NC0021156_Inspection_20231120

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Jonathan Wilson, Utilities Director
City of Mount Holly
Post Office Box 406
Mount Holly, North Carolina 28120
SUBJECT: Pretreatment Audit Inspection
City of Mount Holly
NPDES Permit No. NCO021156
Gaston County
Dear Mr. Wilson:
NORTH CAROLINA
Environmental Quality
November 20, 2023
Enclosed is a copy of the Pretreatment Audit Inspection (PAI) Report for the inspection of the City of Mount Holly's
Industrial Pretreatment Program on November 16, 2023, by Mr. Wes Bell of this Office. Please advise the Pretreatment staff of
our findings by forwarding the enclosed corrected report. This Office would like to thank all Pretreatment staff for their
cooperation and the assistance provided during the inspection.
Should you have any questions concerning this report, please do not hesitate to contact Mr. Bell at [phone] or at
wes.bell(a,deq.nc. gov.
Sincerely,
EA
DocuSigned by:
�•�Guw N Pam►
F161 FB69A2D84A3...
Andrew H. Pitner, P.G.
Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
Enclosure: Inspection Report
Cc: NPDES Program Files - Laserfiche
DEQ�
North Carolina Department of Environmental Quality I Division of Water Resources
Mooresville Regional Office 1 610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115
704.663.1699

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT AUDIT REPORT
Background Information:
1. Control Authority (POTW) Name: City of Mt. Holly
2. Control Authority Representative(s): Keith Lynch, Nadine Blackwell
3. Title(s): Pretreatment Coordinator, Consultant
4. Address of POTW:
Street/Post Office Box Post Office Box 406
City/State/Zip Code Mt. Holly, NC 28120
Phone Number: [phone] Fax Number: [phone] E-Mail: [e-mail]
[phone] [phone] [e-mail]
5. Audit Date: 11/16/23
6. Last Inspection Date: 1/12/23 Inspection Type: ® PCI ❑ Audit
7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s) ? ® Yes ❑ No
If No, Explain.
8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? ® Yes ❑ No
If Yes, Explain. A weekly average effluent fecal coliform violation was reported in December 2022.
9. Is POTW under an Order That Includes Pretreatment Conditions? ❑ Yes ® No
Order Type and Number: Are Milestone Dates Being Met? ❑ Yes ❑ No ® NA
Parameters Covered Under Order
ICIS Coding:
Main Program Permit Number
INIC1010I2 I1 I1 Is I6 1
MM/DD/YY
11 I16 I23
10. Current Number of Significant Industrial Users (SIDS)?
....................................................................................................................................................................................................................................................................................................
3
11. Number of SIUs with No IUP, or with an Expired IUP
....................................................................................................................................................................................................................................................................................................
0
12. Number of SIUs Not Inspected by POTW in Last Calendar Year?
....................................................................................................................................................................................................................................................................................................
0
13. Number of SIUs Not Sampled by POTW in Last Calendar Year?
....................................................................................................................................................................................................................................................................................................
0
14. Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi -Annual Periods
....................................................................................................................................................................................................................................................................................................
0
15. Number of SIUs in SNC for Reporting During Either of Last 2 Semi -Annual Periods
....................................................................................................................................................................................................................................................................................................
0
16. Number of SIUs in SNC with Pretreatment Schedules?
....................................................................................................................................................................................................................................................................................................
0
17. Number of SIUs on Schedules?
....................................................................................................................................................................................................................................................................................................
