NC0020591_Pretreatment Audit Inspection_20170925

k ,y
Water Resources
Environmental Quality
September 25, 2017
Mr. Joe Hudson
Water Resources Director
City of Statesville
Post Office Box 1111
Statesville, North Carolina 28687
Subject: Pretreatment Audit Inspection
City of Statesville
NPDES Permit No. NCO020591
Iredell County
Dear Mr. Hudson:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S JAY ZIMMERMAN
Director
Enclosed is a copy of the Pretreatment Audit Inspection Report for the inspection of the City of
Statesville's Industrial Pretreatment Program on September 7, 2017, by Mr. Wes Bell of this Office.
Please inform the Pretreatment Coordinator of our findings by forwarding a copy of the enclosed report.
Should you have any questions concerning this report, please do not hesitate to contact Mr. Bell
at [phone], or via email at [e-mail].
Sincerely,
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
Enclosure:
Inspection Report
cc: Deborah Gore, PERCS Unit
MSC -1617 Central -Basement
State of North Carolina I Environmental Qualrtyl Water Resources I Water Quality Regional Operations
Mooresville Regional Office 1 610 East Center Avenue, Suite 310 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 Statesville
2. Control Authonty Representative(s): Brandy Johnson
3. Title(s): Pretreatment Coordinator
4. Address of POTW:
Street/Post Office Box Post Office Boz 1111
City/State/Zip Code Statesville, NC 28687
Phone Number: [phone] Fax Number: (704)-878-8655 E -Mail: [e-mail]
5. Audit Date: 9/7/2017
6. Last Inspection Date: 1/22/2016 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. Fourth Creek WWTP — Weekly Average BOD effluent limit violations reported in May 2016 and
October 2016.
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
PCS (WENDB)Coding:
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac. Type
N INIC10 IO 12101 51911 I I09I07 1 17 U U U
(DTIA) (TYPI) (INSP) (FACC)
10. Current Number of Significant Industrial Users (SNS)?
11. Current Number of Categorical Industrial Users (CNS)?
12. Number of SIUs Not Inspected by POTW in Last Calendar Year?
13. Number of SIUs Not Sampled by POTW in Last Calendar Year?
14. Enter Higher Number of 12 or 13
15. Number of SIUs with No IUP, or with an Expired IUP
16. Number of SIUs in SNC for Either Reporting or Limits Violations During Either of Last 2
Semi -Annual Periods (Total Number of SIUs in SNC)
17. Number of SIUs in SNC for Reporting During Either of Last 2 Semi -Annual Periods
18. Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi -Annual Periods
19. Number of SIUs in SNC for Both Reporting and Limits Violations During Either of Last 2
Semi -Annual Periods
20. Number of SIUs in SNC for Self -Monitoring Regi irements that were Not Inspected or Sampled
NC DWR Pretreatment Audit Form Revised: July 25, 2007
11
9
0
0
0
0
1
0
1
0
0
SNS
CIUS
NOIN
NOCM
PSNC
MSNC
SNPS
W1400
Page 1

21. PRETREATMENT PROGRAM ELEMENTS REVIEW
Program Element:
NCO020591
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
3/26/13
® Yes ❑ No
6/20/13
® Yes ❑ No
4/1/18
Industrial Waste Survey (IWS)
8/19/16
® Yes ❑ No
8/30/16
® Yes ❑ No
7/1/21
Sewer Use Ordinance (SUO)
10/17/11
® Yes ❑ No
11/14/11
® Yes ❑ No
Enforcement Response Plan (ERP)
9/23/16
® Yes ❑ No
11/29/16
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
2/15/16
® Yes ❑ No
5/9/16
® Yes ❑ No
Program Element:
NCO031836
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
6/5/17
® Yes ❑ No
10/10/12
® Yes ❑ No
In review
Industrial Waste Survey (IWS)
8/19/16
® Yes ❑ No
8/30/16
® Yes ❑ No
7/1/21
Sewer Use Ordinance (SUO)
10/17/11
® Yes ❑ No
11/14/11
® Yes ❑ No
Enforcement Response Plan (ERP)
9/23/16
® Yes ❑ No
11/29/16
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
2/15/16
® Yes ❑ No
5/9/16
® Yes ❑ No
Leal Authoritv (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. Troutman
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. 12/3/12
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 Ordrr and Type of Schedule or Order
None
Resources
30. Please Rate the Following: S=Satisfacto M=Mar inal U=Unsatisfactory
NC DWR Pretreatment Audit Form Revised July 25, 2007 Page 2
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
®S ❑M ❑U
Access to POTW Vehicles for
Sampling, Inspections, and
®S ❑M ❑U
Emergencies
NC DWR Pretreatment Audit Form Revised July 25, 2007 Page 2

