NC0024538_Compliance Evaluation Inspection_20171222

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Water Resources
Environmental Quality
December 22, 2017
Jordan Jackson
Pretreatment Coordinator
City of Shelby
Post Office Box 207
Shelby, North Carolina 28151-0207
ROY COOPER
Governor
MICHAEL S. REGAN
.Secretary
LINDA CULPEPPER
Interim Director
RFCOVEDMENRONR
JAN 0 5 ZOV
Vliater Resources
permitting
Subject: Pretreatment Compliance Inspection
City of Shelby
NPDES Permit No. NCO024538
Cleveland County
Dear Ms Jackson.
Enclosed is a copy of the Pretreatment Compliance Inspection Report for the inspection of the
City of Shelby's Industrial Pretreatment Program on December 15, 2017, by Mr Wes Bell of this Office.
Should you have any questions concerning flus report, please do not hesitate to contact Mr. Bell
at [phone], or via email at wes.bellnncdenr.gov.
Enclosure:
Inspection Report
cc* Vivien Zhong, PERCS Unit
MSC -1617 Central -Basement
ME
Sincerely,
A4atz,_�_1
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
State of North Carolina I Environmental Quality) Water Resources I Water Quality Regional Operations
Mooresville Regional Office 16 10 East Center Avenue, Suite 3101 Mooiesville, North Carolina 28115
704-663-1699

NORTH CAROLINA DIVISION OF WATER RESOURCES
N!`rlo
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PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
Water Resources
L1Yr01PEWi OUAI­
BACKGROUND INFORMATION [Complete Prior To PCI; Review Proaram Info Database Sheets
1. Control Authority (POTW) Name: City of Shelby
2. Control Authority Representative(s): Jordan Jackson
3. Title(s): Pretreatment Coordinator
4. Last Inspection Date: 5/18/16 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
NrfiflU53R 12/15/17
7. Current Number Of Significant Industrial Users (SlUs)?
5
8. Number of SIUs With No IUP, or With an Expired NP?
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)9
3
16. Number CIUs in SNC?
0
POTW INTERVIEW
17. Since the Last PCI, has the POTW had any NPDES Limits Violations? ❑ YES ® NO
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 LJ YES IN NO
Discharge (Interference, Pass -Through, Blockage, Citizens' Complaints, Increased
Sludge Production, Etc.)?
If Yes, How are these Problems Being Addressed9
19. Which Industries have been in SNC for Lmiits or Reporting during N/A
either of the Last 2 Semi -Annual Periods? Not Been Published for Not Published: N/A
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 N/A
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 ❑ YES ® NO
Ones?
LTMP/STMP FILE REVIEW:
22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies9 ® 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 Reports ® 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 December 2016 Page 1

