NC0024538_Inspection_20210816

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
David Hux
Director of Water Resources
City of Shelby
Post Office Box 207
Shelby, North Carolina 28151
Dear Mr. Hux:
NORTH CAROLINA
Environmental Quality
August 16, 2021
Subject: Pretreatment Audit Inspection
City of Shelby
NPDES Permit No. NC0024538
Cleveland County
Enclosed is a copy of the Pretreatment Audit Inspection (PAI) Report for the inspection of the City of Shelby's
Industrial Pretreatment Program on August 12, 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:
A w H Nut4
F161 FB69A2D84A3...
fo r
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 AUDIT REPORT
Background Information
1. Control Authority (POTW) Name: City of Shelby
2. Control Authority Representative(s): John Reuscher, Janet Maddox
3. Title(s): Pretreatment Coordinator, Pretreatment Consultant
4. Address of POTW:
Mailing: PO Box 207
City: Shelby, N.C.
Zip Code: 28151-0207
Phone Number [phone] Fax Number [phone] E-Mail [e-mail]
5. Audit Date 8/12/2021
6. Last Inspection Date: 5/1/2019 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. No effluent limit violations have been reported in past year.
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
INICI0I0I2 I4 15 13 I8 I
10. Current Number of Significant Industrial Users (SIUs)?
11. Number of SIUs with No IUP, or with an Expired IUP?
MM/DD/YY
I 08 1 12 1 21
6
0
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. Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi -Annual Periods?
0
15. Number of SIUs in SNC for Reporting During Either of Last 2 Semi -Annual Periods?
0
16. Number of SIUs in SNC with Pretreatment Schedule?
0
17. Number of SIUs on Schedules?
0
18. Current Number of Categorical Industrial Users (CIUs)?
19. Number of CIUs in SNC?
4
0
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 1

20. PRETREATMENT PROGRAM ELEMENTS REVIEW:
Program Element
NC0024538
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
07/27/20
01 Yes ❑ No
02/24/17
/1 Yes ❑ No
In Review
Industrial Waste Survey (IWS)
03/29/19
/1 Yes ❑ No
06/17/19
Cl Yes ❑ No
03/30/24
Sewer Use Ordinance (SUO)
09/07/11
a Yes ❑ No
09/23/11
/1 Yes ❑ No
Enforcement Response Plan (ERP)
10/05/11
0 Yes ❑ No
12/22/11
/1 Yes ❑ No
Long Term Monitoring Plan (LTMP)
01/06/21
0 Yes ❑ No
04/05/21
/1 Yes ❑ No
In Review
Legal Authority (Sewer Use Ordinance-SUO)
21. 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. Kingstown, Fallston
22. If yes to #21, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? ® Yes ❑ No ❑ NA
A copy, if not already submitted, should be sent to Division.
23. If yes to #21, Have you had any trouble working with these towns or districts? ❑ Yes ® No ❑ NA
If yes, Explain.
24. Date of Last SUO Adoption by Local Council 10/03/2011
25. Have you had any problems interpreting or enforcing any part of the SUO? ❑ Yes ® No
If yes, Explain.
Enforcement (Enforcement Response Plan-ERP)
26. Did you send a copy of the ERP to your industries? ® Yes ❑ No
If no, POTW must send copy within 30 days.
27. 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.
28. List Industries under a Schedule or Order and Type of Schedule or Order. None
Resources
29. Please Rate the Following: S=Satisfactory M=Marginal U=Unsatisfacto
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
a S ❑M ❑U
Access to POTW Vehicles for
Sampling, Inspections, and
Emergencies
/1 S ❑M ❑U
Access to Operable Sampling
Equipment
0 S ❑M ❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
0 S ❑M ❑U
Reference Materials
►1S ❑M ❑U
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
0 S ❑M ❑U
Computer Equipment (Hardware and
Software)
0 S ❑M ❑U
NC DWR Pretreatment Audit Form
Revised: December 2016
Page 2

30. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No
Explain Yes or No. Hach WIMS, Excel
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
All SIUs must pay a monthly administration fees, permit application fee, and surcharges.
32. Are there any local issues affecting the pretreatment program (e.g.. odor, plant closing, new or proposed plants)?
❑ Yes ® No If yes, Explain.
33. 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? By appointment with the Director of Water Resources or
Pretreatment Coordinator/staff; files would be reviewed at the WWTP with Pretreatment staff in attendance.
34. 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 be reviewed by the Director of Water Resources
and Pretreatment Coordinator/staff; any confidential files would be secured in a locked file cabinet at Utilities Operations
Center.
35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? ® Yes ❑ No
36. Is the public notified about changes in the SUO or Local Limits? ® Yes ❑ No
37. Were all industries in SNC published in the last notice? ❑ Yes ❑ No ® N/A
Permitting (Industrial Waste Survey-IWS)
38. How does the POTW become aware of new or changed Users? Director of Water Resources reviews new permits in
the City's on-line permit tracking system and forwards the new users to the Pretreatment Coordinator/staff.
39. 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
SIU?) Review information on IWS forms; water use records, categorical activities, SIC Code and confer with
Division's Pretreatment staff if needed.
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 (1 - landfill leachate and 1— groundwater remediation system)
Please list each site and how it is permitted, if applicable. County Landfill - local agreement (includes maintenance
and sampling plan); Honeywell (groundwater remediation) — local permit.
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) Septage haulers have a designated point, manifests/tracking system and are randomly sampled.
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?
45. If yes to #44, What is being done to address the over allocations? (short-term IUPs, HWA to be revised, pollutant study, etc.)
46. Does the POTW keep pollutant loading in reserve for future growth / safety? ® Yes ❑ No
If yes, what percentage of each parameter 10%
47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) ❑ Yes ® No
If yes, Explain.
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 3

