NC0020591_Inspection_20220531

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Andy Smith
City of Statesville
Post Office Box 1111
Statesville, North Carolina 28677
SUBJECT: Pretreatment Audit Inspection
City of Statesville
NPDES Permit No. NC0020591
Iredell County
Dear Mr. Smith:
NORTH CAROLINA
Environmental Quality
May 31, 2022
Enclosed is a copy of the Pretreatment Audit Inspection (PAI) Report for the inspection of the City of Statesville's
Industrial Pretreatment Program on May 25, 2022, by Mr. Wes Bell of this Office. Please advise the City's Pretreatment staff
of our findings by forwarding the enclosed report.
Should you have any questions concerning this report, please do not hesitate to contact Mr. Bell at [phone] or at
[e-mail].
Enclosure:
Inspection Report
Cc: NPDES Program Files - Laserfiche
DE
Sincerely,
-DocuSigned by:
`--A14CC681 AF27425...
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
North Carolina Department of Environmental Quality I Division of Water Resources
Mooresville Regional Office 1610 East Center Avenue. Suite 301 1 Mooresville. North Carolina 28115
704.663.1699

North Carolina Department of Environmental Quality I Division of Water Resources
Mooresville Regional Office 1610 East Center Avenue. Suite 301 1 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 Statesville
2. Control Authority Representative(s): Brandy Johnson, Jimmy Rickert
3. Title(s): Pretreatment Coordinator, Pretreatment Technician
4. Address of POTW:
Street/Post Office Box Post Office Box 1111
City/State/Zip Code Statesville, NC 28687
Phone Number: [phone] E-Mail: [e-mail]
5. Audit Date: 05/25/2022
6. Last Inspection Date:07/14/21 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 Third Creek WWTP (NC0020591) — Monthly average effluent ammonia violation — May 2021;
Fourth Creek WWTP (NC0031836) — Effluent chronic toxicity failure — January 2021, Monthly average flow
violations — February and March 2021, Weekly and monthly average effluent ammonia violations — April 2021.
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
NC0020591
MM/DD/YY
05/25/22
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?
13. Number of SIUs Not Sampled by POTW in Last Calendar Year?
14. Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi -Annual Periods
15. Number of SIUs in SNC for Reporting During Either of Last 2 Semi -Annual Periods
16. Number of SIUs in SNC with Pretreatment Schedule?
10
0
0
0
0
0
0
17. Number of SIUs on Schedules?
0
18. Current Number of Categorical Industrial Users (CIUS)?
19. Number of CIUs in SNC?
8
0
NC DWR Pretreatment Audit Form
Revised: July 25, 2007 Page 1

21. PRETREATMENT PROGRAM ELEMENTS REVIEW
Program Element:
Third Creek - NC0020591
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
6/10/21
// Yes ❑ No
6/1/18
// Yes ❑ No
In Review
Industrial Waste Survey (IWS)
6/23/21
@ Yes ❑ No
10/14/21
@ Yes ❑ No
10/12/26
Sewer Use Ordinance (SUO)
10/17/11
// Yes ❑ No
11/14/11
// Yes ❑ No
Enforcement Response Plan (ERP)
7/15/21
// Yes ❑ No
11/16/21
// Yes ❑ No
Long Term Monitoring Plan (LTMP)
3/1/19
@ Yes ❑ No
4/2/19
@ Yes ❑ No
Program Element:
Fourth Creek - NC0031836
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
3/1/19
' Yes ❑ No
5/6/19
@ Yes ❑ No
7/1/22
Industrial Waste Survey (IWS)
6/23/21
// Yes ❑ No
10/14/21
@ Yes ❑ No
10/12/26
Sewer Use Ordinance (SUO)
10/17/11
@ Yes ❑ No
11/14/11
I1 Yes ❑ No
Enforcement Response Plan (ERP)
7/15/21
@ Yes ❑ No
11/16/21
@ Yes ❑ No
Long Term Monitoring Plan (LTMP)
3/1/19
// Yes ❑ No
4/2/19
r Yes ❑ No
Legal Authority (Sewer Use Ordinance-SUO)
22. 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. Troutman.
23. If yes to #22, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? ® Yes ❑ No ❑ NA
A copy, if not already submitted, should be sent to Division.
24. If yes to #22, Have you had any trouble working with these towns or districts? ❑ Yes ® No ❑ NA
If yes, Explain
25. Date of Last SUO Adoption by Local Council. 12/3/12
26. Have you had any problems interpreting or enforcing any part of the SUO? ❑ Yes ® No
If yes, Explain
Enforcement (Enforcement Response Plan-ERP)
27. Did you send a copy of the ERP to your industries? ® Yes ❑ No
If no, POTW must send copy within 30 days.
28. Have you had any problems interpreting or enforcing any part of the ERP (i.e. any adjudication, improper enforcement, etc?
El Yes ® No If yes, Explain.
29. List Industries under a Schedule or Order and Type of Schedule or Order. None
NC DWR Pretreatment Audit Form
Revised: July 25, 2007 Page 2

