17 U S 2
(DTIA) (TYPI) (INSP) (FACC)
1.Industry Inspected: Earth Farms Organics
2.Industry Address: Mailing:PO Box 184,Dallas,NC 28164 Physical:351 Colt Thornburg Road,Dallas,NC 26184
3.Type of Industry/Product: Compost and Topsoil Products
4.Industry Contact: Shane Roberts Title: Facility Manager/Interim Field Operations Manager Phone:[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:
The facility operates one 12-hr. shift(7AM—7PM)five days per week and currently has 21 employees. The facility receives two waste
streams(septage and food waste/grease traps);however,only the treated wastewater for the grease trap waste stream is discharged to the
POTW. The treated septage (filtrate) is land applied on-site under a Division of Waste Management Permit. The dewatered solids
from the septage treatment system are incorporated into the composting process.
The facility's wastewater pretreatment system(grease trap waste stream)includes the following: settling tank(roll back dumpster),bar
screen, influent pump tank,pH adjustment(lime stabilization),polymer addition,dewatering box,holding tank,effluent pump tank,and
flow measurement system. The pump tanks are equipped with audible and visual alarms.The dewatered solids are incorporated into the
composting process. The compost is distributed to commercial companies.
SUMMARY AND COMMENTS:
The records reviewed during the inspection were organized and well maintained. The POTW staff must ensure that all required IUP
detection levels are met by the applicable laboratory and the IUPs specify how the daily pH monitoring(by SIU)is to be reported. The
POTW's Industrial Pretreatment Program was being properly implemented.
NOD: ❑Yes ® No
NOV: 0 Yes ® No
QNCR: 0 Yes ® No
POTW Rating:
Satisfactory ® Marginal 0 Unsatisfactory 0
,
Audit COMPLETED BY: ' tt, .-.1 — - DATE:July 13,2017
Wes Bell,Mooresville Regional Office

ROY COOPER
N Governor
MICHAEL S.REGAN
.,Pi..-d Secreterr
Water Resources Z
S.JAY ZIMMERMAN
Director
Environmental Quality
April 26, 2017
Ms.Janet Maddox
Pretreatment Supervisor
Two Rivers Utilities
Post Office Box 1748
Gastonia,North Carolina 28053-1748
Subject: PAR Review
Two River Utilities
NPDES Permit No.NC0020184
Gaston County
Dear Ms. Maddox:
Mooresville Regional Office staff has reviewed your Pretreatment Annual Report(PAR)for the
reporting period of January through December 2016. Based on the review,the POTW completed the
PAR in accordance with 15A NCAC 2H .0908(b)requirements and guidelines set forth in Comprehensive
Guidance for North Carolina Pretreatment Programs. The next PAR will be due March 1, 2018.
If you have any questions concerning your PAR,please do not hesitate to contact me at(704)
235-2192 and/or Deborah Gore at(919) 807-6383 or at [e-mail] and
[e-mail].
Sincerely,
4\1
C_w-- W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources,NCDEQ
cc: Deborah Gore, PERCS Unit
MSC-1617 Central-Basement
WB
State of North Carolina I Environmental Quality'Water Resources I Water Quality Regional Operations
Mooresville Regional Office 1610 East Center Avenue,Suite 310 I Mooresville,North Carolina 28115
704-663-1699

MCCRORY
s"••- Governor
DONALD R. VAN DER VAART
Sect etat7r
Water Resources S. JAY ZIMMERMAN
ENVIRONMENTAL QUALITY Doeclor
April 27, 2016
Ms. Janet Maddox
Pretreatment Supervisor
Two Rivers Utilities
Post Office Box 1748
Gastonia,North Carolina 28053-1748
Subject: PAR Review
Two Rivers Utilities
NPDES Permit No.NC0020184
Gaston County
Dear Ms. Maddox:
Mooresville Regional Office staff has reviewed your Pretreatment Annual Report(PAR)for the
reporting period of January through December 2015. Based on the review,the POTW completed the
PAR in accordance with 15A NCAC 2H .0908(b)requirements and guidelines set forth in Comprehensive.
Guidance for North Carolina Pretreatment Programs. The next PAR will be due March 1,2017.
If you have any questions concerning your PAR,please do not hesitate to contact Mr.Wes Bell at
[phone] and/or Ms. Sarah Bass at(919) 807-6310 or at [e-mail] and
[e-mail].
Sincerely,
W. Corey Basinger,Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources,NCDEQ
cc: Sarah Bass,PERCS Unit
MSC-1617 Central-Basement
WB
State of North Carolina Environmental Quality I Water Resources I Water Quality Regional Operations
Mooresville Regional Office 1610 East Center Avenue,Suite 301 I Mooresville,North Carolina 28115
704 663 1699

AFILE
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory Donald van der Vaart
Governor Secretary
April 22,2015
Ms.Janet Maddox
Pretreatment Supervisor
Two Rivers Utilities
Post Office Box 1748
Gastonia,North Carolina 28053-1748
Subject: PAR Review
Two River Utilities
NPDES Permit No.NC0020184
Gaston County
Dear Ms. Maddox:
Mooresville Regional Office staff has reviewed your Pretreatment Annual Report(PAR)for the reporting
period of January through December 2014. Based on the review,the POTW completed the PAR in accordance
with 15A NCAC 2H.0908(b)requirements and guidelines set forth in Comprehensive Guidance for North Carolina
Pretreatment Programs. The next PAR will be due March 1,2016.
If you have any questions concerning your PAR,please do not hesitate to contact me at(704)235-2192 and/or
Sarah Bass at(919) 807-6310 or at [e-mail] and [e-mail].
Sincerely, ,r
•
Wes Bell
Environmental Specialist
Water Quality Regional Operations Section
cc: Sarah Bass,PERCS Unit
Mooresville Regional Office
Location:610 East Center Ave.,Suite 301 Mooresville,NC 28115
Phone:[phone] t Fax:[phone] t Customer Service:1-877-623-6748
Internet:www.ncwaterquality.org
An Equal Opportunity\Affirmative Action Employer-30%Recycledll0%Post Consumer paper

Ir
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory John E. Skvarla, III
F 1 LE
4674:7A
IGove.`'
rnor Secretary
March 27,2014
Ms. Janet Maddox
Pretreatment Supervisor
Two Rivers Utilities
Post Office Box 1748
Gastonia,North Carolina 28053-1748
Subject: PAR Review
Two Rivers Utilities
NPDES Permit No.NC0020184
Gaston County
Dear Ms. Maddox:
Mooresville Regional Office staff has reviewed your Pretreatment Annual Report(PAR)for the reporting
period of January through December 2013. Based on the review,the POTW completed the PAR in accordance
with 15A NCAC 2H .0908(b)requirements and guidelines set forth in Comprehensive Guidance for North Carolina
Pretreatment Programs. The next PAR will be due March 1,2015.
4.:. If you have any questions concerning your PAR,please do not hesitate to contact me at(704)235-2192 and/or
Sarah Bass at(919) 807-6310 or at wes.bell,,ncdenr.gov and [e-mail].
st
Sincerely,
V-44----_,//1.e.--e(
Wes Bell,Environmental Specialist
Mooresville Regional Office
Water Quality Regional Operations Section ,
Division of Water Resources,NCDENR 4 ,
i
cc: Sarah Bass, PERCS Unit !1 .
r y
itt
Mooresville Regional Office 'L
Location:610 East Center Ave.,Suite 301 Mooresville,NC 28115
Phone:[phone] Fax:[phone]\Customer Service:1-877-623-6748 ,,
Internet:www.ncwaterquality.orgill

r AiA
NCDENR F ILE
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Water Quality Programs
Pat McCrory Thomas A. Reeder John E.Skvarla, III
Governor Director Secretary
March 18,2014
Mr. David Shellenbarger
Assistant Division Manager/Wastewater Resources
City of Gastonia
Post Office Box 1748
Gastonia,North Carolina 28053-1748
Subject: Pretreament Compliance Inspection
City of Gastonia
NPDES Permit No. NC0020184
Gaston County
Dear Mr. Shellenbarger:
Enclosed is a copy of the Pretreatment Compliance Inspection Report for the inspection conducted at the
subject facility on March 6,2014 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(704)235-2192 or at [e-mail].
Sincerely,
C.t..: -L.'d/
Michael L. Parker
Supervisor
Water Quality Regional Operations Section
Enclosure:
Inspection Report
cc: Central Files
Sarah Bass,PERCS Unit
WB
Mooresville Regional Office One
Location:610 East Center Ave.,Suite 301 Mooresville,NC 28115 North Carolina
Phone:[phone] Fax:[phone] Customer Service:1-877-623-6748
Internet:www.ncwaterquality.org Naturally
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WA _
NORTH CAROLINA DIVISION OF WATER QUALITY -©a °�
NCDENR PRETREATMENT COMPLIANCE INSPECTION(PCI)REPORT a
BACKGROUND INFORMATION[Complete Prior To PCI;Review Program Info Database Sheet(s)1
1. Control Authority(POTW)Name: City of Gastonia
2. Control Authority Representative(s): Janet Maddox,David Shellenbarger,Lawanda Waite
3. Title(s):Pretreatment Supervisor,Assistant Division Manager/Wastewater Resources,Industrial Chemist
4. Last Inspection Date:4/18/12 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
PCS CODING
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac.Type
N NC0020184 03/06/14 P S 1
(DTIA) (TYPI) (INSP) (FACC)
7. Current Number Of Significant Industrial Users(SIUs)? 26 SIUS
8. Current Number Of Categorical Industrial Users(CIUs)? 10 CIUS
9. Number of SIUs Not Inspected By POTW in the Last Calendar Year? 0
10.Number of SIUs Not Sampled By POTW in the Last Calendar Year? 0
11.Enter the Higher Number of 9 or 10 0 NOIN
12.Number of SIUs With No IUP,or With an Expired IUP 0 NOCM
13.Number of SIUs in SNC for Either Reporting or Limits Violations During Either of the Last 2 6
Semi-Annual Periods(Total Number of SIUs in SNC) PSNC
14.Number of SIUs in SNC For Reporting During Either of the Last 2 Semi-Annual Periods 0 MSNC
15.Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi-Annual Periods 6 SNPS
16.Number of SIUs In SNC For Both Reporting and Limits Violations During Either of the Last 2 0
Semi-annual Periods
POTW INTERVIEW
17. Since the Last PCI,has the POTW had any NPDES Limits Violations? ❑YES ® NO
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 ❑YES ®NO
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 SNC for Limits:See Comments Section
either of the Last 2 Semi-Annual Periods?Not Been Published for SNC for Reporting:None
Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not Published: None
20. Which Industries are on Compliance Schedules or Orders?For all SIUs on an Town of Clover,Industrial
Order,Has a Signed Copy of the Order been sent to the Division? Fabricators,Bessemer City;Yes
21. Are Any Permits Or Civil Penalties Currently Under Adjudication?If Yes,Which ❑YES Z NO
Ones?
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? Z YES ❑ NO Is Table Adequate? Z 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 LIMP/STMP? ❑YES ® NO
If yes,which ones?Eliminated: Added:
NC DWQ Pretreatment Compliance Inspection(PCI)Form pdated 7/25 07 Page 1

