NC0046728_Inspection_20210521

ROY COOPER
Governor
DIONNE DELLI-GATTI
Secretary
S. DANIEL SMITH
Director
Jeff Campbell
Environmental Compliance Supervisor
Town of Mooresville
Post Office Box 878
Mooresville, NC 28115
Dear Mr. Campbell:
NORTH CAROLINA
Environmental Quality
May 25, 2021
SUBJECT: Pretreatment Compliance Inspection
Town of Mooresville
NPDES Permit No. NC0046728
Iredell County
Enclosed is a copy of the Pretreatment Compliance Inspection report for the inspection of the Town of Mooresville's
approved Industrial Pretreatment Program on May 19, 2021, by Mr. Wes Bell of this Office
The report should be self-explanatory; however, should you have any questions concerning this report, please do not
hesitate to contact Mr. Bell at [phone] or via email at [e-mail].
Enclosure:
Inspection Report
NORTH CPPOLINA
OE
Sincerely,
EDocuSigned by:
A14CC681AF27425...
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
North Carolina Department of Environmental Quality I Division of Water Resources
Mooresville Regional Office 1610 East Center Avenue. Suite 301 I Mooresville. North Carolina 28115
704.663.1699

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
BACKGROUND INFORMATION:
1. Control Authority (POTW) Name: Town of Mooresville
2. Control Authority Representative(s): Jeff Campbell, Cory Lane
3. Title(s): Environmental Compliance Supervisor, Environmental Compliance Officer
4. Last Inspection Date: 1/9/19 Inspection Type: ® PCI ❑ Audit
5. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? ® YES ❑ NO
6. Is POTW under an Order That Includes Pretreatment Conditions? ❑ YES ® NO
Order Type, Number, Parameters: Are Milestone Dates Being Met? ❑ YES ❑ NO ® NA
ICIS CODING
Main Program Permit Number
NC0046728
MM/DD/YY
05/19/21
7. Current Number Of Significant Industrial Users (SIUs)?
3
8. Number of SIUs With No IUP, or With an Expired IUP?
0
9. Number of SIUs Not Inspected By POTW in the Last Calendar Year?
0
10. Number of SIUs Not Sampled By POTW in the Last Calendar Year?
0
11. Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi -Annual Periods
0
12. Number of SIUs in SNC For Reporting During Either of the Last 2 Semi -Annual Periods
0
13. Number of SIUs in SNC with Pretreatment Schedule?
0
14. Number of SIUs on Schedules?
0
15. Current Number of Categorical Industrial Users (CIUs)?
0
16. Number CIUs in SNC?
0
POTW INTERVIEW
17. Since the Last PCI, has the POTW had any NPDES Limits Violations?
If Yes, What are the Parameters and How are these Problems Being Addressed?
18. Since the Last PCI, has the POTW had any Problems Related to an Industrial
Discharge (Interference, Pass -Through, Blockage, Citizens' Complaints, Increased
Sludge Production, Etc.)?
If Yes, How are these Problems Being Addressed?
19. Which Industries have been in SNC for Limits or Reporting during
either of the Last 2 Semi -Annual Periods? Not Been Published for
Public Notice?(May refer to PAR if Excessive SIUs in SNC)
N/A
Not Pu
20. Which Industries are on Compliance Schedules or Orders? For all SIUs on an
Order, Has a Signed Copy of the Order been sent to the Division?
21. Are Any Permits Or Civil Penalties Currently Under Adjudication? If Yes, Which
Ones?
❑ YES /1 NO
❑ YES /1 NO
dished: N/A
N/A
❑ YES /1 NO
LTMP/STMP FILE REVIEW:
22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑ NO
23. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ® YES ❑ NO
24. Is LTMP/STMP Data Maintained in a Table or Equivalent? ® YES ❑ NO Is Table Adequate? ® YES ❑ NO
25. All LTMP/STMP effluent data reported on Discharge Monitoring Report? ® YES ❑ NO
26. If NO to 23 - 26, list violations:
27. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ® NO
If yes, which ones? Eliminated: Added:
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 1