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) NPDES POCs, Categorical parameters,
application info, historical need.
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Volume of discharge; potential impacts to WWTP; once per six months minimum and new SIUs may be sampled more
frequently to establish a baseline.
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
(limits, monitoring, reporting, permit conditions) 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 Division 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 implement a slug/spill control plan.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Emergency contacts kept up to date, proper chemical storage practices including adequate secondary containment,
presence of emergency response equipment.
56. How does the POTW decide where the sample point for an SIU should be located? Pretreatment system effluent prior to
combining with domestic wastewater.
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. POTW has a sampling SOP and the SIU's
sampling practices are evaluated during on -site inspections.
58. Who performs sample analysis for the POTW for Metals: Pace Analytical Services
Conventional Parameters: Pace Analytical Services
Organics: Pace Analytical Services
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
POTW uses internal chain of custody (COC) form and the contract lab's COC if applicable; SIUs use the contracted lab's
COC.
Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis (HWA)
60a. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑ NO
60b. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ® YES ❑ NO
60c. Is LTMP/STMP Data Maintained in Table or Equivalent? ® YES ❑ NO Is Table Adequate? ® YES ❑ NO
60d. All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? ® YES ❑ NO
60e. If NO to any above, list violations
60f. 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? Phone ( ) --
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
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 4

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 - WWTP has sufficient capacity.
Summary
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment? No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW
66. User Name 1. Greenheck Fan Corp. 2. IMC Metals America
3. Clearwater Pipe Corp.
67. IUP Number
1008 J
1003
1007
68. Does File Contain Current Permit?
/1 Yes ❑ No
/1 Yes ❑ No
/1 Yes ❑ No
69. Permit Expiration Date
7/1/25
4/19/26
5/1/24
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
433
468
430.120
71. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
@ Yes ❑ No
/1 Yes ❑ No
A Yes ❑ No
72. Does File Contain Inspection Completed Within Last Calendar Year?
/1 Yes ❑ No
i1 Yes ❑ No
A Yes ❑ No
73. a. Does File Contain Slug/Spill Control Plan?
b. If No, is One Needed? (See Inspection Form from POTW)
a. AYes •No
b. •Yes •No
a. @Yes •No
b. •Yes •No
a. ► Yes •No
b. •Yes •No
74. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
Organic Management Plan (TOMP)?
DYes❑No❑N/A
❑ Yes ❑No0N/A
❑Yes❑NoON/A
75. a. Does File Contain Original Permit Review Letter from Division?
b. All Issues Resolved?
a. AYes •No
b.❑Yes❑No®N/A
a. @Yes •No
b.®Yes❑No❑N/A
a. ► Yes •No
b.❑Yes❑No®N/A
76. During Most Recent Semi -Annual Period, Did POTW Complete its
Sampling as Required by IUP, including Flow?
/1 Yes ❑ No
0 Yes ❑ No
1 Yes ❑ No
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
Al Yes ❑ No
i1 Yes ❑ No
A Yes ❑ No
78. During Most Recent Semi -Annual Period, Did SIU Complete its
Sampling as Required by IUP, including Flow?
DYes❑No❑N/A
® Yes ❑No❑N/A
®Yes❑No❑N/A
79. During Most Recent Semi -Annual Period, Did SIU submit all reports on
time?
❑Yes®No❑N/A
®Yes❑No❑N/A
®Yes❑No❑N/A
80a. For categorical IUs with Combined Wastestream Formula (CWF), does
file include process/dilution flows as Required by IUP?
❑ Yes ❑NoNN/A
❑Yes❑NoON/A
❑Yes❑NoNN/A
80b. For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
❑Yes❑NoON/A
❑ Yes ❑NoON/A
❑Yes❑NoON/A
81. During Most Recent Semi -Annual Period, Did POTW Identify All
Limits Non -Compliance from Both POTW and SIU Sampling?
❑Yes❑No ON/A
® Yes ❑No❑N/A
❑Yes❑NoNN/A
82. During Most Recent Semi -Annual Period, Did POTW Identify All
Reporting Non -Compliance from SIU Sampling?
❑Yes❑NoNN/A
❑Yes❑No®N/A
❑ Yes ❑NOON/A
83. a. Was 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. 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?
a.❑Yes❑NOON/A
b.❑Yes❑No®N/A
c.❑Yes❑No®N/A
a.❑Yes ❑No®N/A
b.❑Yes ❑No®N/A
c.❑Yes❑No®N/A
a.❑Yes❑NOON/A
b.❑Yes❑No®N/A
c.❑Yes❑No®N/A
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
❑ Yes /1 No
❑ Yes /1 No
❑ Yes 1 No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
Specified in POTW's ERP (NOVs, Penalties, timing, etc.)?
❑Yes❑NoON/A
® Yes ❑No❑N/A
❑ Yes ❑NoON/A
86. Does File Contain Penalty Assessment Notices?
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑NoNN/A
87. Does File Contain Proof Of Penalty Collection?
❑Yes❑NoON/A
❑Yes❑No®N/A
❑Yes❑NoON/A
88. a. Does File Contain Any Current Enforcement Orders?
b. Is SIU in Compliance with Order?
a.❑Yes❑No0N/A
b.❑Yes❑No®N/A
a.❑Yes ❑No®N/A
b.❑Yes ❑No®N/A
a.❑Yes❑NOON/A
b.❑Yes❑No®N/A
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
Information For You?
❑ Yes 0 No
❑ Yes i1 No
❑ Yes A No
NC DWR Pretreatment Audit Form Revised: December 2016
Page 5

