NC0023736_PCI_Compliance Evaluation Inspection_20220808

DocuSign Envelope ID: 678408A0-5EFC-4ECA-B37C-6CCB87BCACE7
ROY COOPER
Governor
ELIZABETH S. RISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED.
August 8, 2022
Elisa R. Triplett, Wastewater Superintendent
City of Lenoir Lower Creek WWTP
E-mail: [e-mail]
SUBJECT: Pretreatment Audit
Gunpowder Creek WWTP& Lower Creek WWTP
NPDES WW Permit No. NC0023736
Caldwell County
Dear Permittee:
The North Carolina Division of Water Resources conducted Pretreatment Audit of the Lenoir Pretreatment
Program on 8/02/2022. This inspection was conducted to verify that the facility is operating in
compliance with the conditions and limitations specified in NPDES WW Permit No. NC0023736. The
findings and comments noted during this inspection are provided in the enclosed copy of the inspection
report entitled "Compliance Inspection Report".
There were no significant issues or findings noted during the inspection and therefore, a response to this
inspection report is not required.
If you should have any questions, please do not hesitate to contact me with the Water
Quality Regional Operations Section in the Asheville Regional Office at 828-296-4500 or via email at
[e-mail].
ATTACHMENTS
Ec: LF
Sincerely,
DocuSigned by:
fiKlb tAuwl
"-082B1105A3CA418...
Tim Heim, Environmental Engineer
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ
North Carolina Department of Environmental Quelfy I olvtslon of Water Resources
Asheville Regional Office 12090 O.S. Highway 70 I Swannanoa, Noah Carolina 28778
828.296.4500

DocuSign Envelope ID: 678408A0-5EFC-4ECA-B37C-6CCB87BCACE7
United States Environmental Protection Agency
EPA Washington, D.C. 20460
Water Compliance Inspection Report
Form Approved.
OMB No. 2040-0057
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction
1 IN
Code
I 2
L
NPDES yr/mo/day Inspection Type Inspector Fac
I 3 I NC0023736 111 121 22/08/02 117 18 [ �. j 19 I S I 201
Type
21IIIIII
IIIIIIIIIIIIIIIIII
I
IIIIII
IIIIIIIIIII
P6
Inspection
671
Work Days
Facility Self -Monitoring
I 70I
Evaluation Rating
I 711
B1
1
72
QA
I N I
731
I
I I
Reserved
74 71
I
I I
I
I
I
180
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
Gunpowder Creek WWTP
450 Pine Mtn Rd
Hudson NC 28638
Entry Time/Date
09:OOAM 22/08/02
Permit Effective Date
21/04/01
Exit Time/Date
01:OOPM 22/08/02
Permit Expiration Date
26/03/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Elisa Robbins Triplett/ORC/828-757-2198/
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Elisa Robbins Triplett,PO Box 958 Lenoir NC 286450958//828-757-4462/
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Pretreatment
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Timothy H Heim DWR/ARO WQ/828-296-4665/ 8/8/2022
p- Docu•Siigned by:
jitm AAA C1Lt,lN4
,--nn,R11nsGar4al tt
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Q Date
D S:g dby 8/8/2022
Fe
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page# 1

DocuSign Envelope ID: 678408A0-5EFC-4ECA-B37C-6CCB87BCACE7
sI
NPDES yr/mo/day
N C 0023736 111 121 22/08/02
117
Inspection Type
18 {j
(Cont.)
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Tim Heim of the Asheville Regional Office performed a Pretreatment Audit on August 2nd, 2022. Lisa
Triplett (Pretreatment Coordinator), Donnie Hawkins (ORC), and Haden Land (Pretreatment Sampler)
assisted with the inspection and with records and sampling results review.
An inspection of the Beocare Facility was performed with the Lenoir Pretreatment Staff.
The program appears compliant. The Pretreatment Coordinator reports good communications and
working relationships with all lUs in the program.
See attached NC DEQ Pretreatment Compliance Inspection form for details.
Page# 2

DocuSign Envelope ID: 678408A0-5EFC-4ECA-B37C-6CCB87BCACE7
Permit: NC0023736
Inspection Date: 08/02/2022
Owner - Facility: Gunpowder Creek WWTP
Inspection Type: Pretreatment Audit
Yes No NA NE
Page# 3

