NC0036196_NOD-2021-PC-0414 Response_20220105

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dHIt(IiaT Li G,•P HIGH
RECEIVED/NCDEQ/DWR
JAN_'..
WOROS
MOORESVILLE REGIONAL OFFICE
P.O. Box 550* Newton, N.C. 28658*[phone]
January 5, 2022
Wes Bell
Division of Water Resources
610 East Center Ave. Ste. 301
Mooresville, NC 28115
Subject: Notice of Deficiency
Pretreatment Audit Inspection
NPDES Permit No. NC0036196
Tracking #: NOD-2021-PC-0414
Catawba County
Dear Mr. Bell:
In response to the Notice of Deficiency (NOD) that was issued to the City of Newton for its failures to
initiate enforcement of their ERP. We responded by email on August 3, 2021 to Wes Bell regarding the
NOD. (Response enclosed)
-We did put Special Metals on a consent order. There was confusion on being able to change the limit
since it's a categorical limit. Under the consent order they were still in violation on some samples, but at
that time, we did not issue individual violations because we understood it to be under the consent order
and we didn't think we needed to send out individual violations.
We did correct this and sent them the violations for every sample that was out. We also sent Special
Metals a copy of our ERP plan. (copy was emailed to Wes Bell)
-We have also reached out to Meritech to lower their detection limits for Nickel. Technibilt/Wanzl uses
Pace and we spoke to them about reaching out to Pace to lower the detection limit for Nickel and
Cyanide. They were also issued a copy of our ERP.
-We spoke with Dennis Falder and Dusty Wentz about getting an SOP in place for when someone wants
to come in and look at any of our files since they are public record.

The City of Newton works very diligently to remain in compliance in all aspects of the Pretreatment
Program.
Thank you for your time and consideration in reviewing this.
Eric Jones
Su,rintendent
cc Dust entz
cc Dennis Falder
cc Stacy Rowe

Jones Eric
From: Michael,Brianna
Sent: Tuesday, August 3, 2021 2:31 PM
To: '[e-mail]'
Cc: Rowe,Stacy; Jones Eric
Subject: Updates
Attachments: NOTICE OF VIOLATION Apr, May.docx
Hello Wes,
I just wanted to update you on some things that have been done since our audit last week.
1. I've sent the attached NOV (with signatures) to Special Metals, and I also sent them a copy of our ERP and
requested an updated copy of their spill plan.
2. We've contacted our Finance department, and they'll be sending us a copy of the check Special Metals sent
for their late fee.
3. I've gotten in touch with Technibilt and told them to have Pace lower their detection limits for nickel and
cyanide to 0.001 mg/L and 0.005 mg/L, respectively. I've also send them an updated copy of our ERP.
4. We've gotten in touch with Meritech about lowering our detection limits for Nickel to 0.01 mg/L.
5. We've gotten with Dennis Falder and Dusty Wentz, and we're working on creating an SOP for when
someone wants to look at our files.
Thanks,
Brianna Michael
Pretreatment Coordinator
Clark Creek WWTP
City of Newton
Phone: [phone]
Cell: [phone]
[e-mail]
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P.O. Box 550* Newton, N.C. 28658*[phone]
NOTICE OF VIOLATION
Pursuant to the Newton City Code, Chapter 98, Special Metals holder of Permit No. 1015 is
hereby issued this Notice of Violation. This notice is a result of the following situation:
Several sampling events revealed the
following violations:
Parameter, Date Result (Ibs/davl
Nickel, 4/20/2021 0.01024
Nickel, 4/21/2021 0.01269,
Nickel, 4/27/2021 0.01383
Nickel, 4/28/2021 0.01224
Nickel, 5/11/2021 0.01065
Nickel, 5/12/2021 0.01065
Nickel, 5/19/2021 0.01474
Nickel, 5/20/2021 0.01471
Nickel, 5/27/2021 0.01669
Limit (Ibs/day)
0.009364
0.009364
0.009364
0.009364
0.009364
0.009364
0.009364
0.009364
0.009364
Special Metals is required to respond to this notice within 30 days as described by the City
Code, Chapter 98 section 235. Failure to respond or an inadequate response to this notice will
initiate follow-up action and escalated action as described by the City of Newton Enforcement
Response Plan. Any questions concerning this violation are to be directed to the Pretreatment
Coordinator at [phone].
Signed
Signed
Pretreatment Coordinator
Director of Public Works and Utilities
Date
Date