NC0024252_Response to Notice_20231218

City of Conover
Mr. Wes Bell
This letter is in response to the NOV's for the City of Conover's Pretreatment Audit Inspection conducted on
November 21, 2023. The NOV states that the City of Conover failed to properly implement the Division -approved
Industrial Pretreatment Program. Specifically, failure to renew Industrial User Permits (IUPs) for Hickory Springs and
Engineered Controls International (ECI) prior to their expiration dates and submit new draft IUPs to the Division for
review 30 days prior to their effective dates as required by 15A NCAC 2H .0917. This failure occurred due to lack of
experience and knowledge of pretreatment regulations by the pretreatment coordinator for the City.
Also the Cities failure to initiate enforcement according to the Division -approved Enforcement Response
Plan (ERP) for the following IUP violations: ECI's failure to submit the May 2023 flow data and obtain prior approval to
construct a new pretreatment system as well as failure to submit a permit renewal application 180 days prior to the
existing IUP's expiration date. Hickory Springs failure to submit a permit renewal application 180 days prior to the
existing IUP's expiration date. Failure to enforce was also due to the lack of awareness and experience of the
pretreatment coordinator for the City. In response to this the City has issued to both Hickory Springs and ECI NOV's for
these violations in accordance with the cities Division -approved ERP on 11/28/23 (Hickory Springs: 180 days) and
12/7/23 (ECI: 180 days, Construction, and May flow data).
As well as failure to enforce the Division -approved ERP the City also failed to conduct SIU inspections in 2022.
This failure occurred due to miscommunication as pretreatment coordinator responsibilities changed hands.
Inspections were performed in 2023 as required by 15A NCAC 02H .0905 of both Hickory Springs and ECI.
Failure to submit a completed IWS by October 1, 2022 was due to lack of awareness and experience as well.
The IWS is being vigorously worked on and should without any doubt be submitted to the division by the March 1,
2024 date specified in the PAI report. The 2022 PAR (PPS form and Narrative) is being updated accordingly as well as
ECI's permit renewal application and all additional info, this will be sent to the Division and received by December 29,
2023 as specified in the PAI report. Public requests to review pretreatment files and the review/approval of
confidentiality requests from Industrial Users is listed in the Cities SUO section Sec. 22-131, the City is in the process of
writing a guidance for these requests. Standard Operating Procedure's (SOP) for SIU sampling for current and new
staff is in progress as well.
In addition to all these abatements, the city has reached out to NC Rural Water for guidance and assistance in
our pretreatment program. We are going to collaborate with them on a total program review, as well as permit
related questions and concerns.
Thank you for the continued patience and with time and a strong continued effort I feel the City will achieve a
high -quality pretreatment program that will protect the city's sewer system that will in turn protect the waterways in
accordance with state regulations. If I have missed anything, or you need more information, please feel free to reach
out at your convenience.
Regards,
Andrew Evans
WWTP ORC/Pretreatment Coordinator
City of Conover, North Carolina
828-443-7659
[Post Office Box 549 1 Conover, North Carolina 1 28613 1 voice/tdd [phone] 1 fax [phone]]