NC0024538_Inspection_20231212

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Brian Wilson, Director of Water Resources
City of Shelby
Post Office Box 207
Shelby, North Carolina 28151
NORTH CAROLINA
Environmental Quality
December 15, 2023
SUBJECT: Pretreatment Compliance Inspection
City of Shelby
NPDES Permit No. NCO024538
Cleveland County
Dear Mr. Wilson:
Enclosed is a copy of the Pretreatment Compliance Inspection (PCI) Report for the inspection of the City of Shelby's
approved Industrial Pretreatment Program on December 7, 2023, by Mr. Wes Bell of this Office. This Office would like to
thank all staff in their cooperation and assistance provided throughout the inspection. Please inform the City's Pretreatment
Coordinator of our findings by forwarding a copy of the enclosed report.
The report should be self-explanatory; however, should you have any questions, please do not hesitate to contact Mr. Bell
at [phone] or at [e-mail].
Sincerely,
EDocuSigned by:
A wNNuft
F161 F669A2D84A3...
Andrew H. Pitner, P.G., Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
Enclosure: Inspection Report
Cc: NPDES Program Files - Laserfiche
Q Q��
North Carolina Department of Environmental Quality I Division of Water Resources
Mooresville Regional Office 1 610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115
704.6631699

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
BACKGROUND INFORMATION:
1. Control Authority (POTW) Name: City of Shelby
2. Control Authority Representative(s): John Reuscher
3. Title(s): Pretreatment Coordinator
4. Last Inspection Date: 1/18/23 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 MM/DD/YY
NCO024538 12/07/23
7. Current Number Of Significant Industrial Users (SIUs)?
1 6
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?
F 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 ?
4
16. Number CIUs in SNC? 11
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 N/A
either of the Last 2 Semi -Annual Periods? Not Been Published for Not Pu
Public Notice?(May refer to PAR if Excessive SIUs in SNC)
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?
[—]YES ® NO
❑ YES ® NO
)lished: N/A
N/A
[:]YES ❑ 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
NCO024538
Last Submittal Received
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
07/27/20
® Yes ❑ No
2/24/17
® Yes ❑ No
In Review
Industrial Waste Survey IWS
03/29/19
® Yes ❑ No
06/17/19
® Yes ❑ No
03/30/24
Sewer Use Ordinance SUO
09/07/11
® Yes ❑ No
09/23/11
® Yes ❑ No
Enforcement Response Plan (EPP)
1015111
® Yes ❑ No
1 12/22/11
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
08/24/21
® Yes ❑ No
1 04/05/21
® Yes ❑ No
In Review
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW:
29. User Name
1. Clearwater Paper
2. Clearwater Paper Corp., Shelby II
3. IMC Metals America, LLC
30. IUP Number
1004
1007
1003
31. Does File Contain Current Permit?
® Yes ❑
I ® Yes ❑
I ® Yes ❑ No
32. Permit Expiration Date
11/2/24
5/1/24
4/20/26
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
430.12
430.12 11
468
34. Does File Contain Permit Application Completed Within One Year Prior
® Yes ❑ No
FMTes ❑ No
® Yes ❑ No
to Permit Issue Date?
35. Does File Contain an Inspection Completed Within Last Calendar Year?
I ® Yes ❑ No
® Yes ❑ No 11
® Yes ❑
No
36. a. Does the File Contain a Slug/Spill Control Plan?
a. EYes ❑No
a. ®Yes ❑No
a. ®Yes ❑No
b. If No, is One Needed? See Inspection Form from POTW
b. ❑Yes ❑No
b. ❑Yes ❑No I
b. []Yes []No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑NoEN/A
Organic Management Plan (TOMP)?
38. a. Does File Contain Original Permit Review Letter from the Division?
a. EYes ❑No
a. EYes []No
a. EYes ❑No
b. All Issues Resolved?
b.❑Yes❑NoEN/A
b.❑Yes❑NoEN/A
b.❑Yes❑No®N/A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
its Sampling as Required b IUP, includingflow?
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
® Yes ❑ No�jj
® Yes ❑ No
® Yes ❑ No
41 a. During the Most Recent Semi -Annual Period, Did the SIU Complete its
EYes❑No❑N/A
®Yes❑No❑N/A
®Yes❑No❑N/A
Sampling as Required by IUP, including flow?
41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports
EYes❑No❑N/A
EYes❑No❑N/A
EYes❑No❑N/A
on time?
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑NoEN/A
file includeprocess/dilution flows as Required by IUP?
11
42b. For categorical IUs with Production based limits, does file include
❑Yes❑NoEN/AFEVc;❑No
❑Yes❑NoEN/A
production rates and/or flows as Required by IUP?
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑NoENA
EYes❑No❑N/A
❑Yes❑NoEN/A
All Limits Non -Compliance from Both POTW and SIU Sampling?
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑NoEN/A
All Reporting Non -Compliance from SIU Sampling?
44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
a.❑Yes❑NoEN/A
a.EYes❑No❑N/A
a.❑Yes❑NoEN/A
Monitoring Violations?
b. Did Industry Resample and submit results to POTW Within 30 Days?
b.❑Yes❑No®N/A
b.❑Yes❑No®N/A
b.❑Yes❑NoEN/A
c. Did POTW resample within 30 days of knowledge of SIU limit
c.❑Yes❑NoEN/A
c.❑Yes❑No®N/A
c.❑Yes❑NoEN/A
violations from the POTW sample event?
45. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
❑
Yes
®
No 11
❑
Yes
®
No
❑
Yes
®
No
46. During the Most Recent Semi -Annual Period, Was Enforcement Taken
❑Yes❑NoEN/A
EYes❑No❑N/A
❑Yes❑NoEN/A
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
47. Does the File Contain Penalty Assessment Notices?
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑NoEN/A
48. Does The File Contain Proof Of Penalty Collection?
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑NoEN/A
49. a. Does the File Contain Any Current Enforcement Orders?
a.❑Yes❑NoEN/A
a.❑Yes❑No®N/A
a.❑Yes❑NoEN/A
b. Is SIU in Compliance with Order?
b.❑Yes❑No®N/A
b.❑Yes❑NoEN/A
b.❑Yes❑No®N/A
50. Did the POTW Representative Have Difficulty in Obtaining Any of This
❑ Yes ® No
❑ Yes ® No
❑ Yes ® No
Requested Information For You?
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 2

