NC0046728_Inspection_20240226

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Allison Kraft, Public Utilities Director
Town of Mooresville
Post Office Box 878
Mooresville, North Carolina 28115
NORTH CAROLINA
Environmental Quality
February 26, 2024
SUBJECT: Pretreatment Compliance Inspection
Town of Mooresville
NPDES Permit No. NCO046728
Iredell County
Dear Ms. Kraft:
Enclosed is a copy of the Pretreatment Compliance Inspection (PCI) Report for the inspection of the Town of
Mooresville's Pretreatment Program on February 23, 2024, by Mr. Wes Bell of this Office. Please advise the Town's
Pretreatment staff of our findings by forwarding the enclosed corrected report. This Office would also like to thank the Town's
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.
Sincerely,
EA
DocuSigned by:
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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
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North Carolina Department of Environmentat Quality I Division of Water Resources
Mooresville Regional Office 1 610 East Center Avenue. Suite 30I 1 Mooresville, North Carolina 28115
704.6631699

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
BACKGROUND INFORMATION:
1. Control Authority (POTW) Name: Town of Mooresville
2. Control Authority Representative(s): Jeff Campbell, Lane Cory
3. Title(s): Environmental Compliance Supervisor, Environmental Compliance Officer
4. Last Inspection Date: 12/9/21 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
NCO046728 02/23/24
7. Current Number Of Significant Industrial Users (SIUs)?
1 2
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 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
0
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 ?
F 0
16. Number CIUs in SNC? 11
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?
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.)?
If Yes, How are these Problems Being Addressed?
19. Which Industries have been in SNC for Limits or Reporting during Limits:
either of the Last 2 Semi -Annual Periods? Not Been Published for Reporti
Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not Pu
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?
21. Are Any Permits Or Civil Penalties Currently Under Adjudication? If Yes, Which
Ones?
® YES ❑ NO; Weekly average
effluent BOD limit violation -
June 2023.
[—]YES ® NO
v/A
►g: N/A
)Iished: N/A
N/A
[—]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
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
Last Submittal Received
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
11/6/23
® Yes ❑ No
2/26/19
® Yes ❑ No
In Review
Industrial Waste Survey IWS
10/3/22
® Yes ❑ No
1/26/23
® Yes ❑ No
N/A
Sewer Use Ordinance SUO
1/2/13
® Yes ❑ No
1/10/13
® Yes ❑ No
Enforcement Response Plan (ERP)
9/6/19
® Yes ❑ No
11/18/19
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
10/22/19
® Yes ❑ No
1/9/20
® Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW:
29. User Name =
1. Carolina Beverage Group
2. BestCo, Inc.
3.
30. IUP Number
0017
0006
31. Does File Contain Current Permit?
® Yes ❑ No
® Yes ❑
I ❑ Yes ❑ No
32. Permit Expiration Date
12/31/28
6/30/27
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
N/A
N/A IF-
34. Does File Contain Permit Application Completed Within One Year Prior
® Yes ❑ No
® Yes ❑ No
❑ Yes ❑ No
to Permit Issue Date?
35. Does File Contain an Inspection Completed Within Last Calendar Year?
®
Yes ❑ No
® Yes ❑ No 11
❑ Yes ❑ No
36. a. Does the File Contain a 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
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
❑Yes❑NoON/A
❑Yes❑NoON/A
❑Yes❑No❑N/A
Organic Management Plan (TOMP)?
38. a. Does File Contain Original Permit Review Letter from the Division?
a. ®Yes ❑No
a. ®Yes []No
a. ❑Yes ❑No
b. All Issues Resolved?
b.❑Yes❑No®N/A
b.❑Yes❑No®N/A
b.❑Yes❑No❑N/A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
® Yes ❑ No
® Yes ❑ No
❑ Yes ❑ No
its Sampling as Required by IUP, including flow?
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
® Yes ❑ No
® Yes ❑ No
El Yes ❑ No
41a. During the Most Recent Semi -Annual Period, Did the SIU Complete its
®Yes❑No❑N/A
®Yes❑No❑N/A
❑Yes❑No❑N/A
Sampling as Required by IUP, including flow?
41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports
®Yes❑No❑N/A
®Yes❑No❑N/A
❑Yes❑No❑N/A
on time?
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑No❑N/A
file includeprocess/dilution flows as Required by IUP?
42b. For categorical IUs with Production based limits, does file include
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑No❑N/A
production rates and/or flows as Required by IUP?
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
®Yes❑No❑NA
❑Yes❑No®N/A
❑Yes❑No❑N/A
All Limits Non -Compliance from Both POTW and SIU Sampling?
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑No❑N/A
All Reporting Non -Compliance from SIU Sampling?
44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
a.®Yes❑No❑N/A
a.❑Yes❑No®N/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❑No®N/A
b.❑Yes❑No❑N/A
c. Did POTW resample within 30 days of knowledge of SIU limit
c.❑Yes❑No®N/A
c.❑Yes❑No®N/A
c.❑Yes❑No❑N/A
violations from the POTW sample event?
45. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
❑
Yes
®
No 11
❑
Yes
®
No 11
❑
Yes
❑
No
46. During the Most Recent Semi -Annual Period, Was Enforcement Taken
®Yes❑No❑N/A
❑Yes❑No®N/A
❑Yes❑No❑N/A
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
47. Does the File Contain Penalty Assessment Notices?
®Yes❑No❑N/A
❑Yes❑No®N/A
❑Yes❑No❑N/A
48. Does The File Contain Proof Of Penalty Collection?
®Yes❑No❑N/A
❑Yes❑No®N/A
❑Yes❑No❑N/A
49. a. Does the File Contain Any Current Enforcement Orders?
a.❑Yes❑No®N/A
a.❑Yes❑No®N/A
a.❑Yes❑No❑N/A
b. Is SIU in Compliance with Order?
b.❑Yes❑No®N/A
b.❑Yes❑No®N/A
b.❑Yes❑No❑N/A
50. Did the POTW Representative Have Difficulty in Obtaining Any of This
❑ Yes ®No
❑ Yes ® No 11
❑ Yes ❑ No
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 2

Requested Information For You?
FILE REVIEW COMMENTS:
7. Berry Global was dropped as a SIU on 11/29/23.
35. The Town performed SIU inspections on 12/8/23 (Carolina Beverage Group) and 11/14/23 (BestCo).
39. The Town's on -site certified laboratory (at WWTP) performs analyses on conventional parameters including total phosphorus
(LTMP). Pace Analytical Services, Inc. and Waypoint Analytical have also been contracted to provide analytical support (LTMP and
IUP).
41a. Carolina Beverage Group and BestCo both contract Statesville Analytical to perform IUP analyses.
46. The Town issued a NOV to Carolina Beverage Group for a pH limit violation in September 2023. Carolina Beverage Group was also
issued a NOV with civil penalty for an unauthorized bypass of wastewater in August 2023.
SUMMARY AND COMMENTS:
The POTW's records were organized and well maintained. The POTW's Industrial Pretreatment Program was being properly
implemented.
NOD: ❑ YES ® NO
NOV: ❑ YES ® NO
QNCR: [—]YES ® NO
POTW Ratine:
Satisfactory
PCI COMPLETED BY
PCI REVIEWED BY:
Marginal ❑ Unsatisfactory_ ❑
D/ocuSignedd by:
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2/26/2024
Wes Bell, Environmental Specialist II, DWR/WQROS, Mooresville Regional Office
DocuSigned by:
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2/26/2024
Andrew Pitner, Regional Supervisor, DWR/WQROS, Mooresville Regional Office
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 3