Resources
30. Please Rate the Following: S=Satisfactory
M=Marginal U=Unsatisfactory
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
/1S ❑M ❑U
Access to Operable Sampling
Equipment
/1 S ❑M ❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
1 S ❑M ❑U
Reference Materials
1 S ❑M ❑U
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
L S ❑M ❑U
Computer Equipment (Hardware and
Software)
/1 S ❑M ❑U
31. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No
Explain Yes or No. Excel.
32. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Surcharges, new permit fees; permit renewal fees; sampling/analytical costs
Public Perception/ Participation:
33. Are there any local issues affecting the pretreatment program (e.g.. odor, plant closing, new or proposed plants)?
® Yes ❑ No If yes, Explain. A SIU (Macaro) that was the biggest water user has closed.
34. 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? A written request would be submitted to Water
Resources Director. Copies would be provided for a fee and/or files would be reviewed at Fourth Creek WWTP with
Pretreatment Coordinator in attendance.
35. 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? A written request would be submitted to Water Resources Director.
Water Resources Director and Pretreatment Coordinator would review request and associated documentation. Any
confidential files would be kept in a locked file cabinet inside the Pretreatment Coordinator's office (also locked).
36. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? ® Yes ❑ No
37. Is the public notified about changes in the SUO or Local Limits? ® Yes ❑ No
38. Were all industries in SNC published in the last notice? ❑ Yes ❑ No ® NA
Permitting (Industrial Waste Survey-IWS):
39a...How does the POTW become aware of new or changed Users? The Chamber of Commerce and/or Planning
Department contacts the Pretreatment Coordinator of any potential users. The Pretreatment Coordinator may
also attend Technical Review Criteria meetings for new projects/users with other City Departments.
39b. 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?) Long/Short IWS forms reviewed and a site visit with sampling may be performed based on the information
provided. Flow volumes, type of products produced, categorical processes, discharge characteristics, and
information in the application are all evaluated during the SIU determinations
NC DWR Pretreatment Audit Form
Revised: July 25, 2007 Page 3

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. County Landfill/no permit.
41. Does the POTW accept waste by (mark if applicable) El 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) The POTW does not accept trucked waste.
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 El No
If yes, what percentage of each parameter? 5%
47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) El Yes ® No
If yes, Explain.
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) Categorical parameters and NPDES
POCS.
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Monthly monitoring (six months minimum) for new SIUs to determine baseline; monitoring may be reduced based on
sampling results, quarterly monitoring required at a minimum.
Permit Compliance:
50. Does the POTW currently have or during the past year had any permits under adjudication? El 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; ERP
followed for violations (limit, reporting, permit conditions, etc.).
52. Does the POTW use the Division's model inspection form or equivalent? ® Yes ❑ No
If no, does the POTW form include all DWQ data? El Yes ❑ No
53. Were all SIUs evaluated for the need of a slug/spill control plan during their most recent inspections? ® Yes El No
If no, Explain.
54. What criteria are used to determine if a slug/spill control plan is needed?
Presence of floor drains, chemical storage practices/locations, secondary containment for chemical storage.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
EPA checklist used as a guide; Adequate chemical storage and secondary containment; emergency contacts kept up to date;
presence of spill response equipment.
56. How does the POTW decide where the sample point for an SIU should be located?
Sampling preferred following all treatment processes for regulated waste streams.
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 — Sampling SOP; POTW evaluates SIU
sampling procedures during inspections.
NC DWR Pretreatment Audit Form
Revised: July 25, 2007 Page 4

58. Who performs sample analysis for the POTW for Metals - Certified In-house Lab, Statesville Analytical
Conventional Parameters - Certified In-house Lab, Statesville Analytical
Organics - Meritech
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
POTW uses internal and contracted lab's COCs. SIUs use contracted lab's COCs.
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 El NO DWQ Inspector, verify yourself!
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?
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 EResolve over allocation ®5 year expiration (Fourth Creek WWTP) ['Other, explain.
63. In general, what is the most limiting criteria of your HWA?
®Inhibition (Third Creek WWTP) ® Pass Through (Fourth Creek WWTP) ESludge Quality
64. Do you see any way to increase your loading in the future (Example: obtaining more land for sludge disposal)? ❑ Yes ❑ No
Explain. NA - Sufficient capacity in all WWTPs.
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. DENSO
2. Hi -Tech Plating
3. Rental Uniform
67. IUP Number
4014
3008
3001
68. Does File Contain Current Permit?
/1 Yes ❑ No
L Yes ❑ No
/1 Yes ❑ No
69. Permit Expiration Date
7/1/26
9/29/25
4/30/25
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
433
433.15
N/A
71. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
1 Yes ❑ No
/1 Yes ❑ No
1 Yes ❑ No
72. Does File Contain Inspection Completed Within Last Calendar Year?
/1 Yes ❑ No
L Yes ❑ No
/1 Yes ❑ No
73. a. Does File Contain Slug/Spill Control Plan?
b. If No, is One Needed? (See Inspection Form from POTW)
a. L Yes ■ No
b. •Yes •No
a. A Yes ■ No
b. •Yes •No
a. L Yes ■ No
b. •Yes •No
74. 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❑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. A Yes ■ No
b.❑Yes ❑No®N/A
a. L 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
/1 Yes ❑ No
/1 Yes ❑ No
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
' 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
®Yes❑No❑N/A
80a. For categorical IUs with Combined Wastestream Formula (CWF), does
file include process/dilution flows as Required by IUP?
❑Ycs❑NoON/A
❑Yes❑No®N/A
❑Yes❑No®N/A
NC DWR Pretreatment Audit Form
Revised: July 25, 2007
Page 5

