NC0026573_PCI_20230920

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

September 20, 2023

Eli Self
Email: [e-mail]

SUBJECT: Pretreatment Compliance Inspection Report
Catawba River Pollution Control Facility
NPDES WW Permit No. NC0026573
Burke County

Dear Permittee:

The North Carolina Division of Water Resources conducted a Pretreatment Compliance Inspection (PCI)
of the Catawba River Pollution Control Facility on 8/25/2023. The PCI was conducted to verify that the
program is being managed and maintained in compliance with all Pretreatment regulations. The
findings and comments noted during this inspection are provided in the enclosed copy of the inspection
report entitled "Pretreatment 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 Melanie Kemp with the Water
Quality Regional Operations Section in the Asheville Regional Office at 828-296-4500 or via email at
[e-mail].

Sincerely,

Melanie Kemp, Environmental Specialist
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ

ATTACHMENTS: Pretreatment Compliance Inspection Report

Ec: LF, Tim Arney (Pretreatment Coordinator)
DocuSign Envelope ID: 68837060-211E-4FE6-AAD8-F2C737757AD5
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 NC0026573 23/08/25 P S31112171819 20
21 66
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ----------------------Reserved-------------------
3 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)
Catawba River Pollution Control Facility
1000 Vine Arden Rd
Morganton NC 28680
Entry Time/Date Permit Effective Date
Exit Time/Date Permit Expiration Date
01:00PM 23/08/25 22/09/01
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Timothy Ray Arney/ORC/828-438-5375/
Other Facility Data
04:00PM 23/08/25 27/02/28
Name, Address of Responsible Official/Title/Phone and Fax Number
Eli Self,PO Box 3448 Morganton NC 286559850/WWTP
Superintendent/828-438-5375/
Contacted
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Other
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/ - - /
Daniel J Boss DWR/ARO WQ/828-296-4658/
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: 68837060-211E-4FE6-AAD8-F2C737757AD5
9/20/2023
NPDES yr/mo/day
23/08/25
Inspection Type
P3111218
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Melanie Kemp and Daniel Boss, with the Asheville Regional Office, conducted a Pretreatment
Compliance Inspection (PCI) of the City of Morganton’s Pretreatment Program on August 25, 2023.
Tim Arney (Pretreatment Coordinator) and Eli Self (WWTP Superintendent) were present during the
inspection.
Overall, the program appears to be in compliance with Federal and State Pretreatment requirements.
The Morganton Pretreatment Program has three SIUs: Case Farms, UNIX, and Seiren. Paperwork
was readily accessible and organized.
During the file review, inspectors noted that the POTW would benefit from refining and enforcing the
policies set forth in the Enforcement Response Plan. Currently, there is no streamlined way to
generate penalty costs, and no records are kept on financial enforcements, they are simply added as
a charge on the user’s water utility bills. Additionally, the WWTP has had multiple limits violations in
2023. Further studies should be conducted to determine if industrial users are contributing to these
issues. If sampling frequencies or protocols need to be adjusted based on the findings, IUP’s should
be amended and submitted to the state for review/approval.
NC0026573 17 (Cont.)
Page#2
DocuSign Envelope ID: 68837060-211E-4FE6-AAD8-F2C737757AD5
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: Catawba River Pollution Control Facility
2. Control Authority Representative(s): Tim Arney
3. Title(s): Pretreatment Coordinator
4. Last Inspection Date: 09/08/2022 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: _______________________________ Are Milestone Dates Being Met? YES NO

ICIS CODING
Main Program Permit Number MM/DD/YY
| N | C | 0 | 0 | 2 | 6 | 5 | 7 | 3 | | 08 | 25 | 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? 0
11. Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi-Annual
Periods?
1
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)? 0
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?
BOD and TSS related to I&I, IU’s, and/or solids. WWTP is conducting an
engineering study to investigate issues.
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.)? Case and Unix (BOD and TSS LV’s potentially related)
If Yes, How are these Problems Being Addressed? Violation Notices
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: Unix; published for Public Notice
SNC for Reporting:
Not Published:
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 Added to LTMP/STMP? YES NO
If yes, which ones? Eliminated: Added:_______________________

DocuSign Envelope ID: 68837060-211E-4FE6-AAD8-F2C737757AD5
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) 12/29/2020 Yes No not approved Yes No
Industrial Waste Survey (IWS) 05/02/2022 Yes No 11/08/2022 Yes No 11/04/2027
Sewer Use Ordinance (SUO) 03/06/2013 Yes No 03/28/2013 Yes No
Enforcement Response Plan (ERP) 12/16/2019 Yes No 02/05/2020 Yes No
Long Term Monitoring Plan (LTMP) 02/28/2023 Yes No not approved Yes No
________________________________________________________________________________________________________________
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name 1. Case Farms 2. UNIX 3. Seiren
30. IUP Number 1098 4021 4002
31. Does File Contain Current Permit? Yes No Yes No Yes No
32. Permit Expiration Date 05/31/2025 04/19/2026 03/31/2027
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
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 Yes No Yes No
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: 68837060-211E-4FE6-AAD8-F2C737757AD5
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3
FILE REVIEW COMMENTS:
Overall, the Pretratment Program would benefit from further developing the Enforcement Response Plan. Currently, the Pretreatment
Coordinator sends penalty information to Brad Boris (Morganton Director of Water Resources) and department adds surcharges to water
utility bill. There is no streamlined way to generate penalty costs and no Penalty Assessment Notices or Proof of Collections are kept on
file. The Headworks Analysis and LTMP have been submitted to the state (proof provided), but approval letters have not been received by
City of Morganton.
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: The WWTP (NC0026573) has had multiple Limit Violations of BOD and TSS. The WWTP is conducting an engineering study to assess ways
in which they can mitigate the problem within the treatment process. Case Farms, which contributes approximately 1/3 of the WWTP’s total flow, may be
contributing to these issues and require improvement to their overall pretreatment process. Monthly sampling and flow recording procedures may not be
representative, and the Pretreatment Program should make efforts to investigate permit alterations.
Requirements: ______________________________________________________________________________________________
Recommendations: It is recommended that sampling frequency for Case Farms be increased to weekly or daily and that the POTW investigate installing
an off-site flow meter to collect flow readings. Additionally, the Enforcement Response Plan should be updated and refined so that industries, which may
be contributing to overall WWTP limit violations and deficiencies, are held accountable for non-compliance.
NOD: YES NO
NOV: YES NO
QNCR: YES NO
POTW Rating:
Satisfactory X Marginal UnSatisfactory
PCI COMPLETED BY: Melanie Kemp Daniel Boss DATE: 09/20/2023

DocuSign Envelope ID: 68837060-211E-4FE6-AAD8-F2C737757AD5