28. PRETREATMENT PROGRAM ELEMENTS REVIEW—Please review POTW files,verify POTW has copy of Program Element in
their files,complete with supporting documents and copy of PERCS Approval Letter,and dates consistent with Program Info:
Program Element Last Submittal Received Last Approval Date Next Due,
Long Creek WWTP Date In file? Date In file If Applicable
Headworks Analysis(HWA) 4/18/11 ®Yes❑ No 6/9/11 El Yes❑ No 9/1/15
Industrial Waste Survey(IWS) 2/8/12 ®Yes❑ No 3/2/12 ®Yes❑ No 6/20/15
Sewer Use Ordinance(SUO) 12/6/12 ®Yes ❑ No 12/27/12 ® Yes ❑ No
Enforcement Response Plan(ERP) 11/29/01 ®Yes❑ No 12/6/01 ® Yes❑ No
Long Term Monitoring Plan(LTMP) 9/27/12 ®Yes❑ No 12/10/12 ®Yes❑ No
Program Element Last Submittal Received Last Approval Date Next Due,
Crowders Creek WWTP Date In file? Date In file If Applicable
Headworks Analysis(HWA) 3/28/12 ®Yes❑ No 6/25/12 ®Yes❑ No 11/1/14
Industrial Waste Survey(IWS) 2/8/12 ® Yes❑ No 3/2/12 ®Yes ❑ No 6/20/15
Sewer Use Ordinance(SUO) 12/6/12 ®Yes❑ No 12/27/12 ®Yes❑ No
Enforcement Response Plan(ERP) 11/29/01 ®Yes❑ No 12/6/01 ®Yes❑ No
Long Term Monitoring Plan(LTMP) 9/27/12 ® Yes❑ No 12/10/12 ®Yes❑ No
INDUSTRIAL USER PERMIT(IUP)FILE REVIEW(3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name 1.Industrial Electroplating,Inc. 2.Town of Ranlo 3.Daimler Trucks NA,LLC
30. IUP Number 1011 1050 1023
31. Does File Contain Current Permit? ® Yes ❑ No ®Yes ❑ No ®Yes ❑ No
32. Permit Expiration Date 12/31/15 12/31/15 12/31/15
33. Categorical Standard Applied(I.E.40 CFR,Etc.)Or N/A 433.15 NA, 433.17
34. Does File Contain Permit Application Completed Within One Year Prior ®Yes ❑ No ®Yes ❑ No ®Yes ❑ No
to Permit Issue Date?
35. Does File Contain an Inspection Completed Within Last Calendar Year? ® Yes ❑ No ®Yes ❑ No ®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. ❑Yes❑No b. ❑Yes ZNo b. ❑Yes❑No
37. For 40 CFR 413 and 433 TTO Certification,Does File Contain a Toxic ®Yes❑No❑N/A ❑Yes❑No®N/A ®Yes❑No❑N/A
Organic Management Plan(TOMP)?
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❑No®N/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 ❑ No ®Yes ❑ No ®Yes ❑ No
41a.During the Most Recent Semi-Annual Period,Did the SIU Complete its ®Yes❑No❑N/A ®Yes❑No❑N/A ®Yes❑No❑N/A
Sampling as Required by IUP,including flow?
4 lb.During the Most Recent Semi-Annual Period,Did SIU submit all reports ®Yes❑No❑N/A ElYes❑No❑N/A ®Yes❑No❑N/A
on time?
42a.For categorical Ms with Combined Wastestream Formula(CWF),does ❑Yes❑No®N/A ❑Yes❑No®N/A ❑Yes❑NoON/A
file include process/dilution flows as Required by IUP?
42b.For categorical IUs with Production based limits,does file include ❑Yes❑NOON/A ❑Yes❑No®N/A ❑Yes❑No®N/A
production rates and/or flows as Required by IUP?
43a. During the Most Recent Semi-Annual Period,Did the POTW Identify ❑Yes❑No®NA ❑Yes❑NoON/A ❑Yes❑No®N/A
All Limits Non-Compliance from Both POTW and SIU Sampling?
43b. During the Most Recent Semi-Annual Period,Did the POTW Identify ❑Yes❑No®N/A I ❑Yes❑NoON/A ❑Yes❑No®N/A
All Reporting Non-Compliance from SIU Sampling?
44. a. Was the 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.Did POTW resample within 30 days of knowledge of SIU limit c.❑Yes❑No®N/A c.❑Yes❑No®N/A c.❑Yes❑No®N/A
violations from the POTW sample event? _
45. During the Most Recent Semi-Annual Period,Was the SIU in SNC? ❑Yes ® No ❑Yes ® No j ❑Yes ® No
NC DWQ Pretreatment Compliance Inspection(PCI)Form l Jpdated 7/25..'07 Page 2

During the Most Recent Semi-Annual Period, Was Enforcement Taken ❑Yes❑No®N/A ❑Yes❑No®N/A ❑YesONo®N/A
as Specified in the POTW's ERP(NOVs,Penalties,timing,etc.)?
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 ❑YesDNo®N/A ❑YesDNo®N/A
49. a.Does the 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❑No®N/A b.❑Yes❑No®N/A b.❑Yes❑No®N/A
50. Did the POTW Representative Have Difficulty in Obtaining Any of This ❑ Yes ® No ❑Yes ® No ❑ Yes ® No
Requested Information For You?
FILE REVIEW COMMENTS:
18.SNC limit violations(January—June 2013)—Town of Clover(organic nitrogen),City of Bessemer City(cyanide,organic nitrogen),
Industrial Fabricators(zinc,phosphorus,total suspended solids),Apex Tool Group(nickel);
SNC limit violations (July—December 2013)—Colortex USA(zinc),Stanly Environmental Solutions(total suspended solids,oil&
grease,ammonia)
20. Consent Orders/Compliance Schedules: Town of Clover(mercury)—effective 2/14/12 with expiration date of 12/21/14,City of
Bessemer City(cyanide)—effective 10/21/13 with compliance by end December 2014,Industrial Fabricators(zinc)—effective 10/31/13
with compliance by end of December 2014.
28. SUO adopted on 12/4/12.
35.POTW inspections: Industrial Electroplating,Inc.—10/29/13,Town of Ranlo—10/10/13,Daimler Trucks NA,LLC—11/13/13.
37.Annual TTO monitoring is performed for Daimler Trucks NA,LLC.
39.POTW(Crowders Creek Laboratory)performs all sample collection and selected analyses. POTW contracts Rogers&Callcott to
perform organics,oil&grease,and cyanide(as-needed)analyses.
SUMMARY AND COMMENTS:
Comments:
The records reviewed during the inspection were organized and well maintained. All program elements were complete and up to date.
Requirements:
Recommendations:
NOD: ❑ YES ®NO
NOV: ❑YES Z NO
QNCR: ❑ YES® NO
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory_❑
PCI COMPLETED BY: G / DATE: March 18,2014
Wes Bell,Mooresville Regional Office
NC DWQ Pretreatment Compliance Inspection(PCI)Form I pdated 7/25!07 Page 3

Ara
FILE
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Pat McCrory Thomas A. Reeder John E.Skvarla, Ill
Governor Acting Director Secretary
July 30, 2013
Mr. David Shellenbarger
Two Rivers Utilities
Post Office Box 1748
Gastonia,North Carolina 28053-1748
Subject: PAR Review
Gastonia
NPDES Permit No. NC0020184
Gaston County
Dear Mr. Shellenbarger:
Mooresville Regional Office staff has reviewed your Pretreatment Annual Report (PAR) for the
reporting period of January through December 2012. Based on the review, the POTW completed the PAR in
accordance with 15A NCAC 2H .0908(b) requirements and guidelines set forth in Comprehensive Guidance for
North Carolina Pretreatment Programs. The next PAR will be due March 1, 2014.
If you have any questions concerning your PAR,please do not hesitate to contact Wes Bell at(704) 663-
1699 or by email at wes.bellnncdenr.gov.
S. cer ly, i f
onna Hood
Mooresville Regional Office Contact
Cc: Sarah Morrison, PERCS Unit
Mooresville Regional Office
Location:610 East Center Ave.,Suite 301 Mooresville,NC 28115 One
Phone:[phone]\Fax:[phone] Customer Service:1-877-623-6748 NorthCarolina
Internet:http://portal.ncdenr.org/web/wq
An Equal Opportunity 1 Affirmative Action Employer—50%Recycled/10%Post Consumer paper Naturally

A e
FILE
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild,P. F Dee Freeman
Governor Director Secretary
April 23, 2012
Mr. David Shellenbarger
City of Gastonia
Post Office Box 1748
Gastonia,North Carolina 28053-1748
Subject: Pretreatment Audit Inspection
City of Gastonia
NPDES Permit No. NC0020184
Gaston County,NC
Dear Mr. Shellenbarger
Enclosed is a copy of the Pretreatment Audit Report for the inspection conducted at the subject facility
on April 18, 2012 by John Lesley, Wes Bell, and Donna Hood of the Mooresville Regional Office.
The report should be self-explanatory; however, should you have any questions concerning this report,
please do not hesitate to contact Mr. Lesley or me at(704) 663-1699.
Sincerely,
L �
Robert B. Krebs
Surface Water Protection Regional Supervisor
Enclosure
cc: Central Files
Sarah Morrison, PERCS Unit
JL
Mooresville Regional Office One
Location:610 East Center Ave..Suite 301 Mooresville.NC 28115 NorthCarolina
Phone:[phone] Fax:[phone] Naturally
Internet:http:Uportal.nedenr.orq/web/wq
An Equal Opportunity'•Affirmative Action Employer—50%Recycled/10%Post Consumer paper

ATA, OF "169
NtDENR NORTH CAROLINA DIVISION OF WATER QUALITY
o� PG
PRETREATMENT AUDIT REPORT o
Background Information:
1. Control Authority(POTW)Name: Two Rivers Utilities(City of Gastonia)
2. Control Authority Representative(s):Janet Maddox
3. Title(s):Pretreatment Program Supervisor
4. Address of POTW:
Street/Post Office Box PO Box 1748
City/State/Zip Code Gastonia,NC 28053-1748
Phone Number 704-854-6672 Fax Number 704-922-0619 E-Mail ianetmatworiversutilities.com
5. Audit Date 04/18/2012
6. Last Inspection Date:07/19/2011 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
PCS(WENDB)Coding:
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac.Type
LNJ INICIO IO I2 I0 I1 I8 14 I 104 I181121 IGI IS I I l I
(DTIA) (TYPI) (INSP) (FACC)
10. Current Number of Significant Industrial Users(SIUS)? 25 SIUS
11. Current Number of Categorical Industrial Users(CIUS)? 10 CIUS
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. Enter Higher Number of 12 or 13 0 NOIN
15. Number of SIUs with No IUP,or with an Expired IUP 0 NOCM
16. Number of SIUs in SNC for Either Reporting or Limits Violations During Either of Last 2 1 PSNC
Semi-Annual Periods(Total Number of SIUs in SNC)
17. Number of SIUs in SNC for Reporting During Either of Last 2 Semi-Annual Periods 0 MSNC
18. Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi-Annual Periods 1 SNPS
19. Number of SIUs in SNC for Both Reporting and Limits Violations During Either of Last 2 0
Semi-Annual Periods
20. Number of SIUs in SNC for Self-Monitoring Requirements that were Not Inspected or Sampled 0 SNIN
NC T1W(l Prr traatmpnt Andit Pnrm RPvicnd• Tnly )S ?Cl(7 Pa OP I

21. PRETREATMENT PROGRAM ELEMENTS REVIEW
Program Element: Last Submittal Last Approval Date Next Due,
Long Creek WWTP Date In file? Date In file If Applicable
Headworks Analysis(HWA) 4/18/11 ®Yes 0 No 6/911 ®Yes❑ No 9/1/15
Industrial Waste Survey(IWS) 2/8/12 ®Yes❑ No 3/2/12 Z Yes❑ No 6/20/15
Sewer Use Ordinance(SUO) 3/14/11 ®Yes❑ No 4/27/11 ®Yes❑ No 12/31/12
Enforcement Response Plan(ERP) 11/29/01 ®Yes 0 No 12/6/01 ®Yes❑ No
Long Term Monitoring Plan(LTMP) 10/21/02 ®Yes❑ No 1/13/03 ®Yes❑ No
Program Element: Last Submittal Last Approval Date Next Due,
Crowders Creek WWTP Date In file? Date In file If Applicable
Headworks Analysis(HWA) 3/5/10 Z Yes 0 No 4/27/10 ®Yes❑ No 11/01/14
Industrial Waste Survey(IWS) 2/8/12 ®Yes❑ No 3/2/12 ®Yes❑ No 6/20/15
Sewer Use Ordinance(SUO) 3/14/11 Z Yes❑ No 4/27/11 ®Yes❑ No 12/31/12
Enforcement Response Plan(ERP) 11/29/01 ®Yes❑ No 12/6/01 ®Yes❑ No
Long Term Monitoring Plan(LTMP) 10/21/02 Z Yes❑ No 1/13/03 ®Yes❑ No
Legal Authority(Sewer Use Ordinance-SUO)
22. 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. Bessemer City,Ranlo,Clover SC
23. 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.
24. If yes to#22,Have you had any trouble working with these towns or districts? ❑Yes® No ❑NA
If yes,Explain.
25. Date of Last SUO Adoption by Local Council 03/01/2011
26. Have you had any problems interpreting or enforcing any part of the SUO? ❑Yes ® No
If yes,Explain.
Enforcement(Enforcement Response Plan-ERP)
27. Did you send a copy of the ERP to your industries? ®Yes❑ No
If no,POTW must send copy within 30 days.
28. 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.
29. List Industries under a Schedule or Order and Type of Schedule or Order
Clover SC SOC
NC r1WC Prptreatmvnt Arlrlit Pnrm P.vi zprl• Ally 7S lnm PAOP')

