NC0020591_PCI_20210716

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
Andy Smith
City of Statesville
Post Office Box 1111
Statesville, North Carolina 28677
Dear Mr. Smith:
NORTH CAROLINA
Environmental Quality
July 16, 2021
Subject: Pretreatment Compliance Inspection
City of Statesville
NPDES Permit No. NC0020591
Iredell County
Enclosed is a copy of the Pretreatment Compliance Inspection (PCI) Report for the inspection of the City of
Statesville's Industrial Pretreatment Program on July 14, 2021, by Mr. Wes Bell of this Office. Please inform the City's
Pretreatment Coordinator of our findings by forwarding a copy of the enclosed report.
Should you have any questions concerning this report, please do not hesitate to contact Mr. Bell at [phone],
or via email at [e-mail].
Enclosure: Inspection Report
NORTH
Deparlmant of Environmental Ouallt
Sincerely,
�DocuSigned by:
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W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
North Carolina Department of Environmental Quality 1 Division of Water Resources
Mooresville Regional Office 1610 East Center Avenue, Suite 301 I Mooresville, North Carolina 28115
704.663.1699

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
BACKGROUND INFORMATION:
1. Control Authority (POTW) Name: City of Statesville
2. Control Authority Representative(s): Brandy Johnson
3. Title(s): Pretreatment Coordinator
4. Last Inspection Date: 1/10/19 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
ICIS CODING
Main Program Permit Number
NC0020591
MM/DD/YY
07/14/21
7. Current Number Of Significant Industrial Users (SIUs)?
10
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?
0
15. Current Number of Categorical Industrial Users (CIUs)?
8
16. Number CIUs in SNC?
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
either of the Last 2 Semi -Annual Periods? Not Been Published for
Public Notice?(May refer to PAR if Excessive SIUs in SNC)
N/A
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?
/1 YES ❑ NO
See Comments Section
❑ YES aO
dished: N/A
N/A
❑ YES /1 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
26. If NO to 23 - 26, list violations:
27. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ® NO
If yes, which ones? Eliminated: Added:
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 1

28. PRETREATMENT PROGRAM ELEMENTS REVIEW:
Program Element
Fourth Creek WWTP
Last Submittal Received
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
3/8/19
/1 Yes ❑ No
5/6/19
/1 Yes ❑ No
7/1/22
Industrial Waste Survey (IWS)
6/23/21
a Yes ❑ No
8/30/16
r Yes ❑ No
In Review
Sewer Use Ordinance (SUO)
10/17/11
a Yes ❑ No
11/14/11
/1 Yes ❑ No
Enforcement Response Plan (ERP)
1/17/20
a Yes ❑ No
2/12/20
/1 Yes ❑ No
Long Term Monitoring Plan (LTMP)
3/1/19
a Yes ❑ No
4/2/19
/1 Yes ❑ No
Program Element
Third Creek WWTP
Last Submittal Received
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
6/10/21
a Yes ❑ No
6/1/18
/1 Yes ❑ No
In Review
Industrial Waste Survey (IWS)
6/23/21
r Yes ❑ No
8/30/16
/1 Yes ❑ No
In Review
Sewer Use Ordinance (SUO)
10/17/11
r Yes ❑ No
11/14/11
/1 Yes ❑ No
Enforcement Response Plan (ERP)
1/17/20
a Yes ❑ No
2/12/20
/1 Yes ❑ No
Long Term Monitoring Plan (LTMP)
3/1/19
a Yes ❑ No
4/2/19
/1 Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW:
29. User Name 1. Rental Uniform
2. DENSO
3. Tube Specialties
30. IUP Number
3001
4014
4002
31. Does File Contain Current Permit?
/1 Yes ❑ No
/1 Yes ❑ No
1 Yes ❑ No
32. Permit Expiration Date
5/1/25
7/1/26
4/15/23
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
N/A
433
433
34. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
/1 Yes ❑ No
/1 Yes ❑ No
/1 Yes ❑ No
35. Does File Contain an Inspection Completed Within Last Calendar Year?
/1 Yes ❑ No
/1 Yes ❑ No
1 Yes ❑ No
36. a. Does the File Contain a Slug/Spill Control Plan?
b. If No, is One Needed? (See Inspection Form from POTW)
a. ►Yes •No
b. •Yes ■ No
a. ►Yes •No
b. •Yes ■ No
a. ►Yes •No
b. •Yes ■ No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
Organic Management Plan (TOMP)?
❑Yes❑No®N/A
®Yes❑No❑N/A
❑Yes❑No®N/A
38. a. Does File Contain Original Permit Review Letter from the Division?
b. All Issues Resolved?
a. ►Yes •No
b.❑Yes❑No®N/A
a. ►Yes •No
b.❑Yes❑No®N/A
a. ►Yes •No
b.❑Yes❑No®N/A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
its Sampling as Required by IUP, including flow?
1 Yes ❑ No
/1 Yes ❑ No
1 Yes ❑ No
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
/1 Yes ❑ No
L Yes ❑ No
/1 Yes ❑ No
41a. During the Most Recent Semi -Annual Period, Did the SIU Complete its
Sampling as Required by IUP, including flow?
®Yes❑No❑N/A
❑Yes❑NoON/A
®Yes❑No❑N/A
41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports
on time?
®Yes❑No❑N/A
NYes❑No❑N/A
®Yes❑No❑N/A
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
file include process/dilution flows as Required by IUP?
❑ Yes ❑NoON/A
❑Yes❑No ON/A
❑Yes❑NOON/A
42b. For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
❑Yes❑No®N/A
❑Yes❑NoNN/A
❑Yes❑No®N/A
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Limits Non -Compliance from Both POTW and SIU Sampling?
❑Yes❑NoON/A
❑Yes❑NOON/A
1Yes ■No■NA
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Reporting Non -Compliance from SIU Sampling?
❑Yes❑NoON/A
❑Yes❑NoON/A
❑Yes❑No®N/A
44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
Monitoring Violations?
b. Did Industry Resample and submit results to POTW Within 30 Days?
c. Did POTW resample within 30 days of knowledge of SIU limit
violations from the POTW sample event?
a.❑Yes❑No®N/A
h.®Yes❑No❑N/A
c.❑Yes❑NoNN/A
a.❑Yes❑No®N/A
b.❑Yes❑No®N/A
c.❑Ycs❑No®N/A
a.❑Yes❑No®N/A
b.❑Yes❑No®N/A
c.❑Yes❑No®N/A
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 2

45. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
❑ Yes /1 No
❑ Yes L No
❑ Yes /1 No
46. During the Most Recent Semi -Annual Period, Was Enforcement Taken
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
®Yes ONO ❑N/A
❑Yes❑No ON/A
❑Yes❑No®N/A
47. Does the File Contain Penalty Assessment Notices?
® Yes ❑No❑N/A
❑Yes❑No ON/A
❑Yes ONO EN/A
48. Does The File Contain Proof Of Penalty Collection?
® Yes ❑No❑N/A
❑Yes❑No ON/A
❑Yes❑NoON/A
49. a. Does the File Contain Any Current Enforcement Orders?
b. Is SIU in Compliance with Order?
a.❑Yes❑No®N/A
b.❑Yes❑No®N/A
a.❑Yes❑No®N/A
b.❑Yes ❑No®N/A
a.❑Yes ❑No®N/A
b.❑Yes❑No®N/A
50. Did the POTW Representative Have Difficulty in Obtaining Any of This
Requested Information For You?
❑ Yes /1 No
❑ Yes /1 No
❑ Yes // No
FILE REVIEW COMMENTS:
17. Statesville/Third Creek WWTP reported effluent chronic toxicity failures in July and August 2020 and monthly average effluent ammonia
violations in May 2021. Statesville/Fourth Creek WWTP reported monthly average flow violations in February 2019, February 2020, May
2020, August 2020, February 2021 and March 2021. The Fourth Creek WWTP also reported effluent chronic toxicity failure in January 2021
and weekly and monthly average effluent ammonia violations in April 2021. The monthly average flow violations (Fourth Creek WWTP) were
attributed to higher flows during rainfall events.
35. The POTW performed the SIU inspections on 10/7/20 (Rental Uniform), 8/10/20 (DENSO), and 11/3/20 (Tube Specialties).
39. The POTW's on -site lab performs conventional parameters, cyanide and nitrite/nitrate analyses for LTMP and IUP sampling. Statesville
Analytical, LLC. has also been contracted to perform metals, TKN and oil & grease analyses (LTMP and IUP sampling).
41 a. The POTW performs sampling for Rental Uniform (except oil & grease) and DENSO. Rental Uniform and Tube Specialties both contract
Statesville Analytical, LLC. to perform analyses.
46. The POTW addressed a zinc limit violation in February 2021 from Rental Uniform (POTW sampling event). A civil penalty ($50.00) was
also issued to the SIU. The POTW must ensure to issue an official enforcement action (NONC, NOV, etc.) to the SIUs for any limit and/or
monitoring violations.
SUMMARY AND COMMENTS:
The POTW must ensure that all LTMP and IUP detection levels (silver, cadmium, etc.) are met during future sampling events. In addition, the
POTW must ensure all TTO Certifications are submitted by the listed IUP deadlines (June 30 and December 7) each year. The POTW's ERP
(monitoring/reporting violations) will be updated to include Escalated Enforcement Actions for Reporting Violations/Late Report [NOV/civil
penalty, possible SNC determination if over 30 (or 45) days late].
The records reviewed during the inspection were organized and well maintained. The City's Industrial Pretreatment Program is being properly
implemented.
NOD: ❑ YES ® NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ® NO
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory_ ❑
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 3

PCI COMPLETED BY:
PCI Reviewed BY:
DocuSigned by:
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DATE: 7/16/2021
Wes Bell, Sr. Environmental Specialist, Mooresville Regional Office
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DATE:
7.16.21
W. Corey Basinger, Regional Supervisor, Mooresville Regional Office
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 4