Access to Operable Sampling
Equipment
®S ❑M ❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
®S ❑M ❑U
Reference Materials
®S ❑M ❑U
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
®S ❑M ❑U
Computer Equipment (Hardware and
Software)
®S ❑M ❑U
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.
Surcharges; new permit fees; permit renewal fees; samplinglanalytical costs
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.
34. Has any one from the public ever requested to review pretreatment program files9 ® Yes ❑ No
If yes, Explain procedure. If no, How would the request be addressed? A written request would be submitted to Water
Resources Director. Copies would be provided for a fee and/or files would be reviewed at Fourth Creek WWTP with
Pretreatment Coordinator 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 submitted to Water Resources Director.
Water Resources Director and Pretreatment Coordinator would review request and associated documentation. Any
confidential files would be kept in a locked file cabinet.
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 Survev-IWS):
39a ... How does the POTW become aware of new or changed Users? The Chamber of Commerce and/or Planning
Department contacts the Pretreatment Coordinator of any potential users. The Pretreatment Coordinator also
attends Technical Review Criteria meetings for new projects/users with other City Departments.
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?) Long/Short IWS forms reviewed and a site visit with sampling may be performed based on the information
provided. Flow volumes, type of products produced, categorical processes, discharge characteristics, and
information 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. County Landfill/no permit.
41. Does the POTW accept waste by (mark if applicable) ❑ Track []Dedicated Pipe ® NA
42. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples drawn,
manifests required) N/A
NC DWR Pretreatment Audit Form Revised: Julv 25. 2007 Paee 3

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%
47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) ❑ Yes ® No
If yes, Explain.
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 and NPDES
POCs.
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Monthly monitoring for new SIUs to determine baseline; monitoring may be reduced based on sample results; semi-annual
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 data9 ❑ 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? Presence and locations of floor drains and the
facility's chemical storage practices.
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 practices and secondary containment; presence of emergency
response equipment; how floor drain locations are addressed.
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 SILT: Z Yes ❑ No If yes, Explain. POTW has sampler manuals and on-site training;
SIU — sampling practices reviewed during inspections.
58. Who performs sample analysis for the POTW for Metals — On-site lab, Statesville Analytical, Meritech
Conventional Parameters — On-site Lab, Statesville Analytical
Organics — Meritech
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
POTW uses internal COC and the contracted lab's COC; SIU — contracted lab's COC.
NC DWR Pretreatment Audit Form Revised- July 25, 2007 Page 4

Long/Short Term Monitoring Plan (L/STMP) and Ileadworks 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 ❑ 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 ❑ NO DWQ Inspector, verify yourself!
60e If NO to any above, list violations
60f. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ® NO
If yes, which ones? Eliminated: Added:
61. Do you complete your own headworks analysis (HWA) ? ® Yes ❑ No
If no, Who completes your HWA?
62. Do you have plans to revise your HWA in the near future? ® 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 ®5 year expiration ❑Other, explain.
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)9 ❑ Yes ❑ No
Explain. N/A - sufficient capacity at the W WTPs.
Summary:
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment? No
INDUSTRIAL USER PERMIT (LUP) FILE REVIEW:
66. User Name
1.Paumac Tubing
2. Fischbein
3. Kewaunee Scientific
67. ATP Number
4003
4010
3009
68. Does File Contain Current Permits I
®Yes ❑ No1
® Yes ❑ No
® Yes ❑ No
69. Permit Expiration Date 1
7/1/19 11
9/1/20
3/1/21
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A 1
433
433
433
71. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
® Yes ❑ No
1 11
® Yes ❑ No
® Yes ❑ No
11
72. Does File Contain Inspection Completed Within Last Calendar Year?
I ® Yes ElNo
®Yes ❑ No
®Yes El 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❑No®N/A
❑Yes❑No®N/A
®Yes❑No❑1 1 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❑No®N/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?
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
77. Does File ContainPOTW Sampling Chain -Of -Custody Forms?
®Yes ElNo
® Yes ❑ No
®Yes ❑ No
78. During Most Recent Semi -Annual Period, Did SILT Complete its
Sampling as Required by IUP, including Flow?
®Yes❑No❑N/A
®Yes❑No❑N/A
11
®Yes❑No❑N/A
11
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 rocess/dilution flows as Required b IUP?
❑Yes❑NoON/A
1
❑Yes❑No®N/A
11
❑Yes❑NOON/A
80b. For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑NogN/A
81. During Most Recent Semi -Annual Period, Did POTW Identify All
Limits Non -Compliance from Both POTW and SIU Sampling?
F ❑Yes❑No®N/A
❑Yes❑NoUN/A
❑Yes❑No®N/A
82. During Most Recent Semi -Annual Period, Did POTW Identify All
Re ortin ,Non -Compliance from SIU Sampling?
❑Yes❑No®N/A
❑Yes❑NoON/A
❑Yes❑No®N/A
83. a. Was POTW Notified by SIU (Within 24 Hours) of All Self-
a.❑Yes❑No®N/A
a.❑Yes❑No®N/A
a.❑Yes❑NomN/A
NC DWR Pretreatment Audit Form Revised. July 25, 2007 Page 5

