NC0024244_Pretreatment Compliance Inspection_20211012

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH NORTH CAROLINA
Director Environmental Quality
October 12, 2021
Judy Redwine
City of Albemarle
Post Office Box 190
Albemarle, North Carolina 28002-0190
Subject: Pretreatment Compliance Inspection
City of Albemarle
NPDES Permit No. NC0024244
Stanly County
Dear Ms. Redwine:
Enclosed is a copy of the Pretreatment Compliance Inspection (PCI) Report for the inspection of the City of
Albemarle's Industrial Pretreatment Program on October 6, 2021, by Mr. Wes Bell of this Office. Please inform the City's
Pretreatment Coordinator of our findings by forwarding a copy of the enclosed report.
The WWTP has been experiencing the pass -through of fine suspended solids in the WWTP's effluent for several
months. Effluent total suspended solids (TSS) violations have been reported in September, October and November 2020
and July and August 2021. Mr. Bell observed the fine suspended solids in the WWTP's effluent discharge during the
inspection. The City's Hwy. 52 WTP has been a known significant source of the fine suspended solids that are not removed
by the WWTP processes including the tertiary filters. This Office issued a Compliance Evaluation Inspection report (dated
9/9/2021) to the City requesting the measures being taken to address the discharge of alum sludge (from the Hwy. 52 WTP)
to the WWTP; therefore, no response for this report will be required.
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
Deparlmant of Environmental Ouallt
Sincerely,
/—DocuSigned by:
"—A14CC681AF27425...
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 Albemarle
2. Control Authority Representative(s): Brandon Plyler
3. Title(s): Pretreatment Coordinator/WWTP ORC
4. Last Inspection Date: 11/5/19 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
NC0024244
MM/DD/YY
10/06/21
7. Current Number Of Significant Industrial Users (SIUs)?
0
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
1
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)
Auria A
(TRC) d
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 Section
❑ YES // NO
See Comments Section
lbemarle — Mercury limit violations
uring January — June 2021 period.
)lished: N/A
N/A
❑ YES // 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)
11/19/19
a Yes ❑ No
3/10/20
/1 Yes ❑ No
12/31/24
Industrial Waste Survey (IWS)
3/25/21
a Yes ❑ No
3/31/21
/1 Yes ❑ No
3/30/26
Sewer Use Ordinance (SUO)
12/27/12
0 Yes ❑ No
1/10/13
/1 Yes ❑ No
Enforcement Response Plan (ERP)
6/25/08
a Yes ❑ No
9/12/08
/1 Yes ❑ No
Long Term Monitoring Plan (LTMP)
2/05/19
a Yes ❑ No
4/02/19
/1 Yes ❑ No
7/31/22
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION
29. User Name 1. Auria Albemarle, LLC. 2.
3.
30. IUP Number
0003
31. Does File Contain Current Permit?
/1 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
32. Permit Expiration Date
9/30/2021
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
NA
34. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
A Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
35. Does File Contain an Inspection Completed Within Last Calendar Year?
/1 Yes ❑ No_l
❑ 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. AYes •No
b. •Yes •No
a. •Yes •No
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 ❑NoEN/A
❑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. AYes •No
b.❑Yes❑NoEN/A
a. •Yes •No
b.❑Yes❑No❑N/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?
/1 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
A Yes ❑ No
❑ 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❑No❑N/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?
❑Yes❑NoEN/A
❑Yes❑No❑N/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❑No❑N/A
❑Yes❑No❑N/A
► Yes ■No■NA
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Reporting Non -Compliance from SIU Sampling?
❑Yes❑NOEN/A
❑Yes❑No❑N/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
violations from the POTW sample event?
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
a.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
c.❑Yes❑No❑N/A
45. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
/1 Yes ❑ No
❑ Yes ❑ 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.)?
EYes ❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
47. Does the File Contain Penalty Assessment Notices?
❑Yes❑NoEN/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
48. Does The File Contain Proof Of Penalty Collection?
❑ Yes ❑NoEN/A
❑Yes❑No❑N/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❑No❑N/A
b.❑Yes❑No❑N/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?
❑ Yes /1 No
❑ Yes ❑ No
❑ Yes ❑ No
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 2

FILE REVIEW COMMENTS:
6. The City is currently under a Special Order by Consent (SOC WQ S19-007) that became effective on 10/1/2020. The SOC
does not include pretreatment conditions; however, the SOC includes timelines for the completion of construction activities on
both the collection system and WWTP. The City will have to attain compliance with both the Collection System Permit and
NPDES Permit limits by 9/30/23.
7. The Division approved the SIU (Auria Albemarle) drop request on 7/29/21.
17. Weekly average effluent ammonia violations were reported in November and December 2019 and January2020. Weekly
average effluent fecal coliform violations were reported in November 2019 and May 2020. Weekly average effluent TSS
violations were reported in September, October and November 2020 and August 2021. Effluent monthly average violations
were reported in November 2019 (ammonia), December 2019 (ammonia), January 2020 (ammonia), September 2020 (TSS),
November 2020 (TSS), April 2021 (ammonia), July 2021 (TSS) and August 2021 (TSS).
The violations are attributed to excessive I&I and the WWTP's inability to sustain a biological process to treat ammonia.
As previously stated (#6 Comment), the City is currently under a SOC for construction upgrades to the collection system and
WWTP.
18. The City's Hwy. 52 WTP is a significant contributor to the TSS pass -through at the WWTP. The WTP conveys all waste
streams (including alum sludge) into an equalization tank prior to discharging into the collection system. The fine suspended
solids do not settle in the clarifiers and are too small to be removed by the tertiary filters.
34. The City inspected Auria Albemarle on 12/2/2020.
39. The City contracts Environment 1 for all Long Term Monitoring Plan (LTMP) and Industrial User Permit (IUP) sampling
analyses.
44. The City performs all monitoring/sampling requirements for Auria Albemarlle.
46. The City issued Notice of Violations (NOVs) to Auria Albemarle for mercury limit violations in January and April 2021.
SUMMARY AND COMMENTS:
The contract lab's selenium detection level (3 ug/L) was higher the LTMP's detection level (2 ug/L). The Pretreatment
Coordinator must ensure all LTMP detection levels (at a minimum) are used by the contracted lab during any future LTMP
sampling events.
The City should explore treatment options at the equalization tank for the Hwy. 52 WTP to reduce the levels of suspended
solids being discharged into the collection system/WWTP. Although the construction upgrades to the collection system may
reduce the fine suspended solids attributed to I&I, the Hwy.52 WTP will continue to be a significant source of the fine
suspended solids passing through the WWTP and entering the receiving stream.
The records reviewed during the inspection were organized and well maintained. The City's Industrial Pretreatment Program
appeared to be properly implemented.
NOD: ❑ YES ® NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ® NO
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory_ ❑
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 3

0(4-Bat
PCI COMPLETED BY: a616Q6egnc,3437.. DATE: 10/12/2021
Wes Bell, Sr. Environmental Specialist, WQROS/MRO, DWR
PCI REVIEWED BY:
DocuSigned by:
L
CDocuSigned by:
A14CC681AF27425...
DATE: 10/12/2021
W. Corey Basinger, Regional Supervisor, WQROS/MRO, DWR
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 4