NC0055786_202308PCI_20230811

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
Water Resources
ENVIRONMENTAL QUALITY
BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)]
1. Control Authority (POTW) Name: City of Lexington
2. Control Authority Representative(s): Eglantina Minerali
3. Title(s): Pretreatment Coordinator
4. Last Inspection Date: 9/27/2022 Inspection Type (Check One): ❑ PCI ® Audit
5. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? N 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
ICIS CODING
Main Program Permit Number NCO055786 MM/DD/YY Permit expires: 4/30/2025
7. Current Number Of Significant Industrial Users SIUs ?
6
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?
0
15. Current Number Of Categorical Industrial Users CIUs ?
5
16. Number of 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)
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 YES ❑ NO
*see POTW interview comments
N YES ❑ NO
*See POTW interview comments
SNC for Limits: 0
SNC for Reporting: 0
Not Published: NA
None
❑ YES ® NO
LTMP/STMP FILE REVIEW:
22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? NYES ❑ 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? NYES ❑ NO (Division Inspector, please verify
yourself!)
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated August 2022 Page 1

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:
28. PRETREATMENT PROGRAM ELEMENTS REVIEW— Please review POTW files, verify POTW has copy of Program Element
in their files. comnlete with sunnortina documents and cony of PERCS ADDroval Letter. and dates consistent with Program Info:
Program Element
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
1/30/2020
M Yes ❑ No
7/16/2020
M Yes ❑ No
7/1/2024
Industrial Waste Survey (IWS)
11-28-20
M Yes ❑ No
12/2/2020
M Yes ❑ No
11/23/2025
Sewer Use Ordinance (SUO)
1-8-13
M Yes ❑ No
1 /9/2013
M Yes ❑ No
-
Enforcement Response Plan (ERP)
2-3-20
M Yes ❑ No
2/13/2020
M Yes ❑ No
-
Long Term Monitoring Plan (LTMP)
9-24-20
M Yes ❑ No
3/11/2021
M Yes ❑ No
-
POTW Interview comments:
There have been several NPDES violations concerning BOD and ammonia limits. Violations occurred in September and October 2022
which did not result in NOVs. Additional violation occurred in March, April, May, and June 2023 concerning BOD and ammonia. These
violations resulted in NOV (March 2023) and NOV w/ intent (April/May 2023). June 2023 violation is currently in review. Jesse Barnes
and Gary Hudson conducted a technical assistance visit on August 4, 2023. Preliminary report indicates the possibility of insufficient
aeration (DO levels) in aeration basin due to malfunctioning diffusers.
Eggar Wood Products was issued a NOV for silver limit violation in June 2023. It was an isolated incident and no further issues. Control
Authority could not determine with certainty what caused elevation in silver.
POTW has a contract with Davidson County to intake 500,000 mgd. The contract was recently updated.
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated August 2022 Page 2

INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name IFI,
Egger
2. ASCO
3. Metcor
30. IUP Number
0114
0038
0012
31. Does File Contain Current Permit?
M Yes ❑ No
M Yes ❑ No
M Yes ❑ No
32. Permit Expiration Date
3-16-26
3-31-24
3-31-24
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or
429
I
433.15
IF
433
N/A
34. Does File Contain Permit Application Completed
M Yes ❑ No
M Yes ❑ No
IF
M Yes ❑ No
Within One Year Prior to Permit Issue Date?
35. Does File Contain an Inspection Completed Within
M Yes ❑ No
I
M Yes ❑ No
F
M Yes ❑ No
Last Calendar Year?
36. a. Does the File Contain a Slug/Spill Control Plan?
a M Yes M No
a. M Yes ❑ No
a. M Yes ❑ No
b. If No, is One Needed? (See Inspection Form from
b. ❑ Yes ❑ No
b. ❑ Yes ❑ No
b. ❑ Yes ❑ No
POTW
37. For 40 CFR 413 and 433 TTO Certification, Does
❑ Yes ❑ No M NA
M Yes ❑ No ❑ NA
M Yes ❑ No ❑ NA
File Contain a Toxic Organic Management Plan
TOMP ?
38. a. Does File Contain Original Permit Review Letter
a. MYes ❑No
a. MYes ❑No
a. MYes ❑No
from the Division?
b. All Issues Resolved?
b.❑ Yes ❑ No N/A ®
b. El Yes ❑ No N/A ®
b. El Yes ❑ No N/A M
39. During the Most Recent Semi -Annual Period, Did the
M Yes ❑ No
M Yes ❑ No
M Yes ❑ No
POTW Complete its Sampling as Required by IUP,
including flow?
40. Does File Contain POTW Sampling Chain -Of-
M Yes ❑ No
M Yes ❑ No
M Yes ❑ No
Custody Forms?
41. During the Most Recent Semi -Annual Period, Did the
M Yes ❑ No ❑ NA
M Yes ❑ No ❑ NA
M Yes ❑ No ❑ NA
SIU Complete its Sampling as Required by IUP,
including flow?
41b. During the Most Recent Semi -Annual Period, Did
M Yes ❑ No ❑ NA
M Yes ❑ No ❑ NA
®Yes ❑ No ❑ NA
SIU submit all reports on time?
42a. For categorical IUs with Combined Wastestream
❑ Yes ❑ No M NA
❑ Yes ❑ No M NA
M Yes ❑ No M NA
Formula (CWF), does file include process/dilution
flows as Required by IUP?
42b. For categorical IUs with Production based limits,
❑ Yes ❑ No M NA
❑ Yes ❑ No M NA
❑ Yes ❑ No M NA
does file include production rates and/or flows as
Required by IUP?
43a. During the Most Recent Semi -Annual Period, Did
M Yes ❑ No
M Yes ❑ No
M Yes ❑ No
the POTW Identify All Limits Non -Compliance from
Both POTW and SIU Sampling?
43b. During the Most Recent Semi -Annual Period, Did
❑ Yes ❑ No M NA
❑ Yes ❑ No M NA
❑ Yes ❑ No M NA
the POTW Identify All Reporting_Non-Compliance
from SIU Sampling?
44. a. Was the POTW Notified by SIU (Within 24 Hours)
a. ❑ Yes ❑ No © NA
a. ❑ Yes ❑ No ® NA
a. ❑ Yes ❑ No ® NA
of All Self- Monitoring Violations?
b. Did Industry Resample and submit results to POTW
b ❑ Yes ❑ No ® N/A
b ❑ Yes ❑ No ® N/A
b ❑ Yes ❑ No ® N/A
Within 30 Days?
c. If applicable, Did POTW resample within 30 days
c. ❑ Yes ❑ No ® N/A
c. ❑ Yes ❑ No ® N/A
c. ❑ Yes ❑ No N N/A
of becoming aware of SIU limit violations in the
POTW's sampling of the SIU?
46. During the Most Recent Semi -Annual Period, Was
❑ Yes M No
❑ Yes M No
❑ Yes M No
the SIU in SNC?
47. During the Most Recent Semi -Annual Period, Was
❑Yes ❑ No N N/A
❑Yes ❑ No N N/A
❑Yes ❑ No N N/A
Enforcement Taken as Specified in the POTW's ERP
OVs, Penalties, timing, etc.)?
48. Does the File Contain Penalty Assessment Notices?
❑ Yes ❑ No M NA
❑ Yes ❑ No M NA 11
❑ Yes ❑ No M NA
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated August 2022 Page 3

49. Does The File Contain Proof Of Penalty Collection?
50. a. Does the File Contain Any Current Enforcement
Orders?
b. Is SIU in Compliance with Order?
51. Did the POTW Representative Have Difficulty in
Obtaining Any of This Requested Information For
You?
❑ Yes ❑ No M NA 11
❑ Yes ❑ No M NA
I ❑ Yes ❑ No M NA
a. ❑ Yes ❑ No N/A N
b ❑ Yes ❑ No N/A N
a. ❑ Yes ❑ No N/A N
b ❑ Yes ❑ No N/A N
a. ❑ Yes ❑ No N/A N
b ❑ Yes ❑ No N/A N
❑ Yes M No
❑ Yes ❑X No
❑ Yes M No
FILE REVIEW COMMENTS:
Files are in order. No discrepancies found during inspection.
NO AUDIT CONDUCTED
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
1. Industry Inspected:_
2. Industry Address:
3. Type of Industry/Product
4. Industry Contact: Title:
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:
OVERALL SUMMARY AND COMMENTS:
Comments: .
Requirements: .
Recommendations: .
NOD: ❑YES ENO
NOV: ❑YES ENO
QNCR: ❑YES ENO
POTW Ratina:
Satisfactory E Marginal ❑ Unsatisfactory-0
PCI COMPLETED BY: Tricia Lowery DATE: 8/8/2023
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated August 2022 Page 4