Monitoring Violations?
b. Did Industry Resample and submit results :o 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?
84. During Most Recent Semi -Annual Period, Was SILT in SNC?
85. During Most Recent Semi -Annual Period, VA7as Enforcement Taken as
Specified in POTW's ERP OVs, Penalties; timing, etc.)?
86. Does File Contain Penalty Assessment Notices?
87. Does File Contain Proof Of Penalty Collection?
88. a. Does File Contain Any Current Enforcement Orders?
b. Is SIU in Compliance with Order?
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
Information For You?
b ❑Yes❑No®N/A
c ❑Yes❑No®N/A
b ❑Yes❑NooN/A
c ❑Yes❑NooN/A
b ❑Yes❑NooN/A
c ❑Yes❑No®N/A
❑ Yes ® No
❑ Yes ® No
❑ Yes ® No
❑Yes❑No®N/A
F77 oNN/AIF7!r
®N/A
❑Yes❑No®N/A 11
❑Yes❑No®N/A
I ❑Yes❑NoUN/A
❑Yes❑No®N/A 11
❑Yes❑No®N/A
❑Yes❑No®N/A
a.❑Yes❑No®N/A
b ❑Yes❑No®N/A
a.❑Yes❑NooN/A
b ❑Yes❑No®N/A
a.❑Yes❑No®N/A
b ❑Yes❑NooN/A
❑ Yes ®No
❑Yes ® No
❑ Yes ® No
FILE REVIEW COMMENTS:
16/18. JPS Composite Materials was in SNC during July — December 2016 period for BOD limit violation (TRC).
58. The analyses performed by the POTW include TSS, cadmium, silver, nickel, and lead. Statesville Analytical has been contracted to
performed metals and BOD and ammonia; however, the POTW will resume the BOD and ammonia analyses within the near future.
Mentech performs low-level mercury and bis(2-ethyhexyl)pthalate.
72. POTW performed SlU inspections on 9/15/16 (Paumac Tubing), 9/16/16 (Fischbein), and 9/14/16 (Kewaunee Scientific).
74. Fischbein had mailed a letter (dated 8/11/15) to the POTW indicating that the finishing processes at the facility did not fall under 40
CFR 433.10 that required TTO monitoring, and no chemicals listed on Toxic Organic Compounds list were used at the facility. The
POTW is in the process of determining if the SIU meets the criteria of a 433 Metal Finisher.
78. The following laboratories have been contracted by the SlUs to perform analyses: Prism Laboratories (Paumac Tubing), Statesville
Analytical (Fischbein), and Pace Analytical (Kewaunee Scientific).
INDUSTRY INSPECTION PCS CODING:
Trans Code Main Program Permit Number MM/DD/YY Inspection type
ON N C 0 0 2 0 5 9 1 09 1 07 17 0
(DTIA) (TYPn
1. Industry Inspected: Paumac Tubing, LLC
2. Industry Address: 150 Intercraft Drive, Statesville, NC 28625
3. Type of Industry/Product: 433/Metal parts (racks, tailpipes, etc.) for ATVs, etc.
4. Industry Contact: Gerald Bennette Title: Pretreatment 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
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
Inspector Facility Type
-11 0
(INSP) (FACC)
NC DWR Pretreatment Audit Form Revised- July 25, 2007 Page 6

Industrial Inspection Comments:
The industrial facility currently operates one shift, five (5) days per week/eight (8) hours per day, and has approximately sixty-seven
(67) employees. The fabricated metal parts are conveyed through a five (5) stage process that includes cleaning (acidic), rinse, iron
phosphate coating, rinse, and non -chrome sealer. The first rinse stage is equipped with an oil/water skimmer. The Pretreatment system
includes pH adjustrment (as -needed) and flow measurement. The POTW is contacted prior to any cleaning/dumping of the tanks.
Hazmat has been contracted to remove any sludge, used oils, and/or any hazardous waste.
The SIU's IUP requires composite sampling for specific parameters; however, the SIU does not discharge throughout a 24 -hr. period.
In addition, the inspection revealed potential temperature preservation issues with the composite sampler due to elevated indoor
temperatures and inaccessibility of the sampler for the repacking of ice. The POTW will evaluate the SIU's IUP to potentially modify
the sample type from composite to grab.
SUMMARY AND COMMENTS:
The records reviewed during the inspection were organized and well maintained. The Pretreatment staff must ensure that all split
samples are appropriately averaged for compliance determinations and composite samples are properly preserved (<_ 6°C) throughout
the 24 -hr. period (40 CFR Part 136.3 Table II)
The POTW must complete the 433 verification on Fischbein by October 20, 2017.
NOD: ❑ Yes
® No
NOV: ❑ Yes
® No
QNCR: ❑ Yes
® No
POTW Rating:
Satisfactory ® M g' ElUnsatisfactory F1Audit COMPLETED BY: .f.�— DATE: September 25, 2017
Wes Bell, Mooresville Regional Office
NC DWR Pretreatment Audit Form Revised. July 25, 2007 Page 7