NC0023884_Inspection_20210811

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
Sonja Basinger
Environmental Services Manager
City of Salisbury
1915 Grubb Ferry Road
Salisbury, North Carolina 28144
Dear Ms. Basinger:
NORTH CAROLINA
Environmental Quality
August 11, 2021
Subject: Pretreatment Audit Inspection
City of Salisbury
NPDES Permit No. NC0023884
Rowan County
Enclosed is a copy of the Pretreatment Audit Inspection (PAI) Report for the inspection of the City of Salisbury's
Industrial Pretreatment Program on August 9, 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 wHNut4
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 Salisbury
2. Control Authority Representative(s): Sonia Basinger, Jeffery Greer
3. Title(s): Environmental Services Manager, Pretreatment Coordinator
4. Address of POTW:
Mailing: 1915 Grubb Ferry Road
City: Salisbury, N.C. Zip Code: 28144-1248
Phone Number [phone] Fax Number [phone] E-Mail [e-mail]
[phone] [e-mail]
5. Audit Date 8/9/2021
6. Last Inspection Date: 1/16/2019 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. Monthly average limit violations in February and December 2020 (flow - Grant Creek Train) and
May 2020 (BOD).
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 I3 18 18 I4 I
10. Current Number of Significant Industrial Users (SIUs)?
11. Number of SIUs with No IUP, or with an Expired IUP?
12. Number of SIUs Not Inspected by POTW in Last Calendar Year?
MM/DD/YY
I 08 1 09 1 21 1
7
0
0
13. Number of SIUs Not Sampled by POTW in Last Calendar Year?
1
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?
3
0
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 1

20. PRETREATMENT PROGRAM ELEMENTS REVIEW:
Program Element
NC0023884
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
10/18/17
01 Yes ❑ No
02/22/18
/1 Yes ❑ No
11/01/22
Industrial Waste Survey (IWS)
09/17/19
/1 Yes ❑ No
12/10/19
Cl Yes ❑ No
10/01/24
Sewer Use Ordinance (SUO)
01/03/13
a Yes ❑ No
01/10/13
/1 Yes ❑ No
Enforcement Response Plan (ERP)
05/06/13
0 Yes ❑ No
06/17/13
/1 Yes ❑ No
Long Term Monitoring Plan (LTMP)
02/16/21
0 Yes ❑ No
05/29/18
/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. Landis, China Grove, Faith, Spencer, East Spencer, Granite
Quarry, Rockwell
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 08/20/2013
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 Followine: S=Satisfactory M=Marginal U=Unsatisfacto
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
e S ❑M ❑U
Access to POTW Vehicles for
Sampling, Inspections, and
Emergencies
/1S ❑M ❑U
Access to Operable Sampling
Equipment
/ / S ❑ M ❑ U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
0 S ❑M ❑U
Reference Materials
a ❑M ❑U
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
/1S ❑M ❑U
Computer Equipment (Hardware and
Software)
/1S ❑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.
Surcharges, SIUs billed for sampling/analytical costs and permit renewal fees.
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? An appointment would be made with the Utilities
Director and the 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 and approved by the Utilities
Director, Environmental Services Manager and Pretreatment Coordinator; any confidential files would be kept in a locked
file cabinet inside a secured room.
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?
Permitting (Industrial Waste Survey-IWS)
® Yes ❑ No ❑ N/A
38. How does the POTW become aware of new or changed Users? New users are identified by the POTW's Customer
Service Center, One -Stop Shop (all in one permitting center for industry), and review of local newspaper.
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?) Once information on IWS form is reviewed, the Pretreatment staff determine SIC Code (including any
Categorical processes) and perform on -site inspection to evaluate industry operations and potential impacts to
WWTP.
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
®Yes No If Yes, How many are there? 1
Please list each site and how it is permitted, if applicable. Nouryon (groundwater remediation) — SIU IUP; County
Landfill (leachate) - local agreement.
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 are received at the Town Creek Treatment Train only. All septage haulers
have permits/manifests and are sampled by on -site staff for pH and temperature. No trucked industrial
wastewater allowed.
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 20%
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 are 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 Worksheet for SNC determinations;
compliance judgement/penalties based on point system, ERP is followed for limit, monitoring and reporting violations.
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 and staff training. Note: All SIUs are required to submit annual status updates
of their slug/spill plans.
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 El 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: POTW's on -site certified lab
Organics: Meritech
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 ( ) --
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 4