1
18. Current Number of Categorical Industrial Users (CIUS)?
2
19. Number of CIUs in SNC?
0
NC DWR Pretreatment Audit Form Revised: July 25, 2007
Page 1

21. PRETREATMENT PROGRAM ELEMENTS REVIEW
Program Element:
NCO021156
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
3/28/19
® Yes ❑ No
6/24/19
® Yes ❑ No
4/1/24
Industrial Waste Survey (IWS)
7/28/22
® Yes ❑ No
8/10/22
® Yes ❑ No
8/10/27
Sewer Use Ordinance (SUO)
2/22/22
® Yes ❑ No
1/14/13
® Yes ❑ No
Enforcement Response Plan (ERP)
2/22/22
® Yes ❑ No
2/14/20
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
3/30/16
® Yes ❑ No
5/4/16
® Yes ❑ No
Legal Authority (Sewer Use Ordinance-SUO)
22. Do you have any towns and/or areas from which you receive wastewater which are not in your annexed jurisdiction?
❑ Yes ® No If yes, Please list these towns and/or areas.
23. If yes to #22, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? ❑ Yes ❑ No ® NA
A copy, if not already submitted, should be sent to Division.
24. If yes to #22, Have you had any trouble working with these towns or districts? ❑ Yes ❑ No ® NA
If yes, Explain.
25. Date of Last SUO Adoption by Local Council 9/13/21
26. Have you had any problems interpreting or enforcing any part of the SUO? ❑ Yes ® No
If yes, Explain.
Enforcement (Enforcement Response Plan-ERP)
27. Did you send a copy of the ERP to your industries? ® Yes ❑ No
If no, POTW must send copy within 30 days.
28. Have you had any problems interpreting or enforcing any part of the ERP (i.e. any adjudication, improper enforcement, etc?
❑ Yes ® No If yes, Explain.
29. List Industries under a Schedule or Order and Type of Schedule or Order
A&E is currently under a Consent Order.
Resources
30. Please Rate the Following: S=Satisfactory M=Marginal U=Unsatisfactory
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
®S ❑M ❑U
Access to POTW Vehicles for
Sampling, Inspections, and
®S ❑M ❑U
Emergencies
Access to Operable Sampling
Equipment
❑S ❑M ❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
®S ❑M ❑U
Reference Materials
®S ❑M ❑U
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
®S ❑M ❑U
Computer Equipment (Hardware and
Software)
®S ❑M ❑U
NC DWR Pretreatment Audit Form Revised: July 25, 2007 Page 2

31. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No
Explain Yes or No. Excel Spreadsheets, electronic compliance tracking and compliance judgement.
32. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain. The SIUs are billed to recover
Pretreatment/sampling costs.
Public Perception/ Participation:
33. Are there any local issues affecting the pretreatment program (e.g.. odor, plant closing, new or proposed plants)?
❑ Yes ® No If yes, Explain. Current projections dictate that the City's WWTP will be connected to the Charlotte Water
sewer system by the Fall of 2024. Note: The City will continue to implement the Industrial Pretreatment Program.
34. Has any one from the public ever requested to review pretreatment program files? ❑ Yes ® No
If yes, Explain procedure. If no, How would the request be addressed? The written request would be made to the City Manager
and/or Utility Director and the Pretreatment Coordinator would be involved in the scheduling and oversight of the file
review. The file review would take place at the City's Public Works building and/or City Hall.
35. Has any industry ever requested that certain information remain confidential from the public? ❑ Yes ® No If yes, Explain
procedure for determining whether information qualified for confidential status, as well as procedure for keeping files confidential
from public. If no. how would the request be addressed? The request would have to be made in writing to the City Manager
and/or Utility Director and the information would be reviewed by the Pretreatment Coordinator/Consultant. Confidential
files would be kept in a locked file cabinet and locked office.
36. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? ® Yes ❑ No
37. Is the public notified about changes in the SUO or Local Limits? ® Yes ❑ No
38. Were all industries in SNC published in the last notice? ❑ Yes ❑ No ® NA
Permitting (Industrial Waste Survey-IWS):
39a... How does the POTW become aware of new or changed Users? The City's Planning Department forwards all
applications for new businesses, etc. to the Pretreatment Coordinator.
39b. Once the POTW becomes aware of new or changed Users, how does the POTW determine which industries have the
reasonable potential to adversely impact the WWTP and therefore require a new permit or a permit revision? (Who is an
SIU?) Information on the IWS form is reviewed for wastewater characteristics, flow volumes, POCs, categorical
determinations, and other potential impacts to WWTP.
