NC0020184_Inspection_20211115

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
Stephanie Scheringer, Division Manager
Two Rivers Utilities
Post Office Box 1748
Gastonia, North Carolina 28053-1748
Dear Ms. Scheringer:
NORTH CAROLINA
Environmental Quality
November 15, 2021
Subject: Pretreatment Audit Inspection
Two Rivers Utilities
NPDES Permit No. NC0020184
Gaston County
Enclosed is a copy of the Pretreatment Audit Inspection (PAI) Report for the inspection of Two Rivers Utilities'
Industrial Pretreatment Program on November 9, 2021, by Mr. Wes Bell of this Office. Please advise the Pretreatment staff
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 [phone],
or via email at [e-mail].
Enclosure: Inspection Report
NORTH
Dep®rlmont of Environmental Onolit
Sincerely,
DocuSigned by:
A w H Nut4
F161 FB69A2D84A3...
fo r
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 AUDIT REPORT
Background Information:
1. Control Authority (POTW) Name: Two Rivers Utilities
2. Control Authority Representative(s): Mike Alexander, David Shellenbarger, Cody Austin, Chris English
3. Title(s): Pretreatment Supervisor, Assistant Division Manager Compliance, Pretreatment Coordinators
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: 11/09/2021
6. Last Inspection Date:1/15/2020 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. Long Creek WWTP (NC0020184) — Weekly average effluent BOD violation — July 2021 and two (2)
effluent pH violations (pH minimum not reached) — March 2020; Crowders Creek WWTP (NC0074268) — Effluent
chronic toxicity failure — September 2021.
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
ICIS Coding:
Main Program Permit Number
NC0020184
MM/DD/YY
11/09/21
10. Current Number of Significant Industrial Users (SIUS)?
11. Number of SIUs with No IUP, or with an Expired IUP
12. Number of SIUs Not Inspected by POTW in Last Calendar Year?
13. Number of SIUs Not Sampled by POTW in Last Calendar Year?
14. Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi -Annual Periods
15. Number of SIUs in SNC for Reporting During Either of Last 2 Semi -Annual Periods
16. Number of SIUs in SNC with Pretreatment Schedule?
23
0
0
0
0
0
0
17. Number of SIUs on Schedules?
0
18. Current Number of Categorical Industrial Users (CIUS)?
19. Number of CIUs in SNC?
8
0
NC DWR Pretreatment Audit Form
Revised: July 25, 2007 Page 1

21. PRETREATMENT PROGRAM ELEMENTS REVIEW
Program Element:
NC0020184
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
8/28/20
// Yes ❑ No
8/28/17
// Yes ❑ No
In Review
Industrial Waste Survey (IWS)
6/26/20
@ Yes ❑ No
9/17/20
@ Yes ❑ No
6/30/25
Sewer Use Ordinance (SUO)
12/6/12
// Yes ❑ No
12/27/12
// Yes ❑ No
Enforcement Response Plan (ERP)
2/2/20
// Yes ❑ No
2/5/20
// Yes ❑ No
Long Term Monitoring Plan (LTMP)
9/3/19
@ Yes ❑ No
9/6/19
@ Yes ❑ No
Program Element:
NC0074268
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
10/31/19
' Yes ❑ No
4/15/20
@ Yes ❑ No
11/1/24
Industrial Waste Survey (IWS)
6/18/20
// Yes ❑ No
9/17/20
@ Yes ❑ No
6/30/25
Sewer Use Ordinance (SUO)
12/6/12
@ Yes ❑ No
12/27/12
I1 Yes ❑ No
Enforcement Response Plan (ERP)
2/2/20
@ Yes ❑ No
2/5/20
@ Yes ❑ No
Long Term Monitoring Plan (LTMP)
5/26/17
// Yes ❑ No
8/25/17
r 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 El 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, McAdenvile, portion of Belmont and Dallas.
23. If yes to #22, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? ® Yes El No El 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 El 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? El 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. None
NC DWR Pretreatment Audit Form
Revised: July 25, 2007 Page 2

