NC0023981_IWS_Approval_20181130

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Interim Director
Sent via email ([e-mail])
Lisa Triplett
WWTP Superintendent
City of Lenoir
P.O. Box 958
Lenoir, NC 28645
NORTH CAROLINA
Environmental Quality
November 30, 2018
Subject: Pretreatment Review of Industrial Waste Survey (IWS)
Program: City of Lenoir; Caldwell County
WWTP: Lower Creek WWTP (NC0023981); Gunpowder Creek (NC0023736)
Dear Ms. Triplett:
The Pretreatment, Emergency Response, and Collection Systems Unit (PERCS) of the Division of Water
Resources has reviewed the Industrial Waste Survey (IWS) for the City of Lenoir. This IWS was
received by the Division on August 8, 2018, with additional information requested and received on
October 29, 2018 and again November 29, 2018.
The review indicates that with the following comments, the IWS is adequate and meets the
minimum requirements of 40 CFR 403.8 (f)(2). Proper completion of an Industrial Waste Survey is
also required by the City's NPDES permit. Please refer to the Comprehensive Guidance for North
Carolina Pretreatment Programs (Comprehensive Guide) for additional information and examples.
1. Please submit a description of the POTW's ongoing survey procedures, including communication
with satellite communities by January 31, 2019. (see Chapter 3, Section C, page 9-10, of the
Comprehensive Guide for examples)
2. Please keep the PERCS Unit updated when the POTW receives the response from Precision
Components.
3. Exela Pharma Sciences has an SIC code of 2834, and they manufacture pharmaceutical products
by mixing, compounding and formulating operations. It seems quite clear to the PERCS Unit that
Exela Pharma Sciences, LLC is subject to 40 CFR 439 Subpart D — Mixing/compounding and
formulation. Since the Max facility is a pharmaceutical lab, it subjects to the subpart E. Please
have the industry complete the pollutant checklist in the applications based on the lab results
and work on their IUPs. It was mentioned in the email from the POTW that not all the categorical
parameters were detected. Monitoring waiver could be an option for those parameters if they
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MCartmml I EnWmameeLi Quat9y
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1617
919.707.9000

are in accordance with 40 CFR 40.12 (e)(2), please refer to the attached streamlining guidance
(bottom of the page 2) and the language in state IUP model special condition 11 — monitoring
waiver parameters. The deadline to submit their IUPs is January 31, 2019.
4. As far as your concern with the new coming copper limits, it seems that the current Lower Creek
HWA has the new copper limits factored in already, it has 0.7628 Ibs/day (37.2% of the MAHL)
available for future industries. The industries' daily flow would be needed to decide whether the
copper in their discharge is greater than 5% of the Lower Creek's MAHL and would be a concern
to the Lower Creek and then determine whether the POTW monitors or limits copper for the
industries.
Please remember it is the responsibility of the POTW to continue efforts to ensure that any Significant
Industrial Users (SIUs), as defined by NCAC 15A 2H .0903(b)(33) (A) through (D), are identified and
subsequently added to the City's pretreatment program. This includes evaluation of new IUs before
they commence discharge and evaluation of existing IUs determined to be not SIUs that make
changes to their process.
Next IWS Due Date: The IWS was conducted.in 2018. Your next updated IWS is due on August 1,
2023, unless conditions at the POTW change significantly and thus warrant an earlier submittal.
Thank you for your continued support of the Pretreatment Program. If you have any questions or
comments, please contact me at [phone] [email: [e-mail]] or Deborah Gore,
Unit Supervisor, at [phone] [email: [e-mail]].
vz/Len of r_iws_005
ec: Tim Heim, ARO
PERCS Unit
cc: Central Files (NC0023981)
Sincerely,
V
Vivien Zhong, PERCS Unit
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6apoNnanial Enr4Mmoutnl0ualtly
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1617
919.707.9000