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
❑Yes ®No If Yes, How many are there?
Please list each site and how it is permitted, if applicable.
41. Does the POTW accept waste by (mark if applicable) ❑ Truck ❑Dedicated Pipe ® NA
42. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples drawn,
manifests required) No trucked waste is accepted (including septage haulers).
43. How does the POTW allocate its loading to industries? Mark all that apply
❑ Uniform Limits ® Historical Industry Need ❑ By Surcharge ® Categorical Limits ❑ Other
Explain Other:
44. Review POTW's copies of current allocation tables for each WWTP. Are there any over allocations? ❑ Yes ® No
If yes, What parameters are over allocated?
45. If yes to #44, What is being done to address the over allocations? (short-term IUPs, HWA to be revised, pollutant study, etc.)
TN permit limit (seasonal loading) became effective April 1, 2017 and TP yearly loading limit became effective January 1, 2015.
46. Does the POTW keep pollutant loading in reserve for future growth / safety? ® Yes ❑ No
If yes, what percentage of each parameter? 10%
47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) ❑ Yes ❑ No
If yes, Explain. A&E and Daimler both contested their IUPs due to TN and TP limits. New IUPs were agreed upon and
A&E was placed under a Consent Order for construction of new pretreatment facilities.
NC DWR Pretreatment Audit Form Revised: July 25, 2007 Page 3

48. How does the POTW decide on which pollutants to limit in the permits? Monitor for? (for example: were only those pollutants
listed on the application limited; categorical parameters; NPDES Pollutants of Concern) Categorical parameters, POCs 5%
MAHL, NPDES POCs, potential impacts to WWTP.
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
New SIUs monitors conventionals monthly and metals quarterly. Monitoring frequencies for metals can be adjusted to
semi-annual (at a minimum) based on the discharge data.
Permit Compliance:
50. Does the POTW currently have or during the past year had any permits under adjudication? ❑ Yes ® No
If yes, which industries? What was (will be) the outcome of the adjudication?
51. Demonstrate how the POTW judges compliance. This should include compliance judgment on all violations of limits, reporting
requirements, and permit conditions, as well as for SNC. Compliance judgement per comprehensive guidance, violations (limit,
monitoring, reporting, permit conditions, etc.) are addressed per ERP.
52. Does the POTW use the Division's model inspection form or equivalent? ® Yes ❑ No
If no, does the POTW form include all DWQ data? ❑ Yes ❑ No
53. Were all SIUs evaluated for the need of a slug/spill control plan during their most recent inspections? ® Yes ❑ No
If no, Explain.
54. What criteria are used to determine if a slug/spill control plan is needed?
All current SIUs are required to develop and submit a slug/spill control plan. Criteria includes evaluations of the potential
pathways spills, etc. can enter the sewer system and impact the City's collection and wastewater treatment systems.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Pretreatment staff use a checklist (also given to SIUs) that includes the following criteria: contacts are up to date, adequate
emergency notification procedures, presence of emergency response equipment, proper secondary containment, employee
training, identification of authorized personnel to stop production/operations
56. How does the POTW decide where the sample point for an SIU should be located?
Categorical — categorical and combined waste streams are both monitored. Non -categorical — pretreatment system effluent
preferred.
57. Has the POTW established a procedure to ensure that representative samples will be taken by the POTW or SIU each time?
(example: correct location; proper programming of sampler; clean equipment; swirling the sample bucket uniformly)
POTW: ® Yes ❑ No SIU: ® Yes ❑ No If yes, Explain. Sampling SOPS and manuals, contract lab
performs sampling for POTW and SIUs.
58. Who performs sample analysis for the POTW for Metals Pace Analytical Services
Conventional Parameters Pace Analytical Services
Organics Pace Analytical Services
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
POTW and SIUs both use contract lab's COC.
Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis (HWA):
60a.
60b.
60c.
60d.
