NC0020184_Inspection_20230825 (2)

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
BACKGROUND INFORMATION:
1. Control Authority (POTW) Name: Two Rivers Utilities
2. Control Authority Representative(s): David Shellenbarger, Michael Alexander, Chris English, Cody Austin
3. Title(s): Assistant Division Manager/Compliance, Pretreatment Supervisor, Pretreatment Coordinators
4. Last Inspection Date: 11/9/21 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 MM/DD/YY
NCO020184 08/22/2023
7. Current Number Of Significant Industrial Users (SIUs)?
1 23
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?
1 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 ?
8
16. Number CIUs in SNC? 11
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 N/A
either of the Last 2 Semi -Annual Periods? Not Been Published for Not Pu
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?
® YES ❑ NO; See Comments.
® YES ❑ NO
See Comments.
)lished: N/A
Champion Powder Coating, Yes
❑ 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 7/25/07 Page 1

28. PRETREATMENT PROGRAM ELEMENTS REVIEW:
Program Element
Long Creek WWTP (NC0020184)
Last Submittal Received
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
8/28/20
® Yes ❑ No
8/28/17
® Yes ❑ No
In Review
Industrial Waste Survey IWS
6/26/20
® Yes ❑ No
9/17/20
® Yes ❑ No
6/30/2025
Sewer Use Ordinance SUO
12/6/12
® Yes ❑ No
12/27/12
® Yes ❑ No
Enforcement Response Plan (ERP)
2/2/20
® Yes ❑ No
2/5/20
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
9/3/19
® Yes ❑ No
9/6/19
® Yes ❑ No
Program Element
Crowders Creek WWTP (NC0074268)
Last Submittal Received
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
1/12/22
® Yes ❑ No
4/15/20
® Yes ❑ No
In Review
Industrial Waste Survey IWS
6/26/20
® Yes ❑ No
9/17/20
® Yes ❑ No
6/30/2025
Sewer Use Ordinance SUO
12/6/12
® Yes ❑ No
12/27/12
® Yes ❑ No
Enforcement Response Plan (ERP)
2/2/20
® Yes ❑ No
2/5/20
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
1/11/22
® Yes ❑ No
8/25/17
® Yes ❑ No
In Review
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW:
29. User Name
1. Selkirk 2. Bimbo Bakeries
3. Town of Stanley
30. IUP Number
1071
1056
1 1069
31. Does File Contain Current Permit?
® Yes ❑
I ® Yes ❑ NoI
® Yes ❑ No
32. Permit Expiration Date
6/30/2024
12/31/2025
12/31/2026
33. Categorical Standard Applied I.E. 40 CFR, Etc. Or N/A
N/A
N/A
N/A
34. Does File Contain Permit Application Completed Within One Year Prior
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
to Permit Issue Date?
35. Does File Contain an Inspection Completed Within Last Calendar Year?
I ® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
36. a. Does the File Contain a 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. El es ❑No
b. ❑Yes ❑No
b. ❑Yes ENo
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑NoEN/A
Organic Management Plan (TOMP)?
38. a. Does File Contain Original Permit Review Letter from the Division?
a. ®Yes ❑No
a. ®Yes ❑No
a. ®Yes ❑No
b. All Issues Resolved?
b.❑Yes❑NoEN/A
b.❑Yes❑NoEN/A
b.❑Yes❑NoEN/A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
® Yes ❑ No
®Yes ❑ No
® Yes ❑ No
its Sampling as Required by IUP, including flow?
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
1 ® Yes ❑ No
® Yes
❑
No
® Yes ❑ No
41a. During the Most Recent Semi -Annual Period, Did the SIU Complete its
®Yes❑No❑N/A
®Yes❑No❑N/A
❑Yes❑NoEN/A
Sampling as Required by IUP, including flow?
41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports
EYes❑No❑N/A
®Yes❑No❑N/A
❑Yes❑NoEN/A
on time?
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑NoEN/A
file include process/dilution flows as Required by IUP?
42b. For categorical IUs with Production based limits, does file include
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑NoEN/A
production rates and/or flows as Required by IUP?
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑NoONA
EYes❑No❑N/A
❑Yes❑NoEN/A
All Limits Non -Compliance from Both POTW and SIU Sampling?
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑NoEN/A
All Reporting Non -Compliance from SIU Sampling?
44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
a.❑Yes❑NoEN/A
a.❑Yes❑NoEN/A
a.❑Yes❑NoEN/A
Monitoring Violations?
b. Did Industry Resample and submit results to POTW Within 30 Days?
b.❑Yes❑No®N/A
b.❑Ycs❑No®N/A
b.❑Yes❑NoEN/A
c. Did POTW resam le within 30 days of knowledge of SIU limit
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 2

