NC0023736_Lenoir Pretreatment PCI_20190115 (4)

DocuSign Envelope ID: 4F1ADC05-2FCB-4C37-AD58-EBECE3187F8C
ROY COOPER
(:&wOrnor
K41C-IAEL S. R.EGAN
Secrerary
LINDA CULPEPPER
Directar
Alisa Triplett
City of Lenoir
PO Box 958
Lenoir, NC 28645-0958
NORTH CAROLINA
Environmental Quad"
January 14, 2019
SUBJECT: Pretreatment Compliance Inspection Report
Gunpowder Creek WWTP
NPDES WW Permit No. NCO023736
Caldwell County
Dear Permittee:
The North Carolina Division of Water Resources conducted an inspection of the Gunpowder Creek
WWTP on 1/09/2019. This inspection was conducted to verify that the facility is operating in
compliance with the conditions and limitations specified in NPDES WW Permit No. NC0023736. The
findings and comments noted during this inspection are provided in the enclosed copy of the inspection
report entitled "Compliance Inspection Report".
The following items were noted during the inspection:
The same individual is currently serving as the WWTP Superintendent, Lab Manager and Pretreatment
Coordinator. This is a large and diverse workload for a single person. Consider appointing the
Pretreatment Coordinator as a new and distinct position from the other roles currently being performed
by the WWTP Superintendent.
• Excela has been identified as an IU in the most recent IWS. The Long Form has been completed and
submitted to PERCS, and they have been identified as a CIU. Continue to coordinate with PERCS to
develop an IUP for Excela and begin regulating/inspecting/sampling them accordingly.
N"NCarokisDepartment ofEnvironmentalQaslay I OivisionofWater Resourres
Ashevil ie Regional Off. 2090 U.S_ 70 ftimay I Sw nanoa, North Carolaa 23773
Q
32S 29C-0500

DocuSign Envelope ID: 4F1ADC05-2FCB-4C37-AD58-EBECE3187F8C
If you should have any questions, please do not hesitate to contact Timothy Heim with the Water
Quality Regional Operations Section in the Asheville Regional Office at 828-296-4500 or via email at
[e-mail].
Sincerely,
DocuSigned by:
7E617 38285848C...
G. Landon Davidson, P.G., Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS
Cc: WQS Asheville Regional Office - Enforcement File
NPDES Compliance/Enforcement Unit - Enforcement File
G:\WR\WQ\Caldwell\Wastewater\Municipal\Gunpowder Creek 23736\Pretreatment\2019 PCI\20190114_NC0023736_PCI Ltr.Docx
N"NCaroiinsDepartmentofEnvironmentalQuality I OivistnofWaterResources
Ashevil ie Regnnal Office 2090 U.S_ 70 }f� imay I Sw nsnoa, North CamZL 23773
Q
32S 29C-0500

DocuSign Envelope ID: 4F1ADC05-2FCB-4C37-AD58-EBECE3187F8C
NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)l
I. Control Authority (POTW) Name: _City of Lenoir
2. Control Authority Representative(s): Alisa Triplett
3. Title(s): WWTP Supervisor, Lab Manager, Pretreatment Coordinator
4. Last Inspection Date: _7/30/14 Inspection Type (Check One): x PCI ❑ Audit
5. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? x YES ❑ NO
6. Is POTW under an Order That Includes Pretreatment Conditions? ❑ YES x NO
Order Type, Number, Parameters: —NA
PCS CODING
Trans.Code Main Program Permit Number
I—N-J I NICIO 10 12 131918 111
Are Milestone Dates Being Met? ❑ YES ❑ NO
MM/DD/YY
Inspec.Type
1 01 111 1 19 1
L P
(DTIA)
(TYPI)
Inspector Fac. Type
L —SJ LLJ
(INSP) (FACC)
7. Current Number Of Significant Industrial Users (SIUs)?
4
SILTS
8. Current Number Of Categorical Industrial Users (CIUs)?
1
CIUS
9. Number of SIUs Not Inspected By POTW in the Last Calendar Year?
1
10. Number of SIUs Not Sampled By POTW in the Last Calendar Year?
1
11. Enter the Higher Number of 9 or 10
1
NOIN
12. Number of SIUs With No IUP, or With an Expired IUP
0
NOCM
13. Number of SIUs in SNC for Either Reporting or Limits Violations During Either of the Last 2
Semi -Annual Periods Total Number of SIUs in SNC
0
PSNC
14. Number of SIUs in SNC For Reporting During Either of the Last 2 Semi -Annual Periods
3
MSNC
15. Number of SIUs In SNC For Limits Violations DuringEither of the Last 2 Semi -Annual Periods
2 JkSNPS
16. Number of SIUs In SNC For Both Reporting and Limits Violations During Either of the Last 2
Semi-annual Periods
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 SNC for
either of the Last 2 Semi -Annual Periods? Not Been Published for SNC for
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?
❑ YES ®NO
❑ YES ®NO
Limits: 1 — Beocare: Chromium
Reporting:0
dished: Public Notice Published
None.
❑ YES x NO
LTMP/STMP FILE REVIEW:
22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? x YES ❑ NO
23. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? x YES ❑ NO
24. Is LTMP/STMP Data Maintained in a Table or Equivalent? x YES ❑ NO Is Table Adequate? x YES ❑ NO
25. All LTMP/STMP effluent data reported on Discharge Monitoring Report? x 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 x NO
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:
NC DWQ Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 1

