NC0020591_Inspection_20240129

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
January 29, 2024
Andy Smith, Operations Manager Water Resources
City of Statesville
Post Office Box I I I I
Statesville, North Carolina 28677
SUBJECT: Pretreatment Compliance Inspection
City of Statesville
NPDES Permit No. NCO020591
Iredell County
Dear Mr. Smith:
Enclosed is a copy of the Pretreatment Compliance Inspection (PCI) Report for the inspection of the City of Statesville's
Pretreatment Program on January 25, 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�•�Guw N P-Lu"
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
DEQ�
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 Statesville
2. Control Authority Representative(s): Brandy Johnson
3. Title(s): Pretreatment Coordinator
4. Last Inspection Date: 5/25/22 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
NCO020591 01/25/24
7. Current Number Of Significant Industrial Users (SIUs)?
1 9
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?
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 ?
6
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 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 Section
❑ YES ®NO
Limits: N/A
Reporting: N/A
)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 I

28. PRETREATMENT PROGRAM ELEMENTS REVIEW:
Program Element
Fourth Creek WWTP
Last Submittal Received
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
6/28/22
® Yes ❑ No
5/6/19
® Yes ❑ No
In Review
Industrial Waste Survey IWS
6/23/21
® Yes ❑ No
10/14/21
® Yes ❑ No
N/A
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
Third Creek WWTP
Last Submittal Received
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
N/A
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
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW:
29. User Name
1. JPS Composites =12.
Nelson Global
3. Kewaunee Scientific
30. IUP Number
3005
4002
1 3009
31. Does File Contain Current Permit?
® Yes ❑
I ® Yes ❑
I ® Yes ❑
No
32. Permit Expiration Date
2/28/26
4/14/28
2/28/26
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
410
433 11
433
34. Does File Contain Permit Application Completed Within One Year Prior
® Yes ElNo
Fff7TE:1 No
® Yes ❑ No
to Permit Issue Date?
35. Does File Contain an Inspection Completed Within Last Calendar Year?
I ® Yes ❑ N=ol
® Yes ❑ No 11
® Yes ❑ No
36. a. Does the File Contain a Slug/Spill Control Plan?
a. ®Yes ❑No
a. ®Yes []No
a. ®Yes ❑No
b. If No, is One Needed? (See Inspection Form from POTW)
b. ❑Yes ❑No
b. ❑Yes ❑No
b. ❑Yes ❑No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
❑Yes❑NoNN/A
❑Yes❑NoNN/A
®Yes❑No❑N/A
Organic Management Plan (TOMP)?
38. a. Does File Contain Original Permit Review Letter from the Division?
a. ®Yes ❑No
a. ®Yes []No
a. ®Yes ❑No
b. All Issues Resolved?
b.❑Yes❑NoNN/A
b.❑Yes❑NoNN/A
b.❑Yes❑NoNN/A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
® Yes ❑ No
® Yes ❑ No
® Yes ElNo
its Sampling as Required by IUP, including flow?
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
® Yes ❑ No
® Yes ❑ No
®Yes
❑ No
41 a. During the Most Recent Semi -Annual Period, Did the SIU Complete its
NYes❑No❑N/A
NYes❑No❑N/A
NYes❑No❑N/A
Sampling as Required by IUP, including flow?
41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports
NYes❑No❑N/A
NYes❑No❑N/A
NYes❑No❑N/A
on time?
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑NoNN/A
❑Yes❑N❑NN/A
❑Yes❑NoNN/A
file includeprocess/dilution flows as Required by IUP?
42b. For categorical IUs with Production based limits, does file include
❑Yes❑NoNN/A
❑Yes❑NoNN/A
❑Yes❑NoNN/A
1
production rates and/or flows as Required by IUP?
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑NoNNA
❑Yes❑NoNN/A
❑Yes❑NoNN/A
All Limits Non -Compliance from Both POTW and SIU Sampling?
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑NoNN/A
❑Yes❑NoNN/A
❑Yes❑NoNN/A
All Reporting Non -Compliance from SIU Sampling?
44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
a.❑Yes❑NoNN/A
a.❑Yes❑NoNN/A
a.❑Yes❑NoNN/A
Monitoring Violations?
b. Did Industry Resample and submit results to POTW Within 30 Days?
b.❑Yes❑NoNN/A
b.❑Yes❑NoNN/A
b.❑Yes❑NoNN/A
c. Did POTW resample within 30 days of knowledge of SIU limit
c.❑Yes❑NoNN/A
c.❑Yes❑NoNN/A
c.❑Yes❑NoNN/A
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 2