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 Received
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis A
12/2/16
® Yes ❑ No
2/24/17
® Yes ❑ No
6/1/20
Industrial Waste Survey S
3/20/14
® Yes ❑ No
6/17/14
® Yes ❑ No
3/30/19
Sewer Use Ordinance SUO
9/7/11
® Yes ❑ No
9/23/11
® Yes ❑ No
[07Y7es ❑ No
Enforcement Response Plan RP
1/5/11
Yes ❑ No
12/22/11
® Yes ❑ No
35. Does File Contain an Inspection Completed Within Last Calendar Year?
Long Term Monitoring Plan (LTMP)
9/15/10
® Yes ❑ No
11/29/10
® Yes ❑ No
a. ®Yes []No
INDUSTRIAL USER PERMIT ) FILE REVIEW 3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29 User Name
1. IMC Metals America IF
2. Greenheck Fan
3. Clearwater Paper
30 IUP Number
1003
1006 1004
31. Does File Contain Current Permit?
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
32 Permit Expiration Date
6/30/21
9/8/19
11/1/19
33. Categorical Standard Applied I E 40 CFR, Etc) Or N/A
468
433
430.120
34 Does File Contain Permit Application Completed Within One Year Prior
E Yes ❑ No
[07Y7es ❑ No
® Yes E:1No
11
to Permit Issue Date?
35. Does File Contain an Inspection Completed Within Last Calendar Year?
I ® Yes ❑ No
® Yes ❑ No
—EYes ❑ No
36. a. Does the File Contain aSlug/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❑NoON/A
®Yes❑No❑N/A
11
❑Yes❑No®N/A
11
Organic Management Plan (TOMP)9
38. a. Does File Contain Original Permit Review Letter from the Division9
a. EYes [IN o
a ®Yes ❑No
a ®Yes []No
b. All Issues Resolved?
I 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
1 ® Yes ❑ No
®Yes ElNo
its Sampling as Required b ATP, includingflow
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
I ® Yes ❑ No
® Yes ❑ No IFN
Yes ❑ No
41 a. 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 lUP, mcludinflow
41b. During the Most Recent Semi -Annual Period, Did SILT submit all reports
❑Yes®No❑N/A
®Yes❑No❑N/A
®Yes❑No❑N/A
on time
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑NoEN/A
®Yes❑No❑N/A
❑Yes❑No®N/A
file includeprocess/dilution flows as Required by IUP?
42b. For categorical IUs with Production based limits, does file include
❑Yes❑No®N/A
❑Yes❑NoON/A
❑Yes❑No®N/A
production rates and/or flows as Required by IUPC
43a During the Most Recent Semi -Annual Period, Did the POTW Identify
®Yes❑No❑NA
®Yes❑No❑N/A
❑Yes❑NoON/A
All Limits Non -Compliance from Both POTW and SILT Sampling?
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
®Yes❑No❑N/A
❑Yes❑NoON/A
❑Yes❑NoON/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 Violations9
b. Did Industry Resample and submit results to POTW Within 30 Days?
b ®Yes❑No❑N/A
b ❑Yes❑NoNN/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 SILT in SNC?
I ❑ 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 Notizes?
❑Yes❑NoON/A
❑Yes❑NoON/A
❑Yes❑NoON/A
48. Does The File Contain Proof Of Penalty Collections
❑Yes❑NoEN/A
❑Yes❑No0N/A
❑Yes❑NoEN/A
49 a. Does the File Contain Any Current Enforcement Orders9
a ❑Yes❑No®N/A
I
a ❑Yes❑No®N/A
11
a.❑Yes❑No®N/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 This
❑ Yes ®No
[:1Yes ® No
FEI Yes ® No
Requested Information For Your
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

FILE REVIEW COMMENTS:
23. The POTW must ensure that the contracted lab uses the 0.002 mg/L LTMP detection level for copper during all future analyses.
28. SUO adopted on 10/3/11.
39. The POTW's on-site lab only performs analyses on conventional parameters during LTMP sampling events. The POTW contracts
Shealy Environmental Services to perform all analyses (including conventional parameters) during SIU sampling events.
41a. IMC Metals America and Greenheck Fan both contract Shealy Environmental Services to perform analyses. Clearwater Paper
contracts Prism Laboratories to perform all analyses.
42a. POTW had used CWF to determine compliance with Greenheck Fan's IUP limits; however, CWF is no longer used (as of
May 2017) following clarification from the Division's PERCS Unit.
43a. IMC Metals America was issued a NOV for a copper daily maximum limit violation in April 2017. Greenheck Fan was issued a
NOV for a pH minimum violation in June 2017.
43b. IMC Metals America was issued a NOV for the failure to submit the March 2017 sampling data within the required time period.
SUMMARY AND COMMENTS:
The approved ammonia LTMP detection level (0.1 mg/L) is used during the LTMP sampling events. The ammonia detection level of
0.5 mg/L is used during all remaining effluent sampling events per NPDES Permit. The POTW can either request a modification of the
LTMP to increase the ammonia detection level to 0.5 mg/L with written justification, or only use the ammonia results (using 0.1 mg/L
detection level) from the LTMP sampling events during the development of future HWAs.
The records reviewed during the inspection were organized and well maintained. The City's Industrial Pretreatment Program
appeared to be properly implemented.
NOD: ❑ YES ® NO
NOV: ❑ YES ®NO
QNCR: ❑ YES ® NO
POTW Rating:
Satisfactory ® Marginal ❑ Unsati actory_ ❑
f � /
PCI COMPLETED BY:�J2 i DATE: December 21, 2017
Wes Bell, Mooresville Regional Office
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3