NC0021156_Inspection_20190430

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
Mr. Doug Shoutd
Pretreatment Coordinator
City of Mount Holly
Post Office Box 406
Mount Holly, North Carolina 28120
Dear Mr. Shoutd:
NORTH CAROLINA
Environmental Quality
30 April 2019
Subject: Pretreatment Audit Inspection
City of Mount Holly
NPDES Permit No. NCO021156
Gaston County
Enclosed is a copy of the Pretreatment Audit Inspection Report for the inspection of the City of Mount Holly's
approved Industrial Pretreatment Program on April 25, 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(&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 AUDIT REPORT
Background Information:
1. Control Authority (POTW) Name: City of Mt. Holly
2. Control Authority Representative(s): Doug Shoutd, Nadine Blackwell
3. Title(s): Division Manager Wastewater, Consultant
4. Address of POTW:
Street/Post Office Box 400 E. Central Avenue/Post Office Box 406
City/State/Zip Code Mt. Holly, NC 28120
Phone Number: [phone] Fax Number: [phone] E-Mail: [e-mail]
[phone] [phone] [e-mail]
5. Audit Date: 4/25/19
6. Last Inspection Date: 3/8/17 Inspection Type: ® PCI ❑ Audit
7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s) ? ® Yes ❑ No
If No, Explain.
8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? ® Yes ❑ No
If Yes, Explain. 3 — effluent fecal coliform violations (1-monthly average, 2-weekly average) reported in June 2018;
2 — effluent total residual chlorine daily maximum violations reported in July and September 2018 (1 per month);
effluent dissolved oxygen daily minimum violation reported in September 2018.
9. Is POTW under an Order That Includes Pretreatment Conditions? ❑ Yes ® No
Order Type and Number: Are Milestone Dates Being Met? ❑ Yes ❑ No ® NA
Parameters Covered Under Order
ICIS Coding:
Main Program Permit Number
INIC1010I2 I1 I1 Is I6 1
MM/DD/YY
04I25I19
10. Current Number of Significant Industrial Users (SIUS)?
.....................................................................................................................................................................................................................................................................................................
3
SIUS
..........................
11. Current Number of Categorical Industrial Users (CIUS)?
.....................................................................................................................................................................................................................................................................................................
2
CIUS
..........................
12. Number of SIUS Not Inspected by POTW in Last Calendar Year?
.....................................................................................................................................................................................................................................................................................................
0
..........................
13. Number of SIUs Not Sampled by POTW in Last Calendar Year?
.....................................................................................................................................................................................................................................................................................................
0
..........................
14. Enter Higher Number of 12 or 13
.....................................................................................................................................................................................................................................................................................................
0
NOIN
..........................
15. Number of SIUS with No IUP, or with an Expired IUP
.....................................................................................................................................................................................................................................................................................................
0
NOCM
..........................
16. Number of SIUS in SNC for Either Reporting or Limits Violations During Either of Last 2
0
PSNC
Semi -Annual Periods (Total Number of SIUS in SNC)
.....................................................................................................................................................................................................................................................................................................
..........................
17. Number of SIUS in SNC for Reporting During Either of Last 2 Semi -Annual Periods
.....................................................................................................................................................................................................................................................................................................
0
MSNC
..........................
18. Number of SIUS in SNC for Limits Violations During Either of Last 2 Semi -Annual Periods
.....................................................................................................................................................................................................................................................................................................
0
SNPS
..........................