60e.
60f.
Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑ NO
Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ® YES ❑ NO
Is LTMP/STMP Data Maintained in Table or Equivalent? ® YES ❑ NO Is Table Adequate? ® YES ❑ NO
All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? ® YES ❑ NO DWQ Inspector, verify yourself!
If NO to any above, list violations
Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ® NO
If yes, which ones? Eliminated: Added:
61. Do you complete your own headworks analysis (HWA) ? ❑ Yes ® No
If no, Who completes your HWA? Nadine Blackwell, Suez, Inc. Phone [phone]
62. Do you have plans to revise your HWA in the near future? ❑ Yes ® No
NC DWR Pretreatment Audit Form Revised: July 25, 2007 Page 4

If yes, What is the reason for the revision? (mark all that apply) ❑Increased average flow ❑NPDES limits change
❑More LTMP data available ❑Resolve over allocation ❑5 year expiration ❑Other, explain.
63. In general, what is the most limiting criteria of your HWA?
❑Inhibition ❑ Pass Through ®Sludge Quality
64. Do you see any way to increase your loading in the future (Example: obtaining more land for sludge disposal)? ❑ Yes ❑ No
Explain. N/A
Summary:
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
All influent will be connected to Charlotte Water's sewer system by Fall of 2024. The City's ERP and SUO were modified
to include Charlotte Water's additional criteria.
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW:
66. User Name
1. Daimler Trucks NA
2. Clariant Corp.
3. American & Efird
67. IUP Number
1163
1158
1157
68. Does File Contain Current Permit?
® Yes ❑
I ® Yes ❑ No
® Yes ❑ No
69. Permit Expiration Date
12/31/27
1 12/31/27
22/31/27
70. Categorical Standard Applied I.E. 40 CFR, Etc. Or N/A
1 433
414 & 455
410
71. Does File Contain Permit Application Completed Within One Year Prior
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
to Permit Issue Date?
72. Does File Contain Inspection Completed Within Last Calendar Year?
® Yes ❑ No
®Yes ❑ No 11
® Yes ❑ No
73. a. Does File Contain 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
74. 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 ?
75. a. Does File Contain Original Permit Review Letter from Division?
. ®Yes ❑No
Fb
a. ®Yes ❑No
a. ®Yes ❑No
b. All Issues Resolved?
.❑Yes❑NosN/A
b.❑Yes❑NosN/A
b.❑Yes❑NosN/A
76. During Most Recent Semi -Annual Period, Did POTW Complete its
® Yes ❑ No
®Yes ❑ No
® Yes ❑ No
11
Sampling as Required b IUP, includingFlow?
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
78. During Most Recent Semi -Annual Period, Did SIU Complete its
®Yes❑No❑N/A
EYes❑No❑N/A
®Yes❑No❑N/A
Sampling as Required by IUP, including Flow?
79. During Most Recent Semi -Annual Period, Did SIU submit all reports on
EYes❑No❑N/A
EYes❑No❑N/A
EYes❑No❑N/A
time?
80a. 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?
80b. 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?
81. During Most Recent Semi -Annual Period, Did POTW Identify All
es❑No❑N/A
F5Y
❑Yes❑NoEN/A
EYes❑No❑N/A
Limits Non -Compliance from Both POTW and SIU Sampling?
82. During Most Recent Semi -Annual Period, Did POTW Identify All
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑NoEN/A
Re porting_Non-Compliance from SIU Sampling?
83. a. Was POTW Notified by SIU (Within 24 Hours) of All Self-
a.®Yes❑No❑N/A
a.❑Yes❑NosN/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❑NosN/A
b.❑Yes❑NosN/A
c. If applicable, did POTW resample and obtain results within 30 days of
c.❑Yes❑NosN/A
becomingaware of SIU limit violations in the POTW's sampling of SIU?
c.❑Yes❑No®N/A
c.❑Yes❑No®N/A
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
I
❑ Yes
®No
11
❑ Yes
® No
❑
Yes
®
No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
EYes❑No❑N/A
❑Yes❑NoEN/A
EYes❑No❑N/A
Specified in POTW's ERP (NOVs, Penalties, timing, etc.)?
