NC0025984_PCI_20190509

DocuSign Envelope ID: A8C22860-D80E-461 E-B270-A2D8406C3FF4
ROY COOPED
G&v-�rr1ar
K41CHAEL S. R.EGAN
SEC-rerary
LINDA CULPEPPER
arwtor
John Condrey, Town Manager
Town of Forest City
PO Box 728
Forest City, NC 28043-0728
NORTH CAROL INA
Environmental Qual"
May 09, 2019
SUBJECT: Pretreatment Compliance Inspection Report
Forest City WWTP
NPDES WW Permit No. NCO025984
Rutherford County
Dear Permittee:
The North Carolina Division of Water Resources conducted a Compliance Inspection of the Forest City WWTP's
Pretreatment Program on 5/1/2019. The findings and comments noted during this inspection are provided in
the enclosed copy of the inspection report entitled "Compliance Inspection Report".
There were no significant issues or findings noted during the inspection and therefore, a response to this
inspection report is not required
If you should have any questions, please do not hesitate to contact Mikal Willmer with the Water
Quality Regional Operations Section in the Asheville Regional Office at 828-296-4500 or via email at
[e-mail].
ATTACHMENTS: Inspection Report
EC: WQS-ARO Server
LF-PERCS
Jacob Hodge: Pretreatment Coordinator
Sincerely,
byV
COBABAEBEC2434B4_.
�
Mikal Willmer, Environmental Specialist I
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ
North Cam rs depart ment of-Enviro mental Qua-ty I ❑ivisian of Water Resou rw_s
AsF, v E.- fiagors:lDffice 1 2090il.S_70Ktgb ray I Svrannsnoa, North Caro,:rs 2577-5
52 S-ZZ a6-45D D

DocuSign Envelope ID: A8C22860-D80E-461 E-B270-A2D8406C3FF4
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 NCO025984 111 12 I 19/05/01 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)
10:OOAM 19/05/01
16/04/01
Forest City WWTP
397 Riverside Dr
Exit Time/Date
Permit Expiration Date
Forest City NC 28043
03:OOPM 19/05/01
19/07/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Jeffery W Dotson/ORC/828-248-5217/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Charles R Summey,PO Box 728 Forest City NC 280430728//828-248-5203/
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit
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
Mikal Willmer DS L/!/ Division of Water Quality//828-296-4686
5/10/2019
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers
Date
D... Sig— by:
[
J/10/2019
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

DocuSign Envelope ID: A8C22860-D80E-461 E-B270-A2D8406C3FF4
NPDES yr/mo/day Inspection Type (Cont.)
NCO025984 I11 121 19/05/01 117 18 I p I
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Inspector Mikal Willmer, with the Asheville Regional Office, conducted a Pretreatment Compliance
Inspection of the Town of Forest City's WWTP Pretreatment Program under Permit No. NC0025984.
This inspection was conducted to determine whether the program is being managed and maintained in
compliance with all Pretreatment regulations. Jacob Hodge (pretreatment coordinator) and Sonny
Penson (WWTP ORC) were present and assisted in the inspection.
Overall the program is being managed and maintained in compliance with pretreatment requirements.
There are currently 5 SIUs, two of which are CIUs. No ongoing issues reported with four of the five
facilities. No facilities were in SNC for 2018. Steps were taken in 2017 to bring Valley Fine Foods back
into compliance. Issues arose with Everest Textiles in 2018 relating to O&G discharges. O&G monitor
only was added to the permit in September of 2018. O&G monitoring indicated elevated levels being
discharge to the treatment plant. In February 2019 a limit of 40 mg/L of O&G was added to the permit.
The facility has been unable to meet these limits and was placed under a consent order on April 26,
2019 for six months, with the permit limit being raised to 100 mg/L (in line with the SUO). Additionally,
Everest Textiles is required to implement a permanent solution to manage the O&G being discharged
to Forest City.
Page#

DocuSign Envelope ID: A8C22860-D80E-461 E-13270-AM8406CYF4
Permit: NC0025984 Owner - Facility: Forest City WWTP
Inspection Date: 05/01/2019 Inspection Type: Pretreatment Compliance
Permit
Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new
❑
❑
0
❑
application?
Is the facility as described in the permit?
❑
❑
0
❑
# Are there any special conditions for the permit?
❑
❑
0
❑
Is access to the plant site restricted to the general public?
❑
❑
0
❑
Is the inspector granted access to all areas for inspection?
❑
❑
0
❑
Comment: See summary for details. Inspection of pretreatment program.
Page# 3

DocuSign Envelope ID: A8C22860-D80E-461E-B270-A2D8406C3FF4
NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
Water Resources
ENVIRONMENTAL OVAL I TY
BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)l
1. Control Authority (POTW) Name: Forest City WWTP
2. Control Authority Representative(s): Jacob Hodge & Sonny Penson
3. Title(s): Pretreatment Coordinator & ORC
4. Last Inspection Date: 02/9/2017 Inspection Type (Check One): ❑ PCI ®Audit
5. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? ❑ YES ❑ NO ®N/A
6. Is POTW under an Order That Includes Pretreatment Conditions? ❑ YES ® NO
Order Type, Number, Parameters:
ICIS CODING
Main Program Permit Number
NIC101012151918141
Are Milestone Dates Being Met? ❑ YES ❑ NO
MM/DD/YY
1 05 101 119 1
7. Current Number Of Significant Industrial Users (SIUs)?
5
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?
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?
I
15. Current Number Of Categorical Industrial Users CIUs ?
2
16. Number of 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 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
Industry is under a
Consent Order and now has
0&G limits within permit.
Limits:0
Reporting:0
Ilished:N/A
IUP#0009 Everest Textile is under
a consent order as of 4/26/19.
❑ 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 (see 26. below)
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? Z YES U NO Inspector, please verify yourself.
26. If NO to 23 - 26, list violations -current laboratory used for metals analysis states they cannot meet limits for silver,
cadmium and selenium (will send Pre -Tx coordinator methods used by state lab).
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1

