NC0023981_NOV-2024-PC-0515_PCI_20240906

Docusign Envelope ID: 383B336A-F5D7-46F6-AA46-A4829B353338
ROY COOPER
Co,ernor
ELIZABETH S. B1SER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
SENT VIA ELECTRONIC MAIL ONL Y.- NO HARD COPY WILL BE MAILED
September 6, 2024
Jeff Church, Director Public Utilities
City of Lenoir
Email: [e-mail]. US
SUBJECT: NOTICE OF VIOLATION
Tracking Number: NOV-2024-PC-0515
Permit No. NCO023981
Lower Creek WWTP
Caldwell County
Dear Permittee:
The North Carolina Division of Water Resources conducted an inspection of the City of Lenoir's Pretreatment
program on August 22, 2024. The PCI was conducted to verify that the program is being managed and maintained
in compliance with all Pretreatment regulations. A summary of the findings and comments noted during the
inspection are provided in the enclosed copy of the inspection report.
The Pretreatment Compliance inspection was conducted by Division of Water Resources staff from the Asheville
Regional Office. The following violation(s) were noted during the inspection:
Inspection Area Description of Violation
Pretreatment Four out of the required five SIU inspections were not performed in 2023 by the POTW.
Remedial actions should have already been taken to correct this problem and prevent further occurrences in the
future. The Division of Water Resources may pursue enforcement action for this and any additional violations of
State law.
D_EQ- North Carollw Department of En9ronmental OwlhV I NylsionofWater Res mes
2 Ashe,1kRc9kna10 cfl 2090U5.HlghwayX I1 wanna—. North Carattna 26776
626.296.4WO

Docusign Envelope ID: 383B336A-F5D7-46F6-AA46-A4829B353338
To prevent further action, please respond in writing to this office within 30 days upon your receipt of this Notice
of Violation regarding your plans or measures to be taken to address the indicated violations and other identified
issues, if applicable.
If you should have any questions, please do not hesitate to contact Rachel Rose with the Water Quality
Regional Operations Section in the Asheville Regional Office at 828-296-4500.
Sincerely,
Ep
DocuSigned by:
awit f 6ss
E397192DABFB4FF...
Daniel Boss, Assistant Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS
Ec: Laserfiche
Lisa Triplett (Pretreatment Coordinator)
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AO-llkR l—IO CCI 2090U.5.Mghway70 I Swanna—. North Carallna 28776
w..wnwoiw�.woin� 62&296.4500

Docusign Envelope ID: 383B336A-F5D7-46F6-AA46-A4829B353338
United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040-0057
Water Compliance Inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 IN 2 u 3 I NC0023981 111 121 24/08/22 I17
18 L D I 19 I s I 201
211IIIII 111111III II III III1 I I IIIII
IIIIIIIII II r6
Inspection
Work Days Facility Self -Monitoring Evaluation Rating B1 QA
---------------------- Reserved -------------------
67
I 72 I n, I
70I� I 711 LL -1
LJ
71 I 74 79 I I I I I I I80
I I
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES permit Number)
10:OOAM 24/08/22
21/08/01
Lower Creek WWTP
1905 Broadland Rd
Exit Time/Date
Permit Expiration Date
Lenoir NC 28645
12:OOPM 24/08/22
26/02/28
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Elisa Robbins Triplett/ORC/828-757-2198/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Elisa Robbins Triplett,PO Box 958 Lenoir NC 286450958//828-757-4462/
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Pretreatment
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers
Date
D 5'g dby:
DWR/ARO WQ/828-296-4500/Richard
Rachel Rose �:� 63940—C494.
E"CE.
9/9/2024
Eguino DWR/ARO WQ/828-296-4500/
Do-Sig—d by:
9/ 9/ 2 0 2 4
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers
Date
9/9/2024
FVD—Sig"Idby:
atait t J56SS
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

