NC0020737_Inspection_20240125

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 28016
NORTH CAROLINA
Environmental Quality
January 25, 2024
SUBJECT: Pretreatment Compliance Inspection
City of Kings Mountain
NPDES Permit No. NCO020737
Cleveland County
Dear Mr. Duncan:
Enclosed is a copy of the Pretreatment Compliance Inspection (PCI) Report for the inspection of the City of Bessemer
City's Pretreatment Program on January 10, 2024, by Mr. Wes Bell of this Office. Please advise the City's Pretreatment
Coordinator of our findings by forwarding the enclosed corrected report. This Office would also like to thank the City's
Pretreatment Coordinator for the cooperation and assistance provided during the inspection.
Should you have any questions concerning this report, please do not hesitate to contact Mr. Bell at [phone] or at
wes.bell(a,deq.nc. gov.
Sincerely,
DocuSigned by:
A N P,uft
F161 FB69A2D84A3...
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
D 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
704.663.1699

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
BACKGROUND INFORMATION:
1. Control Authority (POTW) Name: City of Kings Mountain
2. Control Authority Representative(s): Kevin Hodges
3. Title(s): Pretreatment Coordinator
4. Last Inspection Date: 5/24/22 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
NCO020737 01/10/24
7. Current Number Of Significant Industrial Users (SIUs)?
1 8
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
2
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?
1
15. Current Number of Categorical Industrial Users CIUs ?
7
16. Number CIUs in SNC? 11
1
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 SNC foi
either of the Last 2 Semi -Annual Periods? Not Been Published for SNC foi
Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not Pu
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
See Comments.
❑ YES ®NO
Limits: See Comments
Reporting: N/A
dished: N/A
Utz Quality Foods, LLC
❑ 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
NCO020737
Last Submittal Received
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
8/28/2020
® Yes ❑ No
4/21/2016
® Yes ❑ No
In review
Industrial Waste Survey IWS
11/27/2019
® Yes ❑ No
3/4/2020
❑ Yes ® No
12/1/2024
Sewer Use Ordinance SUO
10/4/2013
® Yes ❑ No
10/10/2013
® Yes ❑ No
Enforcement Response Plan (ERP)
1/14/2020
® Yes ❑ No
2/5/2020
❑ Yes ® No
Long Term Monitoring Plan (LTMP)
5/4/2020
® Yes ❑ No
7/31/2020
❑ Yes ® No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW:
29. User Name =
1. Fab-Tec, Inc. IF
2. Utz Quality Foods, LLC IF
3. Buckeye Anodizing & Stamping
30. IUP Number
035
037
1 015
31. Does File Contain Current Permit?
® Yes ❑ No
® Yes ❑ NoI
® Yes ❑ No
32. Permit Expiration Date
1 6/18/24
6/12/27
7/29/26
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
433I
N/A
433
34. Does File Contain Permit Application Completed Within One Year
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
Prior to Permit Issue Date?
35. Does File Contain an Inspection Completed Within Last Calendar
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
Year?
36. a. Does the File Contain aSlug/Spill Control Plan?
a. ®Yes ❑No
a. ®Yes ❑No
a. ®Yes ❑No
Fb.
b. If No, is One Needed? See Inspection Form from POTW
b. []Yes []No
b. ❑Yes ❑No
[]Yes ❑No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
®Yes❑No❑N/A
❑Yes❑NoEN/A
®Yes❑No❑N/A
Organic Management Plan (TOMP)?
11
38. a. Does File Contain Original Permit Review Letter from the Division?
a. EYes ❑No
a. ®Yes []No
a. ®Yes ❑No
b. All Issues Resolved?
b.❑Yes❑No®N/A
b.❑Yes❑No®N/A
b.❑Yes❑No®N/A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
®Yes ❑ No
® Yes ❑ No
® Yes ❑
its Sampling as Required b IUP, includingflow?
f1i
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
® Yes ❑ No 11
® Yes ❑ No
® Yes ❑ No
41a. During the Most Recent Semi -Annual Period, Did the SIU Complete its
®Yes❑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
❑YesENo❑N/A
F
®Yes❑No❑N/A
®Yes❑No❑N/A
reports on time?
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑NoEN/A
0Yes0No[9
❑Yes❑NoEN/A
file includeprocess/dilution flows as Required by IUP?
42b. For categorical IUs with Production based limits, does file include
❑Yes❑NoEN/A
❑Yes❑NoON/A
❑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
®Yes❑No❑N/A
®Yes❑No❑N/A
All Limits Non -Compliance from Both POTW and SIU Sampling?
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
®Yes❑No❑N/A
®Yes❑No❑N/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❑No®N/A
a.❑Yes❑No®N/A
a.❑Yes❑No®N/A
Monitoring Violations?
b. Did Industry Resample and submit results to POTW Within 30 Days9
b.❑Yes❑No®N/A
b.❑Yes❑No®N/A
b.❑Yes❑No®N/A
c. Did POTW resample within 30 days of knowledge of SIU limit
c.❑Yes❑No®N/A
c.❑Yes❑No®N/A
c.❑Yes❑No®N/A
violations from the POTW sample event?
45. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
❑
Yes
®
No
®
Yes
❑
No 11
®
Yes
❑
No
46. During the Most Recent Semi -Annual Period, Was Enforcement Taken
®Yes❑No❑N/A
®Yes❑No❑N/A
®Yes❑No❑N/A
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
47. Does the File Contain Penalty Assessment Notices?
I ❑Yes❑NoSN/A
®Yes❑No❑N/AF
❑Yes❑NoEN/A
48. Does The File Contain Proof Of Penalty Collection?
❑Yes❑No®N/A
❑Yes®No❑N/A
I ❑Yes❑No®N/A
49. a. Does the File Contain Any Current Enforcement Orders?
a.❑Yes❑No®N/A
a.®Yes❑No❑N/A
a.❑Yes❑NOON/A
b. Is SIU in Compliance with Order?
b.❑Yes❑No®N/A
b.®Yes❑No❑N/A
b.❑Yes❑No®N/A
50. Did the POTW Representative Have Difficulty in Obtaining Any of
I ® Yes ❑ Nol
® Yes ❑ N=ol
® Yes ❑ No
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 2