violations from the POTW sample event?
45. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
46. During the Most Recent Semi -Annual Period, Was Enforcement Taken
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
47. Does the File Contain Penalty Assessment Notices?
48. Does The File Contain Proof Of Penalty Collection?
49. a. Does the File Contain Any Current Enforcement Orders?
b. Is SIU in Compliance with Order?
50. Did the POTW Representative Have Difficulty in Obtaining Any of This
Requested Information For You?
FILE REVIEW COMMENTS:
c.❑Yes❑No®N/A
c.®Yes❑No❑N/A
c.❑Yes❑No®N/A
❑
Yes
®
No
❑
Yes
®
No
❑
Yes
®
No
❑Yes❑No®N/A
®Yes❑No❑N/A
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑NoON/A
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑No®N/A
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
❑ Yes ® No
❑ Yes ® No
❑ Yes ® No
17. The Long Creek WWTP reported BOD violations in April 2022 (weekly and monthly average) and July 2022 (weekly average). The
Crowders Creek WWTP reported a chronic toxicity failure in September 2021.
18. Excessive foaming was detected in the collections systems of the POTW and Town of Stanley. A suspected industry is currently being
investigated. The Town of Stanley was issued a NOV for the SUO violation due to the excessive foaming and downstream impacts (flow
measurement).
35. The POTW performed the SIU inspections on 10/21/22 (Selkirk), 10/21/22 (Bimbo Bakeries), and 9/15/22 (Town of Stanley).
39. The POTW's on -site certified lab performs all analyses (LTMP and IUP) except for oil & grease, phenols, organics, chloride, and fluoride.
Pace Analytical Servies has been contracted to perform these analyses.
41 a. The POTW performs IUP monitoring for the SIUs; however, Selkirk submits flow and pH data and Bimbo Bakeries submits flow data.
46. Bimbo Bakeries was issued a NOV for a pH minimum violation in May 2023.
SUMMARY AND COMMENTS:
The records reviewed during the inspection were organized and well maintained. The POTW must ensure that the Slug/Spill Control Plans are
developed and adequately address all storage containers (volume, product listing, etc.) and not just petroleum -based containers covered under
the SPCC Plans. The POTW should contact the contracted lab that performs total recoverable phenols to analyze future samples at a lower
detection level (5 ug/L). Please note that analytical methods shall be in accordance with 40 CFR Part 136 and shall be sufficiently sensitive to
determine whether parameters are present in concentrations greater than applicable standards and criteria.
The POTW is properly implementing the Division -approved Industrial Pretreatment Program.
NOD: ❑ YES ®NO
NOV: ❑ YES ®NO
QNCR: ❑ YES ® NO
POTW Rating:
Satisfactory ❑
PCI COMPLETED BY
PCI REVIEWED BY:
Marginal ❑ Unsatisfactory_ ❑
aa�D/ocuSignedd by:
WPiY EGG
A61696D90CC3437...
DATE: 8/25/2023
Wes Bell, Environmental Specialist II, DWR/WQROS, MRO
DocuSigned by:
A�w H Nuft
F161 FB69A2D84A3... DATE:
Andrew H. Pitner, Regional Supervisor, DWR/WQROS, MRO
8/25/2023
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 3