NC0024538_Inspection_20190502

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
Ms. Janet Maddox
Pretreatment Coordinator
City of Shelby
Post Office Box 207
Shelby, North Carolina 28151
Dear Ms. Maddox:
NORTH CAROLINA
Environmental Quality
2 May 2019
Subject: Pretreatment Compliance Inspection
City of Shelby
NPDES Permit No. NCO024538
Cleveland County
Enclosed is a copy of the Pretreatment Compliance Inspection Report for the inspection of the City of Shelby's
approved Industrial Pretreatment Program on May 1, 2019, by Mr. Wes Bell of this Office.
The report should be self-explanatory; however, should you have any questions concerning this report, please do
not hesitate to contact Mr. Bell at [phone] or at wes.bell(&ncdenr.gov.
Sincerely,
DocuSigned by:
A14CC681 AF27425...
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
Enclosure: Inspection Report
Cc: PERCS (LaserFiche)
MRO (LaserFiche)
D Q
� 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
NORTH CAROLINA
Da"MoM a enWmn�bl mwnq 704,663.1699

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
BACKGROUND INFORMATION:
1. Control Authority (POTW) Name: City of Shelby
2. Control Authority Representative(s): Janet Maddox
3. Title(s): Pretreatment Coordinator
4. Last Inspection Date: 12/15/17 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
ICIS CODING
Main Program Permit Number MM/DD/YY
NCO024538 05/01/19
7. Current Number Of Significant Industrial Users (SIUs)?
1 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?
F 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 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 N/A
either of the Last 2 Semi -Annual Periods? Not Been Published for Not Pu
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
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
)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 1

28. PRETREATMENT PROGRAM ELEMENTS REVIEW:
Program Element
NCO020737
Last Submittal Received
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
12/2/16
® Yes ❑ No
2/24/17
® Yes ❑ No
6/1/20
Industrial Waste Survey (IWS)
3/29/19
® Yes ❑ No
6/17/14
® Yes ❑ No
In Review
Sewer Use Ordinance (SUO)
9/7/11
® Yes ❑ No
9/23/11
® Yes ❑ No
Enforcement Response Plan (ERP)
10/5/11
® Yes ❑ No
12/22/11
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
5/21/18
® Yes ❑ No
5/21/18
® Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW:
29. User Name
1. Greenheck Fan 2. IMC Metals America
3. KSM Castings
30. IUP Number
1006
1003
1005
31. Does File Contain Current Permit?
® Yes ❑ No
® Yes ❑ NoI
® Yes ❑ No
32. Permit Expiration Date
9/8/19
6/30/21
5/5/22
33. Categorical Standard Applied I.E. 40 CFR, Etc.) Or N/A
433
468
464
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 ❑ Nol
® 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. [I es []No
b. ❑Yes ONO 11
b. []Yes []No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
®Yes❑No❑N/A
®Yes❑No❑N/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❑No®N/A
b.❑Yes❑NoEN/A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
®Yes ❑ No
® Yes ❑ No
®Yes ❑ No
1
its Sampling as Required b IUP, includingflow?
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
® Yes ❑ No
I
❑
Yes ❑ No
® Yes ❑
No
41a. 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 IUP, including flow?
41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports
EYes❑No❑N/A
❑YesEN0❑N/A
EYes❑No❑N/A
on time?
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑NoEN/A
file include process/dilution flows as Required by IUP?
42b. For categorical IUs with Production based limits, does file include
❑Yes❑NoEN/A
EYes❑No❑N/A
EYes❑No❑N/A
production rates and/or flows as Required by IUP?
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑NoENA
EYes❑No❑N/A
❑Yes❑NoEN/A
All Limits Non -Compliance from Both POTW and SIU Sampling?
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑NoEN/A
EYes❑No❑N/A
❑Yes❑NoEN/A
All Reporting Non -Compliance from SIU Sampling?
44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
a.❑Yes❑NoEN/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
❑
Yes
®
No
❑
Yes
®
No
46. During the Most Recent Semi -Annual Period, Was Enforcement Taken
❑Yes❑NoEN/A
EYes❑No❑N/A
❑Yes❑NoEN/A
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
47. Does the File Contain Penalty Assessment Notices?
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑NoEN/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❑No®N/A
b.❑Yes❑No®N/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 7/25/07 Page 2

FILE REVIEW COMMENTS:
35. The POTW performed SIU inspections on 10/1/18 (Greenheck Fan), 10/2/18 (IMC Metals America), and 6/29/18 (KSM
Castings).
39. Shealy Environmental Services performs all LTMP analyses except for ammonia. The POTW's on -site certified laboratory
performs the ammonia analysis.
41 a. Greenheck Fan, IMC Metals America, and KSM Castings all contract Shealy Environmental Services to perform IUP
required analyses.
43a/46. The POTW issued a NOV (dated 8/28/18) to IMC Metals for a pH permit limit violation (POTW sampling event) in
August 2018.
43b/46. The POTW issued a NOV (dated 12/23/18) to IMC Metals for late reporting of the September 2018 monitoring
results.
SUMMARY AND COMMENTS:
The POTW staff must ensure that the contracted lab (Shealy Environmental Services) consistently uses the correct copper
detection level during LTMP and SIU sampling events. The LTMP and IUP required detection limit for copper is 2 ug/L and
the contracted lab was measuring down to 5 ug/L.
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 Rating:
Satisfactory ® Marginal ❑ Unsatisfactory_ ❑
a-'--'96D90CC3437
cuSigneddby:
PCI COMPLETED BY• ...
Wes Bell, Env. Specialist II
DocuSigned by:
E
PCI REVIEWED BY: A14CC681AF27425...
W. Corey Basinger, Regional Supervisor
DATE: 5/2/2019
DATE: 5/2/2019
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 3