DocuSign Envelope ID: 678408A0-5EFC-4ECA-B37C-6CCB87BCACE7
NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT AUDIT REPORT
Water Resources
ENVIRONMENTAL QUALITY
Background Information [Complete prior to audit; review Program Info Database Sheet(s)]
1. Control Authority (POTW) Name: City of Lenoir: Gunpowder Creek & Lower Creek WWTPs
2. Control Authority Representative(s) & Titles: Lisa Triplett (Pretreatment Coordinator), Donnie Hawkins (ORC), Haden
Land (Pretreatment Sampler)
3. Address of POTW:
Mailing 1905 Broadland Road
City Lenoir Zip Code 28645
Phone Number 828-757-4462 Fax Number E-Mail lrtriplett(,ci.lenoir.nc.us
5. Audit Date 08/02/2022
6. Last Inspection Date: 01/09/2019 Inspection Type: ❑ PCI ® Audit
7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s) ? ® Yes ❑ No
If No, Explain. NA
8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? ['Yes ® No
If Yes, Explain. NA
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
INICI0I012 13 17 I3 I6 1
10. Current Number of Significant Industrial Users (SIUs)?
11. Number of SIUs with No IUP, or with an Expired IUP?
MM/DD/YY
I08IO2I22I
5
0
12. Number of SIUs Not Inspected by POTW in Last Calendar Year?
0
13. Number of SIUs Not Sampled by POTW in Last Calendar Year?
0
14. Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi -Annual Periods?
0
15. Number of SIUs in SNC for Reporting During Either of Last 2 Semi -Annual Periods?
0
16. Number of SIUs in SNC with Pretreatment Schedule?
0
17. Number of SIUs on Schedules?
0
18. Current Number of Categorical Industrial Users (CIUs)?
19. Number of CIUs in SNC?
3
0
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 1

DocuSign Envelope ID: 678408A0-5EFC-4ECA-B37C-6CCB87BCACE7
20. PRETREATMENT PROGRAM ELEMENTS REVIEW- Review POTW files, verify POTW has copy of each Program
Element in their File, complete with all supporting documents and PERCS Approval Letter, and dates consistent with Program Info:
Program Element
Last Submittal
Date In file?
Last Approval
Date In file
Headworks Analysis (HWA)
3/31/2022
x Yes ❑ No
11/30/2018
x Yes ❑ No
Industrial Waste Survey (IWS)
08/08/2018
x Yes ❑ No
11/08/2012
x Yes ❑ No
Sewer Use Ordinance (SUO)
10/11/12
x Yes ❑ No
10/05/15
x Yes ❑ No
Enforcement Response Plan (ERP)
08/20/2015
x Yes ❑ No
12/20/15
x Yes ❑ No
Long Term Monitoring Plan (LTMP)
10/21/04
x Yes ❑ No
10/29/04
x Yes ❑ No
Legal Authority (Sewer Use Ordinance-SUO)
21. Do you have any towns and/or areas from which you receive wastewater which are not in your annexed jurisdiction?
❑ Yes ® No If yes, Please list these towns and/or areas. NA
22. If yes to #21, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? ❑ Yes ❑ No ® NA
A copy, if not already submitted, should be sent to Division.
23. If yes to #21, Have you had any trouble working with these towns or districts? ❑ Yes ❑ No ® NA
If yes, Explain.
24. Date of Last SUO Adoption by Local Council 12/04/2012
25. Have you had any problems interpreting or enforcing any part of the SUO? ❑ Yes ® No
If yes, Explain.
Enforcement (Enforcement Response Plan-ERP)
26. Did you send a copy of the ERP to your industries? ® Yes ❑ No
If no, POTW must send copy within 30 days. (Performed during inspection)
27. 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.
28. List Industries under a Schedule or Order and Type of Schedule or Order
NA
Resources
29. Please Rate the Following: S=Satisfactory M=Marginal U=Unsatisfactory
Rating
Explanation, if Unsatisfactory
Persormel Available for Maintaining
POTW's Pretreatment Program
Ideally, a program of this size would have a dedicated
Pretreatment Coordinator.
❑S 0 M ❑U
Access to POTW Vehicles for
Sampling, Inspections, and
Emergencies
iI S ❑M ❑U
Access to Operable Sampling
Equipment
// S ❑M ❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
OS ❑M ❑U
Reference Materials
► S ❑M ❑U
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
It is highly suggested that staff attend the annual NC
Pretreatment Conference on a yearly basis.
0 S ❑M ❑U
Computer Equipment (Hardware and
Software)
' S ❑M ❑ U
30. Does the POTW have an adequate data management system to run the pretreatment program? ® Ycs ❑ No
NC DWR Pretreatment Audit Form Revised: December 2016
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DocuSign Envelope ID: 678408A0-5EFC-4ECA-B37C-6CCB87BCACE7
Explain Yes or No. Spreadsheets
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Cost is recovered through penalties associated with Pretreatment violations. It is recommended that the program consult
with other municipalities about the potential for additional cost recovery options.
Public Perception/ Participation
32. Are there any local issues affecting the pretreatment program (e.g.. odor, plant closing, new or proposed plants)?
❑ Yes ® No If yes, Explain.
33. 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?
34. 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?
35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? ® Yes ❑ No
36. Is the public notified about changes in the SUO or Local Limits? ® Yes ❑ No
37. Were all industries in SNC published in the last notice? ❑ Yes ® NA
Permitting (Industrial Waste Survey-IWS)
38. How does the POTW become aware of new or changed Users? Chamber of Commerce, communication with other
city officials, applications for new taps.
39. 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 Form, Interviews and Inspections, Nature of Business, Flow Request.
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
EYes No If Yes, How many are there?
Please list each site and how it is permitted, if applicable.
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) Septage Haulers Agreement, Log
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: HWA
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 —20% recommended, working with McGill on this.
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)
Historical Use
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
As directed by DEQ Pretreatment program.
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 3

