NC0020664_Pretreatmeant Compliance Inspection Report_20230821

SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED.

August 21, 2023

Scott Webber, Town Manager
Town of Spindale
Email: [e-mail]

SUBJECT: Compliance Inspection Report
Spindale WWTP
NPDES WW Permit No. NC0020664
Rutherford County

Dear Permittee:

The North Carolina Division of Water Resources conducted an inspection of the Spindale WWTP on
7/27/2023. This inspection was conducted to verify that the facility is operating in compliance with the
conditions and limitations specified in NPDES WW Permit No. NC0020664. The findings and comments
noted during this inspection are provided in the enclosed copy of the inspection report entitled
"Compliance Inspection Report".

There were no significant issues or findings noted during the inspection and therefore, a response to this
inspection report is not required.

If you should have any questions, please do not hesitate to contact Lauren Armeni with the Water
Quality Regional Operations Section in the Asheville Regional Office at 828-296-4667 or via email at
[e-mail].

Sincerely,

Lauren Armeni, Environmental Specialist II
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ

ATTACHMENTS: Inspection Report, Pretreatment Compliance Report

Ec: Laserfiche
Guy O’Connor (ORC)
DocuSign Envelope ID: 17173700-223E-41A3-928B-6CDEC1E3F27A
EPA
United States Environmental Protection Agency
Washington, D.C. 20460
Water Compliance Inspection Report
Form Approved.
OMB No. 2040-0057
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 N 52 NC0020664 23/07/27 P S31112171819 20
21 66
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ----------------------Reserved-------------------
N67707172 73 74 75 80
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
Spindale WWTP
Ecology St
Spindale NC 28160
Entry Time/Date Permit Effective Date
Exit Time/Date Permit Expiration Date
10:00AM 23/07/27 20/07/01
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Other Facility Data
12:00PM 23/07/27 24/07/31
Name, Address of Responsible Official/Title/Phone and Fax Number
Guy O'Connor,327 Ecology St Spindale NC 28160//828-286-3407/Contacted
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
Melanie Kemp DWR/ARO WQ/ - - /
Lauren E Armeni DWR/ARO WQ/828-296-4500/
Mara G Chamlee DWR/ARO WQ/828-296-4500/
Rachel Rose DWR/ARO WQ/828-296-4500/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#1
DocuSign Envelope ID: 17173700-223E-41A3-928B-6CDEC1E3F27A
8/18/2023
8/18/2023
8/18/2023
8/18/2023
8/21/2023
NPDES yr/mo/day
23/07/27
Inspection Type
P3111218
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Lauren Armeni, Melanie Kemp, Mara Chamlee, and Rachel Rose, with the Asheville Regional Office,
conducted a Pretreatment Compliance Inspection (PCI) of the Town of Spindale's Pretreatment
Program on July 27, 2023. Guy O'Connor (ORC) and Earl Wyss (WWTP Operator) were present
during the inspection.
Overall, the program appears to be in compliance with Federal and State Pretreatment requirements.
The Spindale Pretreatment Program has three SIUs, one of which is a CIU (Timken). The other two
IUs are Ultimate Textile and Manual Woodworkers. Paperwork was readily accessible and organized.
During the file review, inspectors noted that many of the laboratory detection limits for the sampling
data reviewed for both the industry and POTW were not low enough to meet the required laboratory
detection levels in the IUPs. It was noted that some of the labs were not using the correct methods.
Mr. O’Connor indicated that he would reach out to the laboratory they use for analysis, as well as to
the SIUs, to make sure all laboratories are aware of which methods/detection limits need to be used
moving forward. Some of the LTMP PQLs needed to be changed and Mr. O’Connor revised the LTMP
and sent it to the Pretreatment Unit for review.
NC0020664 17 (Cont.)
Page#2
DocuSign Envelope ID: 17173700-223E-41A3-928B-6CDEC1E3F27A
Permit:NC0020664
Inspection Date:07/27/2023
Owner - Facility:
Inspection Type:
Spindale WWTP
Pretreatment Compliance
Yes No NA NE
Page#3
DocuSign Envelope ID: 17173700-223E-41A3-928B-6CDEC1E3F27A
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1
NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT

BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)]
1. Control Authority (POTW) Name: Town of Spindale WWTP
2. Control Authority Representative(s): Guy O’Connor
3. Title(s): ORC
4. Last Inspection Date: 05/17/22 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: _______________________________ Are Milestone Dates Being Met? N/A YES NO

ICIS CODING
Main Program Permit Number MM/DD/YY
| N | C | 0 | 0 | 2 | 0 | 6 | 6 | 4 | | 07 | 27 | 23 |

7. Current Number Of Significant Industrial Users (SIUs)? 3
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?
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)? 1
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?
The daily minimum was not reached for pH for three days in July 2022. The
POTW has not had any issues with pH since.
YES NO

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?
YES NO
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)
SNC for Limits: None
SNC for Reporting: None
Not Published: None
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?

