NC0025984_Pretreatment Compliance Inspection Report_20230830 (2)

SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED.

August 30, 2023

Sonny Penson, Public Works Director
Town of Forest City
Email: [e-mail]

SUBJECT: Pretreatment Compliance Inspection Report
Forest City WWTP
NPDES WW Permit No. NC0025984
Rutherford County

Dear Permittee:

The North Carolina Division of Water Resources conducted a Pretreatment Compliance Inspection of Forest
City’s Pretreatment Program on 8/22/2023. The findings and comments noted during this inspection are
provided in the enclosed copy of the inspection report entitled "Compliance Inspection Report".

There were no significant issues or findings noted during the inspection and therefore, a response to this
inspection report is not required.

If you should have any questions, please do not hesitate to contact Lauren Armeni with the Water
Quality Regional Operations Section in the Asheville Regional Office at 828-296-4667 or via email at
[e-mail].

Sincerely,

Lauren Armeni, Environmental Specialist II
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ

ATTACHMENTS: Inspection Report, Pretreatment Compliance Inspection Report

Ec: Laserfiche
Tim Atkins (Pretreatment Coordinator)
Jacob Hodge (ORC)
DocuSign Envelope ID: 8172D322-CD48-4312-96E8-C05BCF076E93
EPA
United States Environmental Protection Agency
Washington, D.C. 20460
Water Compliance Inspection Report
Form Approved.
OMB No. 2040-0057
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 N 52 NC0025984 23/08/22 P S31112171819 20
21 66
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ----------------------Reserved-------------------
N67707172 73 74 75 80
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
Forest City WWTP
397 Riverside Dr
Forest City NC 28043
Entry Time/Date Permit Effective Date
Exit Time/Date Permit Expiration Date
10:15AM 23/08/22 21/12/01
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Jacob William Hodge/ORC/828-248-5217/
Other Facility Data
01:30PM 23/08/22 26/07/31
Name, Address of Responsible Official/Title/Phone and Fax Number
Sonny Penson,PO Box 728 Forest City NC 280430728//828-248-5217/8282474626 Contacted
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Pretreatment
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s)Agency/Office/Phone and Fax Numbers Date
Melanie Kemp DWR/ARO WQ/ - - /
Lauren E Armeni DWR/ARO WQ/828-296-4500/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#1
DocuSign Envelope ID: 8172D322-CD48-4312-96E8-C05BCF076E93
8/30/2023
8/30/2023
8/30/2023
NPDES yr/mo/day
23/08/22
Inspection Type
P3111218
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Lauren Armeni and Melanie Kemp, with the Asheville Regional Office, conducted a Pretreatment
Compliance Inspection (PCI) of the Town of Forest City's Pretreatment Program on August 22, 2023.
Tim Atkins (Pretreatment Coordinator) and Jacob Hodge (ORC) were present during the inspection.
Overall, the program appears to be in compliance with Federal and State Pretreatment requirements.
The Forest City Pretreatment Program has five SIUs total, two of which are CIUs. Paperwork was
readily accessible and organized. No SIUs were in SNC during the January through July 2023
sampling period. Befesa Zinc went under a Consent Order on May 27, 2022 and have been
completing deadlines as outlined in the compliance schedule.
NC0025984 17 (Cont.)
Page#2
DocuSign Envelope ID: 8172D322-CD48-4312-96E8-C05BCF076E93
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1
NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT

BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)]
1. Control Authority (POTW) Name: Forest City WWTP
2. Control Authority Representative(s): Tim Atkins
3. Title(s): Pretreatment Coordinator
4. Last Inspection Date: 12/07/21 Inspection Type (Check One): 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

ICIS CODING
Main Program Permit Number MM/DD/YY
| N | C | 0 | 0 | 2 | 5 | 9 | 8 | 4 | | 08 | 22 | 23 |

7. Current Number Of Significant Industrial Users (SIUs)? 5
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? 1
15. Current Number Of Categorical Industrial Users (CIUs)? 2
16. Number of CIUs in SNC? 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?
Riverstone Industrial Park WWTP had fecal coliform limit violations in
January 2023. Befesa Zinc caused excess flow into the WWTP due to a DI
water filtration system that was constantly running that they were unaware
of, which caused the violation. There have been no issues since.
YES NO

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? See answer to #17.
YES NO
19. Which Industries have been in SNC for Limits or Reporting during
either of the Last 2 Semi-Annual Periods? Not Been Published for
Public Notice?(May refer to PAR if Excessive SIUs in SNC)
SNC for Limits: N/A
SNC for Reporting: N/A
Not Published: N/A
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?
Befesa Zinc – yes, the Division has the signed Consent Order

21. Are Any Permits or Civil Penalties Currently Under Adjudication? If Yes, Which
Ones?
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 Inspector, please verify yourself!

