NC0044121_NOV-2019-PC-0418_20190521

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
NORTH CAROLINA
Environmental Quality
21 May 2019
CERTIFIED MAIL #: 7018 0360 0002 2099 1772
RETURN RECEIPT REQUESTED
Mr. Shawn Pennell
Assistant Public Services Director/Public Utilities
City of Hickory
Post Office Box 398
Hickory, North Carolina 28603
Subject: Notice of Violation
Compliance Evaluation Inspection
Hickory WTP
NPDES Permit No. NCO044121
Catawba County
Tracking #: NOV-2019-PC-0418
Dear Mr. Pennell:
Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the subject facility on
May 8, 2019, by Mr. Wes Bell of this Office. Please inform the facility's Operator -in -Responsible Charge (ORC) of our findings
by forwarding a copy of the enclosed report.
This report is being issued as a Notice of Violation (NOV) due to the following:
1) Failure to analyze effluent pH and total residual chlorine samples within 15 minutes of collection (multiple
occasions);
2) Failure to properly collect effluent total nitrogen samples in April 2018, July 2018, October 2018 and January
2019.
These are violations of the subject NPDES Permit and North Carolina General Statute (G.S.) 143-215 as detailed in the
Record Keeping/Summary Section of the attached report. Pursuant to G.S. 143-215.6A, a civil penalty of not more than
twenty-five thousand dollars ($25,000.00) per violation, per day may be assessed against any person who violates or fails to act
in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S. 143-215.1. Penalties may also
be assessed for any damage to surface waters of the State that may result from the violations.
North Carolina Department of Environmental Quality I Division of Water Resources
D_ E� Mooresville Regional Office 1610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115
NORTH CAROLINA
Da"MoM a enWmn�bl mwnq 704,663.1699

Mr. Shawn Pennell
Page Two
21 May 2019
It is requested that a written response be submitted to this Office by June 14, 2019, detailing the actions taken to address all
above -noted violations. In responding, please address your comments to the attention of Mr. Wes 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.bellkncdenr.gov.
Sincerely,
DocuSigned by:
A14CC681 AF27425...
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
Enclosure:
Inspection Report

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 NC0044121 111 12 I 19/05/08 I17 18 I S I 19 I G I 201 I
211111 I I I I I I II I I I I I I I I I I I I I I I I I I I I I I I II I I I I I f6
Inspection
Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved -------------------
67
2.0 70 71 [.. I 72 73 L_LJ74 751 I I I I I I I80
I —I u
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)
09:27AM 19/05/08
16/03/01
Hickory WTP
1560 Old Lenoir Rd
Exit Time/Date
Permit Expiration Date
Hickory NC 28603
12:OOPM 19/05/08
20/04/30
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Mark E Haynes/ORC/828-323-7530/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Shawn Pennell,PO Box 398 Hickory NC 28603/Asst. Public Services
Director/828-323-7427/8283221405 No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program Sludge Handling Disposal Facility Site Review Effluent/Receiving Waters
Laboratory
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
Wes Bell cSignede by: MRO WQ//704-663-1699 Ext.2192/ 5/21/2019
E�:'�961D90=43T
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
W. Corey Basinger Division of Water Quality//704-2;
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
DocuSigned by:
e 5/21/2019
A14CC681AF27425...
Page#

NPDES yr/mo/day Inspection Type (Cont.)
NCO044121 I11 121 19/05/08 117 18 ICI
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
On -site Representatives:
The following City of Hickory personnel were in attendance during the inspection: Andrew Foy, Mark
Haynes, Wesley Boyd and Chris Osborne.
RECORD KEEPING SECTION cont'd:
Effluent pH and total residual chlorine (TRC) samples were not analyzed within 15 minutes of collection
(on multiple occasions) as required by 40 CFR 136.3 Table II. Staff must ensure that all holding times
are met for all permit monitoring requirements.
The facility reported the effluent total kjeldahl nitrogen (TKN) result as the effluent total nitrogen (TN)
result on the eDMRs during all quarterly sampling events (4-total) during this review period. Note: Only
the TKN analysis was designated on the chain of custody (CoC) forms submitted to the contracted lab.
Please be advised that TN is the sum of TKN and nitrite + nitrate values. Future CoCs must designate
TN to comply with the permit monitoring requirement. In addition, all applicable eDMRs (with the
quarterly TN values) from January 2018 to present must be revised and resubmitted to the Division.
Once processed, two signed copies of each revised eDMR must also be mailed in to the Division.
The facility staff must ensure that all sampling and analysis times (either military or a.m./p.m.) are
properly documented on internal and external CoCs for all effluent parameters including field (pH and
TRC).
Page#

