NC0024252_Inspection_20231204

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
CERTIFIED MAIL#: 7020 3160 0000 3283 0892
RETURN RECEIPT REQUESTED:
Brian Bradshaw
City of Conover
Post Office Box 549
Conover, North Carolina 28613
SUBJECT: Notice of Violation
Pretreatment Audit Inspection
City of Conover
NPDES Permit No. NCO024252
Catawba County
Tracking #: NOV-2022-PC-0595
Dear Mr. Bradshaw:
NORTH CAROLINA
Environmental Quality
December 4, 2023
Enclosed is a copy of the Pretreatment Audit Inspection (PAI) Report for the inspection of the City of Conover's
Industrial Pretreatment Program on November 21, 2023, by Mr. Wes Bell of this Office. This Office would like to thank all
staff in their cooperation and assistance provided throughout the inspection. Please advise the Pretreatment staff of our
findings by forwarding a copy of the enclosed report.
This report is being issued as a Notice of Violation (NOV) due to the City's failures to properly implement the Division -
approved Industrial Pretreatment Program. Specially, the City failed to do the following:
- Properly renew the Industrial User Permits (IUPs) for Hickory Springs and Engineered Controls International (ECI) prior
to their expiration dates;
- Submit the new draft IUPs for Hickory Springs and ECI to the Division for review 30 days prior to their effective dates;
- Initiate enforcement according to the Division -approved Enforcement Response Plan (ERP) for ECI's failures to submit
the May 2023 flow data and obtain prior approval to construct a new pretreatment system;
- Initiate enforcement according to the Division -approved Enforcement Response Plan (ERP) for Hickory Springs' failure
to submit a permit renewal application 180 days prior to the existing IUP's expiration date;
- Conduct SIU inspections in 2022;
- Submit a completed Industrial Waste Survey to the Division by October 1, 2022.
Q Q��
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
704.6631699

These failures are violations of North Carolina General Statute (G.S.) 143-215.1, 15A North Carolina Administrative Code
(NCAC) 2H .0900 and subject NPDES Permit. Please be advised that in accordance with G.S. 143-215.6A, a civil penalty
assessment of not more than twenty-five thousand dollars ($25,000.00), or twenty-five thousand dollars ($25,000.00) per day
when the violation is of a continuing nature, may be assessed against any person who violates or fails to act in accordance with
the terms, conditions, or requirements of any permit issued pursuant to G.S. 143-215.1.
It is requested that a written response be submitted to this Office by December 18, 2023, addressing the City's actions
to address all violations as discussed in more detail in the attached report. In addition, the City must submit a completed IWS
by March 1, 2024, and initiate enforcements to ECI and Hickory Springs, update and submit the 2022 PAR (PPS form and
Narrative), and submit the new ECI permit documentation all by December 29, 2023. In responding, please address your
comments to the attention of Mr. Bell. The response should also include a copy of the City's enforcement actions to ECI and
Hickory Springs.
Should you have any questions concerning this report, please do not hesitate to contact Mr. Bell at [phone] or at
wes.bellkdeq.nc. gov.
Enclosure: Inspection Report
Cc: NPDES Program Files - Laserfiche
Sincerely,
Docu Signed by:
F161 FB69A2D84A3...
Andrew H. Pitner, Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
QW
1\.ell�
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
704.6631699

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT AUDIT REPORT
Background Information:
1. Control Authority (POTW) Name: City of Conover
2. Control Authority Representative(s): Andrew Evans
3. Title(s): Pretreatment Coordinator
4. Address of POTW:
Street/Post Office Box Post Office Box 549
City/State/Zip Code Conover, NC 28613-0549
Phone Number: [phone] Work Cell: 828-443-7659 E-Mail: [e-mail]
5. Audit Date: 11/21/2023
6. Last Inspection Date: 01/11/2022 Inspection Type: ®PCI ❑ Audit
7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s) ? ❑ Yes ®No
If No, Explain. The City has not completed the Industrial Waste Survey (IWS) due 10/1/2022. The Pretreatment
Coordinator indicated that approximately 45 of the 80 industries have been surveyed. The organization and
retrieval of the required pretreatment documentation continues to need improvement.
8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? ® Yes ❑ No
If Yes, Explain. Monthly average effluent ammonia violations were reported in October 2022 and June and July
2023. The violations were attributed to the lack of adequate aeration. The lack of aeration was addressed by the
activation of an additional blower which in turn, no ammonia violations were reported since the July 2023
violation.
