NC0020401_Inspection_20230612

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Shawn Pennell, Public Utilities Director
City of Hickory
Post Office Box 398
Hickory, North Carolina 28603
SUBJECT: Pretreatment Audit Inspection
City of Hickory
NPDES Permit No. NCO020401
Catawba County
Dear Mr. Pennell:
NORTH CAROLINA
Environmental Quality
June 12, 2023
Enclosed is a copy of the Pretreatment Audit Inspection (PAI) Report for the inspection of the City of Hickory's Industrial
Pretreatment Program on June 6, 2023, by Mr. Wes Bell of this Office. This Office would like to thank all Pretreatment staff
for the cooperation and the assistance provided throughout this inspection. Please advise the City's Pretreatment staff of our
findings by forwarding the enclosed report.
Should you have any questions concerning this report, please do not hesitate to contact Mr. Bell at [phone] or at
wes.bell(a,ncdeq.nc. gov.
Sincerely,
DocuSigned by:
A�•�Guw N Pam►
F161 FB69A2D84A3...
Andrew H. Pitner, P.G.
Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
Enclosure: Inspection Report
Cc: NPDES Program Files - Laserfiche
D North Carolina Department of Environmental Quality I Division of Water Resources
Mooresville Regional Office 1 610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115
704.663.1699

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT AUDIT REPORT
Background Information
1. Control Authority (POTW) Name: City of Hickory
2. Control Authority Representative(s): Morgan Bowers, David Cox
3. Title(s): Pretreatment Coordinator, Environmental Manager
4. Address of POTW:
Mailing: 310 Cloninger Mill Road
City: Hickory Zip Code: 28601
Phone Number [phone] Ext. 204 Fax Number [phone] E-Mail mbowers(a hickorvnc.2ov
5. Audit Date 06/06/2023
6. Last Inspection Date: 12/14/2021 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. Northeast WWTP — Daily maximum effluent TRC violations (2-total) were reported in October
2022; Henry Fork WWTP —No effluent limit violations reported since November 2012 (Chronic Tox Failure).
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
INIC1010I2 Io 14 to I1
MM/DD/YY
1 06 1 06 1 23
NC DWR Pretreatment Audit Form Revised: December 2016
Page 1

20. PRETREATMENT PROGRAM ELEMENTS REVIEW:
Program Element
Northeast WWTP (NC0020401)
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
07/30/18
® Yes ❑ No
08/09/18
® Yes ❑ No
08/01/23
Industrial Waste Survey (IWS)
09/04/18
® Yes ❑ No
10/09/18
® Yes ❑ No
10/01/23
Sewer Use Ordinance (SUO)
09/20/12
® Yes ❑ No
10/22/12
® Yes ❑ No
Enforcement Response Plan (ERP)
08/16/19
® Yes ❑ No
11/13/19
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
06/01/18
® Yes ❑ No
06/07/18
® Yes ❑ No
Program Element
Henry Fork WWTP (NC0040797)
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
04/17/23
® Yes ❑ No
07/18/19
® Yes ❑ No
04/1/23
Industrial Waste Survey (IWS)
09/04/18
® Yes ❑ No
10/09/18
® Yes ❑ No
10/01/23
Sewer Use Ordinance (SUO)
09/20/12
® Yes ❑ No
10/22/12
® Yes ❑ No
Enforcement Response Plan (ERP)
08/16/19
® Yes ❑ No
11/13/19
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
07/01/19
® Yes ❑ No
07/18/19
® Yes ❑ No
Legal Authoritv (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. Hildebran, Longview, Brookford, and Catawba (Towns);
Alexander, Burke, and Caldwell Counties.
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.
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. N/A
NC DWR Pretreatment Audit Form Revised: December 2016 Page 2