Pr
Resources
30. Please Rate the Following: S=Satisfactory M=Marginal U=Unsatisfactory
Rating Explanation,if Unsatisfactory
Personnel Available for Maintaining 4 full time employees
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❑U
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
31. Does the POTW have an adequate data management system to run the pretreatment program?®Yes❑ No
Explain Yes or No.Currently in process of transfering from Data Trend to Hach WIMS.
32. How does the POTW recover the cost of the Pretreatment Program from their industries?Explain.
Surcharges,civil penalties,program charges,permitting fees
Public Perception/Participation:
33. Are there any local issues affecting the pretreatment program (e.g..odor,plant closing,new or proposed plants)?
®Yes❑ No If yes,Explain.Wastewater from Clover SC is going septic in collection system causing noncompliance with
their IUP. Clover is currently on a SOC.
34. 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?
35. 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?.Written request,may copy files,cannot take files from premisses.
36. In addition to annual inspection,does the POTW periodically meet with industries to discuss pretreatment? ®Yes❑ No
37. Is the public notified about changes in the SUO or Local Limits? ®Yes❑ No
38. Were all industries in SNC published in the last notice? ®Yes❑ No ❑NA
Notice dated 2/28/2012 Clover SC in SNC
Permitting(Industrial Waste Survey-IWS):
39a...How does the POTW become aware of new or changed Users?Cayenta Database,Financial Services notifies of new
users and all nonresidential connections,Long IWS Form is sent to new users.
39b.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
SIU?)Long IWS Form evaluation followed by site visit,historical data review.
NC T1Wfl PrrotrPatmPnt Audit Fnrm RPvicpri• Tilly 75 7(1117 pave 1

40. Does the POTW receive waste from any groundwater remediation projects(petroleum,CERCLA)or landfill leachate?
ZYes❑No If Yes,How many are there? Gaston County Landfill leachate
Please list each site and how it is permitted,if applicable.Permitted as an SIU
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)Landfill leachate
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 Z No
If yes,What parameters are over allocated?
45. If yes to#43, What is being done to address the over allocations?(short-term IUPs,HWA to be revised,pollutant study,etc.)
NA
46. Does the POTW keep pollutant loading in reserve for future growth/safety? ®Yes❑ No
If yes,what percentage of each parameter 10%
47. Has the POTW experienced any difficulty in allocation?(for example: adjudication by an industry) ❑Yes® No
If yes,Explain.
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)
IUP Application listed pollutants,categorical parameters,NPDES pollutants of concern,pollutant loading>5%MARL.
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
All IUPs are issued for monthly frequency,after baseline is established the frequency may be reduced.
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. Limits: evaluated each 6 month period for SNC(66%chronic and
33%TRC violations is SNC). Single events judged for potential to impact(high strength wastewater). Reporting: 30 days
past due recieves a civil penalty assessment,beyond 30 days is SNC. Permit Condition: Case by case basis(SNC if there is
a potential to impact WWTP).
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.
54. What criteria are used to determine if a slug/spill control plan is needed?
Case by case basis after site visit based on potential to impact,reevaluated annually.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
EPA Slug/Spill Control Plan check list.
N( r1W(1 Pr,.tr,.atrn,.nt Andit Form R,.vic,.d• Inly 15 7(1(17 Pao,.A.

r56. How does the POTW decide where the sample point for an SIU should be located?
Representative sampling point,process wastewater only if possible.
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 a sampling SOP,staff present for SIU
sampling events.
58. Who performs sample analysis for the POTW for Metals City of Gastonia Lab
Conventional Parameters City of Gastonia Lab
Organics Rogers and Callcott Lab
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Required chain of custody form with each sample event,original chain of custody forms kept in City of Gastonia Lab at
Crowders Creek WWTP copies are maintained in files.
Long/Short Term Monitoring Plan(L/STMP)and Headworks Analysis(HWA):
60a. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ®YES ❑NO
60b. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ®YES ❑NO
60c. Is LTMP/STMP Data Maintained in Table or Equivalent? ®YES ❑NO Is Table Adequate? ®YES ❑NO
60d. All LIMP/STMP effluent data on Discharge Monitoring Report(DMR)?®YES❑NO DWQ Inspector,verify yourself?
60e. If NO to any above,list violations
60f. 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? Phone( ) --
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.
63. In general,what is the most limiting criteria of your HWA?
[Inhibition ®Pass Through(Crowders Creek WWTP) ®Sludge Quality(Long)
64. Do you see any way to increase your loading in the future(Example: obtaining more land for sludge disposal)? ❑Yes® No
Explain.
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.Gaston County Landfill 2.Apex Tool Group 3.Powder Coatings Services
67. IUP Number 1051 1034 1059
68. Does File Contain Current Permit? ®Yes ❑ No ®Yes ❑ No ®Yes El No
69. Permit Expiration Date 12/31/15 12/31/15 8/31/16
70. Categorical Standard Applied(I.E.40 CFR,Etc.)Or N/A NA 433 433
71. Does File Contain Permit Application Completed Within One Year Prior CO Yes ❑ No ®Yes ❑ No ®Yes ❑ No
to Permit Issue Date?
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. ❑Yes ENo a. EYes❑No a. ®Yes❑No
b. If No,is One Needed?(See Inspection Form from POTW) b. ❑Yes ENo b. ❑Yes❑No b. ❑Yes❑No
74. For 40 CFR 413 and 433 TTO Certification,Does File Contain a Toxic I ❑Yes❑No❑N/A II ❑Yes❑No®N/A II ❑Yes❑No®N/A
Organic Management Plan(TOMP)? Performs TTO Performs TTO
N('11WCl Pretreatment Anriit Form RPvi¢P(i• T,,Iv 7S ')(1f17 Poe 5

75. a. Does File Contain Original Permit Review Letter from Division? a. ®Yes❑No a. EYes❑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 El No ®Yes ❑ No ®Yes El No
Sampling as Required by IUP, including Flow?
77. Does File Contain POTW Sampling Chain-Of-Custody Forms? ®Yes ❑ No ®Yes ❑ No ®Yes ❑ No
78. During Most Recent Semi-Annual Period,Did SIU Complete its ®Yes❑No❑N/A ❑Yes❑NoZN/A ❑Yes❑NoEIN/A
Sampling as Required by IUP,including Flow?
79. During Most Recent Semi-Annual Period,Did SIU submit all reports on ®Yes❑NoEN/A ❑Yes❑NoEN/A ❑Yes❑NoEN/A
time?
80a.For categorical IUs with Combined Wastestream Formula(CWF),does ❑Yes❑NoON/A ❑Yes❑NOON/A ❑Yes❑NoZN/A
file include process/dilution flows as Required by IUP?
80b.For categorical IUs with Production based limits,does file include ❑Yes❑NoEN/A ❑Yes❑NoEN/A ❑Yes❑NoEN/A
production rates and/or flows as Required by IUP?
81. During Most Recent Semi-Annual Period,Did POTW Identify All ❑Yes❑NoEN/A ❑Yes❑No21N/A ❑Yes❑NoON/A
Limits Non-Compliance from Both POTW and SIU Sampling?
82. During Most Recent Semi-Annual Period,Did POTW Identify All ❑Yes❑NoEN/A ❑Yes❑NoZN/A ❑Yes❑No❑N/A
Reporting Non-Compliance 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 c.❑Yes❑No®N/A
becoming aware of SIU limit violations in the POTW's sampling of SIU? c.❑Yes❑No®N/A c.❑Yes❑No®N/A
84. During Most Recent Semi-Annual Period,Was SIU in SNC? El Yes ® No El Yes ® No ❑Yes ® No I
85. During Most Recent Semi-Annual Period,Was Enforcement Taken as ❑Yes❑NoEN/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❑NoEN/A ❑Yes❑NoEN/A ❑Yes❑No®N/A
87. Does File Contain Proof Of Penalty Collection? ❑Yes❑N:ON/A ❑Yes❑NoON/A ❑Yes❑NoEN/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❑No®N/A b.❑Yes❑No®N/A b.❑Yes❑No®N/A
89. Did POTW Representative Have Difficulty in Obtaining Any Requested ❑Yes ® No ❑Yes ® No El Yes ® No
Information For You?
FILE REVIEW COMMENTS:
Gaston County Landfill: The IUP Application was revised to provide more information on 3/28/11. The IUP was approved by the Division
on 5/24/11. A site inspection was conducted on 9/2/11 and was also included for inspection as part of this Audit. Priority Pollutants
Analyses were conducted by Rogers and Callcott Laboratory Services on 5/25/11 (report dated 6/10/11) there was no discharge sufficient
for a sampling event in the July-December 2011 period. No violations were reported in 2011.
Apex Tool Group: Categorical Industry 40 CFR 433.15 and 40 CFR 437.36. The RIP Application is dated 6/21/10. A site inspection was
performed on 11/25/11. The TTO anaylses are conducted annually(2/9/11)in lieu of Certification.
Powder Coating Services, Inc: IUP Application was signed on 1/11/11. The IUP was modified for flow on 3/28/12 and approved by the
Division on 4/11/12. A site inspection was conducted on 10/4/11. TTO analyses were performed on 2/9/11. Notices of Violation were
sent for flow limit violations during 2011. The noncompliance has been resolved by the IUP modification.
NC num PrPtreatmvnt Andit Fnrm Rnvicpd• lily 75 11107 Pa OP A

Pr
INDUSTRY INSPECTION PCS CODING:
Trans.Code Main Program Permit Number MM/DD/YY Inspection type Inspector Facility Type
N NC 0 0 2 0 1 8 4 04 18 12 U S 2
(DTIA) (TYPI) (INSP) (FACC)
1. Industry Inspected: Gaston County Landfill
2.Industry Address: 3155 Philadelphia Church Road,Dallas NC 28034
3.Type of Industry/Product: Landfill Leach ate
4.Industry Contact: Emily Melton Title: Environmental Anaylist Phone: [phone] Fax:
5.Does the POTW Use the Division Model Inspection Form or Equivalent? ®Yes El 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 El No
E. Exit Interview ®Yes El No
Industrial Inspection Comments:
Landfill leachate is collected in 2-250,000 tanks and shipped via tanker to a secured designated point in the collection system.
The leachate can be adjusted for pH if needed. Some of the leachate is recirculated back to cells to increase gas for use in
energy production.
SUMMARY AND COMMENTS:
Audit Comments: The Pretreatment Program files are well organized and maintained. All documentation was complete and
up-to-date.
Requirements: See the Program Elements Review Section of this report.
Recommendations: None
NOD: El Yes Z No
NOV: ❑Yes ® No
QNCR: ❑Yes Z No
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory❑
Audit COMPLETED BY:- P.. --tom DATE: April 23,2012
M esley,Mooresville Reg' I ffice
401
Wes Bell and Donna Hood,Mooresville Regional Office,a so participated in the Audit.
NC 11WC1 PrvtrvatmPnt Anrlit Pnrm Rvuicvri• Tilly')5 71107 Pao.7