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 MM/DD/YY
NCO024252 11/21/23
10. Current Number of Significant Industrial Users (SIUS)?
.............................................
2
11. Number of SIUs with No IUP...or with an Expired IUP.................................................................................................................................
............................................................................................. r ..
0
12. Number of SlUs Not Inspected by POTW in. Last Calendar Year?
.......................................... ................................................................................................................................................................
2
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 Schedule?
....................................................................................................................................................................................................................................................................................................
0
17. Number of SIUs on Schedules?
....................................................................................................................................................................................................................................................................................................
0
18. Current Number of Categorical Industrial Users(CIUS�?............................................................................................
2
1
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:
NCO020401
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
NA
❑ Yes ❑ No
NA
❑ Yes ❑ No
NA
Industrial Waste Survey (IWS)
1/24/18
® Yes ❑ No
3/9/18
® Yes ❑ No
10/1/22
Sewer Use Ordinance (SUO)
1/15/13
® Yes ❑ No
4/2/13
® Yes ❑ No
Enforcement Response Plan (ERP)
7/2/15
® Yes ❑ No
8/19/15
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
NA
❑ Yes ❑ No
NA
❑ 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. Hickory (residential).
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 7/1/13
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
None
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
The City should investigate the incorporation off fees to recover SIU
Additional Sampling and/or Analysis
❑S ®M ❑U
sampling costs (at a minimum).
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, Microsoft applications.
32. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain. The City does not recover any
costs from their industries.
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.
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 request would be evaluated by the City's Utilities
Director (UD), Deputy UD and Pretreatment Coordinator. A review location would be determined (not at WWTP) on a
case -by -case basis.
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 be evaluated by the City's Utilities Director (UD),
Deputy UD and Pretreatment Coordinator. A locked cabinet and office are available for any confidential files.
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 UD and Deputy UD are members of the
SRC Committee that receives all new applications for industrial users from the City's Planning Department. An
IWS form would be sent to the industrial user if needed.
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
SILT?) IWS Long Form information, categorical processes, potential impacts to WWTP and volume of the process
wastewater being discharged.
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 and/or septage accepted.
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? Both SIUs discharge to the City of Newton, no over allocations.
45. If yes to #44, What is being done to address the over allocations? (short-term IUPs, HWA to be revised, pollutant study, etc.)
N/A
46. Does the POTW keep pollutant loading in reserve for future growth / safety? ❑ Yes ❑ No
If yes, what percentage of each parameter? N/A
47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) ❑ Yes ® No
If yes, Explain.
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, NPDES POCs,
SUO parameters
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
New SIUs — monthly monitoring with daily flow and pH to establish a baseline prior to a potential reduction of monitoring
based on results; Active SIUs — quarterly monitoring minimum.
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 Worksheet - SNC determinations; violations
(limit, monitoring, reporting, etc.) based on approved 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?
Both SIUs are required to develop and submit a slug/spill control plan. New SIUs — chemical storage practices, presence of
floor drains, secondary containment structures and pathway of spills to sewer system are all evaluated.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Contact information required to be updated, personnel listing and appropriate agencies for emergency notification,
authorized personnel to stop production/discharge, containment structures are in place and availability of spill response
equipment (spill kits, etc.).
56. How does the POTW decide where the sample point for an SIU should be located?
Representative of the process wastewater discharge and segregated from the domestic flow.
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. City - sampler manuals; SIUs - sampling
procedures evaluated during inspection.
58.Who performs sample analysis for the POTW for Metals - Water Tech Labs, Meritech Laboratories
Conventional Parameters - Water Tech Labs
Organics - Water Tech Labs, Meritech Laboratories
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
POTW and SIUs both use contracted laboratory's COC.
Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis (HWA): Not Applicable
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? N/A
62. Do you have plans to revise your HWA in the near future? ❑ Yes ❑ No N/A
If yes, What is the reason for the revision? (mark all that apply) ❑Increased average flow
❑NPDES limits change
NC DWR Pretreatment Audit Form Revised: July 25, 2007 Page 4

❑More LTMP data available ❑Resolve over allocation ❑5 year expiration ❑Other, explain.
