NC0046728_Inspection_20190114

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, Eric Brackett
3. Title(s): Environmental Compliance Supervisor, Environmental Compliance Officer
4. Last Inspection Date: 3/16/17 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 01/09/19
7. Current Number Of Significant Industrial Users (SIUs)?
1 3
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 N/A
either of the Last 2 Semi -Annual Periods? Not Been Published for Not Pu
Public Notice?(May refer to PAR if Excessive SIUs in SNC)
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; monthly average
effluent fecal coliform violation in
May 2017.
❑ YES ®NO
)lished: 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)
11/5/18
® Yes ❑ No
1/14/14
® Yes ❑ No
In Review
Industrial Waste Survey IWS
3/13/17
® Yes ❑ No
1 5/23/17
® Yes ❑ No
5/30/22
Sewer Use Ordinance SUO
1/2/13
® Yes ❑ No
1/10/13
® Yes ❑ No
Enforcement Response Plan (ERP)
2/11/11
® Yes ❑ No
3/29/11
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
6/30/16
® Yes ❑ No
9/20/16
® Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW:
29. User Name =
1. Carolina Beverage Group
2. BestCo, Inc.
3. Niagra Bottling
30. IUP Number
0017
0006
F 0-018
31. Does File Contain Current Permit?
® Yes ❑ No
® Yes ❑
I ® Yes ❑ No
32. Permit Expiration Date
12/31/23
6/30/22
22/31/21
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
N/A
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?
I ® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
36. a. Does the File Contain aSlug/Spill Control Plan?
a. EYes ❑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❑NoNN/A
❑Yes❑NoNN/A
❑Yes❑NoNN/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 ❑ No
its Sampling as Required by IUP, including flow?
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
I ® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
41a. During the Most Recent Semi -Annual Period, Did the SIU Complete its
®Yes❑No❑N/A
❑YesNNo❑N/A
❑YesNNo❑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❑NoEN/A
❑Yes❑NoNN/A
❑Yes❑NoEN/A
file includeprocess/dilution flows as Required by IUP?
42b. For categorical IUs with Production based limits, does file include
❑Yes❑NoNN/A
❑Yes❑NoNN/A
❑Yes❑NoNN/A
production rates and/or flows as Required by IUP?
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
EYes❑No❑NA
❑Yes❑NoNN/A
❑Yes❑NoEN/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
NYes❑No❑N/A
❑YesNNo❑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
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?
❑
Yes
®
No 11
❑
Yes
®
No
❑
Yes
®
No
46. During the Most Recent Semi -Annual Period, Was Enforcement Taken
EYes❑No❑N/A
NYes❑No❑N/A
❑YesNNo❑N/A
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
47. Does the File Contain Penalty Assessment Notices?
NYes❑No❑N/A
❑Yes❑NoNN/A
❑Yes❑NoNN/A
48. Does The File Contain Proof Of Penalty Collection?
EYes❑No❑N/A
❑Yes❑NoNN/A
❑Yes❑NoEN/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
❑Yes ® No
Requested Information For You?
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 2

FILE REVIEW COMMENTS:
35. The POTW performed SIJ inspections on 3/7/18 (Carolina Beverage Group), 5/9/18 (BestCo), and 8/1/18 (Niagra).
39. The POTW's on -site lab performs analyses on conventional parameters. Pace Analytical Services, Inc. (LTMP analyses) and Prism
Labs (low level mercury) have also been contracted to provide analytical support.
41a. Carolina Beverage Group and BestCo both contract Statesville Analytical, Inc. for analyses. Niagra contracts Pace Analytical
Services, Inc. for analyses. Niagra completed all IUP monitoring except for aluminum (monitor only) during the second half of 2018.
46. The POTW issued a NOV to BestCo for the failure to monitor IUP parameters during the 31 quarter of 2018. Carolina Berverage
Group was issued a NOV for a BOD permit limit violation in November 2018. No enforcement action per Division approved ERP was
taken against Niagra for the aluminum monitoring violation during the second half of 2018. Note: The POTW has submitted a request to
the PERCS Unit to drop Niagra as a SI J.
SUMMARY AND COMMENTS:
Records reviewed during the inspection were organized and well maintained. The POTW will submit a revised LTMP to update the TSS
and cyanide detection levels. The POTW must ensure that the SIUs monitor all parameters according to their IUPs and proper
enforcement (per Division approved ERP) is initiated for any monitoring/reporting violations.
Overall, the POTW's Industrial Pretreatment Program was being properly implemented.
NOD: ❑ YES ®NO
NOV: ❑ YES ®NO
QNCR: ❑ YES ®NO
POTW Ratine:
Satisfactory ® Marginal ❑ Unsatisfactory_ ❑
E�—"96DWCC3437
cuSigneddby:
PCI COMPLETED BY: ... DATE: January 14, 2019
Wes Bell, Mooresville Regional Office
DocuSigned by:
�^ 1/14/2019
A14CC681AF27425...
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 3

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
Jeff Campbell
Environmental Compliance Supervisor
Town of Mooresville
Post Office Box 878
Mooresville, North Carolina 28115
Dear Mr. Campbell:
NORTH CAROLINA
Environmental Quality
14 January 2019
Subject: Pretreatment Compliance Inspection
Town of Mooresville
NPDES Permit No. NCO046728
Iredell County
Enclosed is a copy of the Pretreatment Compliance Inspection Report for the inspection of the Town of
Mooresville's approved Industrial Pretreatment Program on January 9, 2019, by Mr. Wes Bell of this Office.
The report should be self-explanatory; however, should you have any questions concerning this report, please do
not hesitate to contact Mr. Bell at [phone] or at wes.bell(c lacdenr.gov.
Sincerely,
DocuSigned by:
A14CC681AF27425...
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
Enclosure:
Inspection Report
D Q
� North Carolina Department of Environmental Quality I Division of Water Resources
Mooresville Regional Office 1 610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115
NORTH CAROLINA
Da"MoM a enWmn�bl mwnq 704,663.1699