28. PRETREATMENT PROGRAM ELEMENTS REVIEW:
Program Element
Last Submittal Received
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
4/1/20
a Yes ❑ No
2/26/19
/1 Yes ❑ No
11/1/23
Industrial Waste Survey (IWS)
3/13/17
a Yes ❑ No
5/23/17
/1 Yes ❑ No
3/30/22
Sewer Use Ordinance (SUO)
1/2/13
0 Yes ❑ No
1/10/13
/1 Yes ❑ No
Enforcement Response Plan (ERP)
9/6/19
a Yes ❑ No
11/18/19
/1 Yes ❑ No
Long Term Monitoring Plan (LTMP)
10/22/19
a Yes ❑ No
1/9/20
/1 Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW:
29. User Name 1. Carolina Beverage Group
2 BestCo, Inc.
3. Berry Global
30. IUP Number
0017
0006
0022
31. Does File Contain Current Permit?
/1 Yes ❑ No
/1 Yes ❑ No
/1 Yes ❑ No
32. Permit Expiration Date
12/31/23
6/30/22
12/31/23
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
N/A
N/A
N/A
34. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
A Yes ❑ No
/1 Yes ❑ No
A Yes ❑ No
35. Does File Contain an Inspection Completed Within Last Calendar Year?
/1 Yes ❑ No
/1 Yes ❑ No
1 Yes ❑ No
36. a. Does the File Contain a Slug/Spill Control Plan?
b. If No, is One Needed? (See Inspection Form from POTW)
a. A Yes •No
b. •Yes •No
a. ►E Yes ■ No
b. •Yes •No
a. A Yes ■ No
b. •Yes •No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
Organic Management Plan (TOMP)?
❑ Yes ❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑NoEN/A
38. a. Does File Contain Original Permit Review Letter from the Division?
b. All Issues Resolved?
a. A Yes ■ No
b.❑Yes❑NoEN/A
a. ►E Yes ■ No
b.❑Yes❑No®N/A
a. A Yes ■ No
b.❑Yes❑NoEN/A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
its Sampling as Required by IUP, including flow?
/1 Yes ❑ No
/1 Yes ❑ No
i1 Yes ❑ No
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
/1 Yes ❑ No
L Yes ❑ No
/1 Yes ❑ No
41a. During the Most Recent Semi -Annual Period, Did the SIU Complete its
Sampling as Required by IUP, including flow?
® Yes ONO ❑N/A
®Yes❑No❑N/A
®Yes❑No❑N/A
41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports
on time?
®Yes❑No❑N/A
NYes❑No❑N/A
®Yes❑No❑N/A
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
file include process/dilution flows as Required by IUP?
❑ Yes ❑NoEN/A
❑Yes❑NoEN/A
III Yes❑NoEN/A
42b. For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑NoEN/A
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Limits Non -Compliance from Both POTW and SIU Sampling?
►EYes ■No■NA
EYes❑No❑N/A
EYes❑No❑N/A
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Reporting Non -Compliance from SIU Sampling?
❑ Yes ❑NoEN/A
❑Yes❑NoEN/A
III Yes❑NoEN/A
44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
Monitoring Violations?
b. Did Industry Resample and submit results to POTW Within 30 Days?
c. Did POTW resample within 30 days of knowledge of SIU limitc
violations from the POTW sample event?
a.®yes❑No❑N/A
b.❑Yes❑NoEN/A
.❑yes❑NoNN/A
a.®Yes❑No❑N/A
b.❑Yes❑NoEN/A
c.❑Yes❑No®N/A
a.®Yes❑No❑N/A
b.❑Yes❑NoEN/A
c.❑Yes❑No®N/A
45. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
❑ Yes /1 No
❑ Yes L No
❑ Yes /1 No
46. During the Most Recent Semi -Annual Period, Was Enforcement Taken
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
EYes❑No❑N/A
EYes❑No❑N/A
EYes❑No❑N/A
47. Does the File Contain Penalty Assessment Notices?
EYes ❑No❑N/A
EYes❑No❑N/A
EYes ❑No❑N/A
48. Does The File Contain Proof Of Penalty Collection?
EYes❑No❑N/A
EYes❑No❑N/A
EYes❑No❑N/A
49. a. Does the File Contain Any Current Enforcement Orders?
b. Is SIU in Compliance with Order?
a.❑Yes❑NoEN/A
b.❑Yes❑NoEN/A
a.❑Yes❑NoEN/A
b.❑Yes❑NoEN/A
a.❑Yes❑NoEN/A
b.❑Yes❑NoEN/A
50. Did the POTW Representative Have Difficulty in Obtaining Any of This
❑ Yes /1 No
❑ Yes r No
❑ Yes I No
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 2

Requested Information For You?
FILE REVIEW COMMENTS:
35. The POTW performed SIU inspections on 11/17/20 (Carolina Beverage Group), 11/12/20 (BestCo), and 11/3/20 (Berry Global).
39. The POTW's on -site lab performs analyses on conventional parameters including total phosphorus (LTMP). Pace Analytical Services,
Inc. (LTMP and IUP analyses) and Waypoint Analytical (low level mercury) have also been contracted to provide analytical support.
41 a. Carolina Beverage Group, BestCo and Berry Global all contract Statesville Analytical to perform IUP analyses.
46. Carolina Beverage Group was issued a NOV for pH limit violations (in December 2020). BestCo was issued NOVs for pH limit
violation (in November 2020) and the failure to notify the POTW of planned changes. Berry Global was issued a NOV for pH limit
violations (in August 2020). All of these SIUs were assessed civil penalties for the violations.
SUMMARY AND COMMENTS:
The POTW must ensure that the chain of custody forms (CoCs) completed by the SIUs are properly completed including the reporting of
the start/end dates and times (composite sampling), temperature inside the composite samplers and times composite samples were
collected. The POTW must also ensure that the internal CoC includes all personnel involved with the relinquishing of samples.
The POTW's records were organized and well maintained. The POTW's Industrial Pretreatment Program was being properly
implemented.
NOD: ❑ YES ® NO
NOV: ❑ YES ®NO
QNCR: ❑ YES NO
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory_ ❑
DocuSigned by:
PCI COMPLETED BY: � 3detDATE: May 25, 2021
A61696D90CC3437...
Wes Bell, Environmental Specialist/Mooresville Regional Office
PCI REVIEWED BY:
DoccuSigned by:
—A14CC681AF27425...
DATE: May 25, 2021
W. Corey Basinger, Regional Supervisor/Mooresville Regional Office
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 3