F I LL.
A
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
July 21, 2011
Mr. David Shellenbarger
City of Gastonia
Post Office Box 1748
Gastonia,North Carolina 28053-1748
Subject: Pretreatment Compliance Inspection
City of Gastonia
NPDES Permit No. NC0020184
Gaston County,NC
Dear Mr. Shellenbarger:
Enclosed is a copy of the Pretreatment Compliance Inspection Report for the inspection conducted at the
subject facility on July 19, 2011 by John Lesley 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. Lesley or(704) 663-1699.
Sincerely,
tg\(:(J
(::2
P7...__ -Robert B. Krebs
Surface Water Protection
Regional Supervisor
Enclosure
cc: Central Files
Sarah Morrison, PERCS Unit
JL
Mooresville Regional Office One
Location:610 East Center Ave.,Suite 301 Mooresville,NC 28115 NorthCarolina
Phone:[phone]\Fax:[phone]\Customer Service: 1-877-623-6748 7atlll al/l/
Internet:http://portal.ncdenr.orq/web/wq
An Equal Opportunity\Affirmative Action Employer—50%Recycled/10%Post Consumer paper

of ^
A7WA ti.a rF NORTH CAROLINA DIVISION OF WATER QUALITY �y��
NCDENR PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT`
O BACKGROUND INFORMATION (Complete Prior To PCI; Review Program Info Database Sheet(s)l
1. Control Authority(POTW)Name: City of Gastonia
2. Control Authority Representative(s): David Shellebarger
3. Title(s): Assistant Division Manager-Compliance
4. Last Inspection Date: 9/21/2010 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
PCS CODING
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac.Type
N NC0020184 07/19/11 P S 1
(DTIA) (TYPI) (INSP) (FACC)
7. Current Number Of Significant Industrial Users(SIUs)? 26 SIUS
8. Current Number Of Categorical Industrial Users(CIUs)? 11 CIUS
9. Number of SIUs Not Inspected By POTW in the Last Calendar Year? 0
10.Number of SIUs Not Sampled By POTW in the Last Calendar Year? 0
11. Enter the Higher Number of 9 or 10 • 0 NOIN
12.Number of SIUs With No IUP,or With an Expired IUP 0 NOCM
13.Number of SIUs in SNC for Either Reporting or Limits Violations During Either of the Last 2 3 PSNC
Semi-Annual Periods(Total Number of SIUs in SNC)
14.Number of SIUs in SNC For Reporting During Either of the Last 2 Semi-Annual Periods 0 MSNC
15.Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi-Annual Periods 3 SNPS
16.Number of SIUs In SNC For Both Reporting and Limits Violations During Either of the Last 2 0
Semi-annual Periods
POTW INTERVIEW
17. Since the Last PCI,has the POTW had any NPDES Limits Violations? ❑YES ®NO
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 ❑YES ®NO
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 SNC for Limits:See Comments
either of the Last 2 Semi-Annual Periods?Not Been Published for SNC for Reporting:NA
Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not Published: none
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 ❑YES ®NO
Ones?
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: See Comments Added: See Comments
NC DWQ Pretreatment Compliance Inspection(PCI)Form Updated 7/25/07 Page 1

8. PRETREATMENT PROGRAM ELEMENTS REVIEW— Please review POTW files,verify POTV has copy of Program Elem,:nt in
2 rtheir files,complete with supporting documents and copy of PERCS Approval Letter,and dates consistent with Program Info:
Program Element Last Submittal Received Last Approval Date Next Due,
Long Creek WWTP Date In file? Date In file If Applicable
Headworks Analysis(HWA) 4/18/11 ® Yes❑ No _ 6/9/11 ® Yes❑ No 9/1/15
Industrial Waste Survey(IWS) 6/30/10 ® Yes❑ No 11/3/10 ® Yes❑ No 9/30/11
_ Sewer Use Ordinance(SUO) 3/14/11 El Yes [1___No 4/27/11 ElYes T] No
_ Enforcement Response Plan(ERP) 11/29/01 ® Yes ❑ No 12/6/01 ® Yes ❑ No
Long Term Monitoring Plan(LTMP) 10/21/02 ®Yes ❑ No 1/13/03 ® Yes❑ No 1
Program Element Last Submittal Received Last Approval Date Next Due,
Crowders Creek WWTP Date In file? Date In file If Applicable
Headworks Analysis(HWA) 3/5/10 ®Yes❑ No 4/27/10 ® Yes❑ No 11/1/4
Industrial Waste Survey(IWS) 6/30/10 _ ®Yes ❑ No 11/3/10 ®Yes❑ No 9/30/I1
Sewer Use Ordinance(SUO) 3/14/11 ® Yes❑ No - 4/27/11 El Yes ® No
_ Enforcement Response Plan (ERP) 11/29/01 ® Yes El No 12/6/01 ® Yes ❑ No _
Long Term Monitoring Plan(LTMP) 10/21/02, ® Yes❑ No 1/13/03 ® Yes LI No
INDUSTRIAL USER PERMIT(IUP)FILE REVIEW(3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name 1. A.B.Carter 2. Modena. 3. Cookson
30. IUP Number 1049 1032 1065
31. Does File Contain Current Permit? ®Yes ❑ No ®Yes ❑ N• o ®Yes ❑ No
32. Permit Expiration Date 8/31/11 12/31/15 12/31/15
33. Categorical Standard Applied(I.E.40 CFR,Etc.)Or N/A 465.14 NA 433.17
34. Does File Contain Permit Application Completed Within One Year Prior ® Yes ❑ No ®Yes ❑ N• o ®Yes ❑ No
to Permit Issue Date?
35. Does File Contain an Inspection Completed Within Last Calendar Year? ®Yes ❑ No Z Yes ❑ No Z Yes ❑ No
36. a.Does the File Contain a Slug/Spill Control Plan? a. ®Yes ONo a. [Wes No a. ®Yes ONo
b. If No,is One Needed?(See Inspection Form from POTW) b. ❑Yes ONo b. DYes®No b. ❑Yes ONo
37. For 40 CFR 413 and 433 TTO Certification,Does File Contain a Toxic ❑Yes❑NoON/A ❑Yes❑No®N/A ®Yes❑No❑N/A
Organic Management Plan(TOMP)?
38. a.Does File Contain Original Permit Review Letter from the Division? a. ®Yes ONo a. ®Yes ONo a. ®Yes❑No
b. All Issues Resolved? b.®Yes❑No❑N/A b.®Yes❑No❑N/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 ❑ No ® Yes ❑ N• o ® Yes ❑ No
41a. During the Most Recent Semi-Annual Period,Did the SIU Complete its ❑Yes❑No®N/A ®Yes❑No❑N/A ❑Yes❑No®N/A
Sampling as Required by IUP,including flow?
41b. During the Most Recent Semi-Annual Period,Did SIU submit all reports ❑Yes❑No®N/A ®Yes❑No❑N/A ❑Yes❑No®N/A
on time? _
42a. For categorical lUs with Combined Wastestream Formula(CWF), does ❑Yes❑No®N/A ❑Yes❑No®N/A ❑Yes❑No®N/A
file include process/dilution flows as Required by IUP?
42b. For categorical IUs with Production based limits,does file include ®Yes❑No❑N/A ❑Yes❑No®N/A ❑Yes❑NOON/A
production rates and/or flows as Required by 1UP?
43a. During the Most Recent Semi-Annual Period,Did the POTW Identify ❑Yes❑No®NA ❑Yes❑NoEIN/A ❑Yes❑No®N/A
All Limits Non-Compliance from Both POTW and SIU Sampling?
43b. During the Most Recent Semi-Annual Period,Did the POTW Identify ❑Yes❑NoIEN/A ❑Yes❑NoEIN/A ❑Ycs❑No®N/A
All Reporting Non-Compliance from SIU Sampling?
44. a. Was the 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.❑YespNo®N/A b.®Yes❑No❑N/A
c.Did POTW resample within 30 days of knowledge of SIU limit c.®YespNo❑N/A c.❑YespNo®N/A c.®Yes❑No❑N/A
NC DWQ Pretreatment Compliance Inspection(PCI)Form Updated 7/25/07 Page 2

violations from the POTW sample event?
45. During the Most Recent Semi-Annual Period, Was the SR. in SNC? ❑ Yes ® No ❑Yes ® No ❑Yes Z No
46. During the Most Recent Semi-Annual Period, Was Enforcement Taken ®Yes❑No❑N/A ❑Yes❑NogN/A ❑Yes❑NogN/A
as Specified in the POTW's ERP(NOVs, Penalties,timing,etc.)?
47. Does the File Contain Penalty Assessment Notices? ❑Yes❑NogN/A ❑Yes❑NogN/A ❑Yes❑NogN/A
48. Does The File Contain Proof Of Penalty Collection? ❑Yes❑NogN/A ❑Yes❑NogN/A ❑Yes❑NogN/A
49. a. Does the File Contain Any Current Enforcement Orders? a.OYcsONo®N/A a.❑Ycs❑No®N/A a.❑Yes❑No®N/A
b. Is S1U in Compliance with Order? b.DYesONo®N/A b.❑Yes❑NoON/A b.❑Yes❑No®N/A
50. Did the POTW Representative Have Difficulty in Obtaining Any of This ❑ Yes ® No ❑ Yes ® No ❑Yes ® No
Requested Information For You?
FILE REVIEW COMMENTS:
34. IUP Applications: AB Carter, 1/21/11 (IUP effective date,9/1/11); Modena,6/21/10;Cookson,7/30/10.
35. SIU Inspections: AB Carter,6/6/11; Modena,6/24/10; Cookson,11/8/10
38. A.B.Carter, 11/30/10(see email of 7/18/11 for comments on most recent submittal); Modena,5/24/11; Cookson,5/24/11.
41a and 41b. POTW performs all sampling,Modena splits samples with POTW-Prism Labs.
46. A.B.was sent a Notice of Violation on 3/21/11.
SUMMARY AND COMMENTS:
Comments:
20. Clover,Bessemer City,and Sunny Uniform were in SNC in the July-December 2010 period.
21. SOCs were in effect for Clover and Bessemer City. Clover has a compliance date of December 2011. Bessemer City SOC expired on
3/1/11.
27. The NPDES Permits are being reviewed for possible revision of the LTMP parameters.
Requirements:
See the Pretreatment Program Elements Review section of this report.
Submit a revised PPS page to the 2010 PAR to Sarah Morrison of the DWQ PERCS Unit,and to the DWQ Mooresville Regional Office that
corrects the SNC reporting error.
Recommendations:
NOD: ❑YES ® NO
NOV: ❑YES ® NO
QNCR: ❑YES ®NO
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory_❑
PCI COMPLETED BY: C ' ' `" _DATE: July 20,2011
l
ohn esley,Mooresville Regional Office
NC DWQ Pretreatment Compliance Inspection(PCI)Form Updated 7/25/07 Page 3

_
FILE
NCDENR •
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
April 25, 2011
Mr. David Shellenbarger
City of Gastonia
Post Office Box 1748
Gastonia,North Carolina 28053-1748
Subject: PAR Review
City of Gastonia
NPDES Permit No.NC0020184
Gaston County,NC
Dear Mr. Shellenbarger:
Mooresville Regional Office staff has reviewed your Pretreatment Annual Report (PAR) for the
reporting period of January through December 2010. Based on the review, the POTW completed the PAR in
accordance with 15A NCAC 2H .0908(b) requirements and guidelines set forth in Comprehensive Guidance for
North Carolina Pretreatment Programs. The next PAR will be due March 1, 2012.
If you have any questions concerning your PAR, please do not hesitate to contact me at [phone]
or by email at [e-mail].
Sincerely,
J6 Lesley
Mooresville Regional Office Contact
Cc: Dana Folley, PERCS Unit
•
Mooresville Regional Office One
Location:610 East Center Ave.,Suite 301 Mooresville,NC 28115 NorthCarolina
Phone:[phone]\Fax:[phone]\Customer Service: 1-877-623-6748 Naturally
Internet:http://portal.nedenr.orq/web/wq 7
An Equal Opportunity\Affirmative Action Employer—50°6 Recycled/10'V°Post Consumer paper

