NC0021156_Inspection_20230117

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
David Johnson, Utilities Director
City of Mount Holly
Post Office Box 406
Mount Holly, North Carolina 28120
NORTH CAROLINA
Environmental Quality
January 17, 2023
SUBJECT: Pretreatment Compliance Inspection
City of Mount Holly
NPDES Permit No. NC0021156
Gaston County
Dear Mr. Johnson:
Enclosed is a copy of the Pretreatment Compliance Inspection (PCI) Report for the inspection of the City of Mount Holly's
approved Industrial Pretreatment Program on January 12, 2023, by Mr. Wes Bell of this Office. Please forward a copy of this
report to all staff involved with the implementation of the City's Industrial Pretreatment Program.
The report should be self-explanatory; however, should you have any questions, please do not hesitate to contact Mr. Bell
at [phone] or at [e-mail].
Enclosure:Inspection Report
Cc: NPDES Program Files - Laserfiche
D_E
Sincerely,
�DocuSigned by:
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Andrew H. Pitner, P.G.
Assistant Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
North Carolina Department of Environmental Quality I Division of Water Resources
Mooresville Regional Office 1610 East Center Avenue. Suite 301 1 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 Mount Holly
2. Control Authority Representative(s): Doug Shoutd, Nadine Blackwell
3. Title(s): Pretreatment Coordinator, Consultant
4. Last Inspection Date: 5/27/21 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
NC0021156
MM/DD/YY
01/12/23
7. Current Number Of Significant Industrial Users (SIUs)?
3
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?
1
15. Current Number of Categorical Industrial Users (CIUs)?
2
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)
N/A
Not Pu
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 r NO
)lished: N/A
American Efird — Consent
Agreement; Yes
/1 YES ❑ NO
American Efird and Daimler
Trucks NA
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)
3/28/19
/1 Yes ❑ No
6/24/19
/1 Yes ❑ No
4/1/24
Industrial Waste Survey (IWS)
12/13/21
a Yes ❑ No
8/10/22
/1 Yes ❑ No
8/10/27
Sewer Use Ordinance (SUO)
2/22/22
a Yes ❑ No
1/14/13
/1 Yes ❑ No
Enforcement Response Plan (ERP)
2/22/22
0 Yes ❑ No
12/15/10
/1 Yes ❑ No
Long Term Monitoring Plan (LTMP)
3/30/16
a Yes ❑ No
5/4/16
/1 Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW:
29. User Name
1. American Efird
2. Clariant
3. Daimler Trucks NA
30. IUP Number
1157
1158
1163
31. Does File Contain Current Permit?
/1 Yes ❑ No
/1 Yes ❑ No
/1 Yes ❑ No
32. Permit Expiration Date
12/31/27
12/31/27
12/31/27
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
410
414 & 455
433
34. Does File Contain Permit Application Completed Within One Year
Prior to Permit Issue Date?
@ Yes ❑ No
@ Yes ❑ No
A Yes ❑ No
35. Does File Contain an Inspection Completed Within Last Calendar
Year?
/1 Yes ❑ No
r Yes ❑ No
1 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. AYes •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
❑Yes❑NOON/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❑No®N/A
a. ► Yes •No
b.❑Yes❑No®N/A
a. AYes •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
/1 Yes ❑ No
1 Yes ❑ No
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
/1 Yes ❑ No
/1 Yes ❑ No
A 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❑NoON/A
❑Yes❑NOON/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❑No®N/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❑No®N/A
❑Yes❑NoON/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❑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
45. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
❑ Yes ao
❑ Yes L No
❑ Yes /1 No
46. During the Most Recent Semi -Annual Period, Was Enforcement Taken
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
®Yes❑No❑N/A
®Yes❑No❑N/A
®Yes❑No❑N/A
47. Does the File Contain Penalty Assessment Notices?
®Yes❑No❑N/A
❑Yes❑NoNN/A
❑Yes❑No®N/A
48. Does The File Contain Proof Of Penalty Collection?
®Yes❑No❑N/A
❑Yes❑NoDN/A
❑Yes❑No®N/A
49. a. Does the 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
50. Did the POTW Representative Have Difficulty in Obtaining Any of
This Requested Information For You?
❑ Yes r No
❑ Yes r No
❑ Yes I No
NC DWR Pretreatment Compliance Inspection (PCI) Form
Updated 7/25/07 Page 2

FILE REVIEW COMMENTS:
17. Effluent weekly average fecal coliform violations were reported in July and August 2022. An effluent monthly average fecal coliform
violation was also reported in August 2022.
35. The POTW performed SIU inspections on 11/22/22 (American Efird), 11/17/22 (Clariant), and 11/17/22 (Daimler Trucks NA).
37. Daimler Trucks NA performs TTO sampling.
39. The POTW performs field and TSS analyses and contracts Pace Analytical Services to perform all remaining LTMP analyses. Pace
Analytical Services is also contracted to perform all IUP analyses during POTW's sampling of SIUs.
41a. American Efird and Clariant have contracted Pace Analytical Services to perform IUP analyses. Daimler Trucks NA had previously
contracted Pace Analytical Services to perform all IUP analyses; however, Waypoint Analytical was contracted as of November 2022.
46. American Efird was issued NOVs for limit violations of total nitrogen (January, February and March 2022), BOD (January and March
2022), CBOD (January 2022), and total phosphorus (April 2022). A civil penalty was also assessed for the limit violations in March 2022.
Clariant was issued NOVs for limit violations of total nitrogen (May and June 2022) and total phosphorus (June 2022). Daimler Trucks
NA was issued a NOV for a total nitrogen limit violation in May 2022.
SUMMARY AND COMMENTS:
The POTW's records 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 ® Marginal ❑ Unsatisfactory_ ❑
PCI COMPLETED BY:
PCI REVIEWED BY:
HDe,J,
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Wes Bell, Sr. Environmental Specialist, Mooresville Regional Office/DWR
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DATE: 1/17/2023
DATE:
1/17/2023
Andrew H. Pitner, Acting Regional Supervisor, Mooresville Regional Office/DWR
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 3