NC0020184_NOD-2019-PC-0032 Response_20190219

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We are TRU to our customers!
February 19, 2019
Mr. Wes Bell
Division of Water Resources, NC DEQ
Mooresville Regional Office
610 East Center Avenue, Suite 301
Mooresville, NC 28115
Re: Notice of Deficiency
Pretreatment Compliance Inspection
Two Rivers Utilities
NPDES Permit No. NCO020184
Gaston County
Tracking No. NOD-2019-PC-0032
Dear Mr. Bell:
Thank you for your time during the January 18, 2019 inspection of TRU's pretreatment program and for promptly
providing the report from the inspection. The report asked for a response by February 19", to the Notice of
Deficiency concerning a lack of enforcement action for multiple instances of late reporting of flow volumes.
The following actions have been taken to address this issue and to prevent its recurrence:
• An NOV has been issued to Stabilus Inc. for violations of the flow reporting requirements. (A copy of the
NOV is attached.)
• Files have been reviewed for all other permitted industrial users for other instances of late reporting.
Following this review, NOVs have been issued to CaroMont Regional Medical Center; Choice Beverage
USA; Powder Coating Services, Inc.; Sunshine Uniform Services; and Valley Proteins.
• All Significant Industrial Users have been contacted and informed that going forward, TRU will be
enforcing all reporting deadlines stringently including the issuances of NOVs.
• Pretreatment staff have been instructed to follow the Enforcement Response Plan and to issue NOVs
when reporting deadlines are not met, except for extenuating circumstances. The reason for any
exceptions is to be documented. Escalated responses shall be taken in accordance with the ERP for
frequent repeat or more severe reporting violations.
During the inspection and in the report, a concern was raised about the in -line pH monitoring system located at
Sunshine Uniform Services and TRU's response to issues concerning the system. Following the inspection these
actions have been taken:
• Sunshine Uniform Services has been issued an NOV for failure to properly maintain its pH system. (A
opy of the NOV is attached.)

• Pretreatment staff from TRU have met with Sunshine Uniform Services staff concerning the short
comings of the system, maintenance on it, and discrepancies between pH readings. System operation,
calibration and maintenance were reviewed.
• Sunshine Uniform Services has performed maintenance on the acid pump used for pH control, which
they believe caused the pH excursions.
• TRU will be conducting an evaluation of Sunshine Uniform Service's system by taking multiple pH
readings over extended periods of time to verify the system's effectiveness. If adequate correlation
and effectiveness of the system cannot be demonstrated, Sunshine Uniform Services will be required to
modify or replace the pH control and adjustment system.
• Pretreatment staff have been instructed to thoroughly review all received information for similar types
of issues and to take appropriate actions where warranted.
TRU strives to meet or exceed all compliance obligations, and appreciates NC DEQ's inspection and report.
Please let me know if additional actions and/or documentation is needed.
Sincerely,
Stephanie Scheringer
Division Manager Wastewater Treatment
Attachments: NOV sent to Stabilus Inc. 1/29/19
NOV sent to Sunshine Uniform 1/29/19
Certified Mail: 7009 0820 0001 5806 2307

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We are TRU to ourcustarners!
January 29, 2019
Mr. Mike Ellington
Stabilus .
1201 Tulip Dr.
Gastonia, NC 28052
RE: NOTICE OF VIOLATIONS
Dear Mr. Ellington:
State and Federal Pretreatment Regulations require regular monitoring and issuing of Notices of Violations (NOV's)
when permit conditions are not followed.
As stated in Industrial User Permit #1021 Part H; General Conditions; (2) (b), "Monitoring results and flow
information obtained by the permittee shall be reported on forms specified by the City. The laboratory data, Chain
of Custody, and Industrial Flow Monitor forms must be postmarked no later than the tenth day of the month, or
delivered by hand, fax, or email by the fifteenth day, following the month in which the samples were collected. If
the penmittee fails to submit the reports on or before the due date, the results obtained from the sampling event
may be excluded for surcharge proposes."
According to TRU's Enforcement Response Plan, late reporting will result in the issuance of a Notice of Violation.
The Industrial User Self -Monitoring Summary for the months of January, February, April, May, June, August,
September, October, November, and December of 2018, were received after the 15' of the following months.
Stabilus is required to submit in writing, within fourteen days, corrective action taken to achieve compliance.
Sincerely,
Two Rivers Utilities
Cody Austin
Pretreatment Coordinator
Two Rivers Utilities
Certified Mail: 7014 0150 0000 7611 8421

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January 29, 2019
Mr. Tommy Daniels
Sunshine Uniform Service, Inc.
P.O. Box 12632
Gastonia, NC 28053
RE: NOTICE OF VIOLATIONS
Dear Mr. Daniels:
State and Federal Pretreatment Regulations require regular monitoring and issuing of Notices of Violations (NOV's) when
permit conditions are not followed.
As stated in Industrial User Permit #1013 Part 11; General Conditions; (2) (b), "Monitoring results and flow information
obtained by the permittee shall be reported on forms specified by the City. The laboratory data, Chain of Custody, and
Industrial Flow Monitor forms must be postmarked no later than the tenth day of the month, or delivered by hand, fax, or
email by the fifteenth day, following the month in which the samples were collected. If the permittee fails to submit the
reports on or before the due date, the.results obtained from the sampling event may be excluded for surcharge purposes."
The Industrial User Self -Monitoring Summary for the month of January 2018, which was due by February 15, 2018 was
received on February 26, 2018. According to TRU's Enforcement Response Plan, late reporting will result in the issuance
of a Notice of Violation.
Part I Specific Conditions (G) (10) of Industrial User Permit #1013 states that "The continuous pH monitoring & recording
system shall be maintained in proper operating condition at all times. All such devices shall be installed, calibrated, and
maintained to ensure accuracy. Calibration of the system shall be performed per manufacturer's directions as often as
necessary to maintain correct pH readings at all times, with a minimum calibration frequency of once per month."
On November 6, 2018 Sunshine's pH meter was reading more than 1 s.u. different from TRU's reading. This suggests that
the pH meter and the alarm system is not being maintained in proper operating condition at all times.
Sunshine Uniform Service, Inc. is required to submit in writing, within fourteen days, corrective action taken to achieve
compliance regarding both of these issues.
Sincerely,
Two ers Uti 'ties
Cody Austin
Pretreatment Coordinator
Two Rivers Utilities
Certified Mail: 7014 0150 0000 7611 5512
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