19. Number of SIUS in SNC for Both Reporting and Limits Violations During Either of Last 2
0
Semi -Annual Periods
20. Number of SIUS in SNC for Self -Monitoring Requirements that were Not Inspected or Sampled
0
SNIN
NC DWR Pretreatment Audit Form Revised: July 25, 2007 Page 1

21. PRETREATMENT PROGRAM ELEMENTS REVIEW
Program Element:
NCO021156
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
4/1/14
® Yes ❑ No
9/30/14
® Yes ❑ No
4/1/19
Industrial Waste Survey (IWS)
12/7/16
® Yes ❑ No
3/13/17
® Yes ❑ No
12/1/21
Sewer Use Ordinance (SUO)
12/20/12
® Yes ❑ No
1/14/13
® Yes ❑ No
Enforcement Response Plan (ERP)
9/15/10
® Yes ❑ No
12/15/10
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
3/30/16
® Yes ❑ No
5/4/16
® Yes ❑ No
Legal Authority (Sewer Use Ordinance-SUO)
22. Do you have any towns and/or areas from which you receive wastewater which are not in your annexed jurisdiction?
❑ Yes ® No If yes, Please list these towns and/or areas.
23. If yes to #22, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? ❑ Yes ❑ No ® NA
A copy, if not already submitted, should be sent to Division.
24. If yes to #22, Have you had any trouble working with these towns or districts? ❑ Yes ❑ No ® NA
If yes, Explain.
25. Date of Last SUO Adoption by Local Council 11/12/12
26. Have you had any problems interpreting or enforcing any part of the SUO? ❑ Yes ® No
If yes, Explain.
Enforcement (Enforcement Response Plan-ERP)
27. Did you send a copy of the ERP to your industries? ® Yes ❑ No
If no, POTW must send copy within 30 days.
28. Have you had any problems interpreting or enforcing any part of the ERP (i.e. any adjudication, improper enforcement, etc?
❑ Yes ® No If yes, Explain.
29. List Industries under a Schedule or Order and Type of Schedule or Order
None
Resources
30. Please Rate the Following: S=Satisfactory M=Marginal U=Unsatisfactory
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
®S ❑M ❑U
Access to POTW Vehicles for
Sampling, Inspections, and
®S ❑M ❑U
Emergencies
Access to Operable Sampling
Equipment
❑S ❑M ❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
®S ❑M ❑U
Reference Materials
®S ❑M ❑U
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
®S ❑M ❑U
Computer Equipment (Hardware and
Software)
®S ❑M ❑U
NC DWR Pretreatment Audit Form Revised: July 25, 2007 Page 2

31. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No
Explain Yes or No. Excel Spreadsheets, electronic compliance tracking and compliance judgement.
32. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain. The SIUs are billed every six
months to recover Pretreatment/sampling costs.
Public Perception/ Participation:
33. Are there any local issues affecting the pretreatment program (e.g.. odor, plant closing, new or proposed plants)?
❑ Yes ® No If yes, Explain. No short term issues; however, long term plans include the closing of the WWTP and
sending the wastewater to another POTW (Charlotte Water). Note: The POTW (City of Mt. Holly) will continue to
implement the Industrial Pretreatment Program.
34. Has any one from the public ever requested to review pretreatment program files? ❑ Yes ® No
If yes, Explain procedure. If no, How would the request be addressed? The written request would be made to the City
Engineer/Utility Director and Pretreatment Coordinator to schedule a file review. The file review would take place at City
Hall.
35. Has any industry ever requested that certain information remain confidential from the public? ❑ Yes ® No If yes, Explain
procedure for determining whether information qualified for confidential status, as well as procedure for keeping files confidential
from public. If no. how would the request be addressed? The request would have to be made in writing to the City
Engineer/Utility Director and the information would be reviewed by the Pretreatment Coordinator/Consultant.
Confidential files would be kept in a locked file cabinet.
36. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? ® Yes ❑ No
37. Is the public notified about changes in the SUO or Local Limits? ® Yes ❑ No
38. Were all industries in SNC published in the last notice? ❑ Yes ❑ No ® NA
Permitting (Industrial Waste Survey-IWS):
39a... How does the POTW become aware of new or changed Users? The Pretreatment Coordinator is included on all
applications for new businesses, construction activities, etc.
39b. Once the POTW becomes aware of new or changed Users, how does the POTW determine which industries have the
reasonable potential to adversely impact the WWTP and therefore require a new permit or a permit revision? (Who is an
SILT?) Information on the IWS form is reviewed for wastewater characteristics, flow volumes, POCs, categorical
determinations, and other potential impacts to WWTP.