•
A •A
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
March 30, 2010
Ms. Janet Maddox
Pretreatment Program Supervisor
Post Office Box 1748
Gastonia,North Carolina 28053-1748
Subject: PAR Review
City of Gastonia
NPDES Permit No.NC0020184
Gaston County,NC
Dear Ms. Maddox:
Mooresville Regional Office staff has reviewed your Pretreatment Annual Report (PAR) for the
reporting period of January through December 2009. Based on the review, it appears that the POTW completed
the PAR in accordance with 15A NCAC 2H .0908(b) requirements and guidelines set forth in Comprehensive
Guidance for North Carolina Pretreatment Programs. The next PAR will be due March 1, 2011.
•
If you have any questions concerning your PAR, please do not hesitate to contact me at [phone]
or by email at [e-mail].
Sinc elyr
hn Lesley
Mooresville Regional Office Contact
Cc: Dana Folley, PERCS Unit
Mooresville Regional Office One
Location:610 East Center Ave.,Suite 301 Mooresville,NC 28115 NorthCarolina
Phone:[phone]\Fax:[phone]\Customer Service: 1-877-623-6748 Naturally
Internet:http:llportal.ncdenr.orglweb/wq 7
An Equal Opportunity\Affirmative Action Employer—50%Recycled/10%Post Consumer paper

FILE
AA,
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
September 27, 2010
Mr. David Shellenbarger
City of Gastonia
Post Office Box 1748
Gastonia,North Carolina 28053-1748
Subject: Pretreatment Compliance Inspection
City of Gastonia
NPDES Permit No. NC0020184
Gaston County,NC
•
Dear Mr. Shellenbarger:
Enclosed is a copy of the Pretreatment Compliance Inspection Report for the inspection conducted at the
subject facility on September 27, 2010 by John Lesley 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. Lesley or at [phone].
Sincerely,
obert B. Krebs
z Surface Water Protection
Regional Supervisor
Enclosure
cc: Central Files
Dana Folley, PERCS Unit
Mooresville Regional Office One
Location:610 East Center Ave.,Suite 301 Mooresville,NC 28115 NorthCarollina
Phone:[phone]\Fax:[phone]\Customer Service:1-877-623-6748 (atura 111
Internet:http://portal.ncdenr.orglweb/wq
An Equal Opportunity\Affirmative Action Employer-50%Recycled/10%Post Consumer paper

0,\ M'FROG
NORTH CAROLINA DIVISION OF WATER QUALITY
NCDENR PRETREATMENT COMPLIANCE INSPECTION (PCI)REPORT
pgila
KGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)1
1. Control Authority(POTW)Name: City of Gastonia
2. Control Authority Representative(s):David Shellenbarger and Janet Maddox
3. Title(s):Assistant Divison Manger and Pretreatment Program Supervisor
4. Last Inspection Date: 9/4/09 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
PCS CODING
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac.Type
N NC0020184 09/21/10 P S 1
(DTIA) (TYPI) (INSP) (FACC)
7. Current Number Of Significant Industrial Users(SIUs)? 25 SIUS
8. Current Number Of Categorical Industrial Users(CIUs)? 10 CIUS
9. Number of SIUs Not Inspected By POTW in the Last Calendar Year? 0
10.Number of SIUs Not Sampled By POTW in the Last Calendar Year? 0
11.Enter the Higher Number of 9 or 10 0 NOIN
12.Number of SIUs With No IUP,or With an Expired IUP 0 NOCM
13.Number of SIUs in SNC for Either Reporting or Limits Violations During Either of the Last 2 3 pSNC
Semi-Annual Periods(Total Number of SIUs in SNC)
14.Number of SIUs in SNC For Reporting During Either of the Last 2 Semi-Annual Periods 0 MSNC
15.Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi-Annual Periods 2 SNPS
16.Number of SIUs In SNC For Both Reporting and Limits Violations During Either of the Last 2 1
Semi-annual Periods
POTW INTERVIEW
17. Since the Last PCI,has the POTW had any NPDES Limits Violations? ❑YES Z NO
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 ®YES ❑NO
Discharge(Interference,Pass-Through,Blockage,Citizens' Complaints,Increased Color Tex,blockage.
Sludge Production,Etc.)?
If Yes,How are these Problems Being Addressed?
19. Which Industries have been in SNC for Limits or Reporting during SNC for Limits:See Comments Section
either of the Last 2 Semi-Annual Periods?Not Been Published for SNC for Reporting:Color Tex
Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not Published:None
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? Bessemer City(Hg and Cyanide)
Color Tex(exp.3/31/10)
21. Are Any Permits Or Civil Penalties Currently Under Adjudication?If Yes,Which ❑YES Z NO
Ones?
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 Z NO
If yes,which ones?Eliminated: Added:
NC DWQ Pretreatment Compliance Inspection(PCI)Form Updated 7/25/07 Page 1

28. PRETREATMENT PROGRAM ELEMENTS REVIEW—Please review POTW files,verify POTW has copy of Program Element i
their files,complete with supporting documents and copy of PERCS Approval Letter,and dates consistent with Program Info:
Program Element Last Submittal Received Last Approval Date Next Due,
Long Creek WWTP Date In file? Date In file If Applicable
Headworks Analysis(HWA) 8/31/10 ® Yes❑ No 11/22/05 ® Yes❑ No under review
Industrial Waste Survey(IWS) 6/29/10 ®Yes❑ No 7/27/05 ® Yes❑ No under review
Sewer Use Ordinance(SUO) 5/24/07 ® Yes❑ No 10/5/07 ® Yes❑ No
Enforcement Response Plan(ERP) 11/29/01 _ ® Yes❑ No 12/6/01 ® Yes❑ No
Long Term Monitoring Plan(LTMP) 10/21/02 ®Yes❑ No 1/13/03 ® Yes❑ No
Program Element Last Submittal Received Last Approval Date Next Due,
Crowder Creek WWTP Date In file? Date In file If Applicable
Headworks Analysis(HWA) 3/5/10 ® Yes❑ No 4/27/10 _ ®Yes❑ No 11/1/14
Industrial Waste Survey(IWS) 6/29/10 ® Yes❑ No 7/27/05 _ ® Yes❑ No under review
Sewer Use Ordinance(SUO) 5/24/07 _ ® Yes❑ No 10/5/07 ®Yes❑ No
Enforcement Response Plan (ERP) 11/29/01 ®Yes❑ No 12/6/01 ® Yes❑ No
Long Term Monitoring Plan(LTMP) 10/21/02 ®Yes❑ No 1/13/03 ® Yes❑ No
INDUSTRIAL USER PERMIT(IUP)FILE REVIEW(3 IUP FILE REVIEWS OR 1 FILE REVIEW AND I IU INSPECTION)
29. User Name 1.Cookson Inc. 2. Industrial Fabricators 3.Choice Beverage
30. IUP Number 1065 1062 1035
31. Does File Contain Current Permit? ®Yes ❑ No ® Yes ❑ No ® Yes ❑ No
32. Permit Expiration Date 12-31-10 8/31/10 12/31/10
33. Categorical Standard Applied(I.E.40 CFR,Etc.)Or N/A 433.17 433.17 NA
34. Does File Contain Permit Application Completed Within One Year Prior ®Yes ❑ No ®Yes ❑ No ® Yes ❑ No
to Permit Issue Date?
35. Does File Contain an Inspection Completed Within Last Calendar Year? ®Yes ❑ No ®Yes ❑ No ®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. ❑Yes❑No b. [Wes❑No b. ❑Yes❑No
37. For 40 CFR 413 and 433 TTO Certification,Does File Contain a Toxic ®Yes❑No❑N/A ❑Yes❑No®N/A ❑Yes❑No®N/A
Organic Management Plan(TOMP)?
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❑No❑N/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 ❑ No ® Yes ❑ No ® Yes ❑ No
41a.During the Most Recent Semi-Annual Period,Did the SIU Complete its ❑Yes❑No®N/A ❑Yes❑No®N/A ❑Yes❑NoON/A
Sampling as Required by IUP,including flow?
41b.During the Most Recent Semi-Annual Period,Did SIU submit all reports ❑Yes❑No®N/A ❑Yes❑No®N/A ❑Yes❑NoON/A
on time?
42a.For categorical IUs with Combined Wastestream Formula(CWF),does ❑Yes❑No®N/A ❑Yes❑No®N/A ❑Yes❑No®N/A
file include process/dilution flows as Required by IUP?
42b.For categorical IUs with Production based limits,does file include ❑Yes❑NoON/A ❑Yes❑No®N/A ❑Yes❑No®N/A
production rates and/or flows as Required by IUP?
43a. During the Most Recent Semi-Annual Period,Did the POTW Identify ❑Yes❑No®NA ❑Yes❑No®N/A ❑Yes❑NoON/A
All Limits Non-Compliance from Both POTW and SIU Sampling?
43b. During the Most Recent Semi-Annual Period,Did the POTW Identify ❑Yes❑NOON/A ❑Yes❑NoON/A ❑Yes❑No®N/A
All Reporting Non-Compliance from SIU Sampling?
NC DWQ Pretreatment Compliance Inspection(PCI)Form Updated 7/25/07 Page 2

as the 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
onitoring 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.Did POTW resample within 30 days of knowledge of SIU limit c.❑Yes❑No®N/A c.❑Yes❑No®N/A c.❑Yes❑No®N/A
violations from the POTW sample event? _
45. During the Most Recent Semi-Annual Period,Was the SIU in SNC? ❑Yes ® No ❑ Yes Z No ❑ Yes Z No
46. During the Most Recent Semi-Annual Period, Was Enforcement Taken ®Yes❑No❑N/A ®Yes❑No❑N/A ❑Yes❑No®N/A
as Specified in the POTW's ERP(NOVs,Penalties,timing,etc.)?
47. Does the File Contain Penalty Assessment Notices? ❑Yes❑NoElN/A ❑Yes❑No®N/A ❑Yes❑NogN/A
48. Does The File Contain Proof Of Penalty Collection? ❑Yes❑No®N/A ❑Yes❑No®N/A ❑Yes❑No®N/A
49. a.Does the 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❑No®N/A b.❑Yes❑No®N/A b.❑Yes❑No®N/A
50. Did the POTW Representative Have Difficulty in Obtaining Any of This ❑Yes ® No ❑Yes Z No ❑Yes ® No
Requested Information For You?
FILE REVIEW COMMENTS:
34. Permit Application: Cookson,7/22/08;Industrial Fabricators,8/30/06;Choice Beverage,6/20/05. Cookson and Choice Beverage
has submitted the IUP Applications for IUP renewal.
35. IU Inspections: Cookson,6/3/09;Industrial Fabricators,9/16/09; Choice Beverage,8/10/10.
38. Permit Approval: Cookson,9/4/08; Industrial Fabricators, 11/14/06; Choice Beverage, 10/21/08.
41a. The POTW has responsibility for all sampling. Industrial Fabricators has a waiver for flow reporting due to safety concerns.
43a. The POTW performs all sampling.
46. Cookson,NOV 4/7/10 for zinc; Industrial Fabricators,NOV 4/20/10 for TP and NOV 6/2/10 for zinc.
SUMMARY AND COMMENTS:
Comments:
13. 7-12/09 Bessemer City wa in SNC for mercury; 1/6/10 Clover was in SNC for organic nitrogen;Color Tex was in SNC for reporting,color,
and zinc.
18. Color Tex caused a blockage by dropping a plastic cover from an RV into the collection system,lint accumulated around the cap leading to
the blockage.
20. Bessemer City is under two Orders, one for mercury limit noncompliance and one for cyanide limit noncompliance. The mercury
noncompliance appears to be resolved. Cyanide limit noncompliance is ongoing. Bessemer City has placed Dole Foods under an Order for
cyanide. Dole Foods is currently conducting pilot studies utilizing hydrogen peroxide for cyanide reduction.
28. The SUO was last adopted by City Council on 2/4/03.
Requirements:
See the Program Elements Review Section of this report.
NC DWQ Pretreatment Compliance Inspection(PCI)Form Updated 7/25/07 Page 3

44‘
Recommendations:
Bessemer City(a municipality permitted as a SIU by Gastonia) is under a SOC for cyanide which includes required submittals from
Bessemer City regarding Dole Foods(under an IUP from Bessemer City). The City of Gastonia must ensure compliance with the
conditions of the SOC;however, Bessemer City claims that all pertinent information has been submitted. It is recommended that some
resolution be reached between the two local governments to resolve the SOC reporting dispute in a timely manner.
NOD: ❑YES ®NO
NOV: ❑ YES ®NO
QNCR: ❑YES® NO
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory_❑
PCI COMPLETED B �� `� DATE: September 27,2010
Joh Lesley,Mooresville Regiodal Office
NC DWQ Pretreatment Compliance Inspection(PCI)Form Updated 7/25/07 Page 4