63. In general, what is the most limiting criteria of your HWA? N/A
❑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 - the wastewater from both SIUs is conveyed to the City of Newton's WWTP. In addition, the City of Hickory
re -directed approximately 300,000 gallons of the flow (originally treated by the City of Conover) back into their own sewer
system.
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
Upgrades to the headworks and aeration system will be initiated in the Fall of 2024.
INDUSTRIAL USER PERMIT IUP FILE REVIEW:
66. User Name
1. Hickory Springs
2. Engineered Controls Int.
3
67. IUP Number
101HS
IO1J
68. Does File Contain Current Permit?
® Yes ❑ No
® Yes ❑ No
❑ Yes ❑ No
69. Permit Expiration Date
5/12/28
5/12/28
70. Categorical Standard Applied I.E. 40 CFR, Etc. Or N/A
1 433.1=1
433.17
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
❑ 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❑No❑N/A
®Yes❑No❑N/A
❑Yes❑No❑N/A
Organic Management Plan TOMP ?
75. a. Does File Contain Original Permit Review Letter from Division?
. ❑Yes NNo
Fb
a. []YesNNo
a. ❑Yes ❑No
b. All Issues Resolved?
.❑Yes❑No®N/A
b.❑Yes❑NoNN/A I
b.❑Yes❑No❑N/A
76. During Most Recent Semi -Annual Period, Did POTW Complete its
Yes ®No
F
®Yes ❑ No
ElYes ❑ No
Sampling as Required by IUP, including Flow?
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
® Yes ❑ No
® Yes
❑ -N-o-11
❑ Yes ❑ No
78. During Most Recent Semi -Annual Period, Did SIU Complete its
®Yes❑No❑N/A
®Yes❑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
NYes❑No❑N/A
❑YesNNo❑N/A
❑Yes❑No❑N/A
time?
80a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑NoNN/A
❑Yes❑NoNN/A
❑Yes❑No❑N/A
file include process/dilution flows as Required by IUP?
80b. For categorical IUs with Production based limits, does file include
❑Yes❑NoNN/A
❑Yes❑NoNN/A
❑Yes❑No❑N/A
production rates and/or flows as Required by IUP?
81. During Most Recent Semi -Annual Period, Did POTW Identify All
❑Yes❑NoNN/A
❑Yes❑NoNN/A
❑Yes❑No❑N/A
Limits Non -Compliance from Both POTW and SIU Sampling?
82. During Most Recent Semi -Annual Period, Did POTW Identify All
❑Yes❑NoNN/A
NYes❑No❑N/A
❑Yes❑No❑N/A
Reporting Non -Compliance from SIU Sampling?
83. a. Was POTW Notified by SIU (Within 24 Hours) of All Self-
a.❑Yes❑NoNN/A
a.❑Yes❑NoNN/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❑NoNN/A
b.❑Yes❑No❑N/A
c. If applicable, did POTW reample and obtain results within 30 days of
becomingaware of SIU limit violations in the POTW's sampling of SIU?
c.❑Yes❑NoNN/A
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
❑Yes❑NoNN/A
❑YesNNo❑N/A
❑Yes❑No❑N/A
Specified in POTW's ERP (NOVs, Penalties, timing, etc.)?
86. Does the File Contain Penalty Assessment Notices?
❑Yes❑NoNN/A
❑Yes❑NoNN/A
❑Yes❑No❑N/A
87. Does File Contain Proof Of Penalty Collection?
❑Yes❑NoNN/A
❑Yes❑NoNN/A
❑Yes❑No❑N/A
88. a. Does File Contain Any Current Enforcement Orders?
a.❑Yes❑NoNN/A
a.❑Yes❑NoNN/A
a.❑Yes❑No❑N/A
b. Is SIU in Compliance with Order?
b.❑Yes❑NoNN/A
b.❑Yes❑No®N/A
b.❑Yes❑No❑N/A
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
® Yes ❑
® Yes ❑ No
❑ Yes ❑ No
Information For You?
!IF
NC DWR Pretreatment Audit Form Revised: July 25, 2007 Page 5

FILE REVIEW COMMENTS:
1. Both SIUs are under the control of the City of Conover; however, their discharges are conveyed to the City of Newton's WWTP.
The City of Newton determines the appropriate limits based on the Newton WWTP HWA, available allocation, and NPDES and land
application concerns.
