NC0023884_Compliance Evaluation Inspection_20180508

s
Water Resources
Environmental Quality
8 May 2018
Ms. Sonja Basinger
Environmental Services Manager
Salisbury -Rowan Utilities
1915 Grubb Ferry Road
Salisbury, North Carolina 28144
Subject: Pretreatment Compliance Inspection
City of Salisbury
NPDES Permit No. NCO023884
Rowan County
Dear Ms. Basinger:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Interim Director
Enclosed is a copy of the Pretreatment Compliance Inspection Report for the inspection of the City
of Salisbury's Industrial Pretreatment Program on May 1, 2018, by Mr. Wes Bell of this Office.
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,
DocuSigned by:
A14CC681 AF27425...
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
Enclosure:
Inspection Report
cc: Monti Hassan, PERCS Unit ([e-mail])
State of North Carolina I Environmental Quality) Water Resources I Water Quality Regional Operations
Mooresville Regional Office 1610 East Center Avenue, Suite 310 1 Mooresville, North Carolina 28115
704-663-1699

NORTH CAROLINA DIVISION OF WATER RESOURCES
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PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
Water Resources
ENVIRONMENTAL DUALITY
BACKGROUND INFORMATION
1. Control Authority (POTW) Name: City of Salisbury
2. Control Authority Representative(s): Sonja Basinger, Jeff Greer
3. Title(s): Environmental Services Manager, Pretreatment Coordinator
4. Last Inspection Date: 3/14/17 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
PCS CODING
Main Program Permit Number MM/DD/YY
NCO023884 5/1/18
7. Current Number Of Significant Industrial Users SIUs ?
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?
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)?
3
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?
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 fox
either of the Last 2 Semi -Annual Periods? Not Been Published for SNC fox
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
[—]YES ® NO
Limits: None
Reporting: None
flished: 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
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1

28. PRETREATMENT PROGRAM ELEMENTS REVIEW
Program Element
Last Submittal Received
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
10/18/17
® Yes ❑ No
2/22/18
® Yes ❑ No
11/1/22
Industrial Waste Survey IWS
9/11/14
® Yes ❑ No
10/13/14
® Yes ❑ No
10/1/19
Sewer Use Ordinance (SUO)
1/3/13
® Yes ❑ No
1/10/13
® Yes ❑ No
® Yes ❑ No
Enforcement Response Plan (ERP)
5/6/13
® Yes ❑ No
6/17/13
® Yes ❑ No
35. Does File Contain an Inspection Completed Within Last Calendar Year?
Long Term Monitoring Plan (LTMP)
4/24/17
® Yes ❑ No
6/28/17
® Yes ❑ No
a. ®Yes ❑No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name
1. Freirich Foods 2. Hitachi Metals
3. Innospec
30. IUP Number
0007
0026
0038
31. Does File Contain Current Permit?
® Yes ❑ No
® Yes ❑ NoI
® Yes ❑ No
32. Permit Expiration Date
3/30/21
6/30/21
9/30/22
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
N/A
471
N/A
34. Does File Contain Permit Application Completed Within One Year Prior
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
to Permit Issue Date?
35. Does File Contain an Inspection Completed Within Last Calendar Year?
I ® Yes ❑ No
® Yes ❑ No
® 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. 0 e []No
b. ❑Yes ❑No
b. []Yes []No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑NoEN/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❑NoEN/A
b.❑Yes❑NoEN/A
b.❑Yes❑NoEN/A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
® Yes ❑No
® Yes EINo
® Yes [_1No
its Sampling as Required b IUP, includingflow?
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
EYes❑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 reports
®Yes❑No❑N/A
❑YesENo❑N/A
®Yes❑No❑N/A
on time?
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑NOEN/A
❑Yes❑NoEN/A
❑YesONOEN/A
1
file include process/dilution flows as Required b IUP?
42b. For categorical IUs with Production based limits, does file include
❑Yes❑NoEN/A
Eyes❑No❑N/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❑No❑NA
❑Yes❑NoON/A
❑YesONOEN/A
All Limits Non -Compliance from Both POTW and SIU Sampling?
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
EYes❑No❑N/A
EYes❑No❑N/A
EYes❑No❑N/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❑NoEN/A
a.❑Yes❑NoEN/A
Monitoring Violations?
b. Did Industry Resample and submit results to POTW Within 30 Days?
b.®Yes❑No❑N/A
b.❑Yes❑No®N/A
b.❑Yes❑NoEN/A
c. Did POTW resample within 30 days of knowledge of SIU limit
c.❑Yes❑NoEN/A
c.❑Yes❑NoEN/A
c.❑Yes❑NoEN/A
violations from the POTW sample event?
45. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
❑ Yes ® No 11
❑ Yes ® No 11
❑ Yes ® No
46. During the Most Recent Semi -Annual Period, Was Enforcement Taken
EYes❑No❑N/A
EYes❑No❑N/A
EYes❑No❑N/A
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
47. Does the File Contain Penalty Assessment Notices?
❑Yes❑NoEN/A
❑YesONOEN/A
❑YesONoNN/A
48. Does The File Contain Proof Of Penalty Collection?
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑NoEN/A
49. a. Does the File Contain Any Current Enforcement Orders?
a.❑Yes❑NoEN/A
a.❑Yes❑NoEN/A
a.❑Yes❑NoEN/A
b. Is SIU in Compliance with Order?
b.❑Yes❑No®N/A
b.❑Yes❑NoEN/A
b.❑Yes❑NoEN/A
50. Did the POTW Representative Have Difficulty in Obtaining Any of This
❑ Yes ® No
❑ Yes ® No
❑ Yes ®No
Requested Information For You?
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

FILE REVIEW COMMENTS:
23. A revised LTMP (dated 5/1/18) has been submitted to the Division's PERCS Unit to change the nitrite -nitrate detection level from
0.05 mg/L to 0.3 mg/L.
28. SUO was adopted on 8/20/13.
35. POTW performed SIU inspections on 4/18/17 (Freirich Foods), 11/16/17 (Hitachi Metals), and 11/7/17 (Innospec).
39. The POTW's on-site certified laboratory performs analyses on conventional parameters, cyanide, chloride, TKN, total phosphorus,
sulfate, and turbidity. R&A Labs (metals, oil & grease, phenols, nitrite, nitrate, hardness) and Meritech (Priority Pollutants, toxicity)
have also been contracted to preform analyses.
41a. Freirich Foods and Hitachi Metals both contract R&A Labs for analyses. Innospec contracts Pace Analytical Services for
analyses.
43a/46. Freirich Foods was issued a NOV for an oil & grease daily maximum limit violation (August 2017).
43b/46. Freirich Foods and Innospec were issued Notice of Noncompliances for the failures to properly report results on the IDMRs.
Hitachi Metals was issued a NOV for the late submittal of the November 2017 flow report.
SUMMARY AND COMMENTS:
The records reviewed during the inspection were organized and well maintained. The POTW's Industrial Pretreatment Program was
being properly implemented.
NOD: ❑ YES ® NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ® NO
POTW Ratinjj•
Satisfactory ❑ Marginal ❑ Unsatisfactory ❑
cuSigned by:
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Be&
PCI COMPLETED BY: ... DATE: 5/7/2018
Wes Bell, Mooresville Regional Office
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3