NC0024945_Inspection_20240213

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
February 13, 2024
Bill Gintert, Environmental Compliance Manager
System Protection
Charlotte Water
4222 Westmont Drive
Charlotte, North Carolina 28217
SUBJECT: Pretreatment Compliance Inspection
Charlotte Water
NPDES Permit No. NCO024945
Mecklenburg County
Dear Mr. Gintert:
Enclosed is a copy of the Pretreatment Compliance Inspection (PCI) Report for the inspection of the Charlotte Water's
Pretreatment Program on February 9, 2024, by Mr. Wes Bell of this Office. This Office would like to thank all Pretreatment
staff for the cooperation and 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.
Enclosure: Inspection Report
Cc: NPDES Program Files - Laserfiche
Sincerely,
EA
DocuSigned by:
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F161 FB69A2D84A3...
Andrew H. Pitner, P.G.
Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
North Carolina Department of Environmental Quality I Division of Water Resources
Moores0le Regional Office 1 610 East Center Avenue. Suite 301 1 Mooresville. North Carolina 26115
704.b63.1699

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
BACKGROUND INFORMATION:
1. Control Authority (POTW) Name: Charlotte Water
2. Control Authority Representative(s): Bill Gintert, Sarah Daley
3. Title(s): Environmental Compliance Manager, Environmental Compliance Supervisor
4. Last Inspection Date: 2/2/23 Inspection Type: ® 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 ® NA
ICIS CODING
Main Program Permit Number MM/DD/YY
NCO024945 02/09/24
7. Current Number Of Significant Industrial Users (SIUs)?
1 53
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?
1 1
10. Number of SIUs Not Sampled By POTW in the Last Calendar Year?
4
11. Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi -Annual Periods
5
12. Number of SIUs in SNC For Reporting During Either of the Last 2 Semi -Annual Periods
1
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 ?
22
16. Number CIUs in SNC? 11
5
POTW INTERVIEW:
17. Since the Last PCI, has the POTW had any NPDES Limits Violations? ® YES ❑ NO
If Yes, What are the Parameters and How are these Problems Being Addressed? See Comments Section
18. Since the Last PCI, has the POTW had any Problems Related to an Industrial U YES � NO
Discharge (Interference, Pass -Through, Blockage, Citizens' Complaints, Increased
Sludge Production, Etc.)?
If Yes, How are these Problems Being Addressed?
19. Which Industries have been in SNC for Limits or Reporting during Limits: See Comments Section
either of the Last 2 Semi -Annual Periods? Not Been Published for Reporting: Princeton Pharmaceuticals, 2"
Public Notice?(May refer to PAR if Excessive SIUs in SNC) half of 2023.
Not Published:N/A
20. Which Industries are on Compliance Schedules or Orders? For all SIUs on an II N/A
Order, Has a Signed Copy of the Order been sent to the Division?
21. Are Any Permits Or Civil Penalties Currently Under Adjudication? If Yes, Which II U YES � NO
Ones?
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
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:
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 1

28. PRETREATMENT PROGRAM ELEMENTS REVIEW:
Program Element
Irwin Creek WWTP (NC0024945)
Last Submittal Received
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
9/1/23
® Yes ❑ No
10/31/18
® Yes ❑ No
In Review
Industrial Waste Survey IWS
12/20/19
® Yes ❑ No
10/19/20
® Yes ❑ No
N/A
Sewer Use Ordinance SUO
10/28/13
® Yes ❑ No
9/13/12
® Yes ❑ No
Enforcement Response Plan (ERP)
10/11/19
® Yes ❑ No
1/7/20
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
5/30/18
® Yes ❑ No
7/6/18
® Yes ❑ No
Program Element
Sugar Creek WWTP (NC0024937)
Last Submittal Received
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
12/28/22
® Yes ❑ No
8/14/18
® Yes ❑ No
In Review
Industrial Waste Survey IWS
12/20/19
® Yes ❑ No
10/19/20
® Yes ❑ No
N/A
Sewer Use Ordinance SUO
10/2/13
® Yes ❑ No
9/13/12
® Yes ❑ No
Enforcement Response Plan (ERP)
10/11/19
® Yes ❑ No
1/7/20
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
5/30/18
® Yes ❑ No
7/6/18
® Yes ❑ No
Program Element
McAlpine Creek WWTP (NC0024970)
Last Submittal Received
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
11/30/18
® Yes ❑ No
12/5/18
® Yes ❑ No
7/1/24*
Industrial Waste Survey IWS
12/20/19
® Yes ❑ No
10/19/20
® Yes ❑ No
N/A
Sewer Use Ordinance SUO
10/28/13
® Yes ❑ No
9/13/12
® Yes ❑ No
Enforcement Response Plan (ERP)
10/11/19
® Yes ❑ No
1/7/20
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
5/30/18
® Yes ❑ No
7/6/18
® Yes ❑ No
Program Element
Mallard Creek WWTP (NC0030210)
Last Submittal Received
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
7/10/23
® Yes ❑ No
8/15/18
® Yes ❑ No
In Review
Industrial Waste Survey (IWS)
12/20/19
® Yes ❑ No
10/19/20
® Yes ❑ No
N/A
Sewer Use Ordinance (SUO)
10/28/13
® Yes ❑ No
9/13/12
® Yes ❑ No
Enforcement Response Plan (ERP)
10/11/19
® Yes ❑ No
1/7/20
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
5/30/18
® Yes ❑ No
7/6/18
® Yes ❑ No
*Charlotte Water — McDowell Creek WWTP (NC0036277) has no SIUs.
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW:
29. User Name
F. Barnhardt
2. Duff -Norton
3. Qualawash
30. IUP Number
0003
0370
F 1009
31. Does File Contain Current Permit?
® Yes ❑ NoI
® Yes ❑ No
® Yes ❑ No
32. Permit Expiration Date
7/31/25
6/30/28
2/28/27
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
N/A
433
442
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?
I ® Yes ❑ NoI
® 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. El es ❑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
11
❑Yes❑No®N/A
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 2