Docusign Envelope ID: 383B336A-F5D7-46F6-AA46-A4829B353338
NPDES yr/mo/day Inspection Type (Cont.)
NCO023981 I11 12I 24/08/22 117 18 1 p I
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Rachel Rose and Richard Eguino, with the Asheville Regional Office, conducted a Pretreatment
Compliance Inspection (PCI) of the City of Lenoir's Pretreatment Program on August 22, 2024. Lisa
Triplett (Pretreatment Coordinator) and Donnie Hawkins (WWTP ORC) were present during the
inspection.
Overall, the program is marginally in compliance with Federal and State Pretreatment Program
requirements. The City of Lenoir Pretreatment program is split between Lower Creek WWPT (NPDES
Permit No NC0023981) & Gunpowder Creek WWTP (NPDES Permit No. NC0023736). Lower Creek
has three Significant Industrial Users (SIU), all of which are Categorial Industrial Users (CIU).
Gunpowder Creek has two SIUs with one CIU. See the attached PCI form for file review comments and
recommendations.
The following was noted during the file review:
All SIUs were late for the January 2024 sampling because of a new sampling requirement
implemented by the POTW. Additionally, none of the sampling records from Statesville Analytical
Labs had the detection limits reported. It is recommended to have the POTW send a copy of each
industry's IUP to at least Statesville Analytical Labs, and it is recommended to each industry that they
do the same for any samples sent to Statesville Analytical Labs to ensure that the detection limits are
correct and listed in the results. It was observed that the duties for the pretreatment program would
highly benefit from a dedicated pretreatment coordinator with little to no other duties to allow for more
time & organization for the program.
The following violation was noted during the inspection:
1. Four out of the five required SIU inspections were not performed in 2023 by the POTW.
Page#

Docusign Envelope ID: 383B336A-F5D7-46F6-AA46-A4829B353338
'' NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
Water Resources
ENVIRONMENTAL OVAL I TY
BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)l
1. Control Authority (POTW) Name: Lower Creek WWTP & Gunpowder Creek WWTP
2. Control Authority Representative(s): Lisa Triplett
3. Title(s): Pretreatment Coordinator/WWTP Superintendent
4. Last Inspection Date: 09/25/2023 Inspection Type (Check One): ® 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:
ICIS CODING
Main Program Permit Number
NIC10 Io 12 13 19 1 8111
MM/DD/YY
108122124 J
Are Milestone Dates Being Met? ❑ YES ❑ NO
7. Current Number Of Significant Industrial Users (SIUs)?
5
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?
4
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 ?
4
16. Number of 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?
Lower Creek had an isolated Fecal coliform exceedance in October 2023.
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.)? The issues with BeoCare have been resolved.
If Yes, How are these Problems Being Addressed?
19. Which Industries have been in SNC for Limits or Reporting during SNC fox
either of the Last 2 Semi -Annual Periods? Not Been Published for SNC fox
Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not Pul
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?
EYES ❑ NO
❑ YES ® NO
Limits: 0
Reporting: 0
Ilished: 0
0
❑ 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 Inspector, please verify yourself!
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 December 2016 Page 1