11. The Hickory Springs IUP had expired for approximately 6 months prior to renewal. The Engineered Controls International (ECI)
IUP had expired for approximately 11 days prior to renewal.
72. Hickory Springs and ECI were not inspected by the City in 2022.
75. The City failed to submit to the Division the draft IUPs for ECI and Hickory Springs within 30 days prior to both IUP's expiration
dates.
76/77. Hickory Springs has not reported a discharge since the end of February 2023. The City samples semi-annually and was not able
to secure a sample during the first half of 2023.
78. Hickory Springs and ECI both contract Pace Analytical Services to perform IUP analyses.
79. ECI failed to submit the May 2023 flow data.
82. The City issued a Notice of Violation (NOV) to ECI for a pH reporting violation (unauthorized sampling location) in February
2023.
85. The City failed to initiate enforcement according to the Division -approved ERP to ECI for the failures to submit the May 2023 flow
data, obtain approval prior to the construction of a new pretreatment system and submit a permit renewal application within 180 days
prior to the IUP expiration date. The City also failed to initiate enforcement to Hickory Springs for the failure to submit a permit
renewal application within 180 days prior to the IUP expiration date.
89. The City's record keeping system continues to need improvement.
INDUSTRY INSPECTION PCS CODING:
Main Program Permit Number MM/DD/YY
N I C 10 10 12 14 12 111 121 23
1. Industry Inspected: Engineered Controls International (REGO)
2. Industry Address: 911 Industrial Drive SW, Conover, NC 28613
3. Type of Industry/Product: Metal Finisher/LP Gas Regulators
4. Industry Contact: Tammy Isaacs Title: Clean Energy Solutions EHS Manager 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 manufactures LP gas regulators and operates two shifts, five days per week with approximately 57 employees.
The pretreatment system includes equalization, pH adjustment, chemical addition, metal precipitation (batch process), ion
exchange, filter press, and flow measurement. Dewatered sludge is disposed by World Resources.
ECI's on -site records were organized and well maintained.
NC DWR Pretreatment Audit Form Revised: July 25, 2007 Page 6

SUMMARY AND COMMENTS:
The City's Industrial Pretreatment Program has not been properly implemented. The annual 2022 SIU inspections were not performed
and the City failed to initiate enforcement according to the Division -approved ERP for ECI's failures to report May 2023 flow data and
obtain prior approval for a new pretreatment system, and ECI and Hickory Springs' failures to submit the permit renewal applications
within 180 days prior to the expiration dates of both IUPs. In addition, the City has failed to submit a completed IWS by the required
deadline of 10/1/2022. Record keeping deficiencies continue to be observed as in previous inspections.
Hickory Springs submitted a cover letter in May 2022 to the City acknowledging a request for a permit renewal; however, a formal
application was not submitted within 180 days prior to the IUP expiration date as required by 15A NCAC 2H .0916. The draft IUPs for
ECI and Hickory Springs were not submitted to the Division (for review) within 30 days prior to the new IUP effective dates as required
by 15A NCAC 2H .0917. The Division currently has the new IUP and supporting documentation for Hickory Springs; however, there
is no documentation for ECI (new IUP, previous inspection, application, allocation table, etc.). All supporting documentation for ECI
must be submitted to the Division by December 29, 2023.
It is recommended that the City establish a written guidance for both public requests to review pretreatment files and the
review/approval of confidentiality requests from Industrial Users. In addition, the City should develop a written Standard Operation of
Procedures (SOP) for SIU sampling for current and new staff.
The City must submit a completed IWS by March 1, 2024 and initiate enforcement according to the Division -approved ERP to ECI
and Hickory Springs for the previously discussed violations (previous two paragraphs) by December 29, 2023. The 2022 PAR (PPS
form and Narrative) must also be revised and submitted to the Division by December 29, 2023, to accurately reflect that no SILT
inspections were performed in 2022.
NOD: ❑ Yes
® No
NOV: ® Yes
❑ No
QNCR: ® Yes
❑ No
POTW Rating:
Satisfactory ❑ Marginal ❑ Unsatisfactory
E�`,,96D90CC3437
uSipgnedd by:
23AUDIT COMPLETED BY: ... DATE: 12/4/2023
Wes Bell, Environmental Specialist II, WQROS/DWR, Mooresville Regional Office
EDocuSigned by:
F161FB69A2D84A3
er' H p 12/4/2023
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