Resources
29. Please Rate the Following: S=Satisfactory M=Marginal U=Unsatisfactory
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
®S ❑M ❑U
Access to POTW Vehicles for
Sampling, Inspections, and
®S ❑M ❑U
Emergencies
Access to Operable Sampling
Equipment
®S ❑M ❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
®S ❑M ❑U
Reference Materials
®S ❑M ❑U
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
®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? ® Yes ❑ No
Explain Yes or No. Excell
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Surcharges, penalties, SIU performs resampling for violations found during POTW sampling event.
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. A SIU (Ward Hosiery) has closed.
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? Written request would have to be submitted and
reviewed/approved by POTW's Attorney. Files would be reviewed at the Pretreatment Office under the supervision of
the Pretreatment Coordinator and Environmental Manager.
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? Written request would have to be submitted and the documentation
would be reviewed by the POTW Attorney, Public Services Managers (including Environmental Manager) and
Pretreatment Coordinator. Confidential files would be kept in a locked office and file cabinet.
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 ❑ No ❑ N/A
Permitting (Industrial Waste Survey-IWS)
38. How does the POTW become aware of new or changed Users? The Public Services Department including
Pretreatment Coordinator meet monthly to discuss any new users. All satellite communities contact the
Pretreatment Coordinator of any new potential users.
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 Short/Long Form information reviewed for type of industrial activity, flow, loading, POCs (including
>5% of MARL), and categorical parameters.
NC DWR Pretreatment Audit Form Revised: December 2016 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? 0
Please list each site and how it is permitted, if applicable. Caldwell County Landfill Leachate
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) Henry Fork WWTP — Caldwell County Leachate hauled via tanker to designated point with
samples drawn and manifests maintained. Septage haulers have a designated point in the Henry Fork WWTP's
collection system (Brookford) with each hauler being tracked by an electronic monitoring system.
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 %
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) NPDES POCs, categorical parameters.
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
The POTW requires potential SIUs to provide multiple sets of sampling data (if available) prior to issuance of IUPs. All
SIUs are required to monitor three times per six-month period at a minimum.
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 Judgment Worksheet used for SNC determinations,
violations (limit, monitoring, reporting, permit conditions, etc.) are addressed per ERP.
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? POTW requires all SIUs to have a slug/spill control
plan.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate? All emergency contacts kept
updated, proper secondary containment/chemical storage practices, presence of emergency response equipment.
56. How does the POTW decide where the sample point for an SIU should be located? Sampling is preferred only at the regulated
waste stream.
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. Sampling SOPS and sampler O&M manuals
NC DWR Pretreatment Audit Form Revised: December 2016 Page 4

58. Who performs sample analysis for the POTW for Metals: Pace Analytical Services
Conventional Parameters: POTW's on -site certified lab
Organics: Pace Analytical Services
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
POTW uses internal COC and/or contracted lab's COC; SIU's used contracted lab's COC.
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 ❑ 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 ❑ NO
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? 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
❑More 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. N/A — both WWTPs have sufficient capacity.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 5

Summary
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment? No;
however, the POTW will have a new SIU (Cataler) starting in July 2023.
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW
66. User Name
1. The Sock Factory, Inc. 2. Catawba Valley Medical Center
3. Gusmer Enterprises,
Inc.
67. IUP Number
0017
0003
0052
68. Does File Contain Current Permit?
® Yes
❑
1 ®
Yes
❑ No
® Yes ❑ No
69. Permit Expiration Date
07/07/2026
07/07/2026
03/13/2027
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
410
460
463 & 430
71. Does File Contain Permit Application Completed Within One Year Prior
® Yes ❑ No
®Yes ❑ No
® Yes ❑ No
to Permit Issue Date?
72. Does File Contain Inspection Completed Within Last Calendar Year?
® Yes ❑ No
® Yes
❑
No
® Yes ❑ No
73. a. Does File Contain Slug/Spill Control Plan?
a. ®Yes []No
a. ®Yes ❑No
a. ®Yes []No
b. If No, is One Needed? See Inspection Form from POTW)
b. [-]Yes [-]No
b. []Yes ❑No
I b. ❑Yes ❑No
74. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
❑Yes❑No®N/A
F
❑Yes❑No®N/A
❑Yes❑NoON/A
Organic Management Plan (TOMP)?
75. a. Does File Contain Original Permit Review Letter from Division?
®Yes []No
RoYesoNoON/A
a. ®Yes ❑No
a. ®Yes []Nob.
All Issues Resolved?
b.❑Yes❑No®N/A
b.❑Yes❑No®N/A
76. During Most Recent Semi -Annual Period, Did POTW Complete its
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
Sampling as Required by IUP, including Flow?
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
78. During Most Recent Semi -Annual Period, Did SIU Complete its
®Yes❑No❑N/A
®Yes❑No❑N/A
❑Yes®No❑N/A
11
Sampling as Required by IUP, including Flow?
79. During Most Recent Semi -Annual Period, Did SIU submit all reports on
®Yes❑No❑N/A
®Yes❑No❑N/A
❑Yes❑No®N/A
time?
80a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑NoON/A
file includeprocess/dilution flows as Required by IUP?
80b. For categorical IUs with Production based limits, does file include
❑Yes❑No®N/A
❑Yes❑NOON/A
❑Yes❑NoON/A
production rates and/or flows as Required by IUP?
81. During Most Recent Semi -Annual Period, Did POTW Identify All
®Yes❑No❑N/A
®Yes❑No❑N/A
❑Yes❑No®N/A
Limits Non -Compliance from Both POTW and SIU Sampling?
82. During Most Recent Semi -Annual Period, Did POTW Identify All
®Yes❑No❑N/A
❑Yes❑No®N/A
®Yes❑No❑N/A
Reporting_Non-Compliance from SIU Sampling?
83. a. Was POTW Notified by SIU (Within 24 Hours) of All Self-
a.®Yes❑No❑N/A
a.®Yes❑No❑N/A
a.❑Yes❑NoON/A
Monitoring Violations?
b. Did Industry Resample and submit results to POTW within 30 Days?
b.®Yes❑No❑N/A
b.®Yes❑No❑N/A
b.❑Yes❑No®N/A
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?
c.®Yes❑No❑N/A
c.❑Yes❑No®N/A
c.❑Yes❑No®N/A
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
®
Yes
❑
No 11
❑
Yes
®
No
11
®
Yes
❑
No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
®Yes❑No❑N/A
®Yes❑No❑N/A
®Yes❑No❑N/A
Specified in POTW's ERP (NOVs, Penalties, timing, etc.)?
86. Does File Contain Penalty Assessment Notices?
OYes❑No❑N/A
❑Yes❑No®N/A
®Yes❑No❑N/A
87. Does File Contain Proof Of Penalty Collection?
®Yes❑No❑N/A
❑Yes❑No[D
®Yes❑No❑N/A
88. a. Does File Contain Any Current Enforcement Orders?
a.❑Yes❑No®N/A
a.❑Yes❑No®N/A
a.❑Yes❑No®N/A
b. Is SIU in Compliance with Order?
b.❑Yes❑No®N/A
b.❑Yes❑No®N/A
b.❑Yes❑No®N/A
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
❑ Yes ® No
❑ Yes ® No
❑ Yes ® No
Information For You?
FILE REVIEW COMMENTS:
10. The POTW will have a total of fourteen (14) SIUs as of July 2023.
14. The Sock Factory, Inc. was in SNC for chromium limit violations during the first half of 2022. Gusmer Enterprises, Inc. was also in
SNC during first half of 2022 for reporting violations.
72. POTW performed SIU inspections on 8/30/2022 (Sock Factory), 8/4/2022 (Catawba Valley Medical Center) and 2/3/2022 (Gusmer
Enterprises).
NC DWR Pretreatment Audit Form Revised: December 2016 Page 6

