NC0024252_Pretreatment_20210715

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
Donald Duncan, Jr.
City of Conover
Post Office Box 549
Conover, North Carolina 28613-0549
Dear Mr. Duncan:
NORTH CAROLINA
Environmental Quality
July 15, 2021
Subject: Notice of Deficiency
Pretreatment Compliance Inspection
City of Conover
NPDES Permit No. NC0024252
Tracking #: NOD-2021-PC-0402
Catawba County
Enclosed is a copy of the Pretreatment Compliance Inspection (PCI) Report for the inspection of the City of
Conover's Industrial Pretreatment Program on June 23, 2021, by Mr. Wes Bell of this Office.
This report is being issued as a Notice of Deficiency (NOD) due to the City's failures to provide records required
under the Division -approved Industrial Pretreatment Program. Specifically, the City failed to provide Total Toxic Organics
(TTO) Certifications, Toxic Organic Management Plan (TOMP) and slug spill control plan (ECI only), and Division
approval letters for Enforcement Response Plan (ERP), Sewer Use Ordinance (SUO) and Industrial User Permits (IUPs).
Please be advised that records must be maintained in accordance with North Carolina General Statute (G.S.) 143-215.1,
15A North Carolina Administrative Code (NCAC) 2H .0908 and NPDES Permit No. NC0024252. In accordance with G.S.
143-215.6A, a civil penalty assessment of not more than twenty-five thousand dollars ($25,000.00), or twenty-five thousand
dollars ($25,000.00) per day when the violation is of a continuing nature, may be assessed against any person who violates
or fails to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S. 143-215.1.
It is requested that a written response be submitted to this Office by August 6, 2021, addressing the City's actions
to properly maintain all pretreatment records. In responding, please address your comments to the attention of Mr. Bell.
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
D,p®rlmont of Environmental Onolit
Sincerely,
,-DocuSigned by:
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W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
North Carolina Department of Environmental Quality 1 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: City of Conover
2. Control Authority Representative(s): Brian Bradshaw, Eric Williams
3. Title(s): Public Utilities Director, WWTP ORC
4. Last Inspection Date: 9/12/19 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
NC0024252
MM/DD/YY
06/23/21
7. Current Number Of Significant Industrial Users (SIUs)?
2
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 of 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)
SNC for
SNC for
Not Pul
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
❑ YES // NO
Limits: N/A
Reporting: N/A
)lished: N/A
N/A
❑ YES iI NO
LTMP/STMP FILE REVIEW: Not Applicable
22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ❑ YES
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
❑ NO
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 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)
N/A
❑ Yes ❑ No
N/A
❑ Yes ❑ No
N/A
Industrial Waste Survey (IWS)
1/24/18
/1 Yes ❑ No
3/9/18
a Yes ❑ No
10/1/22
Sewer Use Ordinance (SUO)
1/15/13
a Yes ❑ No
4/2/13
❑ Yes /1 No
Enforcement Response Plan (ERP)
7/2/15
a Yes ❑ No
8/19/15
❑ Yes /1 No
Long Term Monitoring Plan (LTMP)
N/A
❑ Yes ❑ No
N/A
❑ Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW
29. User Name II
1. Hickory Springs 2. Engineered Controls Int.
3.
30. IUP Number
101HS
101J
31. Does File Contain Current Permit?
/1 Yes ❑ No
/1 Yes ❑ No
❑ Yes ❑ No
32. Permit Expiration Date
11/13/22
5/1/23
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
433.17
433.17
34. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
/1 Yes ❑ No
/1 Yes ❑ No
❑ Yes ❑ No
35. Does File Contain an Inspection Completed Within Last Calendar Year?
Al Yes ❑ No
/1 Yes ❑ No
❑ 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. ►Yes ■No
b. •Yes ■No
a. Yes ENO
b. •Yes ■No
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 ❑No❑N/A
El Yes ❑No❑N/A
❑Yes❑No❑N/A
38. a. Does File Contain Original Permit Review Letter from the Division?
b. All Issues Resolved?
a. ►Yes ■No
b.❑Yes❑NoEN/A
a. ►Yes ■No
b.❑Yes❑NoEN/A
a. •Yes ■No
b.❑Yes❑No❑N/A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
its Sampling as Required by IUP, including flow?