Docusign Envelope ID: 383B336A-F5D7-46F6-AA46-A4829B353338
28. PRETREATMENT PROGRAM ELEMENTS REVIEW— Please review POTW files, verify POTW has copy of Program Element
in their files, complete with supporting documents and copy of PERCS Approval Letter, and dates consistent with Program Info:
Program Element
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
12/22/2022
® Yes ❑ No
❑ Yes ® No
Industrial Waste Survey IWS
08/08/2018
® Yes ❑ No
11/30/2018
® Yes ❑ No
N/A
Sewer Use Ordinance SUO
10/11/2012
® Yes ❑ No
11/08/2012
® Yes ❑ No
Enforcement Response Plan ERP
05/28/2020
® Yes ❑ No
08/18/2020
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
1 10/23/2004
® Yes ❑ No
10/29/2004
® Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name
1. BeoCare
2.
3.
30. IUP Number
008
31. Does File Contain Current Permit?
® Yes ❑ No
❑ Yes ❑
I ❑ Yes ❑ No
32. Permit Expiration Date
09/10/2028
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
N/A
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
❑ 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❑No[D
❑Yes❑No❑N/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 b IUP, includingflow?
1
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
I ® Yes ❑ No
❑ Yes ❑
No
❑ Yes ❑ No
41. 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❑N 10
❑Yes❑No❑N/A
on time?
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
0Yes0No[9
❑Yes❑No❑N/A
❑Yes❑No❑N/A
file include process/dilution flows as Required by IUP?
42b. For categorical IUs with Production based limits, does file include
❑Yes❑No®N/A 17�
o❑N/A
❑Yes❑No❑N/A
production rates and/or flows as Required b IUP?
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑NoON/A
ElYes ❑ No
❑ Yes ❑ No
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 Re porting_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 Days9
b.❑Yes❑No®N/A
b.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
c. If applicable, Did POTW resample within 30 days of becoming aware
of SIU limit violations in the POTW's sampling of the SIU?
c.❑Yes❑No®N/A
c.❑Yes❑No❑N/A
c.❑Yes❑No❑N/A
46. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
❑
Yes
®
No J1
❑
Yes
❑
No
I
❑
Yes
❑
No
47. During the Most Recent Semi -Annual Period, Was Enforcement Taken
❑Yes❑No[D
❑Yes❑No❑N/A
❑Yes❑No❑N/A
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
48. Does the File Contain Penalty Assessment Notices?
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
49. Does The File Contain Proof Of Penalty Collection?
❑Yes❑NoON/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
50. 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
51. Did the POTW Representative Have Difficulty in Obtaining Any of This
❑ Yes ® No
❑ Yes ❑ No
ElYes ❑ No
Requested Information For You?
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

Docusign Envelope ID: 383B336A-F5D7-46F6-AA46-A4829B353338
FILE REVIEW COMMENTS:
All except one of the SIU inspections were not performed by the POTW in 2023. All SIU inspections need to be done annually. All
industries including BeoCare were late for the January 2024 sampling because of a new sampling requirement implemented by the
POTW. Additionally, none of the sampling records from Statesville Analytical Labs had the detection limits reported. It is
recommended to have the POTW send a copy of each industry's IUP to at least Statesville Analytical Labs, and it is recommended
to each industry that they do the same for any samples sent to Statesville Analytical Labs to ensure that the detection limits are
correct and listed in the results. The most recent HWA approval has not been approved yet.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
N 1 C 1 0 1 0 1 2 1 3 1 9 1 8 1 1 1 1 08 1 22 1 24 1
1. Industry Inspected: Lenoir Mirror (IUP 007)
2. Industry Address: 401 Kincaid St. Lenoir, NC 28645
3. Type of Industry/Product: Mirrors
4. Industry Contact: John Crawford
Phone: [phone]
Title: Maintenance Manager
Fax:
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:
Lenor Mirror installed a copper pretreatment unit to help ensure the POTW stay within their copper limits. All drains inside the
industry go to the copper pretreatment and settling basins before being discharged to the main collection system. None of the 55-
gallon drums observed during the inspection were stored on secondary containment which could lead to chemicals reaching the
main collection system. It is recommended to have Lenoir Mirror store all 55-gallon drums and other totes with chemicals on
approved secondary containment pallets.
OVERALL SUMMARY AND COMMENTS:
Comments:
Requirements:
Recommendations: It is highly recommended for the POTW to have additional pretreatment staff, specifically, a dedicated
pretreatment coordinator with little to no other duties to allow more time & organization for the program.
NOD: ❑ YES ❑ NO
NOV: EYES ❑ NO
QNCR: ❑ YES ❑ NO
POTW Rating:
Satisfactory Marginal X
UnSatisfactory
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3

Docusign Envelope ID: 383B336A-F5D7-46F6-AA46-A4829B353338
PCI COMPLETED BY: Rachel Rose and Richard E iu o DATE: 09/09/2024
os os
DS ��
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 4