NC0024945_Inspection_20230203

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Bill Gintert
Environmental Compliance Manager
System Protection
Charlotte Water
4222 Westmont Drive
Charlotte, North Carolina 28217
NORTH CAROLINA
Environmental Quality
February 3, 2023
SUBJECT: Pretreatment Compliance Inspection
Charlotte Water
NPDES Permit No. NC0024945
Mecklenburg County
Dear Mr. Gintert:
Enclosed is a copy of the Pretreatment Compliance Inspection (PCI) Report for the inspection of the Charlotte Water's
approved Industrial Pretreatment Program on February 2, 2023, by Mr. Wes Bell of this Office.
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
Sincerely,
DocuSigned by:
A wHPam►
F161FB69A2D84A3..
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: Charlotte Water
2. Control Authority Representative(s): Bill Gintert, Sarah Daley
3. Title(s): Environmental Compliance Manager, Environmental Compliance Supervisor
4. Last Inspection Date: 8/25/21 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
PCS CODING
Main Program Permit Number
NC0024945
MM/DD/YY
02/02/23
7. Current Number Of Significant Industrial Users (SIUs)?
55
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 Violations During Either of the Last 2 Semi -Annual Periods
0
13. Number of SIUs in SNC with Pretreatment Schedule?
0
14. Current Number of SIUs on Schedules?
0
15. Current Number Of Categorical Industrial Users (CIUs)?
24
16. Number of CIUs in SNC?
1
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)
YES ❑ NO;
See Comments Section
YES NO
See Comments Section
SNC for Limits: IGM, Toluene limit violation
(TRC), January — June 2022 time period
SNC for Reporting: N/A
Not Published: None
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?
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 December 2016 Page 1

28. PRETREATMENT PROGRAM ELEMENTS REVIEW
Program Element
Irwin Creek WWTP (NC0024945)
Last Submittal Received
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
12/20/19
/1 Yes ❑ No
5/12/20
/1 Yes ❑ No
10/01/23
Industrial Waste Survey (IWS)
12/20/19
/1 Yes ❑ No
10/19/20
/1 Yes ❑ No
12/31/24
Sewer Use Ordinance (SUO)
8/20/12
/1 Yes ❑ No
9/13/12
/1 Yes ❑ No
Enforcement Response Plan (ERP)
10/11/19
/1 Yes ❑ No
1/7/20
/1 Yes ❑ No
Long Term Monitoring Plan (LTMP)
5/30/18
/1 Yes ❑ No
7/6/18
/1 Yes ❑ No
Program Element
Sugar Creek WWTP (NC0024937)
Last Submittal Received
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
12/28/20
/1 Yes ❑ No
8/14/18
/1 Yes ❑ No
4/1/23
Industrial Waste Survey (IWS)
12/20/19
/1 Yes ❑ No
10/19/20
/1 Yes ❑ No
12/31/24
Sewer Use Ordinance (SUO)
8/20/12
/1 Yes ❑ No
9/13/12
0 Yes ❑ No
Enforcement Response Plan (ERP)
10/11/19
/1 Yes ❑ No
1/7/20
r Yes ❑ No
Long Term Monitoring Plan (LTMP)
5/30/18
/1 Yes ❑ No
7/6/18
r Yes ❑ No
Program Element
McAlpine Creek WWTP (NC0024970)
Last Submittal Received
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
11/30/18
/1 Yes ❑ No
12/5/18
r Yes ❑ No
12/1/23
Industrial Waste Survey (IWS)
12/20/19
/1 Yes ❑ No
10/19/20
r Yes ❑ No
12/31/24
Sewer Use Ordinance (SUO)
8/20/12
/1 Yes ❑ No
9/13/12
r Yes ❑ No
Enforcement Response Plan (ERP)
10/11/19
/1 Yes ❑ No
1/7/20
r Yes ❑ No
Long Term Monitoring Plan (LTMP)
5/30/18
/1 Yes ❑ No
7/6/18
r Yes ❑ No
Program Element
Mallard Creek WWTP (NC0030210)
Last Submittal Received
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
7/31/18
0 Yes ❑ No
8/15/18
@/ Yes ❑ No
6/1/23
Industrial Waste Survey (IWS)
12/20/19
0 Yes ❑ No
10/19/20
a/ Yes ❑ No
12/31/24
Sewer Use Ordinance (SUO)
8/20/12
0 Yes ❑ No
9/13/12
@ Yes ❑ No
Enforcement Response Plan (ERP)
10/11/19
0 Yes ❑ No
1/7/20
a Yes ❑ No
Long Term Monitoring Plan (LTMP)
5/30/18
0 Yes ❑ No
7/6/18
a Yes ❑ No
*Charlotte Water — McDowell Creek WWTP has no SIUs.
SUO adopted on 10/28/13
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