Resources
30. Please Rate the Following: S=Satisfactory
M=Marginal U=Unsatisfactory
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
A S ❑M ❑U
Access to POTW Vehicles for
Sampling, Inspections, and
Emergencies
/1S ❑M ❑U
Access to Operable Sampling
Equipment
/1 S ❑M ❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
1 S ❑M ❑U
Reference Materials
1 S ❑M ❑U
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
L S ❑M ❑U
Computer Equipment (Hardware and
Software)
/1 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, Excel.
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 Staff and City Attorney. Copies of the information would be provided (via email) 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 Staff 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 all new business licenses and
permits maintained/provided by the City's Engineering Department. The County's Economic Development staff
also provides the City's Engineering Dept. of potential new businesses.
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/loading, and potential impacts to WWTP are also evaluated during these determinations.
NC DWR Pretreatment Audit Form
Revised: July 25, 2007 Page 3

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) ® 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. A manhole (collection system to Long Creek WWTP) has been designated for domestic wastewater (<500
gallons) for a truck that houses restrooms, showers, etc. for the underprivileged.
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- 20%
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,
potential impacts to WWTPs, 2 — 5% MAHL parameter will be monitored, > 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 created with Hack WIMS 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 El 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?
Presence of floor drains, chemical storage practices/locations, secondary containment for chemical storage.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
EPA checklist used as a guide; 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: El Yes El No SIU: ❑ Yes ❑ No If yes, Explain. POTW — Sampling SOP; POTW evaluates SIU
sampling procedures during inspections.
NC DWR Pretreatment Audit Form
Revised: July 25, 2007 Page 4

58. Who performs sample analysis for the POTW for Metals - Certified In-house Lab
Conventional Parameters - Certified In-house Lab
Organics - Pace Analytical 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. SIUs use contracted lab's COCs.
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 El NO
60c. Is LTMP/STMP Data Maintained in Table or Equivalent? ® YES ❑ NO Is Table Adequate? ® YES ❑ NO
60d. All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? ® YES El 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?
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 EResolve over allocation ®5 year expiration (Long Creek WWTP) [Other, explain.
63. In general, what is the most limiting criteria of your HWA?
❑Inhibition ® Pass Through (Long Creek WWTP) ®Sludge Quality (Crowders Creek WWTP)
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. Stabilus
2. Town of Clover (S.C.)
3. United Site Services of Florida
67. IUP Number
1021
1048
1057
68. Does File Contain Current Permit?
1 Yes ❑ No
/1 Yes ❑ No
1 Yes ❑ No
69. Permit Expiration Date
12/31/25
6/30/26
12/31/25
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
433.17
N/A
N/A
71. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
/1 Yes ❑ No
L Yes ❑ No
/1 Yes ❑ No
72. Does File Contain Inspection Completed Within Last Calendar Year?
1 Yes ❑ No
/1 Yes ❑ No
1 Yes ❑ No
73. a. Does File Contain Slug/Spill Control Plan?
b. If No, is One Needed? (See Inspection Form from POTW)
a. ►Yes •No
b. •Yes •No
a. ►Yes •No
b. •Yes •No
a. •Yes rNo
b. •Yes 1No
74. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
Organic Management Plan (TOMP)?
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑NoNN/A
75. a. Does File Contain Original Permit Review Letter from Division?
b. All Issues Resolved?
a. ►Yes •No
b.❑Yes❑No®N/A
a. ►Yes •No
b.❑Yes❑No®N/A
a. ►Yes •No
b.❑Yes❑No®N/A
76. During Most Recent Semi -Annual Period, Did POTW Complete its
Sampling as Required by IUP, including Flow?
/1 Yes ❑ No
r Yes ❑ No
1 Yes ❑ No
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
/1 Yes ❑ No
/1 Yes ❑ No
/1 Yes ❑ No
78. During Most Recent Semi -Annual Period, Did SIU Complete its
Sampling as Required by IUP, including Flow?
®Yes❑No❑N/A
®Yes❑No❑N/A
NYes❑No❑N/A
79. During Most Recent Semi -Annual Period, Did SIU submit all reports on
time?
®Yes❑No❑N/A
®Yes❑No❑N/A
®Yes❑No❑N/A
80a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑No®N/A
❑Yes❑NoON/A
❑Yes❑NoNN/A
NC DWR Pretreatment Audit Form
Revised: July 25, 2007
Page 5