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
September 9, 2009
Mr. David Shellenbarger •
City of Gastonia
Post Office Box 1748
Gastonia,North Carolina 28053-1748
Subject: Pretreatment Compliance Inspection
City of Gastonia
NPDES Permit No. NC0020184
Gaston County, NC
Dear Mr. Shellenbarger
Enclosed is a copy of the Pretreatment Compliance Inspection Report for the inspection conducted at the
subject facility on September 4, 2009 by John Lesley 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. Lesley or me at [phone]. •
Sincerely,
l
obert B. Krebs
c Surface Water Protection
Regional Supervisor
Enclosure
cc: Central Files
Dana Folley, PERCS Unit
Mooresville Regional Office One
Location:610 East Center Ave.,Suite 301 Mooresville,NC 28115 NorthCarolina
Phone:[phone]\Fax:[phone]\Customer Service: 1-877-623-6748 Naturally
Internet:www.ncwaterquality.org

o �
W rE9NORTH CAROLINA DIVISION OF WATER QUALITY aFAVA
CDENR PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)1
1. Control Authority(POTW)Name: City of Gastonia
2. Control Authority Representative(s): Mr. David Shellenbarger
3. Title(s): Assistant Division Manager,Wastewater Treatment
4. Last Inspection Date: 8/5/08 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
PCS CODIN_ G
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac.Type
N NC0020184 09/04/09 P S 1
(DTIA) (TYPI) (INSP) (FACC)
7. Current Number Of Significant Industrial Users(SIUs)? 25 SIDS
8. Current Number Of Categorical Industrial Users(CIUs)? 10 CIUS
9. Number of SIUs Not Inspected By POTW in the Last Calendar Year? 0
10.Number of SIUs Not Sampled By POTW in the Last Calendar Year? 0
1 1.Enter the Higher Number of 9 or 10 0 NOIN
12.Number of SIUs With No IUP,or With an Expired IUP 0 NOCM
13.Number of SIUs in SNC for Either Reporting or Limits Violations During Either of the Last 2 3 PSNC
Semi-Annual Periods(Total Number of SIUs in SNC)
14.Number of SIUs in SNC For Reporting During Either of the Last 2 Semi-Annual Periods 0 MSNC
15.Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi-Annual Periods 2 L SNPS
16.Number of SIUs In SNC For Both Reporting and Limits Violations During Either of the Last 2 1
Semi-annual Periods
POTW INTERVIEW
17. Since the Last PCI,has the POTW had any NPDES Limits Violations? ❑ YES ®NO
If Yes,What are the Parameters and How are these Problems Being Addressed? See comments
18. Since the Last PCI,has the POTW had any Problems Related to an Industrial ® YES ❑NO
Discharge(Interference,Pass-Through,Blockage,Citizens' Complaints,Increased See comments
Sludge Production,Etc.)?
If Yes,How are these Problems Being Addressed?
19. Which Industries have been in SNC for Limits or Reporting during SNC for Limits:Color Tex,Danaher,Cookson
either of the Last 2 Semi-Annual Periods?Not Been Published for SNC for Reporting:Color Tex
Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not Published: None
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? Bessemer City,Hg, CN
Danaher,Hg,CN
21. Are Any Permits Or Civil Penalties Currently Under Adjudication?If Yes,Which ❑ YES ®NO
Ones?
LTMP/STMP FILE REVIEW:
22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? Z 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 DWo Pretreatment Comnliance Tncnectinn(PCT)Form Undated 7/25/07 Page 1

28. PRETREATMENT PROGRAM ELEMENTS REVIEW—Please review POTW files,verify POTW has copy of Program Element in
their files,complete with supporting documents and copy of PERCS Approval Letter,and dates consistent with Program Info:
LONG CREEK WWTP
Program Element Last Submittal Received Last Approval Date Next Due,
Date In file? Date In file If Applicable
Headworks Analysis(HWA) 10/28/05 ® Yes ❑ No 11/22/05 ®Yes❑ No 5/31/10
Industrial Waste Survey(IWS) 6/29/05 ®Yes ❑ No 7/27/05 ® Yes ❑ No 6/30/10
Sewer Use Ordinance(SUO) 5/24/07 ®Yes ❑ No 10/5/07 ® Yes❑ No
Enforcement Response Plan(ERP) 11/29/01 ® Yes ❑ No 12/6/01 ®Yes❑ No
Long Term Monitoring Plan(LIMP) 10/21/02 ® Yes❑ No 1/13/03 ®Yes ❑ No
28. PRETREATMENT PROGRAM ELEMENTS REVIEW—Please review POTW files,verify POTW has copy of Program Element in
their files,complete with supporting documents and copy of PERCS Approval Letter,and dates consistent with Program Info:
CROWDERS CREEK WWTP
Program Element Last Submittal Received Last Approval Date Next Due,
Date In file? Date In file If Applicable
Headworks Analysis(HWA) 4/23/09 ®Yes❑ No 7/16/09 ®Yes❑ No 12/15/09
Industrial Waste Survey(IWS) 6/29/05 ® Yes ❑ No 7/27/05 ®Yes❑ No 6/30/10
Sewer Use Ordinance(SUO) 5/24/07 ®Yes❑ No 10/5/07 ®Yes❑ No
Enforcement Response Plan(ERP) 11/29/01 ®Yes❑ No 12/6/01 ®Yes ❑ No
Long Term Monitoring Plan (LIMP) 10/21/02 ®Yes❑ No 1/13/03 ®Yes ❑ No
INDUSTRIAL USER PERMIT(IUP)FILE REVIEW(3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name 1.Stabilus 2.Lubrizol 3.Port-A-Jon
30. IUP Number 1021 1053 1057
31. Does File Contain Current Permit? ®Yes ❑ No ®Yes ❑ No ®Yes ❑ No
32. Permit Expiration Date 12/31/10 8/31/11 12/31/11
33. Categorical Standard Applied(I.E.40 CFR,Etc.)Or N/A 433.17 414.85 NA
34. Does File Contain Permit Application Completed Within One Year Prior ®Yes ❑ No ®Yes ❑ No ®Yes ❑ No
to Permit Issue Date?
35. Does File Contain an Inspection Completed Within Last Calendar Year? ® Yes ❑ No ®Yes ❑ No ®Yes ❑ No
36. a.Does the File Contain a Slug/Spill Control Plan? a. ®Yes ONo a. ®Yes ONo a. ❑Yes ENo
b.If No,is One Needed?(See Inspection Form from POTW) b. ❑Yes ONo b. ['Yes ONo b. ❑Yes ENo
37. For 40 CFR 413 and 433 TTO Certification,Does File Contain a Toxic ❑Yes❑No®N/A ❑Yes❑No®N/A ❑Yes❑No®N/A
Organic Management Plan(TOMP)?
38. a.Does File Contain Original Permit Review Letter from the Division? a. EYes ONo a. EYes ONo a. EYes ONo
b.All Issues Resolved? b.®Yes❑No❑N/A b.fig Yes❑No❑N/A b.®Yes❑No❑N/A
39. During the Most Recent Semi-Annual Period,Did the POTW Complete ®Yes ❑ No ® Yes ❑ No Z Yes ❑ No
its Sampling as Required by IUP,including flow?
40. Does File Contain POTW Sampling Chain-Of-Custody Forms? ®Yes ❑ No Z Yes ❑ No ®Yes ❑ No
41a. During the Most Recent Semi-Annual Period,Did the SIU Complete its ®Yes❑No❑N/A ®Yes❑No❑N/A ®Yes❑No❑N/A
Sampling as Required by IUP,including flow?
4 lb. During the Most Recent Semi-Annual Period,Did SIU submit all reports ®Yes❑No❑N/A ®Yes❑No❑N/A ®Yes❑No❑N/A
on time?
42a.For categorical IUs with Combined Wastestream Formula(CWF),does ®Yes❑No❑N/A ❑Yes❑NoE3N/A ❑Yes❑NoE1N/A
file include process/dilution flows as Required by IUP?
42b. For categorical IUs with Production based limits,does file include ❑Yes❑No®N/A ❑Yes❑NoEN/A ❑Yes❑NoON/A
production rates and/or flows as Required by IUP?
43a. During the Most Recent Semi-Annual Period,Did the POTW Identify EYes❑No❑NA ®Yes❑No❑N/A ®Yes❑No❑N/A
All Limits Non-Compliance from Both POTW and SIU Sampling?
43b. During the Most Recent Semi-Annual Period,Did the POTW Identify ®Yes❑No❑N/A ®Yes❑No❑N/A ®Yes❑No❑N/A
All Reporting Non-Compliance from SIU Sampling?
44. a.Was the 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?
NC DWQ Pretreatment Compliance Inspection(PCI)Form Updated 7/25/07 Page 2

rd
Industry Resample and submit results to POTW Within 30 Days?
b.❑Yes❑NoN/A b.❑Yes❑No®N/A b❑Yes❑NoN/A
id POTW resample within 30 days of knowledge of SIU limitc❑Yes❑NoN/Avoations from the POTW sample event? c.®Yes❑No❑N/A c.❑Yes❑No®N/A
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 ®Yes❑No❑N/A ❑Yes❑No®N/A ❑Yes❑NoON/A
as Specified in the POTW's ERP(NOVs, Penalties,timing,etc.)?
47. Does the File Contain Penalty Assessment Notices? ❑Yes❑No®N/A ❑Yes❑NoON/A ❑Yes❑No®N/A
48. Does The File Contain Proof Of Penalty Collection? ❑Yes❑No®N/A ❑Yes❑No®N/A ❑Yes❑No®N/A
49. a.Does the 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❑No®N/A b.❑Yes❑No®N/A b.❑Yes❑No®N/A
50. Did the POTW Representative Have Difficulty in Obtaining Any of This ❑ Yes ® No ❑ Yes ® No ❑ Yes ® No
Requested Information For You?
FILE REVIEW COMMENTS:
34. IUP Applications: Stabilus,7/12/05; Lubrizol Advanced Materials, 1/16/06; Port-A-Jon Piedmont,7/11/05
35. Inspections: Stabilus,9/9/08; Lubrizol Advanced Materials,6/15/09;Port-A-Jon Piedmont, 12/12/08.
36. Port-A-Jon Piedmont does not need a spill and slug control plan because the waste is brought in by truck.
37. Stabilus performs the TTO analyses.
46. Stabilus was issued NOVs for ammonia nitrogen and oil&grease in 1/09 and flow in 2/09.
SUMMARY AND COMMENTS:
Comments:
1. R&R Powder Coating was dropped from the program on 4/27/09.
2. A&S/Southeastern Electroplating was dropped from the program 8/23/08.
3. BOD violations reported at Long Creek WWTP and increses in the BOD values for Crowders Creek WWTP were determined to be caused
by QA/QC problems with the laboratory facility air quality.
4. Carolina By Products caused interference at the Crowders Creek WWTP by discharging elevated nitrite/nitrate. The issue has been resolved.
Requirements:
See the Program Elements Review Section of this report for due dates.
Recommendations:
NOD: ❑ YES ®NO
NOV: ❑ YES ® NO
QNCR: ❑ YES® NO
POTW Rating:
Satisfactory ® Marginal ❑ Unsatis' ctory_❑
�--\ Z
PCI COMPLETED BY: i �"�� DATE: September 8,2009
.ol Lesley,Mooresville RegionOflce
NC DWO Pretreatment Compliance Inspection(PCI)Form Updated 7/25/07 Page 3

W AT94 Michael F.Easley,Governor ^-
�0 �i William G.Ross Jr.,Secretary
rNorth Carolina Department of Environment and Natural Resources
p .� Coleen H.Sullins,Director
Division of Water Quality
August 6, 2008
Mr. David Shellenbarger
Assistant Division Manager, Wastewater Treatment
City of Gastonia
Post Office Box 1748
Gastonia,North Carolina 28053-1748
Subject: Pretreatment Compliance Inspection
City of Gastonia
NPDES Permit No. NC0020184
Gaston County,NC
Dear Mr. Shellenbarger
Enclosed is a copy of the Pretreatment Audit Report for the inspection conducted at the
subject facility on August 5, 2008 by John Lesley 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. Lesley or me at [phone].
Sincerely,
obert B. Krebs
Surface Water Protection Regional Supervisor
Enclosure
cc: Central Files
Dana Folley, PERCS Unit
Gaston County Health Department
Mailing Address Phone[phone] Location Nchv Carolina
610 East Center Avenue,Suite 301 Fax [phone] 610 East Center Avenue,Suite 301 Qtura ly
Mooresville,NC 28115 Mooresville,North Carolina
Internet: www.ncwaterqualitv.org Customer Service 1-877-623-6748
An Equal Opportunity/Affirmative Action Employer—50%Recycled/10%Post Consumer Paper