violations from the POTW sample event?
45. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
46. During the Most Recent Semi -Annual Period, Was Enforcement Taken
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
47. Does the File Contain Penalty Assessment Notices?
48. Does The File Contain Proof Of Penalty Collection?
49. a. Does the File Contain Any Current Enforcement Orders?
b. Is SIU in Compliance with Order?
50. Did the POTW Representative Have Difficulty in Obtaining Any of This
Requested Information For You?
FILE REVIEW COMMENTS:
❑
Yes
®
No
❑
Yes
®
No 11
❑
Yes
®
No
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑NoON/A
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑No®N/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 ® No
❑ Yes ® No
❑ Yes ® No
17. No effluent violations reported at Third Creek WWTP. The Fourth Creek WWTP reported monthly average effluent ammonia violations in
April and May 2022. Effluent copper violations were also reported in July 2022 (daily max) and July 2023 (daily max and monthly average).
35. The POTW performed the SIU inspections on 11/16/23 (JPS), 12/14/23 (Nelson Global) and 12/13/23 (Kewaunee Scientific).
39. The POTW's on -site certified laboratory performs all required analyses (LTMP and IUP) except for mercury (high and low-level), zinc,
selenium and oil & grease. Statesville Analytical, LLC. (along with sub -contracted Meritech Labs) has been contracted to perform these
analyses. Sampling staff must ensure all future oil & grease samples are collected directly into the sample container (not intermediate sampling
devices). The Pretreatment Coordinator must also ensure that all pH calibrations are documented during IUP sampling events.
41 a. JPS and Nelson Global both contract Statesville Analytical for IUP analyses. Kewaunee Scientific contracts Pace Analytical Services for
IUP analyses.
SUMMARY AND COMMENTS:
JPS and Nelson Global both have SPCC plans to address oil spill prevention plans; however, the SIUs should have (if applicable) slug/spill
control plans to address any wastewater discharges (including that from spill containment areas) treated or untreated, that may potentially cause
adverse impacts to the collection system or WWTP. In addition, Pretreatment Coordinator should also evaluate and ensure all applicable SIUs
have developed and implemented adequate slug/spill control plans. DWR staffprovided a follow-up email to the Pretreatment Coordinator with
technical guidance documents on slug/spill control plans and TOMPs (applicable CIUs).
The Mach, June, September, and December 2023 eDMRs will be revised and resubmitted to correct units of measurement for effluent cyanide,
selenium and zinc.
The Pretreatment Coordinator also serves as the Laboratory Manager for both of the City's WWTPs. The City must ensure that the Laboratory
Manager/Pretreatment Coordinator is provided with adequate staffing to implement all NPDES Programs (Laboratory, Pretreatment, etc.).
The records reviewed during the inspection were organized and well maintained. The City's Industrial Pretreatment Program is being properly
implemented.
NOD: ❑ YES ® NO
NOV: ❑ YES ® NO
QNCR: [—]YES ® NO
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory- ❑
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 3

E-:-'96D90CC3437
cuSigned by:
PCI COMPLETED BY: ... DATE: 1/29/2024
Wes Bell, Environmental Specialist II, DWR/WQROS, Mooresville Regional Office
EDocuSigned by:
F161FB69A2D84A3
y.el fi P 1/29/2024
PCI Reviewed BY: ... DATE:
Andrew Pitner, Regional Supervisor, DWRIWQROS, Mooresville Regional Office
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 4