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 05 year expiration ❑Other
Explain.
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. Freirich Foods 2. IPC
3. Hitachi Metals
67. IUP Number
0007
0038
0026
68. Does File Contain Current Permit?
/1 Yes ❑ No
/1 Yes ❑ No
/1 Yes ❑ No
69. Permit Expiration Date
3/29/26
9/30/22
6/30/26
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
N/A
N/A
471
71. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
A/ Yes ❑ No
I1 Yes ❑ No
A Yes ❑ No
72. Does File Contain Inspection Completed Within Last Calendar Year?
Al 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. Yes •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)?
❑Yes❑NoON/A
❑Yes❑NoON/A
❑Yes❑NoON/A
75. a. Does File Contain Original Permit Review Letter from Division?
b. All Issues Resolved?
a. ►Yes •No
b.❑Yes❑No®N/A
a. Yes •No
b.❑Yes ❑NoON/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?
Al Yes ❑ No
/1 Yes ❑ No
A Yes ❑ No
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
1 Yes ❑ No
r Yes ❑ No
1 Yes ❑ No
78. During Most Recent Semi -Annual Period, Did SIU Complete its
Sampling as Required by IUP, including Flow?
®Yes❑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
NYes❑No❑N/A
80a. For categorical IUs with Combined Wastestream Formula (CWF), does
file include process/dilution flows as Required by IUP?
❑Yes❑No ON/A
❑ Yes ❑NOON/A
❑Yes❑NoON/A
80b. For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
❑Yes❑NoNN/A
❑ Yes ❑NoON/A
®Yes❑No❑N/A
81. During Most Recent Semi -Annual Period, Did POTW Identify All
Limits Non -Compliance from Both POTW and SIU Sampling?
®Yes❑No❑N/A
❑Yes❑No®N/A
®Yes❑No❑N/A
82. During Most Recent Semi -Annual Period, Did POTW Identify All
Reporting Non -Compliance from SIU Sampling?
❑Yes❑No®N/A
❑ Yes ❑NOON/A
®Yes❑No❑N/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❑No❑N/A
b.®Yes❑No❑N/A
c.❑Yes❑No®N/A
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
❑ Yes A No
❑ Yes i1 No
❑ Yes A No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
Specified in POTW's ERP (NOVs, Penalties, timing, etc.)?
®Yes❑No❑N/A
® Yes ❑No❑N/A
®Yes❑No❑N/A
86. Does File Contain Penalty Assessment Notices?
❑Yes❑No®N/A
❑ Yes ❑No®N/A
®Yes❑No❑N/A
87. Does File Contain Proof Of Penalty Collection?
❑Yes❑No®N/A
❑ Yes ❑NoON/A
❑Yes❑NoNN/A
88. a. Does File Contain Any Current Enforcement Orders?
b. Is SIU in Compliance with Order?
a.❑Yes❑No®N/A
b.❑Yes❑No ON/A
a.❑Yes ❑No®N/A
b.❑Yes ❑No®N/A
a.❑Yes❑No®N/A
b.❑Yes❑No®N/A
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
Information For You?
❑ Yes 1 No
❑ Yes /1 No
❑ Yes 1 No
NC DWR Pretreatment Audit Form
Revised: December 2016
Page 5

FILE REVIEW COMMENTS:
72. POTW performed the SIU inspections on 9/2/20 (Freirich Foods), 11/17/20 (IPC) and 6/30/20 (Hitachi Metals).
78. Freirich Foods and Hitachi Metals both contract Pace Analytical Services to perform IUP analyses. IPC contracts Statesville
Analytical for IUP analyses.
85. Freirich Foods was issued a NOV for late submittal of permit renewal application. IPC was issued NOVs for zinc permit limit
violations in January and February 2021. Hitachi Metals was issued NOVs for oil & grease (January 2021) and copper (May 2021)
permit limit violations. Hitachi was also issued a NOV for a low level mercury monitoring violation (February 2021). The POTW issued
a $500.00 penalty to Hitachi (based on the point system) due to all violations that had occurred during the first half of 2021.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
INICI01012 1 3 18 18 14 1 1 08 1 09 1 21 1
1. Industry Inspected: Hitachi Metals
2. Industry Address: 1 Hitachi Metals Drive, China Grove, NC 28023
3. Type of Industry/Product: Magnet Manufacturer
4. Industry Contact: Avery Moore Title(s): Director of Manufacturing 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
B. Plant Tour
C. Pretreatment Tour
D. Sampling Review
E. Exit Interview
Z Yes ❑ No
Z Yes ❑ No
Z Yes ❑ No
Z Yes ❑ No
Yes ❑ No
Industrial Inspection Comments:
The facility currently has approximately 115 employees (permanent and temporary) and operates two twelve-hour shifts, twenty-four
hours per day seven days per week. Approximately ten to twelve million magnets are produced per month with the majority all of
magnets being used in the automotive industry. Process wastewater is conveyed through a scrubber system (air emission control system)
prior to entering a drag tank. Magnesium hydroxide is used for pH adjustments. The drag tank overflow/effluent passes through flow
measurement (ultrasonic flow meter) prior to entering the POTW's sewer system. The effluent from the oil/water separator system is
also connected to the drag tank. The oily waste stream from the oil/water separators is removed and disposed by HazMat. The sludge
(non -hazardous) that accumulates in the trench drainage system and other plant areas is solidified (in concrete pit) and disposed by
Concord Industrial Service Company at a permitted landfill.
The SIU's records were organized and well maintained.
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
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 6

POTW Rating:
Satisfactory ❑ Marginal ❑
Audit COMPLETED BY:
DocuSigned by:
A61696D9OCC3437...
Wes Bell, WQROS, Mooresville Regional
DocuSigned by:
I 44t4v H p44.4.for
\--F161 FB69A2D84A3...
Unsatisfactory ❑
DATE: 8/10/2021
Office
8.11.21
Audit Reviewed BY: DATE:
W. Corey Basinger, Regional Supervisor, Mooresville Regional Office
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 7