DocuSign Envelope ID: A8C22860-D80E-461E-B270-A2D8406C3FF4
27. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ® NO
If yes, which ones? Eliminated: POTW has concerns about the added costs of the metals monitoring every six months
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

DocuSign Envelope ID: A8C22860-D80E-461 E-13270-AM8406C3FF4
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:
Program Element
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
8/16/18
® Yes ❑ No
8/17/18
® Yes ❑ No
3/1/24
Industrial Waste Survey WS
8/31/18
® Yes ❑ No
10/5/18
® Yes ❑ No
9/1/23
Sewer Use Ordinance SUO
12/31/12
® Yes ❑ No
2/25/13
® Yes ❑ No
N/A
Enforcement Response Plan (ERP)
2/22/13
® Yes ❑ No
5/1/13
® Yes ❑ No
I N/A
Long Term Monitoring Plan (LTMP)
8/22/18
® Yes ❑ No
8/29/18
® Yes ❑ No
I N/A
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name
1. Everest Textile
2. WestRock
3. Valley Fine Foods
30. IUP Number
0009
0005
0004
31. Does File Contain Current Permit?
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
32. Permit Expiration Date
2/28/2020
2/28/2020
2/28/2020
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
N/A
433 &463
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`?
® 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. ❑Yes ❑No
b. []Yes []No
b. ❑Yes [:]No
®N/A
®N/A
®N/A
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
❑Yes❑NoEN/A
®Yes❑No❑N/A
❑Yes❑NoEN/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❑NomN/A
b.❑Yes❑NomN/A
b.❑Yes❑NomN/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?
®Yes ❑ No
® Yes ❑ No
®Yes ❑ No
41. During the Most Recent Semi -Annual Period, Did the SIU Complete its
YesENo❑N/A
r
®Yes❑No❑N/A
®Yes❑No❑N/A
Sampling as Required b 1UP, includingflow?
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❑NoEN/A
®Yes❑No❑N/A
file includeprocess/dilution flows as Required by IUP?
42b. For categorical IUs with Production based limits, does file include
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑NoEN/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?
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
EYes❑No❑N/A
❑Yes❑NoEN/A
❑Yes❑NoEN/A
All Re ortin Non -Compliance from SIU Sampling?
44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
a.❑Yes❑NomN/A
a.®Yes❑No❑N/A
a.❑Yes❑NomN/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 within 30 days of becoming aware
c.❑YesmNo❑N/A
of SIU limit violations in the POTW's sampling of the SIU?
c.❑Yes❑NomN/A
c.❑Yes❑No®N/A
46. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
❑
Yes
®
No
❑
Yes
®
No
I
❑
Yes
®
No
47. During the Most Recent Semi -Annual Period, Was Enforcement Taken
❑Yes❑NoEN/A
EYes❑No❑N/A
EYes❑No❑N/A
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
48. Does the File Contain Penalty Assessment Notices?
❑Yes❑NoEN/A
❑Yes❑NoEN/A
EYes❑No❑N/A
49. Does The File Contain Proof Of Penalty Collection?
❑Yes❑NoEN/A
❑Yes❑NoEN/A
EYes❑No❑N/A
50. a. Does the File Contain Any Current Enforcement Orders?
a.®Yes❑No❑N/A
a.❑Yes❑NomN/A
a.❑Yes❑No®N/A
b. Is SIU in Compliance with Order?
b.mYes❑No❑N/A
b.❑Yes❑NomN/A
b.❑Yes❑NomN/A
51. Did the POTW Representative Have Difficulty in Obtaining Any of This
El!]FMTeTMYes ®
® No
Requested Information For You?
!oFMT;T
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3

DocuSign Envelope ID: A8C22860-D80E-461E-B270-A2D8406C3FF4
FILE REVIEW COMMENTS:
Everest Textiles went under a sixth month consent order on April 26, 2019. By 8/23/2019, Everest Textiles is supposed to have a
plan in place to bring down the concentration of O&G in their industrial discharge.
44.(c): Everest: POTW sampling of pH indicated a violation of the permit limit. SIU sampled within 30 days and appeared to be in
compliance. VFF: POTW sampling indicated zinc and pH violations and SIU resampled within 30 days.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
1. Industry Inspected:
2. Industry Address:
Type of Industry/Product:
4. Industry Contact: Title:
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:
OVERALL SUMMARY AND COMMENTS:
Comments: Overall the program is being well maintained. Mr. Hodge reports there is good communication with industries. The only
facility that appears to be of continual concern is Everest Textile in relation to their O&G management. The Town is conducting
additional monitoring of the facility as a precaution. The Town should continue to keep the Regional Office and PERCS informed
of any new developments relating to progress with the conditions of the consent order.
Requirements:
Recommendations:
NOD: ❑ YES ❑ NO
NOV: ❑ YES ❑ NO
QNCR: ❑ YES ❑ NO
POTW Rating:
Satisfactory X Marginal UnSatisfactory
PCI COMPLETED BY: Mikal Willmer DATE: 5/1/2019
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 4

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Mikal Willmer
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217 W. Jones Street
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Raleigh, NC 27699
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[e-mail]
IP Address: 149.168.204.10
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May 10, 2019 1 09:26 [e-mail]
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North Carolina Department of Environmental Quality
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DEQ, Division of Water Resources, Water Quality
Regional Operatoins
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