� W ATF9
���; NORTH CAROLINA DIVISION OF WATER QUALITY �� �➢
NCDENR PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
O Y
BACKGROUND INFORMATION(Complete Prior To PCI; Review Program Info Database Sheet(s)1
1. Control Authority(POTW)Name: City of Gastonia
2. Control Authority Representative(s):David Shellenbarger
3. Title(s):Assistant Division Manager Wastewater Treatment
4. Last Inspection Date: 8/3/07 Inspection Type: ❑ PCI ® Audit
5. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? Z 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
PCS CODING
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac.Type
N NC0020184 08/05/08 P S 1
(DTIA) (TYPI) (INSP) (FACC)
7. Current Number Of Significant Industrial Users(SIUs)? 27 SIUS
8. Current Number Of Categorical Industrial Users(CIUs)? 12 CIUS
9. Number of SIUs Not Inspected By POTW in the Last Calendar Year? 0
10.Number of SIUs Not Sampled By POTW in the Last Calendar Year? 0
11.Enter the Higher Number of 9 or 10 0 NOIN
12.Number of SIUs With No IUP,or With an Expired IUP 0 NOCM
13.Number of SIUs in SNC for Either Reporting or Limits Violations During Either of the Last 2 6 PSNC
Semi-Annual Periods(Total Number of SIUs in SNC)
14.Number of SIUs in SNC For Reporting During Either of the Last 2 Semi-Annual Periods 1 MSNC
15.Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi-Annual Periods 5 SNPS
16.Number of SIUs In SNC For Both Reporting and Limits Violations During Either of the Last 2 0
Semi-annual Periods
POTW INTERVIEW
17. Since the Last PCI,has the POTW had any NPDES Limits Violations? ❑ YES Z NO
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 ❑YES ®NO
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 SNC for Limits:See Comments
either of the Last 2 Semi-Annual Periods?Not Been Published for SNC for Reporting:See Comments
Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not Published: None
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? See Comments
21. Are Any Permits Or Civil Penalties Currently Under Adjudication?If Yes,Which ❑YES ®NO
Ones?
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? Z YES ❑NO
If yes,which ones?Eliminated: Antimony,Berylium Added:
NC DWQ Pretreatment Compliance Inspection(PCI)Form Updated 7/25/07 Page 1

. PRETREATMENT PROGRAM ELEMENTS REVIEW—Please review POTW files,verify POTW has copy of Program Element in
eir files,complete with supporting documents and copy of PERCS Approval Letter,and dates consistent with Program Info:
Program Element Headworks Analysis(HWA)
Last Submittal Last Approval Date Next Due,
Date In file? Date In file If Applicable
Crowder 2/17/05 Z Yes El No Crowder 3/15/05 ® Yes❑ No Crowder 12/15/09
Long 10/28/05 Long 11/22/05 Long 5/31/10
Industrial Waste Survey(IWS) 6/29/05 ®Yes 0 No 7/27/05 ® Yes El No 6/30/10
Sewer Use Ordinance(SUO) 5/24/07 ®Yes El No 10/5/07 ®Yes ❑ No
Enforcement Response Plan(ERP) 11/29/01 ®Yes El No 12/6/01 ® Yes III No
Long Term Monitoring Plan(LTMP) Crowder 10/21/02 ®Yes El No Crowder 1/13/03 ® yes❑ No
Long 10/21/02 Long 1/13/03
INDUSTRIAL USER PERMIT(IUP)FILE REVIEW(3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name 1.Sunshine Uniform 2.Choice USA 3. Freightliner
30. IUP Number 1013 1035 1023
31. Does File Contain Current Permit? ®Yes ❑ No ® Yes ❑ No ® Yes ❑ No
32. Permit Expiration Date 12/31/11 12/31/11 12/31/11
33. Categorical Standard Applied(I.E.40 CFR,Etc.)Or N/A NA NA 433.17
34. Does File Contain Permit Application Completed Within One Year Prior ® Yes ❑ No ® Yes ❑ No ® Yes ❑ No
to Permit Issue Date?
35. Does File Contain an Inspection Completed Within Last Calendar Year? ®Yes ❑ No ® Yes ❑ No ® Yes ❑ No
36. a.Does the File Contain a Slug/Spill Control Plan? a. ZYes ONo a. ®Yes ONo a. 0Yes ONo
b.If No,is One Needed?(See Inspection Form from POTW) b. ❑Yes❑No b. ❑Yes ONo b. ❑Yes ONo
37. For 40 CFR 413 and 433 TTO Certification,Does File Contain a Toxic ❑Yes❑No®N/A ❑Yes❑No®N/A ❑Yes❑NOON/A
Organic Management Plan(TOMP)?
38. a.Does File Contain Original Permit Review Letter from the Division? a. ZYes ONo a. ZYes ONo a. ®Yes ONo
b.All Issues Resolved? b.®Yes❑No❑N/A b.®Yes❑No❑N/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 ❑ No ® Yes ❑ No ® Yes ❑ No
41. During the Most Recent Semi-Annual Period,Did the SIU Complete its ❑Yes❑NoON/A ❑Yes❑No®N/A ®Yes❑No❑N/A
Sampling as Required by IUP,including flow?
41b. During the Most Recent Semi-Annual Period,Did SIU submit all reports ®Yes❑No❑N/A ®Yes❑No❑N/A ®Yes❑No❑N/A
on time?
42a. For categorical IUs with Combined Wastestream Formula(CWF),does ❑Yes❑NoIDN/A ❑Yes❑NoElN/A ®Yes❑No❑N/A
file include process/dilution flows as Required by IUP?
42b. 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?
43a. During the Most Recent Semi-Annual Period,Did the POTW Identify ❑Yes❑No®NA ❑Yes❑No®NIA ElYes❑No❑N/A
All Limits Non-Compliance from Both POTW and SIU Sampling?
43b. During the Most Recent Semi-Annual Period,Did the POTW Identify ❑Yes❑No®N/A ❑Yes❑No®N/A ❑Yes❑No®N/A
All Reporting Non-Compliance from SIU Sampling?
44. a. Was the 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.Did POTW resample within 30 days of knowledge of SIU limit c.❑Yes❑No®N/A
violations from the POTW sample event? c.❑Yes❑No®N/A c.®Yes❑No❑N/A
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 ❑Yes❑No®N/A ❑Yes❑No®N/A ®Yes❑No❑N/A
as Specified in the POTW's ERP(NOVs,Penalties,timing,etc.)?
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❑NoE1N/A ❑Yes❑No®N/A ❑Yes❑NoEIN/A
49. a.Does the 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❑No®N/A b.❑Yes❑No®N/A b.❑Yes❑No®N/A
50. Did the POTW Representative Have Difficulty in Obtaining Any of This ❑Yes ® No ❑ Yes ® No ❑ Yes Z No
Requested Information For You?
NC DWQ Pretreatment Compliance Inspection(PCI)Form Updated 7/25/07 Page 2

FILE REVIEW COMMENTS:
1. Inspections: Sunshine Uniform, 11/28/07; Choice USA, 12/7/07, Freightliner, 8/21/07
2. IUP Applications: Sunshine Uniform,6/9/05; Choice USA,6/20/05; Freightliner,7/11/05
3. POTW performs sampling at SIUs,Freightliner splits samples with POTW(results are averaged). POTW performs TTO analyses.
4. Freightliner received NOVs for TSS,zinc,nickel,and pH violations.
SUMMARY AND COMMENTS:
Comments:
1. Rauch Industries was dropped from the program. Division approval for the drop request was dated 5/10/07.
2. Cookson Company,Inc,a powder coating operation,has been added to the City's Pretreatment Program. IUP was submitted for
approval on 7/30/08.
3. The SUO was approved on 10/5/07 with the stipulation that the adopted SUO be submitted with the documentation of adoption
and the effective date of the SUO.
4. The POTW has requested that antimony and beryllium analyses be removed from the LTMP. The Long Creek WWTP NPDES
Permit has dropped these parameters due to non-detection.
5. SNC for Limits Violations: Industrial Fabricators 1-6/07; Town of Clover 7-12/07;Powder Coating Services 7-12/07;R&R
Powder Coating(SOC issued,exp.on 6/30/08) 1-12/07;and Danaher Tool 7-12/07.
6. SNC for Reporting: Colortex 7-12/07.
Requirements:
See the Program Elements Review Section of this report.
Recommendations:
The City's Pretreatment Program is commendable.
NOD: ❑YES ®NO
NOV: ❑YES ® NO
QNCR: ❑YES® NO
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory_❑
PCI COMPLETED BY: (_ `/ DATE: August 6,2008
J hn esley,Mooresville Regional fee
NC DWQ Pretreatment Compliance Inspection(PCI)Form Updated 7/25/07 Page 3

NJ A r Michael F.Easley,Govern r
\O�0 RpG William G.Ross Jr.,Secretary
North Carolina Department of Environment and Natural Resources
Alan W.Klimek,P.E.Director
> ( iltror Division of Water Quality
Y
November 9, 2005
Mr. Larry Cummings
City of Gastonia
Post Office 1748
Gastonia, North Carolina 28053-1748
Subject: Pretreatment Compliance
Inspection
City of Gastonia Pretreatment Program
NPDES Permit No. NC0020184
Gaston County, NC
Dear Mr. Cummings:
Enclosed is a copy of the Pretreatment Compliance Inspection Report for the inspection
of the City of Gastonia's approved Industrial Pretreatment Program on November 7, 2005 by Mr.
John Lesley of this Office. The organization and management of the City's Pretreatment Program
is commendable.
The report should be self-explanatory; however, should you have any questions
concerning this report,please do not hesitate to contact Mr. Lesley or me at(704) 663-1699.
Sincerely,
- D. Rex Gleason, P.E.
�' Surface Water Protection Regional Supervisor
Enclosure
cc: Central Files
Dana Folley, PERCS Unit
Gaston County Health Department
No hCarolina
Aatura!!y A'1
GDENR
N.C.Division of Water Quality,Mooresville Regional Office,610 E.Center Ave.Suite 301,Mooresville NC 28115 [phone] Customer Service
1-877-623-6748

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`W; rip NORTH CAROLINA DIVISION OF WATER QUALITY o�°� arFR76
NCDENR PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
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ENVIRa+MENT ulo NQ4w�l RCScuRCES
•
BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)1
1. Control Authority(POTW)Name: City of Gastonia
2. Control Authority Representative(s): David Shellenbarger Telephone: [phone] Fax: [phone]
3. Title(s): Assistant Division Manager/Wastewater Management E-mail:
4. Last Inspection Date: 10/12/2004 Inspection Type: ®PCI ❑Audit
5. Has Program Completed All Requirements from the Previous Inspection or Program Info Sheet(s)? ® Yes ❑ No
6. Is POTW under an Order That Includes Pretreatment Conditions? ❑Yes ® No
Order Type and Number: Are Milestone Dates Being Met? ❑ Yes ❑ No ® NA
PCS CODING
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac.Type
I I INlcln In 12 In Il I8 14 1 111107105I IP I Is l 11 I
(DTIA) (TYPI) (INSP) (FACC)
7. Current Number Of Significant Industrial Users(SIUs)? 23 SIUS
8. Current Number Of Categorical Industrial Users(CIUs)? 8 CIUS
9. Number of SIUs Not Inspected By POTW in the Last Calendar Year? 0
10.Number of SIUs Not Sampled By POTW in the Last Calendar Year? 0
11.Enter the Higher Number of 9 or 10 0 NON
12.Number of SIUs With No IUP,or With an Expired IUP 0 NOCM
13.Number of SIUs in SNC for Either Reporting or Limits Violations During Either of the Last 2
Semi-Annual Periods(Total Number of SIUs in SNC) 3 PSNC
14.Number of SIUs in SNC For Reporting During Either of the Last 2 Semi-Annual Periods 1 MSNC
15.Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi-Annual Periods 2 SNPS
16.Number of SIUs In SNC For Both Reporting and Limits Violations During Either of the Last 2
Semi-annual Periods 0
POTW INTERVIEW
17. Since the Last PCI,has the POTW had any POTW Permit Limits Violations? ❑Yes ® No
If Yes,What are the Parameters and How are these Problems Being Addressed?
(See Comments Section)
18. Since the Last PCI,has the POTW had any Problems Related to an Industrial ® Yes ❑ No
Discharge(Interference,Pass-Through, Blockage,Citizens' Complaints, Increased Grease blockages in collection
Sludge Production,Etc.)? system.
If Yes,How are these Problems Being Addressed?
19. Which Industries have been in SNC during either of the Last 2 Semi- SNC for Limits: See Comments
Annual Periods?Have any Industries in SNC(During Either of the Last SNC for Reporting: See Comments
2 Semi-Annual Periods)Not Been Published for Public Notice? Not Published: None
(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? AB Carter
21. Are Any Permits Or Civil Penalties Currently Under Adjudication?If Yes, Which ❑ Yes ® No
Ones?
Filename: Gastonia 0506pci Page 1
Revised: 6/30/9R