INDUSTRIAL USER PERMIT (IUP) FILE REVIEW
29. User Name
1. Cargill
2. Avago Technologies
3. Aramark
30. IUP Number
0642
2004
0060
31. Does File Contain Current Permit?
/1 Yes ❑ No
/1 Yes ❑ No
1 Yes ❑ No
32. Permit Expiration Date
12/31/26
11/30/25
4/30/26
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
N/A
433
N/A
34. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
/1 Yes ❑ No
/1 Yes ❑ No
/1 Yes ❑ No
35. Does File Contain an Inspection Completed Within Last Calendar Year?
/1 Yes ❑ No
/1 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. Yes •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❑NoEN/A
38. a. Does File Contain Original Permit Review Letter from the Division?
b. All Issues Resolved?
a. Yes ■No
b.❑Yes❑NoEN/A
a. Yes No
b.❑Yes❑NoEN/A
a. Yes ❑No
b.❑Yes❑NoEN/A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
its Sampling as Required by IUP, including flow?
A Yes ❑ No
/1 Yes ❑ No
A Yes ❑ No
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
/1 Yes ❑ No
/1 Yes ❑ No
11 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❑NoEN/A
❑Yes❑NoEN/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❑NoEN/A
❑Yes❑NoEN/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►1NA
®Yes❑No❑N/A
®Yes❑No❑N/A
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Reporting Non -Compliance from SIU Sampling?
❑Yes ONO EN/A
❑Yes❑NoEN/A
❑Yes❑NoEN/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❑NoDN/A
c.❑Yes❑NoDN/A
a.❑Yes ❑NoEN/A
b.❑Yes❑No®N/A
c.❑Yes❑No®N/A
a.❑Yes❑NoEN/A
b.❑Yes❑NoEN/A
c.❑Yes❑NoDN/A
45. During the Most Recent Semi-Armual Period, Was the SIU in SNC?
❑ Yes 11 No
❑ Yes r No
❑ Yes 11 No
46. During the Most Recent Semi -Annual Period, Was Enforcement Taken
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
❑Yes❑NoEN/A
❑Yes❑NoEN/A
EYes❑No❑N/A
47. Does the File Contain Penalty Assessment Notices?
❑ Yes ❑NoEN/A
❑Yes❑NoEN/A
❑ Yes ❑NoEN/A
48. Does The File Contain Proof Of Penalty Collection?
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes ONO EN/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❑NoEN/A
b.❑Yes ❑NoEN/A
a.❑Yes ❑NoEN/A
b.❑Yes❑NoEN/A
50. Did the POTW Representative Have Difficulty in Obtaining Any of This
Requested Information For You?
❑ Yes /1 No
❑ Yes L No
❑ Yes /1 No
FILE REVIEW COMMENTS:
17. Mallard Creek - Chronic Toxicity effluent limit violation - August 2021. Sugar Creek WWP - Weekly average effluent fecal coliform
violation in January 2023.
18. The Sugar Creek WWTP's UV intensity was negatively impacted (decreased intensity) in January 2023 from an unknown constituent and/or
discharger based on sampling results and SIU evaluations. The UV system returned to proper intensity levels and the investigation is ongoing.
35. The POTW performed SIU inspections on 2/2/22 (Cargill), 5/25/22 (Avago Technologies) and 12/1/22 (Aramark).
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3

39. The POTW's certified laboratory (Charlotte Water Environmental Services Laboratory) performs LTMP and IUP sampling and analyses.
Pace Analytical Services and Waypoint Analytical has also been contracted to perform selected analyses.
41a. The POTW's certified laboratory performs analyses for Cargill, Avago Technologies and Aramark IUP sampling events.
46. The POTW issued a NOV to Aramark for flow limit violations in July 2022.
SUMMARY AND COMMENTS:
The records reviewed during the inspection were organized and well maintained. The Charlotte Water Industrial Pretreatment Program was
being properly implemented.
NOD: ❑ YES ® NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ® NO
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory_ ❑
DocuSigned by:
Clee.J, 2/3/2023
PCI COMPLETED BY: DATE:
A01090D90CC3437...
Wes Bell, Environmental Specialist II, MROWQROS, NC DWR
DocuSigned by:
PCI REVIEWED BY: F161FB69A2D84A3... DATE:
Andrew H. Pitner, Acting Regional Supervisor, MRO/WQROS, NC DWR
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 4