file include process/dilution flows as Required by IUP?
80b. For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
81. During Most Recent Semi -Annual Period, Did POTW Identify All
Limits Non -Compliance from Both POTW and SIU Sampling?
82. During Most Recent Semi -Annual Period, Did POTW Identify All
Reporting Non -Compliance from SIU Sampling?
83. a. Was 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. If applicable, did POTW resample and obtain results within 30 days of
becoming aware of SIU limit violations in the POTW's sampling of SIU?
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
Specified in POTW's ERP (NOVs, Penalties, timing, etc.)?
86. Does File Contain Penalty Assessment Notices?
87. Does File Contain Proof Of Penalty Collection?
88. a. Does File Contain Any Current Enforcement Orders?
b. Is SIU in Compliance with Order?
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
Information For You?
❑Yes❑NOON/A
❑ Yes ❑No®N/A
❑Yes❑No®N/A
❑Yes❑No ON/A
®Yes❑No❑N/A
❑Yes❑No ON/A
❑Yes❑No ON/A
❑ Yes ❑NoON/A
❑Yes❑No ON/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
a. ❑Yes❑No®N/A
b.❑Yes❑No®N/A
c.❑Yes❑No®N/A
❑ Yes /1 No
❑ Yes /1 No
❑ Yes /1 No
❑Yes❑No ON/A
® Yes ONO ❑N/A
❑Yes❑No ON/A
❑Yes❑N°ON/A
❑ Yes ❑NoON/A
❑Yes❑N°ON/A
❑Yes❑No ON/A
❑ Yes ❑NoON/A
❑Yes❑No ON/A
a. ❑ Yes ❑No®N/A
b.❑Yes❑No®N/A
a. ❑Yes❑No®N/A
b.❑Yes❑No®N/A
a. ❑ Yes ❑No®N/A
b.❑Yes❑No®N/A
❑ Yes Al No
❑ Yes L No
❑ Yes Al No
FILE REVIEW COMMENTS:
72. SIU inspection were performed by the POTW on 9/28/20 (Stabilus), 9/1/20 (Town of Clover) and 8/19/20 (United Site Services of
Florida).
78. The POTW performs IUP sampling in lieu of SIUs.
85. The POTW issued NOVs to the Town of Clover for mercury daily maximum IUP violations reported in January and June 2021.
INDUSTRY INSPECTION PCS CODING:
Trans.Code
N
Main Program Permit Number
N
0
0
2
0
1
8
4
MM/DD/YY
11
09
21
(DTIA)
Inspection type
1. Industry Inspected: Stabilus
2. Industry Address: 1201 Tulip Drive, Gastonia, N.C. 28052
3. Type of Industry/Product: Metal Finisher/Gas Springs/Struts
4. Industry Contact: Mike Ellington Title: Plant Engineer 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
B. Plant Tour
C. Pretreatment Tour
D. Sampling Review
E. Exit Interview
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
U
(TYPI)
Inspector Facility Type
S
(1NSP) (FACC)
2
NC DWR Pretreatment Audit Form
Revised: July 25, 2007 Page 6

Industrial Inspection Comments:
The facility manufactures nitrogen gas filled springs that are used in a variety of markets including automotive (95% of
market). The company manufactures the springs twenty-four (24) hours per day, seven (7) days per week with the
painting of the springs only operating five (5) days per week twenty-four (24) hours per day. Approximately 100,000
springs are produced per day. The springs are conveyed through a multi -stage treatment process prior to painting that
includes alkali cleaning, rinses, phosphate coating and sealer. The wastewater generated from this process is conveyed to
the pretreatment system that includes equalization tanks, pH addition and flow measurement. No sludge is generated from
the pretreatment system. HazMat has been contracted to remove/dispose of oil -based waste streams.
SUMMARY AND COMMENTS:
The records reviewed during the inspection 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
Audit COMPLETED BY:
Marginal ❑ Unsatisfactory ❑
DocuSigned by:
[11
(/e - Bdi
A61696D90CC3437...
Wes Bell, Sr. Environmental Specialist, WQROS/MRO, DWR
DATE: 11/15/2021
DocuSigned by:
44 H
AUDIT REVIEWED BY: 'F161FB69A2D84A3...
for WCB 11.15.21
DATE:
W. Corey Basinger, Regional Supervisor, WQROS/MRO, DWR
NC DWR Pretreatment Audit Form
Revised: July 25, 2007 Page 7