NC0024945_Inspection_20180531

s
Water Resources
Environmental Quality
31 May 2018
Mr. 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:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Interim Director
Enclosed is a copy of the Pretreatment Compliance Inspection Report for the inspection of the
Charlotte Water's Industrial Pretreatment Program on May 24, 2018, by Mr. Wes Bell of this Office.
Should you have any questions concerning this report, please do not hesitate to contact Mr. Bell at
[phone], or via email at wes.bell(c�r�,ncdenr.gov.
Sincerely,
DocuSigned by:
A14CC681 AF27425...
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
Enclosure:
Inspection Report
cc: Vivien Zhong, PERCS Unit ([e-mail])
State of North Carolina I Environmental Quality) Water Resources I Water Quality Regional Operations
Mooresville Regional Office 1610 East Center Avenue, Suite 310 1 Mooresville, North Carolina 28115
704-663-1699

NORTH CAROLINA DIVISION OF WATER RESOURCES
K�`r�m
S
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
Water Resources
ENVIRONMENTAL DUALITY
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: 8/23/16 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
PCS CODING
Main Program Permit Number MM/DD/YY
NCO024945 05/24/18
7. Current Number Of Significant Industrial Users (SIUs)?
58
SIUS
8. Number of SIUs With No NP, or With an Expired IUP
0
CIUS
9. Number of SIUs Not Inspected By POTW in the Last Calendar Year?
0
10. Number of SIUs Not Sampled By POTW in the Last Calendar Year?
2
11. Number of SIUs in SNC For Reporting During Either of the Last 2 Semi -Annual Periods
4
NOIN
12. Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi -Annual Periods
5
NOCM
13. Number of SIUs in SNC with Pretreatment Schedule?
F`
PSNC
14. Current Number of SIUs on Schedules?
2
MSNC
15. Current Number Of Categorical Industrial Users (CIUs)?
29
SNPS
16. Number of CIUs in SNC?
4
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 SNC foi
either of the Last 2 Semi -Annual Periods? Not Been Published for SNC fol
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; An effluent pH
violation was reported for Sugar
Creek WWTP in February 2017.
❑ YES ®NO
Limits: Refer to 2017 PAR
Reporting: Refer to 2017 PAR
)lished: See Comments Section
Bakkavor Foods, Express
Container Services (IUP #3008)
® YES [:]No
See Comments Section
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 December 2016 Page 1