FILE REVIEW COMMENTS:
22. The City's on -site certified laboratory performs BOD, ammonia, TSS and field analyses for LTMP sampling events. Pace
Analytical Services has been contracted to perform all remaining LTMP analyses.
28. The City submitted documentation to the Division on 1/6/2020 to advise that no changes would be incorporated in the ERP
for dental discharges.
35. The City performed SIU inspections on 12/15/22 (Clearwater Paper), 12/15/22 (Clearwater Paper, Shelby II) and 10/13/22
(IMC Metals America).
39. The City contracts Pace Analytical Services to perform all IUP sampling and analyses.
41a. Clearwater Paper and Clearwater Paper, Shelby II both contract Waypoint Analytical to perform all IUP analyses. IMC
Metals America contracts Pace Analytical Services to perform all IUP analyses.
43a/46. The City issued Clearwater Paper, Shelby II NOVs for daily maximum flow violations in March and April 2023.
SUMMARY AND COMMENTS:
The records reviewed during the inspection were organized and well maintained. The City's Industrial Pretreatment Program
was being properly implemented.
NOD: ❑ YES ®NO
NOV: ❑ YES ®NO
QNCR: ❑ YES ® NO
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory_ ❑
E�`,,96D90CC3437
uSignedd by:
23PCI COMPLETED BY• ... DATE: 12/15/2023
Wes Bell, Env. Specialist II, WQROS/MRO, DWR
DocuSigned by:
[A41H A12/15/2023
PCI REVIEWED BY: F161 FB69A2D84A3... DATE:
Andrew H. Pitner, Regional Supervisor, WQROS/MRO, DWR
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 3