NC0020184_Inspection_20190128

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
Stephanie Scheringer, Division Manager
Two Rivers Utilities
Post Office Box 1748
Gastonia, North Carolina 28053
Dear Ms. Scheringer:
NORTH CAROLINA
Environmental Quality
28 January 2019
Subject: Notice of Deficiency
Pretreatment Compliance Inspection
Two Rivers Utilities
NPDES Permit No. NCO020184
Gaston County
Tracking No. NOD-2019-PC-0032
Enclosed is a copy of the Pretreatment Compliance Inspection Report for the inspection of the Two Rivers Utilities'
approved Industrial Pretreatment Program on January 18, 2019, by Mr. Wes Bell of this Office.
This report is being issued as a Notice of Deficiency (NOD) due to the POTW's failure to properly implement the
Pretreatment Program. Specifically, the POTW failed to initiate enforcement actions according to the Division
approved ERP on multiple reporting violations (flow) during the second half of 2018. The POTW must initiate an
enforcement action on the reporting violations by February 8, 2019. In addition, it is requested that a written response
be submitted to this Office by February 19, 2019, addressing the actions taken to prevent the recurrence of these
violations. In responding, please address your comments to Mr. Bell.
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(cr�,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
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

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
BACKGROUND INFORMATION:
1. Control Authority (POTW) Name: Two Rivers Utilities
2. Control Authority Representative(s): David Shellenbarger, Chris English, Cody Austin
3. Title(s): Assistant Division Manager/Water Resources/Pretreatment Supervisor, Pretreatment Coordinators
4. Last Inspection Date: 7/7/17 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
NCO020184 01/18/19
7. Current Number Of Significant Industrial Users (SIUs)?
1 24
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?
F 0
15. Current Number of Categorical Industrial Users CIUs ?
8
16. Number CIUs in SNC?
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
® YES ❑ NO
See Comments
)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
Long Creek WWTP (NC0020184)
Last Submittal Received
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
5/26/17
® Yes ❑ No
8/28/17
® Yes ❑ No
9/1/20
Industrial Waste Survey (IWS)
6/11/15
® Yes ❑ No
8/3/15
® Yes ❑ No
6/20/20
Sewer Use Ordinance (SUO)
12/6/12
® Yes ❑ No
12/27/12
® Yes ❑ No
Enforcement Response Plan (ERP)
6/23/16
® Yes ❑ No
9/13/16
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
5/26/17
® Yes ❑ No
8/25/17
® Yes ❑ No
Program Element
Crowders Creek WWTP (NC0074268)
Last Submittal Received
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
3/29/17
® Yes ❑ No
4/18/17
® Yes ❑ No
11/1/19
Industrial Waste Survey (IWS)
6/11/15
® Yes ❑ No
8/3/15
® Yes ❑ No
6/20/20
Sewer Use Ordinance (SUO)
12/6/12
® Yes ❑ No
12/27/12
® Yes ❑ No
Enforcement Response Plan (ERP)
6/23/16
® Yes ❑ No
9/13/16
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
5/26/17
® Yes ❑ No
8/25/17
❑ Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW:
29. User Name
1. A.B. Carter
2. Stabilus
3. Sunshine Uniform Services
30. IUP Number
1049
1021
1 1013
31. Does File Contain Current Permit?
® Yes ❑ NoI
® Yes ❑ NoI
® Yes ❑ No
32. Permit Expiration Date
8/31/21
12/31/20
22/31/20
33. Categorical Standard Applied I.E. 40 CFR, Etc. Or N/A
465.14
433.17
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 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. El es ❑No
b. ❑Yes ONO
b. ❑Yes ❑No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
Nfl
❑Yes❑No[D
❑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?
I ® Yes ❑
No
® Yes ❑ No
® 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
❑YesNNo❑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❑NoNN/A
file include process/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
❑Yes❑No®NA
❑Yes❑NoON/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
❑Ycs❑NoNN/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? 11
❑ Yes ® No 11
❑ Yes ® No 11
❑ Yes ® No
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 2

46. During the Most Recent Semi -Annual Period, Was Enforcement Taken
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
47. Does the File Contain Penalty Assessment Notices?
48. Does The File Contain Proof Of Penalty Collection?
49. a. Does the File Contain Any Current Enforcement Orders?
b. Is SIU in Compliance with Order?
50. Did the POTW Representative Have Difficulty in Obtaining Any of This
Requested Information For You?
FILE REVIEW COMMENTS:
❑Yes❑No®N/A
❑Yes®No❑N/A
®Yes❑No❑N/A
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑No®N/A
a.❑Yes❑No®N/A
b.❑Yes❑No®N/A
a.❑Yes❑No®N/A
b.❑Yes❑No®N/A
a.❑Yes❑No®N/A
b.❑Yes❑No®N/A
❑ Yes ®No
❑ Yes ® No
❑ Yes ❑ No
18.Owens Corning installed anew screening system to improve the removal of fiberglass in the waste stream that was previously being detected
in the Long Creek WWTP operations including sludge. IBC was issued NOV/penalties for VOCs being discharged into collection system as a
result of the on -site operations (tote cleaning). Syncot upgraded the screening system to improve the removal ofplastics in the waste stream that
were previously being observed in the Eagle Road WWTP operations.
35. The POTW performed the SIU inspections on 9/12/18 (A.B. Carter), 11/8/18 (Stabilus), and 12/7/18 (Sunshine Uniform Services).
39. The POTW's on -site lab performs all analyses except for cyanide and metals (RAW sludge only). Shealy Environmental Services is
contracted to perform cyanide, metals analyses (RAW sludge), oil & grease (IUP monitoring) and organics.
41 a. The POTW performs IUP monitoring for the SIUs.
46. Sunshine Uniform Services was issued a NOV for a pH violation in November 2018.
Stabilus failed to submit the flow reports by the 15' of the following month (IUP requirement) on several occasions during the last half of
2018. The POTW failed to initiate enforcement according to the Division approved ERP for these reporting violations. Note: Stabilus did
submit the reports within seven days after the required deadline (with the exception of the May 2018 flow report — received in mid -July 2018).
SUMMARY AND COMMENTS:
The records reviewed during the inspection were organized and well maintained. The POTW must ensure to initiate enforcement actions
according to the Division approved ERP when SIUs fail to meet IUP reporting requirements. The POTW must initiate an enforcement action
(according to the ERP) to Stabilus for the reporting violations by February 8, 2019. The POTW staff should review all SIU reporting and
initiate enforcement for any violations if applicable.
This office is concerned with the in -line pH monitoring system located at Sunshine Uniform Services (Sunshine). Sunshine's pH monitoring
system has encountered operational problems in the past due to floatable materials. In addition, the on -site pH sampling performed by the
POTW staff (including the composite sample - not for compliance) was significantly different on multiple occasions from Sunshine's pH
monitoring system. The POTW must ensure that Sunshine's pH monitoring system is being properly operated and maintained (including proper
calibrations) as required by the subject IUP.
NOD: ® YES ❑ NO
NOV: [-]YES ® NO
QNCR: ❑ YES ® NO
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 3

POTW Rating:
Satisfactory
PCI COMPLETED BY:
Marginal ❑ Unsatisfactory_ ❑
DocuSipgneds�by:
�Piy 2�6
A61696D90CC3437...
Wes Bell, Environmental Specialist II
DATE: 1/28/2019
DocuSigned by:
1/28/2019
PCI REVIEWED BY: A14CC681AF27425... DATE:
W. Corey Basinger, Regional Supervisor
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 4