DocuSign Envelope ID: 8172D322-CD48-4312-96E8-C05BCF076E93
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2
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:_______________________

28. PRETREATMENT PROGRAM ELEMENTS REVIEW- Please review POTW files, verify POTW has copy of Program Element
in their files, complete with supporting documents and copy of PERCS Approval Letter, and dates consistent with Program Info:
Program Element Last Submittal
Date In file?
Last Approval
Date In file
Date Next
Due, If
Applicable
Headworks Analysis (HWA) 08/30/23 (FC)
08/08/22 (RS)
Yes No Not approved
yet (FC)
Not approved
yet (RS)
Yes No 2028 (FC)
2027 (RS)

Industrial Waste Survey (IWS) 08/01/2023 Yes No Not approved
yet
Yes No 2028
Sewer Use Ordinance (SUO) 02/22/13 Yes No 02/25/13 Yes No
Enforcement Response Plan (ERP) 10/28/19 Yes No 02/05/20 Yes No
Long Term Monitoring Plan (LTMP) 08/24/18 (FC)
10/28/14 (RS)
Yes No 08/29/18 (FC)
12/29/14 (RS)
Yes No
________________________________________________________________________________________________________________
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name 1. Befesa Zinc 2. 3.
30. IUP Number 008
31. Does File Contain Current Permit? Yes No Yes No Yes No
32. Permit Expiration Date 02/28/25
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A N/A
34. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
Yes No Yes No Yes No
35. Does File Contain an Inspection Completed Within Last Calendar Year? Yes No Yes No Yes No
36. a. Does the File Contain a Slug/Spill Control Plan?
b. If No, is One Needed? (See Inspection Form from PO TW)
a. Yes No
b. Yes No
a. Yes No
b. Yes No
a. Yes No
b. Yes No
37. 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 No N/A
38. a. Does File Contain Original Permit Review Letter from the Division?
b. All Issues Resolved?
a. Yes No
b.Yes No N/A
a. Yes No
b.Yes No N/A
a. Yes No
b.Yes No N/A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
its Sampling as Required by IUP, including flow?
Yes No Yes No Yes No
40. Does File Contain POTW Sampling Chain-Of-Custody Forms? Yes No Yes No Yes No
41. During the Most Recent Semi -Annual Period, Did the SIU Complete its
Sampling as Required by IUP, including flow?
Yes No N/A Yes No N/A Yes No N/A
41b. During the Most Recent Semi-Annual Period, Did SIU submit all reports
on time?
Yes No N/A Yes No N/A Yes No N/A
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
file include process/dilution flows as Required by IUP?
Yes No N/A Yes No N/A Yes No N/A
42b. For categorical IUs with Production based limit s, does file include
production rates and/or flows as Required by IUP?
Yes No N/A Yes No N/A Yes No N/A
43a. During the Most Recent Semi-Annual Period, Did the POTW Identify
All Limits Non-Compliance from Both POTW and SIU Sampling?
Yes No
N/A
Yes No Yes No
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Reporting Non-Compliance from SIU Sampling?
Yes No N/A Yes No N/A Yes No N/A
44. a. Was the 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 within 30 days of becoming aware
of SIU limit violations in the POTW’s sampling of the 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
46. During the Most Recent Semi -Annual Period, Was the SIU in SNC? Yes No Yes No Yes No
47. During the Most Recent Semi -Annual Period, Was Enforcement Taken Yes No N/A Yes No N/A Yes No N/A
DocuSign Envelope ID: 8172D322-CD48-4312-96E8-C05BCF076E93
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
48. Does the File Contain Penalty Assessment Notices? Yes No N/A Yes No N/A Yes No N/A
49. Does The File Contain Proof Of Penalty Collection? Yes No N/A Yes No N/A Yes No N/A
50. a. Does the 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
51. Did the POTW Representative Have Difficulty in Obtaining Any of This
Requested Information For You?
Yes No Yes No Yes No

FILE REVIEW COMMENTS:
All paperwork was readily available. Befesa Zinc is currently under a Consent Order as of May 27, 2022. Mr. Hodge indicated that
they are on track to meet the compliance schedule deadlines.

INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
| N | C | 0 | 0 | 2 | 5 | 9 | 8 | 4 | | 08 | 22 | 23 |

1.Industry Inspected: Parker Hannafin
2. Industry Address: 203 Pine Street, Forest City, NC 28043
3. Type of Industry/Product: Assembles and dips hydraulic valves
4. Industry Contact: Wayne Lowery Title: Facility Manager
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 YES NO
B. Plant Tour YES NO
C. Pretreatment Tour YES NO
D. Sampling Review YES NO
E. Exit Interview YES NO
Industrial Inspection Comments:
The POTW had the industry representative take us through the entire facility. We observed all drains and
chemical storage onsite. The facility was well-maintained, and it appeared that all secondary containment was
being used as required. We also observed the pretreatment system, and Mr. Lowery went over it in detail with
us.

DocuSign Envelope ID: 8172D322-CD48-4312-96E8-C05BCF076E93
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 4

OVERALL SUMMARY AND COMMENTS:
Comments: Overall, the program is being well-maintained, and paperwork is very well organized. Forest City has a thorough
understanding of the Pretreatment Program. They are currently being diligent about making sure Befesa Zinc is following their
compliance schedule and meeting deadlines.
Requirements: Forest City’s HWA is due March 1, 2024.
Recommendations: Continue to inform the Division of any industry concerns or potential impacts to the system. The current Consent
Order lists AZP, so the industry name can be updated to Befesa Zinc, as well as the Forest City Pretreatment contacts.

NOD: YES NO
NOV: YES NO
QNCR: YES NO
POTW Rating:
Satisfactory X Marginal UnSatisfactory
PCI COMPLETED BY: Lauren Armeni and Melanie Kemp DATE: 08/22/23

DocuSign Envelope ID: 8172D322-CD48-4312-96E8-C05BCF076E93