80b. For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
81. During Most Recent Semi -Annual Period, Did POTW Identify All
Limits Non -Compliance from Both POTW and SIU Sampling?
82. During Most Recent Semi -Annual Period, Did POTW Identify All
Reporting Non -Compliance from SIU Sampling?
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?
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
Specified in POTW's ERP (NOVs, Penalties, timing, etc.)?
86. Does File Contain Penalty Assessment Notices?
87. Does File Contain Proof Of Penalty Collection?
88. a. Does File Contain Any Current Enforcement Orders?
b. Is SIU in Compliance with Order?
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
Information For You?
❑Yes❑N°ON/A
❑ Yes ❑N°ON/A
❑Yes❑No ON/A
❑Yes❑No ON/A
❑ Yes ❑NoON/A
❑Yes❑No ON/A
❑Yes❑No ON/A
III Yes ❑No®N/A
❑Yes❑No ON/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
a. ❑Yes❑No®N/A
b.❑Yes❑No®N/A
c.❑Yes❑No®N/A
❑ Yes /1 No
❑ Yes r No
❑ Yes /1 No
❑Yes❑No ON/A
❑ Yes ❑NoON/A
❑Yes❑N°ON/A
❑Yes❑No ON/A
❑ Yes ❑NoON/A
❑Yes❑No ON/A
❑Yes❑N°ON/A
❑ Yes ❑No®N/A
❑Yes❑N°ON/A
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
❑ Yes /1 No
❑ Yes a No
❑ Yes a No
FILE REVIEW COMMENTS:
72. SIU inspection were performed by the POTW on 11/9/21 (DENSO), 10/27/21 (Hi -Tech Plating) and 12/16/21 (Rental Uniform).
78. The POTW samples in lieu of the SIUs; however, Hi -Tech Plating and DENSO (infrequently) will split samples and Rental Uniform
performs semi-annual oil & grease sampling. All three SIUs contract Statesville Analytical to perform IUP analyses.
INDUSTRY INSPECTION PCS CODING:
Trans.Code
N
Main Program Permit Number
N
C
0
0
2
0
5
9
1
MM/DD/YY
05
25
22
(DTIA)
1. Industry Inspected: DENSO Manufacturing NC, Inc./Statesville Plant
2. Industry Address: 470 Crawford Road, Statesville, N.C., 28625
3. Type of Industry/Product: 433/Power Window Motors (currently) and Power Steering Motors (future) for automobile industry
4. Industry Contact: Maika Khang Title: Advanced Specialist - Safety/Health/Environment 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?
Inspection type
U
Inspector Facility Type
2
Comments:
A. Initial Interview
B. Plant Tour
C. Pretreatment Tour
D. Sampling Review
E. Exit Interview
® Yes ❑ No
® Yes E No
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
(TYPI)
S
(1NSP) (FACC)
Industrial Inspection Comments:
The Company currently has 450 employees and operates three -eight hour shifts, five to six days per week. The
pretreatment system includes equalization, DAF (oil/water separation), pH adjustment, flocculation, clarification,
filtration, sludge conditioning and plate/frame filter press. Republic Services disposes of the dewatered sludge to the
CMS Landfill. Zebra Environmental removes and disposes of the oily waste stream removed by the DAF unit. Indy
Environmental is contracted to remove waste oils and Zebra Environmental would handle any oil spills and remediation
activities.
NC DWR Pretreatment Audit Form
Revised: July 25, 2007 Page 6

SUMMARY AND COMMENTS:
The records reviewed during the inspection 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 ® Marginal ❑ Unsatisfactory El
DocuSigned by:
�G0' 13`11 5/31/2022
Audit COMPLETED BY: DATE:
A61696D90CC3437...
Wes Bell, Environmental Specialist II, WQROS/MRO, DWR
AUDIT REVIEWED BY:
DocuSigned by:
A14CC681AF27425...
DATE:
5/31/2022
W. Corey Basinger, Regional Supervisor, WQROS/MRO, DWR
NC DWR Pretreatment Audit Form
Revised: July 25, 2007 Page 7