Al Yes ❑ No
/1 Yes ❑ No
❑ Yes ❑ No
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
/1 Yes ❑ NoJ
/1 Yes ❑ No
❑ Yes ❑ No
41a. During the Most Recent Semi -Annual Period, Did the SIU Complete its
Sampling as Required by IUP, including flow?
® 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❑No❑N/A
42b. For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
❑YesDNoEN/A
❑Yes❑NoEN/A
❑Yes❑No❑N/A
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Limits Non -Compliance from Both POTW and SIU Sampling?
■ Yes •NoLNA
❑Yes❑NoEN/A
❑Yes❑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
❑Yes❑No❑N/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
a.❑Yes❑NoEN/A
b.❑Yes❑NoEN/A
c.❑Yes❑No®N/A
a.❑Yes❑NoEN/A
b.❑Yes❑NoEN/A
c.❑Yes❑No®N/A
a.❑Yes❑No❑N/A
b.❑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 /1 No
❑ Yes r No
❑ Yes ❑ No
46. During the Most Recent Semi -Annual Period, Was Enforcement Taken
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
❑ Yes ❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑No❑N/A
47. Does the File Contain Penalty Assessment Notices?
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑No❑N/A
48. Does The File Contain Proof Of Penalty Collection?
❑ Yes ❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑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 ❑No❑N/A
b.❑Yes❑No❑N/A
50. Did the POTW Representative Have Difficulty in Obtaining Any of This
Requested Information For You?
/1 Yes ❑ No
0 Yes ❑ No
❑ Yes ❑ No
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

FILE REVIEW COMMENTS:
17. The POTW's WWTP reported effluent limit violations in September 2019 (ammonia monthly average) and May 2020 (BOD weekly
average).
28. The SUO was adopted on 7/2/13. The approval letters for the Enforcement Response Plan (ERP) and Sewer Use Ordinance (SUO) could
not be found during the inspection. Note: Copies of these approval letters were emailed to the POTW following the inspection.
35. The POTW performed the SIU inspections on 6/26/2020 (Hickory Springs) and 6/22/2020 (Engineered Controls Int.).
39. POTW contracts Water Tech Labs for sample analyses.
41a. Hickory Springs contracts Blue Ridge Environmental and Engineered Controls Int. (ECI) contracts Pace Analytical Services to perform
Industrial User Permit (IUP) analyses.
50. In addition to the ERP and SUO approval letters, the POTW's pretreatment staff could not provide the following documentation during the
inspection: TTO certifications (2020) for both SIUs; TOMP and slug/spill control plan for ECI and the Division approval letter for ECI's IUP.
Note: The TOMP and slug/spill control plan for ECI and the Division approval letters (SUO, ERP and SIU IUPs) were available for review
during the previous compliance inspection (performed on 9/12/19).
SUMMARY AND COMMENTS:
The POTW will need to continue to sort through the previous Pretreatment Coordinator' s files and properly organize them to ensure all
documentation is accessible for review by the current pretreatment staff and Division personnel.
The POTW must ensure all pH calibrations (IUP sampling) are documented and all chain of custody forms are completed properly (composite
start/end times, sampler temperatures, etc.).
Overall, the POTW's Industrial Pretreatment Program was being properly implemented.
NOD: ® YES ❑ NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ® NO
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory_ ❑
PCI COMPLETED BY:
DocuSigned by:
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DATE: 7/15/2021
Wes Bell, Sr. Environmental Specialist, Mooresville Regional Office
DocuSigned by:
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PCI REVIEWED BY: DATE:
7.15.21
W. Corey Basinger, Regional Supervisor, Mooresville Regional Office
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3