NC0036196_Inspection_20190612 (2)

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
CERTIFIED MAIL #: 7018 0360 0002 2099 1857
RETURN RECEIPT REQUESTED
Mr. James Wentz, Public Works Director
City of Newton
PO Box 550
Newton, North Carolina 28658
Dear Mr. Wentz:
NORTH CAROLINA
Environmental Quality
12 June 2019
Subject: Notice of Violation
Pretreatment Compliance Inspection
City of Newton
NPDES Permit No. NCO036196
Catawba County
Tracking #: NOV-2019-PC-0462
Enclosed is a copy of the Pretreatment Compliance Inspection Report for the inspection of the City of Newton's
approved Industrial Pretreatment Program on June 5, 2019, by Mr. Wes Bell of this Office.
This report is being issued as a Notice of Violation (NOV) due to the City's failure to properly implement the
Pretreatment Program, violations of North Carolina General Statute (G.S.) 143-215.1, 15A North Carolina
Administrative Code (NCAC) 2H .0905, and the subject NPDES Permit. Specifically, the City failed to initiate
enforcement according to the Division approved Enforcement Response Plan (ERP) on Special Metals Welding
Products Company (IUP #1015) for BOD and COD limit violations and Technibilt LTD (IUP #1018) for pH
monitoring violations during the second half of 2018 and first half of 2019. Pursuant to G.S. 143-215.6A, a civil
penalty of not more than twenty-five thousand dollars ($25,000.00) 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.
In order to come back into compliance with the requirements of the Pretreatment Program, the City must initiate
enforcement actions on the limit and monitoring violations by June 28, 2019. It is requested that a written response
be submitted to this Office by July 5, 2019, addressing the City's actions to prevent the recurrence of these violations.
In responding, please address your comments to Mr. Bell.
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

Mr. James Wentz
Page Two
12 June 2019
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 [e-mail].
Sincerely,
DocuSigned by:
A14CC681 AF27425...
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
Enclosure:
Inspection Report

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
BACKGROUND INFORMATION
1. Control Authority (POTW) Name: City of Newton
2. Control Authority Representative(s): Stacy Rowe
3. Title(s): Pretreatment Coordinator
4. Last Inspection Date: 5/22/18 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
PCS CODING
Main Program Permit Number MM/DD/YY
NCO036196 6/5/19
7. Current Number Of Significant Industrial Users SIUs ?
2
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
1
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?
0
15. Current Number Of Categorical Industrial Users (CIUs)?
2
16. Number of CIUs in SNC?
1
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 foi
either of the Last 2 Semi -Annual Periods? Not Been Published for (Januar
Public Notice?(May refer to PAR if Excessive SIUs in SNC) Decemb
SNC foi
Not Pu
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
Daily maximum TRC violations
in October 2018 and April 2019.
Monthly average flow violation
in February 2019.
❑ YES ®NO
Limits: Special Metals — BOD & COD
V — June 2018) & COD (July —
ar 2018)
Reporting: None
)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
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1

26. If NO to 23 - 26, list violations:
27. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ® NO
28. PRETREATMENT PROGRAM ELEMENTS REVIEW
Program Element
Last Submittal Received
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
11/10/17
® Yes ❑ No
1/19/18
® Yes ❑ No
10/1/22
Industrial Waste Survey (IWS)
11/3/14
® Yes ❑ No
3/26/15
® Yes ❑ No
10/1/19
Sewer Use Ordinance (SUO)
12/18/12
® Yes ❑ No
2/11/13
® Yes ❑ No
Enforcement Response Plan (ERP)
5/23/16
® Yes ❑ No
8/18/16
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
6/30/15
® Yes ❑ No
8/5/15
® Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW
29. User Name
1. Technibilt 2. Special Metals
3.
30. IUP Number
1018
1015
31. Does File Contain Current Permit?
® Yes ❑ No
® Yes ❑ NoI
❑ Yes ❑ No
32. Permit Expiration Date
7/31/20
7/31/20
33. Categorical Standard Applied I.E. 40 CFR, Etc. Or N/A
433.17
471.35
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 11
❑ 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
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
®Yes❑No❑N/A
❑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?
1
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
® 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
®Yes❑No❑N/A
❑Yes❑No❑N/A
on time?
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
®Yes❑No❑N/A
❑Ycs❑No®N/A
❑Yes❑No❑N/A
file include process/dilution flows as Required by IUP?
42b. 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 b IUP?
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
®Yes❑No❑NA
®Yes❑No❑N/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
❑Yes®No❑N/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?
❑
Yes
®
No
®
Yes
❑
No
❑
Yes
❑
No
46. During the Most Recent Semi -Annual Period, Was Enforcement Taken
❑Yes®No❑N/A
❑Yes®No❑N/A
❑Yes❑No❑N/A
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
47. Does the File Contain Penalty Assessment Notices?
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑No❑N/A
48. Does The File Contain Proof Of Penalty Collection?
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑No❑N/A
49. a. Does the File Contain Any Current Enforcement Orders?
a.❑Yes❑No®N/A
a.❑Yes❑No®N/A
a.❑Yes❑No❑N/A
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