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
®Yes ❑No If Yes, How many are there? 2
Please list each site and how it is permitted, if applicable. Jadco Hughes Co. (contracted operation) and Triangle
Texaco; local permits
41. Does the POTW accept waste by (mark if applicable) ❑ Truck ❑Dedicated Pipe ® NA
42. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples drawn,
manifests required) No trucked waste is accepted (including septage haulers).
43. How does the POTW allocate its loading to industries? Mark all that apply
❑ Uniform Limits ® Historical Industry Need ❑ By Surcharge ® Categorical Limits ❑ Other
Explain Other:
44. Review POTW's copies of current allocation tables for each WWTP. Are there any over allocations? ® Yes ❑ No
If yes, What parameters are over allocated? Total Nitrogen (TN) and Total Phosphorus (TP)
45. If yes to #44, What is being done to address the over allocations? (short-term IUPs, HWA to be revised, pollutant study, etc.)
TN permit limit (seasonal loading) became effective April 1, 2017 and TP yearly loading limit became effective January 1, 2015.
The WWTP has maintained consistent compliance with TN and TP effluent limits due in part to an increase in
denitrification in the two aeration basins in service and process adjustments (alum additions, etc.).
46. Does the POTW keep pollutant loading in reserve for future growth / safety? ® Yes ❑ No
If yes, what percentage of each parameter? 10%
NC DWR Pretreatment Audit Form Revised: July 25, 2007 Page 3

47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) ❑ Yes ® No
If yes, Explain.
48. How does the POTW decide on which pollutants to limit in the permits? Monitor for? (for example: were only those pollutants
listed on the application limited; categorical parameters; NPDES Pollutants of Concern) Application review, categorical
parameters, NPDES POCs, potential impacts to WWTP.
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits ? Explain.
New and current SIUs monitor monthly. Monitoring frequencies can be adjusted accordingly based on the discharge data.
Permit Compliance:
50. Does the POTW currently have or during the past year had any permits under adjudication? ❑ Yes ® No
If yes, which industries? What was (will be) the outcome of the adjudication?
51. Demonstrate how the POTW judges compliance. This should include compliance judgment on all violations of limits, reporting
requirements, and permit conditions, as well as for SNC. Compliance judgement per comprehensive guidance, violations (limit,
monitoring, reporting, permit conditions, etc.) are addressed per ERP.
52. Does the POTW use the Division's model inspection form or equivalent? ® Yes ❑ No
If no, does the POTW form include all DWQ data? ❑ Yes ❑ No
53. Were all SIUs evaluated for the need of a slug/spill control plan during their most recent inspections? ® Yes ❑ No
If no, Explain.
54. What criteria are used to determine if a slug/spill control plan is needed?
All SIUs are required to develop and submit a slug/spill control plan.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Contacts are up to date, adequate emergency notification procedures, presence of emergency response equipment, proper
secondary containment, employee training, identification of authorized personnel to stop production/operations
56. How does the POTW decide where the sample point for an SIU should be located?
Categorical — end of pipe (process wastewater and combined waste streams are both evaluated to determine sampling
point), Non -categorical — pretreatment system effluent.
57. Has the POTW established a procedure to ensure that representative samples will be taken by the POTW or SIU each time?
(example: correct location; proper programming of sampler; clean equipment; swirling the sample bucket uniformly)
POTW: ® Yes ❑ No SIU: ® Yes ❑ No If yes, Explain. Sampling SOPS, contract lab performs sampling
for POTW and SIUs. SIUs
58. Who performs sample analysis for the POTW for Metals Shealy Environmental Services
Conventional Parameters Shealy Environmental Services
Organics Shealy Environmental Services
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
POTW uses internal COC and/or contract lab's COC; SIUs used contracted lab's COC.
Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis (HWA):
60a.
60b.
60c.
60d.
60e.
60f.
Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑ NO
Are Correct Detection Levels being used for all LTMP/STMP Monitoring? EYES ❑ NO
Is LTMP/STMP Data Maintained in Table or Equivalent? ® YES ❑ NO Is Table Adequate? ® YES ❑ NO
All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? ® YES ❑ NO DWQ Inspector, verify yourself!
If NO to any above, list violations
Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ® NO
If yes, which ones? Eliminated:
Added:
61. Do you complete your own headworks analysis (HWA) ? ❑ Yes ® No
If no, Who completes your HWA? Nadine Blackwell, Suez, Inc. Phone [phone]
NC DWR Pretreatment Audit Form Revised: July 25, 2007 Page 4

62. Do you have plans to revise your HWA in the near future? ❑ Yes ® No
If yes, What is the reason for the revision? (mark all that apply) ❑Increased average flow ❑NPDES limits change
❑More LTMP data available ❑Resolve over allocation ❑5 year expiration ❑Other, explain.
63. In general, what is the most limiting criteria of your HWA?
❑Inhibition ❑ Pass Through ®Sludge Quality
64. Do you see any way to increase your loading in the future (Example: obtaining more land for sludge disposal)? ❑ Yes ❑ No
Explain. N/A
Summary:
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
Not within in the near future.
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW:
66. User Name
1. Daimler Trucks NA
2. Clariant Corp.
3. American & Efird
67. IUP Number
1 1163
1158
1 1157
68. Does File Contain Current Permit?
I
®
Yes ❑ No
® Yes ❑
I ® Yes ❑ No
69. Permit Expiration Date
1 12/31/22
12/31/22
22/31/22
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
1 433
414 & 455 71
410
71. Does File Contain Permit Application Completed Within One Year Prior
® Yes ❑ No
®Yes ❑ No
® Yes ❑ No
to Permit Issue Date?
72. Does File Contain Inspection Completed Within Last Calendar Year?
® Yes ❑ No
® Yes ❑ No 11
® Yes ❑ No
73. a. Does File Contain 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. []Yes []No
b. ❑Yes ❑No
b. []Yes []No
74. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
❑Yes❑No®N/A
❑Yes❑NoEN/A
❑Yes❑NoEN/A
Organic Management Plan (TOMP)?
75. a. Does File Contain Original Permit Review Letter from Division?
a. EYes ❑No
I
a. ®Yes ❑No
a. EYes ❑No
b. All Issues Resolved?
b.❑Yes❑No®N/A
b.❑Yes❑No®N/A
b.❑Yes❑No®N/A
76. During Most Recent Semi -Annual Period, Did POTW Complete its
® Yes ❑
® Yes ❑ No
® Yes ElNo
Sampling as Required b IUP, includingFlow?
!11
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
78. During Most Recent Semi -Annual Period, Did SIU Complete its
®Yes❑No❑N/A
®Yes❑No❑N/A
®Yes❑No❑N/A
Sampling as Required by IUP, including Flow?
79. During Most Recent Semi -Annual Period, Did SIU submit all reports on
®Yes❑No❑N/A
®Yes❑No❑N/A
❑Yes®No❑N/A
time?
80a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑MEN/A
❑Yes❑NoEN/A
❑Yes❑NoEN/A
file include process/dilution flows as Required b IUP?
80b. For categorical IUs with Production based limits, does file include
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑No®N/A
production rates and/or flows as Required by IUP?
81. During Most Recent Semi -Annual Period, Did POTW Identify All
®Yes❑No❑N/A
❑Yes❑NoEN/A
❑Yes❑NoEN/A
Limits Non -Compliance from Both POTW and SIU Sampling?
82. During Most Recent Semi -Annual Period, Did POTW Identify All
❑Yes❑MSN/A
❑Yes❑NoEN/A
®Yes❑No❑N/A
Re ortin Non-Com liance from SIU Sampling?