DocuSign Envelope ID: 4F1ADC05-2FCB-4C37-AD58-EBECE3187F8C
Program Element
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
3/31/2022
x Yes ❑ No
11/30/2018
x Yes ❑ No
12/01/2021
Industrial Waste Survey (IWS)
08/08/2018
x Yes ❑ No
11/08/2012
❑ Yes x No
Sewer Use Ordinance SUO
10/11/12
x Yes ❑ No
10/05/15
x Yes ❑ No
Enforcement Response Plan (ERP)
08/20/2015
x Yes ❑ No
12/20/95
x Yes ❑ No
Long Term Monitoring Plan (LTMP)
10/21/04
x Yes ❑ No
10/29/04
x 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
0008
31. Does File Contain Current Permit?
x Yes ❑
1 ❑
Yes ❑ No
❑ Yes ❑
No
32. Permit Expiration Date
12/21/2022
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
NA
34. Does File Contain Permit Application Completed Within One Year Prior
x Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
to Permit Issue Date? *Greer First Permit*
35. Does File Contain an Inspection Completed Within Last Calendar Year?
x Yes ❑ No
❑Yes
❑ No
❑Yes ❑
No
36. a. Does the File Contain a Slug/Spill Control Plan?
a. ❑Yes xNo
a. []Yes ❑No
a. ❑Yes []No
b. If No, is One Needed? See Inspection Form from POTW
b. ❑Yes xNo
b. ❑Yes ❑No
b. ❑Yes ❑No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
❑Yes❑NoxN/A
❑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. xYes [:]No
a. ❑Yes ❑No
a. ❑Yes []No
b. All Issues Resolved? *Retro date was fixed.*
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
x Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
its Sampling as Required by IUP, including flow?
Flow -Water Meter
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
x Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
41. During the Most Recent Semi -Annual Period, Did the SIU Complete its
❑Yes❑NoxN/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❑NoxN/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
on time?
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑NoxN/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
xYes❑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
❑ Yes ❑ No
❑ Yes ❑ No
All Limits Non -Compliance from Both POTW and SIU Sampling?
No Violations
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑NoxN/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❑NoxN/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❑NoxN/A
b.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
c. If applicable, Did POTW resample within 30 days of becoming aware
❑ c.Yes❑NoxN/A
of SIU limit violations in the POTW's sampling of the SIU?
c.❑Yes❑No❑N/A
c.❑Yes❑No❑N/A
46. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
❑
Yes x No
❑
Yes
❑
No
I
❑
Yes
❑
No
47. During the Most Recent Semi -Annual Period, Was Enforcement Taken
xYes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
Due to delayed
Consent Order.
48. Does the File Contain Penalty Assessment Notices?
❑Yes❑NoxN/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
49. Does The File Contain Proof Of Penalty Collection?
❑Yes❑NoxN/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
50. a. Does the File Contain Any Current Enforcement Orders?
a.xYes❑No❑N/A
a.❑Yes❑No❑N/A
a.❑Yes❑No❑N/A
b. Is SIU in Compliance with Order?
b.xYes❑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 x No
❑ Yes ❑ No
El Yes ❑ No
Requested Information For You?
F11
FILE REVIEW COMMENTS:
NC DWQ Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 2