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:
20. Special Metal's Consent Order expired on 5/3/19.
28. Silver over allocation has been addressed by the modification of IUPs.
b.❑Yes❑No®N/A 11
b.❑Yes❑No®N/A
I b.❑Yes❑No❑N/A
❑ Yes ®No
El Yes ®!]=
No
35. The POTW performed the SIU inspections on 6/1/18 (Technibilt) and 6/19/18 (Special Metals).
39. The POTW's on -site certified laboratory analyzes BOD, TSS, ammonia, COD, and pH. Meritech Labs has been contracted to perform
metals, oil & grease, fluoride, and TKN.
41a. Technibilt and Special Metals both contract Pace Analytical Services to perform analyses.
41b. Technibilt failed to perform/submit pH samples as required by the IUP (following the 6/1/18 permit modification).
45. The POTW had failed to determine SNC status for Special Metals during the second half of 2018 for COD TRC violations. The Division
has previously addressed this violation through the issuance of a NOV. Note: The POTW had addressed the violations (placing the SIU in SNC
and issuance of a public notice) prior to this inspection.
46. The POTW issued NOVs to Technibilt for TSS (September 2018) and flow (November 2018) IUP limit violations. Special Metals was
issued NOVs for BOD and COD IUP limit violations in October 2018.
The POTW failed to initiate enforcement according to the Division approved ERP for BOD and COD IUP limit violations (July, August,
September 2018) for Special Metals and pH IUP monitoring violations for Technibilt (last half of 2018 and first half of 2019).
SUMMARY AND COMMENTS:
Technibilt's IUP was modified on 11/11/16 to remove the pH self -monitoring requirement; however, the 6/1/18 permit modification added the
pH monitoring requirement back onto the effluent limits/monitoring requirements page (Part 1 Section F). Whether or not this was an oversight,
once the parameter is included in the IUP, all limit/monitoring requirements must be adhered to. If the POTW's intent is to remove the pH
monitoring requirement, then the IUP must be modified and submitted to the PERCS Unit for review/approval. The modified permit must also
include the 11/11/16 permit modification on the permit history page that was left off the 6/1/18 permit modification.
The POTW must initiate enforcement according to the Division approved ERP for the July, August and September 2018 IUP limit violations
(Special Metals) and the pH monitoring violations during last half of 2018 and first half of 2019 (Technibilt) by June 28, 2019.
The POTW should continue to make improvements to the record keeping system and ensure all IUPs are accurate and complete prior to
submittal. In addition, the POTW must ensure all LTMP samples are flow proportional composite samples.
NOD: [-]YES ® NO
NOV: ® YES ❑ NO
QNCR: ® YES ❑ NO
POTW Rating:
Satisfactory ❑ Marginal ® Unsatisfactory ❑
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3

E-:-'96D90CC3437
cuSignedd by:
PCI COMPLETED BY: ...
Wes Bell, Environmental Specialist II
DATE: 6/12/2019
DocuAASigned by:
PCI REVIEWED BY: niaccsainFvazs... DATE:
Corey Basinger, Regional Supervisor
6/12/2019
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 4