86. Does File Contain Penalty Assessment Notices?
❑Yes❑NoEN/A
❑Yes❑NoEN/A
EYes❑No❑N/A
87. Does File Contain Proof Of Penalty Collection?
❑Yes❑NoEN/A
❑Yes❑NoEN/A
EYes❑No❑N/A
88. a. Does File Contain Any Current Enforcement Orders?
a.❑Yes❑NosN/A
❑e❑NosN/A
Fb.E1yYessE1No0N/A
a.❑Yes❑NosN/A
Fb-E:Yes[1No0N/A
b. Is SIU in Compliance with Order?
b.❑Yes❑NosN/A
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
❑Yes ®No
❑ Yes ®No
El Yes ®No
Information For You?
NC DWR Pretreatment Audit Form Revised: July 25, 2007 Page 5

FILE REVIEW COMMENTS:
72. POTW inspection dates: Daimler Trucks NA - 11/17/22; Clariant Corp. - 11/17/22; American & Efird - 11/22/22.
74. TTO sampling is performed in lieu of TOMP/Certification for Daimler.
78. American & Efird and Clariant both contract Pace Analytical Services to perform sampling and analyses. Daimler contracts
Waypoint Analytical to perform IUP sampling and analyses.
85. The City issued NOVs to Daimler for total nitrogen and total phosphorus limit violations in January and June 2023. A&E was also
issued NOVs and civil penalties for total nitrogen and total phosphorus limit violations in January, February and April 2023. Note:
Total nitrogen and total phosphorus are monitored (by both SIUs) monthly per IUP.
INDUSTRY INSPECTION PCS CODING:
Main Program Permit Number MM/DD/YY
N I C 10 10 12 1 1 1 1 15 16 11 116 23
1. Industry Inspected: Clariant
2. Industry Address/Mailing: 625 E. Catawba Avenue, Mt. Holly, NC 28120
3. Type of Industry/Product: OCPSF, Pesticide & Soap/Detergent Manufacturing/Specialty Chemicals (surfactants, insect
repellants, etc.)
4. Industry Contact: Lisa King Title: Environmental Specialist Phone: [phone]
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:
The facility operates 24/7 and currently has 150 employees. The facility can manufacture up to 1,000 different products. Off -spec
materials and non -hazardous waste are disposed by Univar. The pretreatment system includes equalization, pH neutralization,
biological aeration basins, chemical addition (nutrient, polymers, etc.), tertiary sand filtration, effluent holding tank, DAF, sludge
dewatering (screw press) and flow meter. Synagro has been contracted to land apply the sludge. Sludge can also be disposed at a
permitted landfill if the sludge does not meet land application criteria.
The facility's records were organized and well maintained.
SUMMARY AND COMMENTS:
It is recommended that the City develop a written guidance document for the public review of pretreatment files and the
review/approval of confidentiality requests.
The POTW's records were organized and well maintained. The POTW's Industrial Pretreatment Program was being properly
implemented.
NOD: ❑ Yes ® No
NC DWR Pretreatment Audit Form Revised: July 25, 2007 Page 6

NOV: ❑ Yes
QNCR: ❑ Yes
POTW Rating:
ffi
Satisfactory ® Marginal ❑ Unsatisfactory ❑
E�`,,96D90CC3437
uSignedd by:
24AUDIT COMPLETED BY: ... DATE: 11/20/2023
Wes Bell, Env. Specialist II, WQROS/DWR, Mooresville Regional Office
DocuSigned by:
EF161FB69A2D84A3
41-A v H P44." 11/20/2023
AUDIT REVIEWED BY: ... DATE:
Andrew H. Pitner, Regional Supervisor, WQROS/DWR, Mooresville Regional Office
NC DWR Pretreatment Audit Form Revised: July 25, 2007 Page 7