None

21. Are Any Permits or Civil Penalties Currently Under Adjudication? If Yes, Which
Ones?
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 Inspector, please verify yourself!
26. If NO to 23 - 26, list violations _______________________________________________________________________________
27. Should any Pollutants of Concern be Eliminated from or Ad ded to LTMP/STMP? YES NO
If yes, which ones? Eliminated: Added:_______________________

DocuSign Envelope ID: 17173700-223E-41A3-928B-6CDEC1E3F27A
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2
28. PRETREATMENT PROGRAM ELEMENTS REVIEW- Please review POTW files, verify POTW has copy of Program Element
in their files, complete with supporting documents and copy of PERCS Approval 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) 11/13/2020 Yes No 06/29/2022 Yes No 11/30/2024
Industrial Waste Survey (IWS) 01/03/2019 Yes No 01/10/2019 Yes No 12/31/2023
Sewer Use Ordinance (SUO) 12/31/2012 Yes No 01/09/2014 Yes No
Enforcement Response Plan (ERP) 01/22/2020 Yes No 02/12/2020 Yes No
Long Term Monitoring Plan (LTMP) 07/27/2023 Yes No Yes No
________________________________________________________________________________________________________________
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name 1. Ultimate Textile 2. Manual Woodworkers 3. Timken
30. IUP Number 008 003 004
31. Does File Contain Current Permit? Yes No Yes No Yes No
32. Permit Expiration Date 09/01/27 09/01/27 09/01/27
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A N/A N/A 433.17
34. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
Yes No Yes No Yes No
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?
b. If No, is One Needed? (See Inspection Form from POTW)
a. Yes No
b. Yes No
a. Yes No
b. Yes No
a. Yes No
b. Yes No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
Organic Management Plan (TOMP)?
Yes No N/A Yes No N/A Yes No N/A
38. a. Does File Contain Original Permit Review Letter from the Division?
b. All Issues Resolved?
a. Yes No
b.Yes No N/A
a. Yes No
b.Yes No N/A
a. Yes No
b.Yes No N/A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
its Sampling as Required by IUP, including flow?
Yes No Yes No Yes No
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
Sampling as Required by IUP, including flow?
Yes No N/A Yes No N/A Yes No N/A
41b. During the Most Recent Semi-Annual Period, Did SIU submit all reports
on time?
Yes No N/A Yes No N/A Yes No N/A
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
file include process/dilution flows as Required by IUP?
Yes No N/A Yes No N/A Yes No N/A
42b. For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
Yes No N/A Yes No N/A Yes No N/A
43a. During the Most Recent Semi-Annual Period, Did the POTW Identify
All Limits Non-Compliance from Both POTW and SIU Sampling?
Yes No
N/A
Yes No
N/A
Yes No
N/A
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Reporting Non-Compliance from SIU Sampling?
Yes No N/A Yes No N/A Yes No N/A
44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
Monitoring Violations?
b. Did Industry Resample and submit results to POTW Within 30 Days?
c. If applicable, Did POTW resample within 30 days of becoming aware
of SIU limit violations in the POTW’s sampling of the SIU?
a.Yes No N/A

b.Yes No N/A

c.Yes No N/A
a.Yes No N/A

b.Yes No N/A

c.Yes No N/A
a.Yes No N/A

b.Yes No N/A

c.Yes No N/A
46. During the Most Recent Semi -Annual Period, Was the SIU in SNC? Yes No Yes No 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 No N/A Yes No N/A Yes No N/A
48. Does the File Contain Penalty Assessment Notices? Yes No N/A Yes No N/A 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 No Yes No Yes No

DocuSign Envelope ID: 17173700-223E-41A3-928B-6CDEC1E3F27A
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3
FILE REVIEW COMMENTS:
During the file review, inspectors noted that many of the laboratory detection limits for the sampling data reviewed for both the industry
and POTW were not low enough to meet the required laboratory detection levels in the IUPs. It was also noted that some of the labs were
not using the correct methods. Mr. O’Connor indicated that he would reach out to the laboratory they use for analysis, as wel l as to the SIUs,
to make sure all laboratories are aware of which methods/detection limits need to be used moving forward. Some of the LTMP PQLs needed
to be changed and Mr. O’Connor revised the LTMP and sent it to the Pretreatment Unit for review.

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: Overall, all of the requested information was readily available and organized, and all questions during the inspecti on were
answered.
Requirements: The IWS is due in December 2023. All laboratories used for POTW and SIU sampling analyses need to be made aware of
the required laboratory detection levels on the IUPs.
Recommendations: ____________________________________________________________________________________________
__________________________________________________________________________________________________________
NOD: YES NO
NOV: YES NO
QNCR: YES NO
POTW Rating:
Satisfactory X Marginal UnSatisfactory
PCI COMPLETED BY: Lauren Armeni DATE: _07/27/2022____________________________________
DocuSign Envelope ID: 17173700-223E-41A3-928B-6CDEC1E3F27A