38. a. Does File Contain Original Permit Review Letter from the Division?
b. All Issues Resolved?
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
its Sampling as Required by IUP, including flow?
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
41 a. During the Most Recent Semi -Annual Period, Did the SIU Complete its
Sampling as Required by IUP, including flow?
41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports
on time?
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
file include process/dilution flows as Required by IUP?
42b. For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Limits Non -Compliance from Both POTW and SILT Sampling?
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Reporting Non -Compliance from SIU Sampling?
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. Did POTW resample within 30 days of knowledge of SIU limit
violations from the POTW sample event?
45. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
46. During the Most Recent Semi -Annual Period, Was Enforcement Taken
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
47. Does the File Contain Penalty Assessment Notices?
48. Does The File Contain Proof Of Penalty Collection?
49. a. Does the File Contain Any Current Enforcement Orders?
b. Is SIU in Compliance with Order?
50. Did the POTW Representative Have Difficulty in Obtaining Any of This
Requested Information For You?
FILE REVIEW COMMENTS:
a. ®Yes E]N`oF
b.❑Yes❑No®N/A 11
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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
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No 11
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ZYes❑No❑N/A
❑Yes❑NoZN/A11
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❑Yes❑NoZN/A
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a.❑Yes❑No®N/A
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a.❑Yes❑No®N/A
b.❑Yes❑No®N/A
❑ Yes ® No
❑ Yes ® No
❑ Yes ® No
9. A SIU closed in 2022 but the official SIU drop letter was not issued until January 2023.
10. These four SILTS did not have a discharge in 2023; therefore, Charlotte Water staff were unable to collect samples. Note: One of the four
SIUs is discussed in the previous (#9) comment.
17. Sugar Creek WWTP reported effluent limit violations in January 2023 (daily max fecal coliform) and April 2023 (BOD weekly average).
19. Mallard Creek Polymers and Express Container Services (IUP #: 3008) were in SNC for limit violations during first half of 2023 and
National Container Group, Quala Services and Zero Waste Recycling were in SNC for limit violations during second half of 2023. All SIUs
that were in SNC during the first half of 2023 were published in the Charlotte Business Journal. Copies of the publications for all SIUs in SNC
in 2023 will be included with the 2023 PAR submittal.
28. The Division granted a 180-day extension to McAlpine Creek's HWA due date to allow review of the reissued NPDES Permit prior to
HWA submittal.
35. Charlotte Water performed the SIU inspections on 7/13/23 (Barnhardt), 8/17/23 (Duff -Norton), and 6/26/23 (Qualawash).
39. Charlotte Water's certified laboratory performs all LTMP and IUP analyses with the exception of low-level mercury and phenol. Waypoint
Analytical has been contracted to perform these analyses.
41 a. Barnhardt contracts Waypoint Analytical to perform IUP analyses and Duff -Norton and Qualawash both contract Pace Analytical Services
to perform IUP analyses.
46. Charlotte Water issued a Notice of Noncompliance to Barnhardt for a pH limit violation in October 2023. Qualawash was issued a NOV
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 3

and civil penalty ($500.00) for the interference to Charlotte Water's sampling equipment during the second half of 2023.
SUMMARY AND COMMENTS:
The Division was notified on 9/12/23 (via email) by the EPA's Office of Information Management that Charlotte Water's SwiftComply System
was CROMERR compliant. The Division notified Charlotte Water via letter dated l l/l/23 that their pretreatment program is approved to begin
utilizing the Charlotte Water SwiftComply System to receive and send electronic reports as required. Charlotte Water's SwiftComply System is
currently under product development and is estimated to be placed into service (following testing, etc.) in early 2025.
The records reviewed during the inspection were organized and well maintained. Charlotte Water's Industrial Pretreatment Program was being
properly implemented.
NOD: [—]YES ®NO
NOV: [—]YES ®NO
QNCR: ❑ YES ®NO
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory_ ❑
DocuSigned by:
2U� B1& 2/13/2024
PCI COMPLETED BY: DATE:
PCI REVIEWED BY:
Wes Bell, Environmental Specialist II, DWR/WQROS, MRO
CA
DocuSigned by:
4•4w H P4"
F161 FB69A2D84A3...
2/13/2024
DATE:
Andrew Pitner, Regional Supervisor, DWR/WQROS, MRO
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 4