NC0020737_Inspection_20220531

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Rick Duncan, Water Resources Director
City of Kings Mountain
Post Office Box 429
Kings Mountain, North Carolina 28086
SUBJECT: Pretreatment Audit Inspection
City of Kings Mountain
NPDES Permit No. NC0020737
Cleveland County
Dear Mr. Duncan:
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 Kings Mountain's
Industrial Pretreatment Program on May 24, 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 Kings Mountain
2. Control Authority Representative(s): Richelle Meek, Asa Harris
3. Title(s): WWTP Supervisor/Pretreatment Coordinator, Pretreatment Analyst
4. Address of POTW:
Street/Post Office Box Post Office Box 429
City/State/Zip Code Kings Mountain, NC 28086
Phone Number: [phone] E-Mail: [e-mail]
[e-mail]
5. Audit Date: 5/24/22
6. Last Inspection Date: 6/8/21 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
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 MM/DD/YY
NC0020737 05/24/22
10. Current Number of Significant Industrial Users (SIUS)?
7
11. Number of SIUs with No IUP, or with an Expired IUP
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?
1
18. Current Number of Categorical Industrial Users (CIUS)?
7
19. Number of CIUs in SNC?
0
NC DWR Pretreatment Audit Form
Revised: July 25, 2007 Page 1

21. PRETREATMENT PROGRAM ELEMENTS REVIEW
Program Element:
NC0020737
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
8/28/20
0 Yes ❑ No
4/21/16
0 Yes ❑ No
In Review
Industrial Waste Survey (IWS)
11/27/19
// Yes ❑ No
3/4/20
// Yes ❑ No
12/1/24
Sewer Use Ordinance (SUO)
10/4/13
/1 Yes ❑ No
10/10/13
@ Yes ❑ No
Enforcement Response Plan (ERP)
1/14/20
/1 Yes ❑ No
2/5/20
@ Yes ❑ No
Long Term Monitoring Plan (LTMP)
5/4/20
// Yes ❑ No
7/31/20
// 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.
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 9/24/13
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?
❑ Yes ® No If yes, Explain.
29. List Industries under a Schedule or Order and Type of Schedule or Order. KMI, Consent Order
Resources
30. Please Rate the Following: S=Satisfactory
M=Marginal U=Unsatisfactory
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
S ❑M ❑U
1
Access to POTW Vehicles for
Sampling, Inspections, and
Emergencies
S ❑M ❑U
1
Access to Operable Sampling
Equipment
S ❑M ❑U
i1
Availability of Funds if Needed for
Additional Sampling and/or Analysis
S ❑M ❑U
1/
Reference Materials
S ❑M ❑U
1/
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
S ❑M ❑U
i1
Computer Equipment (Hardware and
Software)
S ❑M ❑U
@
NC DWR Pretreatment Audit Form
Revised: July 25, 2007
Page 2

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.
SIU Permit renewal fees and monthly pretreatment permit fees.
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 new food processor with be permitted as a SIU. The industry will produce pork rinds
and tortilla chips. The City is also planning on constructing a new four (4) MGD WWTP in addition to the current
WWTP.
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 reviewed and approved by
the Water Resources Director and WWTP Supervisor/Pretreatment Coordinator. Files would either be mailed to the
requestor or reviewed at City Hall with the Pretreatment Staff 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 reviewed and approved by the Water
Resources Director, City Attorney, City Manager and WWTP Supervisor/Pretreatment Coordinator. Files would be kept
secured in a locked file cabinet/office.
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 POTW's Code/Planning Department contacts the
Water Resources Director and/or WWTP Supervisor/Pretreatment Coordinator of any potential new Users.
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?) Short/Long IWS Forms submitted to the User and a site visit is performed based on the information
provided. Flow volumes, categorical processes, discharge characteristics, and information provided in the
application are all evaluated during the SIU determinations.
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
❑Yes No If Yes, How many are there?
Please list each site and how it is permitted, if applicable. N/A
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) No trucked waste (industrial and/or septage) is accepted.
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? 5% minimum
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: July 25, 2007 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) Categorical Parameters, NPDES POCs,
industrial activities based on SIC Code.
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Monthly monitoring for twelve months (minimum) for a new SIU as baseline; monitoring may be reduced based on sample
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? ❑ 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? ❑ 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 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 and secondary containment; presence of spill response
equipment; employee training.
56. How does the POTW decide where the sample point for an SIU should be located?
The effluent of the pretreatment wastewater treatment system 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 El No If yes, Explain. POTW — sampler O&M manual and employee
training; SIU — sampling practices reviewed during inspections.
58. Who performs sample analysis for the POTW for Metals — Meritech
Conventional Parameters — On -site Certified Lab and Meritech (SIUs)
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. SIU uses 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 El 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
60e. If NO to any above, list violations
60f. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? El YES ® NO
If yes, which ones? Eliminated: Added:
61. Do you complete your own headworks analysis (HWA)? ® Yes El No
If no, Who completes your HWA? POTW will also be assisted by MBD Consulting Engineers Phone: [phone]
62. Do you have plans to revise your HWA in the near future? El 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.
NC DWR Pretreatment Audit Form
Revised: July 25, 2007 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. NA - sufficient capacity at the current WWTP; however, a second WWTP is being planned to be constructed
within the next few years.
Summary:
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment? Yes, the
City is planning on the construction of a second WWTP within a few years.
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW:
66. User Name 1. FAB-TEC
2. Buckeye
3. CFC
67. IUP Number
0035
015
033
68. Does File Contain Current Permit?
/1 Yes ❑ No
/1 Yes ❑ No
/1 Yes ❑ No
69. Permit Expiration Date
6/18/24
7/29/26
1/22/24
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
433
433
433
71. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
Al Yes ❑ No
@ Yes ❑ No
Al Yes ❑ No
72. Does File Contain Inspection Completed Within Last Calendar Year?
/1 Yes ❑ No
/1 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. 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 ONO ❑N/A
® Yes ❑No❑N/A
®Yes❑No❑N/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?
/1 Yes ❑ No
/1 Yes ❑ No
1 Yes ❑ No
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
Al Yes ❑ No
@ Yes ❑ No
Al Yes ❑ No
78. During Most Recent Semi -Annual Period, Did SIU Complete its
Sampling as Required by IUP, including Flow?
NYes ONO ❑N/A
® Yes ❑No❑N/A
NYes❑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❑No ON/A
❑ Yes ❑No®N/A
❑Yes❑N°ON/A
80b. For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
❑Yes❑No ON/A
❑ Yes ❑NoON/A
❑Yes❑No ON/A
81. During Most Recent Semi -Annual Period, Did POTW Identify All
Limits Non -Compliance from Both POTW and SIU Sampling?
NYes❑No❑N/A
❑ Yes ❑No®N/A
❑Yes❑No ON/A
82. During Most Recent Semi -Annual Period, Did POTW Identify All
Reporting Non -Compliance from SIU Sampling?
[AY es❑No❑N/A
❑ Yes ❑No®N/A
❑Yes❑N°ON/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❑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
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
❑ Yes /1 No
❑ Yes L 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 ONO ❑N/A
❑ Yes ❑No®N/A
❑Yes❑NoON/A
86. Does File Contain Penalty Assessment Notices?
❑Yes❑No ON/A
❑ Yes ❑NoON/A
❑Yes❑No ON/A
87. Does File Contain Proof Of Penalty Collection?
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑No®N/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®N/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 r No
❑ Yes 1 No
NC DWR Pretreatment Audit Form Revised: July 25, 2007
Page 5