This Requested Information For You?
FILE REVIEW COMMENTS:
17. Weekly average effluent TSS violations were reported in April 2022 and February 2023. Daily maximum effluent TRC
violations were reported in September 2023 and a monthly average effluent ammonia violation was reported in October 2023.
19. Utz Quality Foods, LLC (Utz) was in SNC during the second half of 2022 and first half of 2023 for limit violations.
Buckeye Anodizing & Stamping (Buckeye) was in SNC during first half of 2023 due to limit violation.
35. The City performed SIU inspections on 6/13/23 (Fab-Tec), 6/14/23 (Utz) and 8/8/23 (Buckeye).
39. The City has contracted Pace Analytical Services to perform ]UP analyses. Utz contracts Rogers & Calcott and Fab-Tec
contracts Two Rivers Utilities to perform ]UP analyses. Buckeye contracts PAR Labs to perform IUP analyses.
43b/46. The City issued a Notice of Non -Compliance to Fab-Tec for the late submittal of the January 2023 monitoring report.
The City issued NOVs and a civil penalty to Utz for limit and reporting violations that had occurred during first half of 2023.
Buckeye was issued NOVs for limit violations in January 2023 (zinc) and June 2023 (total phosphorus).
49. Utz did violate the BOD and TSS Consent Order limits in March 2023.
SUMMARY AND COMMENTS:
The City hired a new Pretreatment Coordinator in 2023 and there have been challenges with finding all pretreatment records.
Although the approval letters for the ERP, IWS and LTMP were reviewed during previous inspections, the letters were not
found during this inspection. Copies of these approval letters were later emailed by DWR staff to the Pretreatment
Coordinator. The Pretreatment Coordinator is in the process of finding and organizing all pretreatment documentation. The
City must ensure that all Pretreatment documentation is maintained at a minimum or three years or greater, pending Program
document.
All effluent LTMP data was not reported on the eDMRs since first quarter of 2023. LTMP sampling was performed; however,
the applicable eDMRs will need to be revised/resubmitted and include all LTMP effluent data. In addition, a less than (<)
value will need to be added to the effluent cyanide result that was reported on the October 2023 eDMR.
The City must ensure that all violations are addressed within the timeframes listed in the Division approved ERP. In addition,
copies of all civil penalty payments must be kept on -site (not Town Hall only). The City has addressed the silver and selenium
reporting violations that were originally addressed as limit violations to Utz (via revised NOV). The City will need to correct
the expiration date on the revised Consent Order (as of 7/26/23) for reissuance to Utz. The updated Consent Order must
include the signatures of the authorized personnel (City and SIU).
NOD: ❑ YES ®NO
NOV: ❑ YES ® NO
QNCR: [—]YES ®NO
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory_ ❑
E�—"96DWCC3437
cuSigneddby:
PCI COMPLETED BY• ... DATE: 1/24/2024
Wes Bell, Environmental Specialist II, DWR/WQROS, Mooresville Regional Office
DocuSigned by:
E
N � � 1/25/2024
PCI REVIEWED BY: F161FB69A2D84A3... DATE:
Andrew Pitner, Regional Supervisor, DWR/WQROS, Mooresville Regional Office
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 3