DocuSign Envelope ID: 4F1ADC05-2FCB-4C37-AD58-EBECE3187F8C
INDUSTRY INSPECTION PCS CODING:
Trans.Code Main Program Permit Number
I -NJ INIC10 101213171316
MM/DD/YY Inspec.Type Inspector Fac. Type
01 110 1 09 1 L1—j L S j L 2
(DTIA) (TYPI) (IINSP) (FACC)
1. Industry Visited: Beocare
2. Industry Address:_1905 International Drive, Hudson, NC
3. Type of Industry/Product:_Medical undergarments with dye process.
4. Industry Contact:_JR McCormick Title:Operations Manager
Phone: [phone] 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:
A complete inspection was conducted as part of the PCI. The IU reports they have resolved the Cr issue and sampling results reflect
this. The IU needs to respond to the NOV in a formal, written manner.
OVERALL SUMMARY AND COMMENTS:
Comments: 1) Ms. Triplett is currently serving as the WWTP Superintendent, Lab Manager and Pretreatment Coordinator. This is
a large and diverse workload for a single individual. 2) Excela has been identified as an IUP in the most recent IWS. The Long
Form has been completed and submitted to PERCS, and they have been identified as a CIU.
Requirements: _IU must complete written response to NOV.
Recommendations: 1) Appoint a Pretreatment Coordinator as a new and distinct position from the other roles currently being
performed by the WWTP Superintendent. 2) Coordinate with PERCS to develop and IUP for Excela and being
regulating/inspecting/sampling them accordingly.
NOD: ❑ YES x NO
NOV: ❑ YES x NO
QNCR: ❑ YES x NO
POTW Rating:
Satisfactory X Marginal UnSatisfactory
DocuSigned by:
fi� (�uw.
PCI COMPLETED BY: DATE: 01/11/2019
082B1105A3CA418...
NC DWQ Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 3

DocuSign Envelope ID: 4F1ADC05-2FCB-4C37-AD58-EBECE3187F8C
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 I 2 IF I 3 I NCO023736 111 12 I 19/01/09 I17
18 L o j
19 L G] 201 I
2111111111111111111III1111I111111_11111111111
f6
Inspection
Work Days Facility Self -Monitoring Evaluation Rating B1 QA
----------------------
Reserved -------------------
671
70 I I 71 I I 72 I r I
u I�
73 I I 174 751 I I I I I I I80
I 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 oermit Number)
09:30AM 19/01/09
14/07/01
Gunpowder Creek WWTP
450 Pine Mtn Rd
Exit Time/Date
Permit Expiration Date
Hudson NC 28638
01:00PM 19/01/09
19/03/31
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
Monte L Wall,PO Box 958 Lenoir NC 286450958//828-757-2198/
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
Timothy H Heim ARO WQ//828-296-4665/
D S'g dby:
C. (M6 f�Uwt
1/15/2019
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers
Date
D... Sig—d bY:
1/15/2019
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

DocuSign Envelope ID: 4F1ADC05-2FCB-4C37-AD58-EBECE3187F8C
NPDES yr/mo/day Inspection Type (Cont.)
NCO023736 I11 121 19/01/09 117 18 1 p I
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Tim Heim of the Asheville Regional Office performed a Pretreatment Compliance Inspection on
January 10th, 2019. Lisa Triplett (Lenoir WWTP Manager, Lab Supervisor & Pretreatment Coordinator)
and Matthew Mackie assisted with the inspection and with records and sampling results review. An
inspection of Industrial User Beocare (IUP # 0008) was performed as part of the inspection. JR
McCormick, The Operations Manager, was present during the IU inspection component.
The pretreatment program, associated record keeping, and the relationship with the IU were in good
order at the time of the inspection and compliant with permit conditions. The IU needs to respond in
written form to the NOV related to chromium exceedances that has since been reported to be resolved.
A new Industrial User: Excela, has been identified during a recent IWS and sampling data of the
wastestream has been analyzed. The associated long form has been completed and submitted to
PERCs, the town is coordinating with PERCS to develop an IUP for this CIU.
See attached NC DEQ Pretreatment Compliance Audit form for details.
Page#

DocuSign Envelope ID: 4F1ADC05-2FCB-4C37-AD58-EBECE3187F8C
Permit: NC0023736
Inspection Date: 01/09/2019
Owner - Facility: Gunpowder Creek WWTP
Inspection Type: Pretreatment Compliance
Yes No NA NE
Page#