FILE REVIEW COMMENTS:
20. The Division is in the process of approving a revised LTMP. The POTW should submit an additional revised LTMP to raise
the detection level for selenium.
58. The POTW's on -site certified lab performs analyses on conventional parameters during LTMP sampling events.
71. Greenheck Fan and Clearwater Pipe both are operating under the originally issued IUPs.
72. POTW performed the SIU inspections on 12/2/20 (Greenheck Fan), 10/27/20 (IMC Metals America) and 11/16/20 (Clearwater
Pipe).
78. Greenheck Fan and IMC Metals America both contract Pace Analytical Services for IUP analyses. Clearwater Pipe contracts
Waypoint Analytical to perform IUP analyses.
79. The POTW must ensure all applicable CIUs submit TTO Certifications by the required dates listed in the IUP (June 15 and
December 15 of each year).
85. The POTW issued a NOV to IMC Metals America for oil & grease permit limit violations in February 2021.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
I N I C I O I O 1 2 14 15 13 18 I 1 88 1 12 1 21 1
1. Industry Inspected: Greenheck Fan
2. Industry Address: 1400 Commerce Center Drive, Shelby, NC 28150
3. Type of Industry/Product: Manufactures aluminum louvers
4. Industry Contact: Mark Miller Title(s): Plant Manager 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 facility manufactures aluminum louvres for fans. The industry receives aluminum extrusions from a separate facility and performs
cutting, machining, fastening (mechanical) and painting prior to shipment. The facility currently has seventy-six employees and operates
two -eight hour shifts five days per week. The fabricated louvres are conveyed through a five stage cleaning/rinsing process prior to
painting. The fifth stage provides an anti -corrosion sealant. The water used in the cleaning/rinsing stages is pretreated with a reverse
osmosis (RO) treatment system. The facility uses basic (pH >11.5 s.u.) and acidic (pH 2 — 3 s.u.) cleaners. The sealer is also acidic (pH
2 - 3 s.u.). The waste stream includes RO backwash, overflow from the five -stage cleaning system and the dumping of the cleaning baths
(2-6 times per year). The wastewater is conveyed to a 1,000-gallon tank equipped with an in -line pH monitoring system. A valve will
automatically shut if the pH monitoring system detects pH levels outside the programmed set points. Manual pH adjusts are performed
on an as -needed basis. The treated wastewater flows through a flow meter prior to entering the POTW's sewer system. Hepaco will be
contracted for the cleanup of spills. Safety Kleen has also been contracted to remove any used oils (hydraulic, etc.). The SIU's records
were organized and well maintained.
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 6

AUDIT SUMMARY/COMMENTS:
The records reviewed during the audit were organized and well maintained. The POTW's Industrial Pretreatment Program was being
properly implemented.
NOD: ❑ Yes ® No
NOV: ❑ Yes ® No
QNCR: ❑ Yes ® No
POTW Rating:
Satisfactory
Audit COMPLETED BY:
Audit Reviewed BY:
Marginal ❑ Unsatisfactory ❑
DocuSigned by:
A61696D90CC3437...
Wes Bell, Sr. Environmental Specialist, WQROS, Mooresville Regional Office
DATE: 8/16/2021
Li0Piy Be�
DocuSigned by:
A4‘0114w 11 P4444
F161FB69A2D84A3
for 8.16.21
DATE:
W. Corey Basinger, Regional Supervisor, WQROS, Mooresville Regional Office
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 7