NC0023981_NOD2023PC0237_PCI_20230925 (2)

DocuSign Envelope ID: 40BF3B71-BOF8-4190-9C24-6C8493E65ECO
ROY COOPER
Goeernor
ELIZABETH S. B1SER
Secrerary
RiCHARD E. ROGERS, JR.
Director
rWp� i
NORTH CAROLINA
Environmental Quality
SENT VIA ELECTRONIC MAIL ONL Y.- NO HARD COPY WILL BE MAILED
October 9, 2023
Radford L Thomas, Director of Public Utilities
City of Lenoir
Email: [e-mail]
SUBJECT: NOTICE OF DEFICIENCY
Tracking Number: NOD-2023-PC-0237
Permit No. NCO023981
Lower Creek WWTP
Caldwell County
Dear Permittee:
The North Carolina Division of Water Resources conducted a Pretreatment Compliance Inspection of the
Lower Creek WWTP on September 25, 2023. This inspection was conducted to verify that the facility is operating
in compliance with the conditions and limitations specified in NPDES WW Permit No. NC0023981. The purpose
of the inspection was to verify the program is being managed and maintained in compliance with all
Pretreatment regulations. Please see the enclosed Pretreatment Compliance Inspection form for more
detailed information about the inspection.
The Pretreatment Compliance inspection was conducted by Division of Water Resources staff from the Asheville
Regional Office. The following deficiency(s) was noted during the inspection:
Inspection Area Description of Deficiency
Pretreatment Semi-annual samples had IUP parameters #7-9 missing for Exela Augusta (IUP 0020).
o m' D+ North lk Rt io Degartc enl0f EnriS Rgh lal 70 1l l Division at rih C Resources
M1she'+ilk Regional Office 120'10 US -Highway 70 I Swannaraa, North Catalina 28778
62&296.9590

DocuSign Envelope ID: 40BF3B71-BOF8-4190-9C24-6C8493E65EC0
Remedial actions should have already been taken to correct this problem and prevent further occurrences in the
future. The Division of Water Resources may pursue enforcement action for this and any additional violations of
State law. To prevent further action, carefully review these deficiencies and address the causes of
non-compliance to prevent the recurrence of similar situations.
If you should have any questions, please do not hesitate to contact Rachel Rose with the Water Quality
Regional Operations Section in the Asheville Regional Office at 828-296-4500.
Sincerely,
DocuSigned by:
LV Awtt b6ss
E397192DABFB4FF...
Daniel Boss, Assistant Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS: Inspection Report/PCI Form
Ec: Laserfiche
Lisa Triplett (Pretreatment Coordinator)
o m' D+ North lk Rt io Degartc enl0f EnriS Rgh lal Qva1 OivlsfonNorih Cr Resources
M1she'+ilk Regional Office 121110 U Highway 70 I Swannaraa,North Carolina 28778
62&29649 0

DocuSign Envelope ID: 40BF3B71-BOF8-4190-9C24-6C8493E65EC0
United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040-0057
Water Compliance Inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 IN 1 2 u 3 I NC0023981 I11 121 23/09/25 I17
18I D I 19 I s I 20L]
21111I I I I I I I II I I I I I I I I I I I I I I I I I
I I I I I I II I I I I I r6
Inspection
Work Days Facility Self -Monitoring Evaluation Rating B1 QA
---------------------- Reserved -------------------
67
I 72 I n, I
701� I 711 LL -1
LJ
71 I 74 79 I I I I I I I80
I I
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES permit Number)
10:OOAM 23/09/25
21/08/01
Lower Creek WWTP
1905 Broadland Rd
Exit Time/Date
Permit Expiration Date
Lenoir NC 28645
01:OOPM 23/09/25
26/02/28
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Elisa Robbins Triplett/ORC/828-757-2198/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Elisa Robbins Triplett,PO Box 958 Lenoir NC 286450958//828-757-4462/
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Pretreatment
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers
Date
Lauren EArmeni EzDWR/ARO WQ/828-296-4500/
10/9/2023
Mara G Chamlee Mmra DWR/ARO WQ/828-296-4500/
C�o
10/9/2023
Rachel Rose =ss.aesA- DWR/ARO WQ/828-296-4500/
10/9/2023
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers
Date
D 5'g 11,:
E
10/9/2023
AAn.tt,�,e�bSS
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