28. PRETREATMENT PROGRAM ELEMENTS REVIEW
Program Element
Irwin Creek WWTP
Last Submittal Received
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis HWA
10/2/13
® Yes ❑ No
7/29/14
® Yes ❑ No
10/01/18
Industrial Waste Survey IWS
7/30/15
® Yes ❑ No
12/2/15
® Yes ❑ No
12/31/19
Sewer Use Ordinance SUO
8/20/12
® Yes ❑ No
9/13/12
® Yes ❑ No
Enforcement Response Plan ERP
1/12/18
® Yes ❑ No
1/19/18
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
11/13/15
® Yes ❑ No
2/8/16
® Yes ❑ No
Program Element
Sugar Creek WWTP
Last Submittal Received
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
4/1/13
® Yes ❑ No
5/30/13
® Yes ❑ No
6/1/18
Industrial Waste Survey (IWS)
7/30/15
® Yes ❑ No
12/2/15
® Yes ❑ No
12/31/19
Sewer Use Ordinance (SUO)
8/20/12
® Yes ❑ No
9/13/12
® Yes ❑ No
Enforcement Response Plan (ERP)
1/12/18
® Yes ❑ No
1/19/18
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
11/13/15
® Yes ❑ No
2/8/16
® Yes ❑ No
Program Element
McAlpine Creek WWTP
Last Submittal Received
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
11/27/13
® Yes ❑ No
7/29/14
❑ Yes ❑ No
12/1/18
Industrial Waste Survey (IWS)
7/30/15
® Yes ❑ No
12/2/15
❑ Yes ❑ No
12/31/19
Sewer Use Ordinance (SUO)
8/20/12
® Yes ❑ No
9/13/12
❑ Yes ❑ No
Enforcement Response Plan (ERP)
1/12/18
® Yes ❑ No
1/19/18
❑ Yes ❑ No
Long Term Monitoring Plan (LTMP)
11/13/15
® Yes ❑ No
2/8/16
® Yes ❑ No
Program Element
Mallard Creek WWTP
Last Submittal Received
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
6/1/13
® Yes ❑ No
8/9/13
® Yes ❑ No
8/1/18
Industrial Waste Survey (IWS)
7/30/15
® Yes ❑ No
12/2/15
® Yes ❑ No
12/31/19
Sewer Use Ordinance (SUO)
8/20/12
® Yes ❑ No
9/13/12
® Yes ❑ No
Enforcement Response Plan (ERP)
1/12/18
® Yes ❑ No
1/19/18
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
11/13/15
® Yes ❑ No
2/8/16
® Yes ❑ No
*Charlotte Water — McDowell Creek WWTP has no SIUs.
SUO adopted on 10/28/13
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name =
1. Carrier Corporation
2. Trimac Transportation
3. Aplix, Inc.
30. IUP Number
1 2003
1 1009
0352
31. Does File Contain Current Permit?
® Yes ❑
I ® Yes ❑ No
®Yes ❑ No
32. Permit Expiration Date
6/30/19
2/28/22
10/31/22
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
1 433.17
422.15
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?
I ® Yes ❑
I ® Yes ❑
I ® Yes ❑ No
36. a. Does the File Contain a Slug/Spill Control Plan?
a. EYes ❑No
a. ®Yes [No
a. ®Yes ❑No
b. If No, is One Needed? (See Inspection Form from POTW)
b. 0 e ❑No
b. ❑Yes ❑No
b. []Yes []No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
®Yes❑No❑N/A
❑Yes❑NoON/A
❑Yes❑NoON/A
Organic Management Plan (TOMP)?
38. a. Does File Contain Original Permit Review Letter from the Division?
a. EYes ❑No
a. EYes []No
a. EYes ❑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 [_1No
its Sampling as Required b IUP, includingflow?
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
I ® Yes ❑ No
® Yes ❑ No 11
® Yes ❑ No
41 a. During the Most Recent Semi -Annual Period, Did the SIU Complete its
®Yes❑No❑N/A
®Yes❑No❑N/A
®Yes❑No❑N/A
1 1
Sampling as Required b IUP, includingflow?
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❑NoEN/A
®Yes❑No❑N/A
11
❑Yes❑NoEN/A
1
file include process/dilution flows as Required b IUP?
42b. For categorical lUs with Production based limits, does file include
❑Yes❑No[g
❑Yes❑NoEN/A
❑Yes❑NoEN/A
production rates and/or flows as Required by IUP?
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑NoENA
®Yes❑No❑N/A
❑Yes❑NoON/A
All Limits Non -Compliance from Both POTW and SIU Sampling?
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑NoEN/A
❑Yes❑NoON/A
❑Yes❑NoEN/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
aaYes❑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?
I ❑ Yes ® No 11
❑ Yes ® No
❑ 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[D
❑Yes❑No[D
❑Yes❑NoEN/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
ElYes ® No
Requested Information For You?
FILE REVIEW COMMENTS:
19/21. The penalties and SNC designations for Liquid Environmental Solutions and S&D Environmental Services (Non -SIU) have been
appealed.
20. The POTW includes copies of Compliance Schedules and/or Orders with the PAR documentation.
28. Division's PERCS Unit extended the HWA due dates for Sugar Creek and Mallard Creek WWTPs.
35. The POTW performed SIU inspections on 12/20/17 (Carrier), 6/28/17 (Trimac), and 6/22/17 (Aplix).
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3

39. The POTW's certified laboratory (Charlotte Water Environmental Services Laboratory) performs sampling and analyses.
41a. SIU contracted laboratories are Pace Analytical Services (Carrier), Shealy Environmental Services (Trimac), and Prism
Laboratories (Aplix).
SUMMARY AND COMMENTS:
Comments:
The records reviewed during the inspection were organized and well maintained. The Charlotte Water Industrial Pretreatment
Program was being properly implemented.
NOD: ❑ YES ®NO
NOV: ❑ YES ®NO
QNCR: ❑ YES ®NO
POTW Ratine:
Satisfactory ® Marginal ❑ Unsatisfactory_ ❑
E�—',,96D90CC3437
cuSignedd by:
23CPCI COMPLETED BY• ... DATE: 5/31/2018
Wes Bell, Mooresville Regional Office
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 4