DocuSign Envelope ID: 678408A0-5EFC-4ECA-B37C-6CCB87BCACE7
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. All of the above as appropriate.
52. Does the POTW use the Division's model inspection form or equivalent? ® Yes ❑ No
If no, does the POTW form include all Division data? ❑ Yes ❑ 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?
Potential for release and nature of the industry.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Potential for release and nature of the industry, discussion with IUs.
56. How does the POTW decide where the sample point for an SIU should be located?
Representative of effluent being discharged to sewer.
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: ® Yes ❑ No SIU: ® Yes ❑ No If yes, Explain. 24-hour composite, random unannounced
inspections
58. Who performs sample analysis for the POTW for Metals MeriTech
Conventional Parameters In House Lab
Organics MeriTech
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Standard industry practice COC SOP.
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 Monitoring? ® YES ❑ NO
60c. Is LTMP/STMP Data Maintained in Table or Equivalent? ® YES ❑ NO Is Table Adequate? ® YES ❑ NO
60d. All LTMP effluent data on Discharge Monitoring Report (DMR)? ® YES ❑ NO Division 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? McGill Engineers Phone [phone]
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
EMore LTMP data available ❑Resolve over allocation ®5 year expiration ❑Other
Explain.
63. In general, what is the most limiting criteria of your HWA? ®Inhibition ❑ Pass Through ❑Sludge Quality
64. Do you see any way to increase your loading in the future (Example: obtaining more land for sludge disposal)? ❑ Yes ® No
Explain.
Summary
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
No.
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 4