Permit: NCO044121 Owner - Facility: Hickory WTP
Inspection Date: 05/08/2019 Inspection Type: Compliance Evaluation
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: The belt press has been taken out of service for many years.
The last compliance evaluation inspection was performed by DWR staff on 4/14/16.
Record Keeping
Yes No NA NE
Are records kept and maintained as required by the permit?
0
❑
❑
❑
Is all required information readily available, complete and current?
0
❑
❑
❑
Are all records maintained for 3 years (lab. reg. required 5 years)?
❑
❑
❑
Are analytical results consistent with data reported on DMRs?
❑0
❑
❑
Is the chain -of -custody complete?
❑
❑
❑
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
Are DMRs complete: do they include all permit parameters?
❑
❑
❑
Has the facility submitted its annual compliance report to users and DWQ?
❑
❑
❑
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator
❑
❑
❑
on each shift?
Is the ORC visitation log available and current?
❑
❑
❑
Is the ORC certified at grade equal to or higher than the facility classification?
❑
❑
❑
Is the backup operator certified at one grade less or greater than the facility classification?
❑
❑
❑
Is a copy of the current NPDES permit available on site?
❑
❑
❑
Facility has copy of previous year's Annual Report on file for review?
❑
❑
❑
Page# 3

Permit: NCO044121
Inspection Date: 05/08/2019
Record Keeping
Owner - Facility: Hickory WTP
Inspection Type: Compliance Evaluation
Comment: The records reviewed durina the inspection were oraanized and well maintained
Yes No NA NE
Discharge Monitoring Reports (eDMRs) were reviewed for the period April 2018 through
March 2019. No effluent limit violations were reported. A "0" mg/L was reported for TN and
total phosphorus (TP) in July 2018. All values must be reported down to the analytical
method's detection level. The required 10-day interval between the collection of the twice
per month samples (TSS, total residual chlorine, PH, turbidity) was not adhered to in
October 2018. See "Summarv" Section for additional comments.
Laboratory
Yes No NA NE
Are field parameters performed by certified personnel or laboratory?
0
❑
❑
❑
Are all other parameters(excluding field parameters) performed by a certified lab?
0
❑
❑
❑
# Is the facility using a contract lab?
0
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
0
❑
❑
❑
Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
❑
❑
0
❑
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
❑
❑
0
❑
Comment: On -site field analvses (pH and TRC) are performed under the Hickory Water Treatment
Plant's field laboratory certification #5072. Pace Analytical Services (all effluent parameter
except field and chronic toxicity) and ETT Environmental (chronic toxicity) have also been
contracted to provide analytical support.
The facility staff must ensure that the annual verification on the TRC meter's factory -set
calibration curve is performed every twelve months [Reference: NC
Wastewater/Groundwater Laboratory Certification Approved Procedure for the Analysis of
Total Residual Chlorine (DPD Method)].
Effluent Sampling
Yes No NA NE
Is composite sampling flow proportional?
❑
❑
0
❑
Is sample collected below all treatment units?
0
❑
❑
❑
Is proper volume collected?
0
❑
❑
❑
Is the tubing clean?
❑
❑
0
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
❑
❑
0
❑
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
0
❑
❑
❑
representative)?
Comment: The subject permit requires effluent grab samples.
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? 0 ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Page# 4

Permit: NCO044121
Inspection Date: 05/08/2019
Operations & Maintenance
Owner - Facility: Hickory WTP
Inspection Type: Compliance Evaluation
Yes No NA NE
Comment: All wastewater is conveved to an equalization (EQ) tank and the sludge (from EQ tank) is
pumped into a gravity thickener. All thickener sludge is pumped to the Hickory Northeast
WWTP for treatment/disposal.
The NPDES facilities appeared to be properly operated and well maintained. The facility is
equipped with a SCADA system to assist the staff with the operation of treatment
processes/units.
De -chlorination
Yes No NA NE
Type of system ?
Gas
Is the feed ratio proportional to chlorine amount (1 to 1)?
0
❑
❑
❑
Is storage appropriate for cylinders?
0
❑
❑
❑
# Is de -chlorination substance stored away from chlorine containers?
0
❑
❑
❑
Are the tablets the proper size and type?
❑
❑
0
❑
Comment: The EQ tank's supernate is dechlorinated with sulfur dioxide prior to flow measurement and
discharge to the receiving stream.
Are tablet de -chlorinators operational? ❑ ❑ 0 ❑
Number of tubes in use?
Comment:
Flow Measurement - Effluent
Yes No NA NE
# Is flow meter used for reporting?
0
❑
❑
❑
Is flow meter calibrated annually?
0
❑
❑
❑
Is the flow meter operational?
0
❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
❑
❑
0
❑
Comment: The flow meter is calibrated annually (at a minimum) and was last calibrated on 4/16/19 b
Diversified Integration.
Effluent Pipe
Yes No NA NE
Is right of way to the outfall properly maintained?
0
❑
❑
❑
Are the receiving water free of foam other than trace amounts and other debris?
0
❑
❑
❑
If effluent (diffuser pipes are required) are they operating properly?
❑
❑
0
❑
Comment: The effluent appeared clear with no floatable solids or foam. The receiving stream did not
appear to be negatively impacted.
Page# 5