PRETREATMENT
PROGRAM ELEMENTS REVIEW- Please review POTW files and complete the following:
Program Element Date of Last Approval Date Next Due,If Applicable
Headworks Analysis(HWA) Long: 9/07/05 Crowders 3/15/05 Long: 5/31/2010 Crowders: 12/15/2009
Industrial Waste Survey(IWS) 7/27/05 6/30/10
Sewer Use Ordinance(SUO) 12/6/01 12/1/06
Enforcement Response Plan(ERP) 12/6/01
Long Term Monitoring Plan(LTMP) Long: 7/13/2003 Crowders: 7/13/2003
LTMP FILE REVIEW:
22. Is the LTMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ®Yes ❑ No
23. Should any Pollutants of Concern be Eliminated from or Added to the LTMP? ❑Yes ® No
If yes,which ones?Eliminated: Added:
24. Are Correct Detection Levels being used for all LTMP Monitoring? ®Yes ❑ No
25. Is the LTMP Data Maintained in a Table or Equivalent? ®Yes ❑ No Is the Table Adequate? ®Yes ❑ No
INDUSTRIAL USER PERMIT(IUP)FILE REVIEW(3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
26. User Name 1. Industrial Electroplating 2. Town of Clover 3. Gaston Memorial Hospital
27. IUP Number 1011 1048 1017
28. Does File Contain Current Permit? ®Yes ❑ No ®Yes ❑ No ® Yes ❑ No
29. Permit Expiration Date 12/31/05 8/31/06 12/31/05
30. Categorical Standard Applied(I.E.40 CFR,Etc.)Or N/A 413.4 NA NA
31. Does File Contain Permit Application Completed Within One Year Prior ® Yes ❑ No ®Yes ❑ No ®Yes ❑ No
to Permit Issue Date?
22. Does File Contain an Inspection Completed Within Last Calendar Year? ® Yes ❑ No ®Yes ❑ No ® Yes ❑ No
33. a.Does the File Contain a Slug Control Plan? a. ®Yes❑No a. ❑Yes ENo a. ®Yes❑No
b. If No,is One Needed? (See Inspection Form from POTW) b. ❑Yes❑No b. ®Yes ❑No b. ❑Yes❑No
34. For 40 CFR 413 and 433 TTO Certifiers,Does File Contain a Toxic ®Yes❑No❑N/A ❑Yes❑NoEN/A ❑Yes❑NoEN/A
Organic Management Plan(TOMP)?
35. a.Does File Contain Original Permit Review Letter from the Division? a. ®Yes❑No a. EYes ❑No a. ®Yes ❑No
b.All Issues Resolved? b.®Yes❑No❑N/A b.®Yes❑No❑N/A b.®Yes❑No❑N/A
36. During the Most Recent Semi-Annual Period,Did the POTW Complete ® Yes ❑ No ®Yes ❑ No ® Yes ❑ No
its Sampling as Required by IUP? .
37. Does File Contain POTW Sampling Chain-Of-Custody Forms? ®Yes ❑ No ®Yes Cl No ®Yes ❑ No
38. During the Most Recent Semi-Annual Period,Did the SIU Complete its ❑Yes❑NoEN/A ❑Yes❑NoEN/A ®Yes❑No❑N/A
Sampling as Required by IUP?
39. Does Sampling Indicate Flow or Production? ®Yes❑No❑N/A ®Yes❑No❑N/A ®Yes❑No❑N/A
40. During the Most Recent Semi-Annual Period,Did the POTW Identify ❑Yes ❑ No ❑ Yes ❑ No ® Yes ❑ No
All Non-Compliance from Both POTW and SIU Sampling? ®NA ®NA ❑NA
41. a. Was the POTW Notified by SIU(Within 24 Hours)of All Self- a.❑Yes❑No®N/A a.❑Yes❑No®N/A a.❑Yes❑NoEN/A
Monitoring Violations?
b.Did Industry Resample Within 30 Days? b. ❑Yes❑No b. ❑Yes❑No b. ❑Yes❑No _
42. Was the SIU Promptly Notified of Any Violations(Per ERP)? ❑Yes❑NoEN/A ❑Yes❑NoEN/A ®Yes❑No❑N/A
43. During the Most Recent Semi-Annual Period,Was the SIU in SNC? 1 ❑Yes ® No ❑ Yes ® No ❑ Yes ® No
44. During the Most Recent Semi-Annual Period,Was Enforcement Taken ❑Yes❑NoEN/A ❑Yes❑NoEN/A ®Yes❑No❑N/A
as Specified in the POTWs ERP?
45. Does the File Contain Penalty Assessment Notices? ❑Yes❑NoEN/A ❑Yes❑NoEN/A ❑Yes❑NoEN/A
46. Does The File Contain Proof Of Penalty Collection? ❑Yes❑NoEN/A ❑Yes❑NoEN/A ❑Yes❑NoEN/A
47. a.Does the File Contain Any Current Enforcement Orders? a.❑Yes❑No®N/A a.❑Yes❑No®N/A a.❑Yes❑NoEN/A
b. Is SIU in Compliance with Order? b.❑Yes❑No®N/A b.❑Yes❑NOON/A b.❑Yes❑No®N/A
48. Did the POTW Representative Have Difficulty in Obtaining Any of This ❑Yes ® No ❑Yes ® No ❑Yes ® No
Requested Information For You?
Filename: Gastonia 0506pci Page 2
Revised. 6/30/9R

r ILL RE V IL'W l'V1V11V1E1V IS:
Question 38: Gaston Memorial Hosptial conducts additional sampling not required by the IUP.
PCI SUMMARY AND COMMENTS:
PCI Comments:
1. (Question 20) AB Carter is in SNC for sample tampering and submitting a false report. AB Carter has signed a consent order
that requires them to construct facilities to improve treatment for copper removal. The SOC was orginally signed on October 6,
2004 and amended on September 28,2005. Rauch Industries(last quarter of 2004)and Stabilus(first quarter of 2005)were in SNC
for limits violations.
2. Radici Spandex,an OCPSF manufacturer,is scheduled to cease operations by 12/31/2005.
3. Other participants: Janet Maddox,Nancy Matherly,John Copeland,and Stephanie Scheringer.
Requirements: See the Pretreatment Program Elements Review Section of this report.
Recommendations: The Pretreatment Program is commendable.
NOD: ❑Yes ® No
NOV: ❑ Yes ® No
QNCR: ❑Yes ® No
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory ❑
PCI COMPLETED BY: - ` DATE: November 8,2005
Lesley,Mooresville Regis nal Office
Filename: Gastonia 0506pci Page 3
Revised: 6/30/9R

\^'A 1'� • Michad F.Easley. ov� crnor
\. 9Q William G.Ross Jr_Secretary
North Carolina Department of Environment and Natural Resources
> r Alan W.Klimek.P.E.Director
_ -{ Division of Water Quality
T Coleen H.Sullins.Deputy Director
Division of Water Quality
March 29, 2004
Mr. David Shellenbarger
Assistant Manager of Compliance WWTD
City of Gastonia
Post Office Box 1748
Gastonia, North Carolina
•
Subject: PAR Review
City of Gastonia
NPDES Permit No. NC0020184
Gaston County,NC
Dear Mr. Shellenbarger:
Mooresville Regional Office staff has reviewed your Pretreatment Annual Report(PAR)
for the reporting period of January through December 2003. Based on the review, it appears that
the POTW completed the PAR in accordance with guidelines set forth in Chapter 9 of the
Comprehensive Guidance for North Carolina Pretreatment Programs.
If you have any questions concerning your PAR, please do not hesitate to contact John
Lesley of this Office at(704) 663-1699.
Sincerely,
n C. 5/
Rex Gleason, P.E.
.r.!c.,>D.
Water Quality Regional Supervisor
Cc: Pretreatment Unit Central Office
Central Files
•
No Carolina Ara.')aturaI11 NCDENR
N.C.Division of Water Quality, Mooresville Regional Office, 919 North Main Street, Mooresville NC 28115 [phone] Customer Service
1-877-623-6748

�OF ^t A1�� Michael F.Easlec.Governor
Q William G.Ross Jr..Secretary
\ North Carolina Department of Environment and Natural Resources
r Alan W.Klimek.P.E.Director
y Division of Water Quality
Colecn H.Sullins.Deputy Director
Division of Water Quality
March 26, 2004
Mr. Billy Edwards, Utility Director
Town of Ranlo
1624 Spencer Mountain Road
Gastonia, NC 28054
Subject: PAR Review
Town of Ranlo
NPDES Permit No. NC0021318 (rescinded)
Gaston
Dear Mr. Edwards:
Mooresville Regional Office staff has reviewed your Pretreatment Annual Report (PAR)
for the reporting period of January through December 2003. Based on the review, it appears that
the POTW completed the PAR in accordance with guidelines set forth in Chapter 9 of the
Comprehensive Guidance for North Carolina Pretreatment Programs. Be advised that the
program is a non-approved program and cannot be approved until all conditions for approval are
met; including, submittal of the City's formal request for program approval and signed copies of
required pretreatment documents.
If you have any questions concerning your PAR, please do not hesitate to contact John
Lesley of this Office at [phone].
Sincerely,
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
Cc; Pretreatment Unit- Central Office
Central Files
JL
•
'lorthCaroIina g,ra
JVaturaIII NCDENR
N.C.Division of Water Quality, Mooresville Regional Office, 919 North Main Street, Mooresville NC 28115 [phone] Customer Service
1-877-623-6748

?�f WATF90
07
�� G Michael F.EasJey,Governor
r
William G.Ross,Jr..Secretary
0 ♦.0 North Carolina Department of Environment and Natural Resoun:es
Alan W.Klimek,P.E.,Director
Division of Water Quay
April 17,2003 •
Mr. Billy Edwards, Utility Director
Town of Ranlo
1624 Spencer Mountain Road •
Gastonia, NC 28054
Subject: PAR Review
Town of Ranlo
NPDES Permit No. NC0021318'(rescinded)
• Gaston
Dear Mr. Edwards:
Mooresville Regional Office staff has reviewed your Pretreatment Annual Report (PAR)
for the reporting period of January through December 2002. Based on the review, it appears that
the POTW completed the PAR in accordance with guidelines set forth in Chapter 9 of the
Comprehensive Guidance for North Carolina Pretreatment Programs.
If you have any questions concerning your PAR, please do not hesitate to contact John
• Lesley of this Office at(704) 663-1699.
Sincerely,
es2,c_zs
Ylri D. Rex Gleason,P.E.
/Water Quality Regional Supervisor
Cc: Deborah Gore,Pretreatment Unit-Central Office
Central Files
JL
Mooresville Regional Office,919 North Main Street,Mooresville,NC 28115 e
PE10PE [phone]
=ze Customer Service