DocuSign Envelope ID: 678408A0-5EFC-4ECA-B37C-6CCB87BCACE7
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION)
66. User Name
1. Beocare
2. Lenoir Mirror
3. Excela Pharma (Augusta)
67. IUP Number
0008
0007
0020
68. Does File Contain Current Permit?
0 Yes ❑ No
0 Yes ❑ No
i1 Yes ❑ No
69. Permit Expiration Date
12/21/2022
12/21/2022
12/21/2022
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
NA
413
439
71. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
/1 Yes ❑ No
/1 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 •No
b. •Yes ■No
Certification, Does File Contain a Toxic
(TOMP)?
❑ Yes ❑NOON/A
®Yes❑No❑N/A
❑ Yes ❑NOON/A
74. For 40 CFR 413 and 433 TTO
Organic Management Plan
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
/1 Yes ❑ No
/1 Yes ❑ No
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
/1 Yes ❑ No
/1 Yes ❑ No
LI Yes ❑ No
78. During Most Recent Semi -Annual Period, Did SIU Complete its
Sampling as Required by IUP, including Flow?
❑ Yes ❑N°ON/A
❑Yes❑NoON/A
❑ Yes ❑NoON/A
79. During Most Recent Semi -Annual Period, Did SIU submit all reports on
time?
❑Yes❑No®N/A
❑Yes❑NOON/A
❑Yes❑No®N/A
80a. For categorical IUs with Combined Wastestream Formula (CWF), does
file include process/dilution flows as Required by IUP?
❑ Yes ❑NOON/A
❑Yes❑No®N/A
❑Yes❑NoON/A
80b. For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
❑ Yes ❑No®N/A
❑Yes❑NoON/A
❑ Yes ❑NOON/A
81. During Most Recent Semi -Annual Period, Did POTW Identify All
Limits Non -Compliance from Both POTW and SIU Sampling?
❑ Yes ❑ No
No Violations
❑ Yes ❑ No
No Violations
❑ Yes ❑ No
No Violations
82. During Most Recent Semi -Annual Period, Did POTW Identify All
Reporting Non -Compliance from SIU Sampling?
❑ Yes ❑N°ON/A
❑Yes❑NoON/A
❑Yes❑NoON/A
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?
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
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
❑ Yes /1 No
❑ Yes 1 No
❑ Yes /1 No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
Specified in POTW's ERP (NOVs, Penalties, timing, etc.)?
❑Yes❑No®N/A
❑Yes❑NoON/A
❑Yes❑No®N/A
86. Does File Contain Penalty Assessment Notices?
❑ Yes ❑NoEIN/A
❑Yes❑NoNN/A
❑ Yes ❑NoON/A
87. Does File Contain Proof Of Penalty Collection?
❑ Yes ❑No®N/A
❑Yes❑NoON/A
❑ Yes ❑NoON/A
88. a. Does File Contain Any Current Enforcement Orders?
b. Is SIU in Compliance with Order?
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
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
Information For You?
❑ Yes /1 No
❑ Yes A No
❑ Yes I1 No
FILE REVIEW COMMENTS: None.
NC DWR Pretreatment Audit Form Revised: December 2016
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DocuSign Envelope ID: 678408A0-5EFC-4ECA-B37C-6CCB87BCACE7
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
1 N 1 C1 1 0 10 12 13 17 13 16 1 108 1 02 1 22 1
1. Industry Inspected: Beocare
2. Industry Address: 1905 International Drive, Hudson, NC
3. Type of Industry/Product: Medical undergarments with dye process
4. Industry Contact: JR McCormick Title: CEO/ Ops Manager Phone: [phone] Fax:
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 ® Yes ❑ No
B. Plant Tour ® Yes ❑ No
C. Pretreatment Tour ® Yes ❑ No
D. Sampling Review ® Yes ❑ No
E. Exit Interview ® Yes ❑ No
Industrial Inspection Comments:
A complete inspection was conducted as part of the PCA. The IU and Lenoir WWTP staff are working together to identify an
unknown source of lint -like material that periodically accumulates in a nearby pump station.
Audit SUMMARY AND COMMENTS:
Audit Comments: All components evaluated were satisfactory.
Requirements: ERPs were sent to all the IUs the day of the Audit as requested.
Recommendations:
• Appoint a Pretreatment Coordinator as a new and distinct position from the other roles currently being performed by
the WWTP Superintendent.
• It is highly suggested that staff attend the annual NC Pretreatment Conference on a yearly basis. This provides
valuable training and a reasonable cost.
• Cost is recovered through penalties associated with Pretreatment violations. It is recommended that the program
consult with other municipalities about the potential for additional cost recovery options.
NOD: ❑ Yes ® No
NOV: ❑ Yes ® No
QNCR: ❑ Yes ® No
POTW Rating:
Satisfactory
Audit COMPLETED BY:
EDocuSigned by:
til44A9 lkuwl
08281105ABCA118...
Marginal ❑ Unsatisfactory ❑
Tim Heim, Asheville Regional Office
DATE: 08/02/2022
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 6