NC0021156_Inspection_20210608

DocuSign Envelope ID: 16224737-849A-48B5-92FD-9FEF54AF7FB2
ROY COOPER
Governor
DIONNE DELLI-GATTI
Secretary
S. DANIEL SMITH
Director
David Johnson, PE
Utilities Director
City of Mount Holly
Post Office Box 406
Mount Holly, NC 28120-0406
Dear Mr. Johnson:
NORTH CAROLINA
Environmental Quality
June 8, 2021
SUBJECT: Notice of Deficiency
Pretreatment Compliance Inspection
City of Mount Holly
NPDES Permit No. NC0021156
Gaston County
Tracking No. NOD-2021-PC-03 81
Enclosed is a copy of the Pretreatment Compliance Inspection Report for the inspection of the City of Mount Holly's
approved Industrial Pretreatment Program on May 27, 2021, by Mr. Wes Bell of this Office.
This report is being issued as a Notice of Deficiency (NOD) due to the City's failure to sample all parameters required in a
SIU's Permit. Specifically, the City did not perform semi-annual TTO monitoring in 2020 as specified in the American Efird's
Industrial User Permit (#1157). This Office requests a written response be submitted by June 29, 2021, detailing the actions
taken to prevent these violations from recurring. The response should be submitted to the attention of Mr. Bell.
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,
DocuSigned by:
A14CC681 AF27425...
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

DocuSign Envelope ID: 16224737-849A-48B5-92FD-9FEF54AF7FB2
NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
BACKGROUND INFORMATION:
1. Control Authority (POTW) Name: City of Mount Holly
2. Control Authority Representative(s): Doug Shoutd, Nadine Blackwell
3. Title(s): Pretreatment Coordinator, Consultant
4. Last Inspection Date: 4/25/19 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
NC0021156
MM/DD/YY
05/27/21
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)?
2
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?
/1 YES ❑ NO
See Comments Section
❑ YES r NO
)lished: 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

DocuSign Envelope ID: 16224737-849A-48B5-92FD-9FEF54AF7FB2
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)
3/28/19
0 Yes ❑ No
6/24/19
0 Yes ❑ No
4/1/24
Industrial Waste Survey (IWS)
12/7/16
/1 Yes ❑ No
3/13/16
/1 Yes ❑ No
12/1/21
Sewer Use Ordinance (SUO)
12/20/12
/1 Yes ❑ No
1/14/13
/1 Yes ❑ No
Enforcement Response Plan (ERP)
9/15/10
/1 Yes ❑ No
12/15/10
/1 Yes ❑ No
Long Term Monitoring Plan (LTMP)
3/30/16
/1 Yes ❑ No
5/4/16
/1 Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW:
29. User Name
1. American Efird
2. Clariant Corp.
3. Daimler Trucks NA
30. IUP Number
1157
1158
1163
31. Does File Contain Current Permit?
/1 Yes ❑ No
/1 Yes ❑ No
/1 Yes ❑ No
32. Permit Expiration Date
12/31/22
12/31/22
12/31/22
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
410
414 & 455
433
34. Does File Contain Permit Application Completed Within One Year
Prior to Permit Issue Date?
/1 Yes ❑ No
/1 Yes ❑ No
/1 Yes ❑ No
35. Does File Contain an Inspection Completed Within Last Calendar
Year?
/1 Yes ❑ No
/1 Yes ❑ No
A 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. ►E Yes ■ No
b. •Yes ■No
a. ►E Yes ■ No
b. •Yes ■No
a. 1 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. ►E Yes ■ No
b.❑Yes❑NoEN/A
a. ►E Yes ■ No
b.❑Yes❑NoEN/A
a. 1 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?
❑ Yes /1 No
/1 Yes ❑ No
A Yes ❑ No
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
/1 Yes ❑ No
/1 Yes ❑ No
11 Yes ❑ No
41a. During the Most Recent Semi -Annual Period, Did the SIU Complete
its Sampling as Required by IUP, including flow?
_1
®Yes❑No❑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
®Yes❑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
❑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
®Yes❑No❑N/A
❑Yes❑NoEN/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
❑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 limit
violations from the POTW sample event?
a.®Yes❑No❑N/A
b.❑Yes❑No®N/A
c.❑Yes❑NoEN/A
a.®Yes❑No❑N/A
b.❑Yes❑No®N/A
c.❑Yes❑NoEN/A
a.❑Yes ❑NoEN/A
b.❑Yes❑NoEN/A
c.❑Yes ❑NoEN/A
45. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
❑ Yes r No
❑ Yes r No
❑ Yes
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
❑Yes❑NoEN/A
47. Does the File Contain Penalty Assessment Notices?
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑NoEN/A
48. Does The File Contain Proof Of Penalty Collection?
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑NoEN/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 Requested Information For You?
❑ Yes /1 No
❑ Yes L No
❑ Yes /1 No
NC DWR Pretreatment Compliance Inspection (PCI) Form
Updated 7/25/07 Page 2

DocuSign Envelope ID: 16224737-849A-48B5-92FD-9FEF54AF7FB2
FILE REVIEW COMMENTS:
17. Effluent dissolved oxygen minimum violations were reported in June 2019 and November 2020. Weekly and monthly average effluent
total suspended solids (TSS) violations were reported in May 2020.
23. The LTMP will be revised to modify the detection levels for TSS and total phosphorus.
25. All 2020 and 2021 eDMRs will be reviewed to ensure all non -detect results and estimated values (J listing) are corrected and reported
down to the appropriate detection levels.
35. The POTW performed SIU inspections on 10/20/20 (American Efird), 10/15/20 (Clariant), and 10/13/20 (Daimler Trucks NA).
39. The POTW performs field and TSS analyses and contracts Pace Analytical Services to perform LTMP analyses. The POTW failed to
sample TTO semi-annually in 2020 as required in American Efird's IUP.
41a. American Efird, Clariant and Daimler Trucks NA all contract Pace Analytical Services to perform analyses.
46. American Efird was issued NOVs for limit violations of zinc (July and September 2020), copper (July 2020), total phosphorus (July
2020) and total nitrogen (December 2020). Clariant was issued a NOV for a total nitrogen limit violation in October 2020.
SUMMARY AND COMMENTS:
The POTW's records were organized and well maintained. Overall, the POTW's Industrial Pretreatment Program was being properly
implemented. The POTW must ensure all sampling is performed according to the IUP and all LTMP results are reported down to the
appropriate detection levels.
NOD: ® YES ❑ NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ® NO
POTW Rating:
Satisfactory ❑ Marginal ❑ Unsatisfactory_ ❑
DocuSigned by:
L1Oe4, Bat
PCI COMPLETED BY: A61696D9OCC3437...
PCI REVIEWED BY:
DATE:
6/8/2021
Wes Bell, Sr. Environmental Specialist, Mooresville Regional Office
DocuSigned by:
A14CC681AF27425...
DATE:
6/8/2021
W. Corey Basinger, Regional Supervisor, Mooresville Regional Office
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 3