83. a. Was 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. If applicable, did POTW resample and obtain results within 30 days of
becoming aware of SIU limit violations in the POTW's sampling of SIU?
c.❑Yes❑No®N/A
c.❑Yes❑No®N/A
c.❑Yes❑No®N/A
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
I
❑ Yes
® No
❑ Yes
® No
❑
Yes
®
No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
®Yes❑No❑N/A
❑Yes❑NoEN/A
®Yes❑No❑N/A
Specified in POTW's ERP (NOVs, Penalties, timing, etc.)?
86. Does File Contain Penalty Assessment Notices?
❑Yes❑NOON/A
❑Yes❑No®N/A
❑Yes❑NoON/A
87. Does File Contain Proof Of Penalty Collection?
❑Yes❑NOON/A
❑Yes❑NoEN/A
0Yes0No0N/A
88. a. Does 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
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
❑ Yes ® No
❑ Yes ®No
ElYes ® No
Information For You?
11
NC DWR Pretreatment Audit Form Revised: July 25, 2007 Page 5

FILE REVIEW COMMENTS:
72. POTW inspection dates: Daimler Trucks NA - 10/17/18; Clariant Corp. - 10/9/18; American & Efird - 10/9/18.
58/76. POTW contracts Shealy Environmental Services to perform all SIU sampling and analyses (including conventional parameters).
The POTW's certified lab performs TSS, pH, dissolved oxygen, and temperature analyses for LTMP sampling.
78. Daimler Trucks NA and Clariant both contract Shealy Environmental Services to perform sampling and analyses. American &
Efird contracts Pace Analytical Services to perform analyses.
85. The POTW issued a NOV to Daimler for a flow violation in December 2018; however, the NOV was later rescinded due to
operational issues with the SIU's flow measurement system. American & Efird was issued a NOV due to the failure to report the
December 2018 monitoring results by the 20th of the following month.
INDUSTRY INSPECTION PCS CODING:
Trans.Code Main Program Permit Number MM/DD/YY Inspection type Inspector Facility Type
0 N C 0 0 2 1 1 109 125 19 ❑ 3:1 2❑
(DTIA) (TYPI) (INSP) (FACC)
1. Industry Inspected: American & Efird
2. Industry Address/Mailing: PO Box 507, Mt. Holly, NC 28120 Physical: 20 American Street, Mt. Holly, NC 28120
3. Type of Industry/Product: Dyed Thread
4. Industry Contact: John Smith Title: Plant Engineer Phone: [phone]
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:
The manufacturing facility has 380 employees and operates three shifts, twenty-four hours per day, six days per week. The facility's
operations include receiving, dyeing, and packaging and approximately 380,000 lbs. per week of finished product is currently being
produced. Giant Recovery Services has been contracted to haul off all hazardous waste. The pretreatment facility consists of an aerated
equalization basin, pH adjustment, and flow measurement. The basin was last cleaned out in 2012 with all sludge being disposed at a
permitted landfill.
The facility's records were organized and well maintained. The facility's composite sampler was evaluated during the inspection and it
was determined that the sampler did not collect samples over the entire 24-hr. period (stopped after approximately 17/18 hours of
operation). The POTW staff will work with the SIU to ensure sampling SOPS are maintained and future composite samplers are
properly collected. Note: The facility was not sampling at the time of the inspection.
SUMMARY AND COMMENTS:
The POTW's records were organized and well maintained. The POTW's Industrial Pretreatment Program was being properly
implemented. Pretreatment staff must ensure all SIUs are properly collecting composite samples according to the IUP.
NC DWR Pretreatment Audit Form Revised: July 25, 2007 Page 6

NOD: ❑ Yes
NOV: ❑ Yes
QNCR: ❑ Yes
POTW Ratiniz:
11
Satisfactory ® Marginal ❑ Unsatisfactory ❑
E�`,,96D90CC3437
Signedd by:
'Be,AUDIT COMPLETED BY: ... DATE: 4/30/2019
Wes Bell, Env. Specialist II
DocuSigned by:
AUDIT REVIEWED BY: A14CC681AF27425...
W. Corey Basinger, Regional Supervisor
DATE: 4/30/2019
NC DWR Pretreatment Audit Form Revised: July 25, 2007 Page 7