FILE REVIEW COMMENTS:
72. POTW performed SIU inspections on 11/8/21 (FAB-TEC), 9/24/21 (Buckeye), and 9/24/21 (CFC).
78. Buckeye and CFC both contract PAR Laboratories, Inc. and FAB-TEC contracts Two Rivers Utilities to perform IUP analyses.
85. The POTW issued FAB-TEC a NOV for a pH IUP limit violation in September 2021 and a Notice of Non -Compliance for the
SIU's failure to submit the October 2021 monitoring report by the required deadline.
INDUSTRY INSPECTION PCS CODING:
Trans.Code
N
Main Program Permit Number
0
0
2
0
7
3
7
MM/DD/YY
24
(DTIA)
05
22
Inspection type
1. Industry Inspected: FAB-TEC
2. Industry Address: 709 Broadview Drive, Kings Mountain, N.C., 28086
3. Type of Industry/Product: Metal fabrication and painting
4. Industry Contact: David Bolding Title: Owner 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
Industrial Inspection Comments:
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
U
(TYPI)
Inspector Facility Type
S
(INSP)
2
(FACC)
The Company currently has twenty-five (25) employees and operates one shift. The fabricated metal parts are cleaned and prepped for
painting by a five (5) stage rinse system with only four (4) stages currently being used. The four (4) stages provide washing, rinsing, a
zirconium coating and a final rinse. The facility also has a manual cleaning station for the metal parts. The wastewater from the manual
cleaning station is collected into storage tanks and discharged into the sewer system at the same location as the five (5) stage rinse
system. The pH levels are checked prior to discharge. No sludge is generated. Two Rivers Utilities has been contracted to provide
sampling and analysis according to the IUP.
SUMMARY AND COMMENTS:
The records reviewed during the inspection were organized and well maintained. The incorrect units of measurement (kg/day and
calculated) was reported for zinc, oil & grease, temperature, etc. on multiple eDMRs. The Pretreatment staff will revise and resubmit
all applicable eDMRs. No low level influent mercury sampling (as required by the LTMP) was performed in April and July 2021;
however, additional sampling will be performed to make up for the missed sampling. The Pretreatment staff must ensure all future
sampling and detection levels (mercury) adhere to the LTMP.
Overall, the City's Industrial Pretreatment Program was being properly implemented.
NOD: ❑ Yes ® No
NOV: ❑ Yes ® No
QNCR: ❑ Yes ® No
NC DWR Pretreatment Audit Form
Revised: July 25, 2007 Page 6

POTW Rating:
Satisfactory El
Marginal ❑ Unsatisfactory ❑
DocuSigned by:
rlePiyBat
AUDIT COMPLETED BY: DATE: 5/31/2022
A61696D90CC3137...
Wes Bell, Environmental Specialist II, MRO/WQROS, DWR
AUDIT REVIEWED BY:
LDocuSigned by:
A14CC681AF27425...
DATE: 5/31/2022
W. Corey Basinger, Regional Supervisor, MRO/WQROS, DWR
NC DWR Pretreatment Audit Form
Revised: July 25, 2007 Page 7