DocuSign Envelope ID: 40BF3B71-BOF8-4190-9C24-6C8493E65EC0
NPDES yr/mo/day Inspection Type (Cont.)
NC0023981 I11 12I 23/09/25 117 18 1 p I
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Rachel Rose, Lauren Armeni, and Mara Chamlee, with the Asheville Regional Office, conducted a
Pretreatment Compliance Inspection (PCI) of the City of Lenoir's Pretreatment Program on
September 25, 2023. Lisa Triplett (Pretreatment Coordinator) and Donnie Hawkins (WWTP ORC)
were present during the inspection.
Overall, the program is marginally in compliance with Federal and State Pretreatment requirements.
The City of Lenoir Pretreatment program is split between Lower Creek WWTP (NPDES Permit No.
NC0023981) & Gunpowder Creek WWTP (NPDES Permit No. NC0023736). Lower Creek has three
Significant Industrial Users (SIU), all of which are Categorical Industrial Users (CIU). Gunpowder
Creek has two SIUs with no CIUs. See the attached PCI form for file review comments and
recommendations.
The following was noted during the file review:
When reviewing the lab data results for the LTMP sampling, it was noted that As, Cd, Se, and TKN
reporting limits were above the recommended laboratory detection limits listed on Exela Augusta's
IUP. Additionally, the reporting limit for CN was missing on the lab data results. It is recommended to
have the POTW send a copy of each industry's IUP to the lab they use for analyses, and it is
recommended to each industry that they do the same for the labs they use. The POTW samples for
the SIU, Exela Augusta, but the new permits will include industry sampling in addition to the POTW
sampling.
The following deficiency was noted during the inspection:
1. The lab results for the Exela Augusta samples showed the IUP parameters #7-9 were not sampled
for during the January -July 2023 semi-annual sampling period.
Page#

DocuSign Envelope ID: 40BF3B71-BOF8-4190-9C24-6C8493E65ECO
NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
Water Resources
ENVIRONMENTAL OVAL I TY
BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)l
1. Control Authority (POTW) Name: Gunpowder Creek WWTP & Lower Creek WWTP
2. Control Authority Representative(s): Lisa Triplett
3. Title(s): Pretreatment Coordinator & Wastewater Treatment Plant Superintendent
4. Last Inspection Date: 08/02/2022 Inspection Type (Check One): ❑ 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:
ICIS CODING
Main Program Permit Number
NIC10 Io 121 3191 gill
MM/DD/YY
1 09 125 123
Are Milestone Dates Being Met? ❑ YES ❑ NO ® NA
7. Current Number Of Significant Industrial Users (SIUs)?
5
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 ?
3
16. Number of 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?
Lower Creek had isolated Fecal Coliform and Copper exceedances in
September 2022 and an isolated ammonia exceedance in January 2023.
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.)? The pump station that receives wastewater from
BeoCare has had issues with clogging due to fibers getting through their
pretreatment system.
If Yes, How are these Problems Being Addressed? The POTW has worked with
BeoCare to eliminate the fibers, and BeoCare has put screens into their
pretreatment system to screen out the fibers.
19. Which Industries have been in SNC for Limits or Reporting during LENot
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?
® YES ❑ NO
® YES ❑ NO
Limits: 0
Reporting: 0
,lished: 0
0
❑ YES ® NO
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1

DocuSign Envelope ID: 40BF3B71-BOF8-4190-9C24-6C8493E65ECO
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 Inspector, please verify yourself!
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. complete with suDDortina documents and conv 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)
12/22/2022
❑ Yes ® No
Not approved yet
❑ Yes ® No
Industrial Waste Survey IWS
08/08/2018
® Yes ❑ No
11/30/2018
® Yes ❑ No
08/01/2023
Sewer Use Ordinance SUO
10/11/2012
® Yes ❑ No
11/08/2012
® Yes ❑ No
Enforcement Response Plan ERP
05/28/2020
® Yes ❑ No
08/18/2020
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
1 10/21/2004
® Yes ❑ No
10/29/2004
® Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name
1. Exela Augusta 2.
3.
30. IUP Number
0020
31. Does File Contain Current Permit?
® Yes ❑ No
❑
Yes ❑ NoI
❑ Yes ❑ No
32. Permit Expiration Date
09/10/2028
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
439.1)
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?
® 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. ❑Yes ®No
b. []Yes []No
b. ❑Yes ❑No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
0Yes0No19
❑Yes❑No❑N/A
❑Yes❑No❑N/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?
EN/A
b.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
b. ❑ Ycs ❑No®N/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?
® Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
41. During the Most Recent Semi -Annual Period, Did the SIU Complete its
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
Sampling as Required b IUP, includingflow?
41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports
❑Yes❑No[D
❑Yes❑No❑N/A
❑Yes❑No❑N/A
on time?
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
®Yes❑No❑N/A7��
❑N/A
❑Yes❑No❑N/A
file include process/dilution flows as Required b IUP?
42b. For categorical IUs with Production based limits, does file include
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
production rates and/or flows as Required by IUP?
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑No®N/A
❑ Yes ❑ No
❑ Yes ❑ No
All Limits Non -Compliance from Both POTW and SIU Sampling?
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑NoON/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
All Reporting_Non-Compliance from SIU Sampling?
44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
a.❑Yes❑NosN/A
a.❑Yes❑No❑N/A
a.❑Yes❑No❑N/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 within 30 days of becoming aware
c.❑Yes❑No®N/A
of SIU limit violations in the POTW's sampling of the SIU?
c.❑Yes❑No❑N/A
c.❑Yes❑No❑N/A
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