78. The Sock Factory and Catawba Valley Medical Center both contract Statesville Analytical to perform IUP analyses. Gusmer
Enterprises contracts Pace Analytical Services for IUP analyses.
81/85. The POTW issued Notice of Noncompliances (NoNCs) to The Sock Factory for pH limit violations (January and May 2022),
ammonia limit violation (May 2022) and chromium limit violations (March, May and June 2022). Catawba Valley Medical Center was
issued NoNCs for zinc limit violations from January through April 2022.
82/85. Gusmer Enterprises was issued a NoNC for failing to monitor according to the IUP during the first half of 2022. The Sock Factory
was also issued a NoNC for the late submittal of the March 2022 monitoring report.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
INIC10 10 12 Io 14 Io 11 I I06I06 I23I
1. Industry Inspected: Catawba Valley Medical Center
2. Industry Address: 810 Fairgrove Church Road SE, Hickory, NC 28602
3. Type of Industry/Product: Hospital/Healthcare
4. Industry Contact: Jeffery Ayers Title: Director Facilities Management 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 ® 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:
The hospital currently has 258 beds and employs approximately 2,000 personnel. The clinical departments work
12-hr. shifts, seven days per week and the maintenance department operates during two 8-hr. shifts (first and
second). The Environmental Services staff work three 8-hr. shifts. There is no pretreatment provided to the
hospital's waste stream which includes discharges from domestic sources, boilers, cooling towers, morgue and
operating room. The Emergency Room is equipped with a decontamination room that is connected (via valve
system) to an outside holding tank for the separate collection and disposal of the waste stream.
AUDIT COMMENTS:
This Office recommends that the Pretreatment Coordinator review the Slug/Spill control Plans during SIU
inspections to ensure the Plan is up to date including correct listing of all stored chemicals, storage practices,
floor drain locations, etc.
The POTW's records were organized and well maintained. The POTW's Industrial Pretreatment Program was
being properly implemented.
NOD: ❑ Yes
NOV: ❑ Yes
QNCR: ❑ Yes
POTW Rating:
Satisfactory
Marginal ❑
Unsatisfactory ❑
NC DWR Pretreatment Audit Form Revised: December 2016 Page 7

E�`,,96D90CC3437
Siiggned by:
24AUDIT COMPLETED BY: ...
TE: 6/12/2023
Wes Bell, Environmental Specialist II, Mooresville Regional Office, WQROS/DWR
EDocu Signed by:
F161FB69A2D84A3
4114 W %j P441t4 6/12/2023
AUDIT REVIEWED BY: ... DATE:
Andrew H. Pitner, Regional Supervisor, Mooresville Regional Office, WQROS/DWR
NC DWR Pretreatment Audit Form Revised: December 2016 Page 8