DocuSign Envelope ID: 40BF3B71-BOF8-4190-9C24-6C8493E65ECO
46. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
❑
Yes
®
No
❑
Yes
❑
No 11
❑
Yes
❑
No
47. During the Most Recent Semi -Annual Period, Was Enforcement Taken
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
❑Yes❑NolZl
❑Yes❑No❑N/A
❑Yes❑No❑N/A
48. Does the File Contain Penalty Assessment Notices?
I ❑Yes❑No®N/A
EffesoNoEl
I ❑Yes❑No❑N/A
49. Does The File Contain Proof Of Penalty Collection?
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
50. a. Does the File Contain Any Current Enforcement Orders?
b. Is SIU in Compliance with Order?
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
51. Did the POTW Representative Have Difficulty in Obtaining Any of This
Requested Information For You?
❑ Yes ® nFMTes
❑ No
❑ Yes ❑ No
FILE REVIEW COMMENTS:
When reviewing the lab data results for the LTMP sampling, it was noted that As, Cd, Se, and TKN reporting limits were above
the recommended laboratory detection limits listed on Exela Augusta's IUP. Additionally, the reporting limit for CN was missing
on the lab data results. It is recommended to have the POTW send a copy of each industry's IUP to the lab they use for analyses,
and it is recommended to each industry that they do the same for the labs they use.
The POTW samples for the SIU, Exela Augusta, but the new permit will include industry sampling in addition to the POTW
sampling. The lab results for the Exela Augusta samples showed the IUP parameters #7-9 were not sampled for the January -July
2023 semi-annual sampling period.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
f NBC 1 0 1 0 1 2 1 3 1 9 1 8 1 1 1 1 09 1 25 1 23 1
1. Industry Inspected: BeoCare Inc.
2. Industry Address: 1905 International Blvd
3. Type of Industry/Product: Medical hosier)
4. Industry Contact: William Miller Title: Maintenance Manager
Phone: [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 EYES ❑ NO
B. Plant Tour ® YES ❑ NO
C. Pretreatment Tour ® YES ❑ NO
D. Sampling Review EYES ❑ NO
E. Exit Interview ® YES ❑ NO
Industrial Inspection Comments:
On September 11, 2023, BeoCare installed mesh screens in a holding tank that collects the industrial wastewater effluent to help
with the fiber clogging issue. The mesh screens are cleaned & checked weekly. The POTW suggested to annually check the secondary
holding tank that is positioned after the screened effluent. The POTW suspected that the debris buildup from the secondary holding
tank could have been the cause of clogging issue at the nearby pump station. Since these mesh screens were recently installed, they
will observe the pump station and see if the issue is resolved. The POTW went over that the SIU will be sampling in addition to the
POTW starting in 2024.
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3

DocuSign Envelope ID: 40BF3B71-BOF8-4190-9C24-6C8493E65EC0
Many 55-gallon drums were not stored on secondary containment pallets which could lead to chemicals reaching the collection
system. It is recommended to have BeoCare store all 55-gallon drums and other totes with chemicals on approved secondary
containment pallets.
OVERALL SUMMARY AND COMMENTS:
Comments:
Requirements:
Recommendations: It is recommended for the POTW to have a dedicated pretreatment coordinator to allow more time &
organization for the program. Additionally, it is recommended to not sample on the last day of the semi-annual sampling period to
allow more time to sample if parameters are missed.
NOD: ® YES ❑ NO
NOV: ❑ YES ❑ NO
QNCR: ❑ YES ❑ NO
POTW Ratine:
Satisfactory Marginal X Unsatisfactory
PCI COMPLETED BY: Lauren Armeni, Rachel Rose, and Mara Chamlee DATE: 09/25/23
^pg �os DI
Il( �a A,
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 4