NC0003450_Pretreatment Compliance Inspection_20200916

DocuSign Envelope ID: BDE9DAF1-B929-4EOF-8AC9-B726408C1B9C
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
Lisa Cottle, Pretreatment Coordinator
Town of Wallace
316 East Murray Street
Wallace, NC 28466
NORTH CAROLINA
Environmental Quality
September 23, 2020
SUBJECT: Pretreatment Compliance Inspection Report
Wallace WWTP
NPDES Permit No. NC0003450
Duplin County
Dear Ms. Cottle:
A Pretreatment Compliance Inspection of the Town of Wallace Wastewater Treatment Facility
Pretreatment Program was conducted by Helen Perez on September 16nd, 2020. This inspection
was conducted to determine the effectiveness of the pretreatment program by reviewing
various aspects of the program, which included files and records, industrial monitoring data,
data management procedures and adherence to the Enforcement Response Plan.
The Town of Wallace continues to do an effective job of achieving the pretreatment program
goals. The findings and comments noted during this inspection are provided in the enclosed
copy of the inspection report. There were no significant issues or findings noted during this
inspection thus a response to this inspection report is not required.
If you have any questions concerning this report, you may contact me at the letterhead contact
information or via email at [e-mail].
Sincerely,
DocuSigned by:
for
'Cha�,i��cuti D:_.
E731361`3456...
Morelia Sanchez -King, Regional Supervisor
Water Quality Regional Operations Section
Wilmington Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS
Cc: Wilmington Regional Office Files WQ0086819-Laserfiche
Central Office- Municipal Unit, Pretreatment -Kristen Litzenberger via email
D ��� North Carolina Department of Environmental Quality I Division of Water Resources
4��AWilmington Regional Office 1 127 Cardinal Drive Extension I Wilmington, North Carolina 28405
NORTH CAROIINA
� a ua­l U.W�y 910.796.7215

DocuSign Envelope ID: BDE9DAF1 -B929-4E0E-8AC9-B726408C1 B9C
r C'. NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
Water Resources
ENVIRONMENTAL QUALITY
BACKGROUND INFORMATION [Complete Prior To PCI; Review Prollram Info Database Sheet(s)]
1. Control Authority (POTW) Name: Town of Wallace
2. Control Authority Representative(s): Lisa Cottle
3. Title(s): WWTP Superintendent, Pretreatment Coordinator
4. Last Inspection Date: 08/29/2019 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:
ICIS CODING
Main Program Permit Number
I N I C 1 0 1 0 1 0 1 3 1 4 1 5 1 0
MM/DD/YY
1' RUIM& IM0 117
Are Milestone Dates Being Met? ❑ YES ❑ NO
7. Current Number Of Significant Industrial Users (SIUs)?
0
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?
F 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 ?
0
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 for
either of the Last 2 Semi -Annual Periods? Not Been Published for SNC for
Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not Put
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
BOD and Ammonia
❑ YES ®NO
Limits: N/A
Reporting: N/A
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 Division Inspector, please verify yourself!
26. IfNO 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

DocuSign Envelope ID: BDE9DAF1 -B929-4E0E-8AC9-B726408C1 B9C
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)
5-29-2014
® Yes ❑ No
7-8-2015
® Yes ❑ No
8-31-2019
Industrial Waste Survey (IWS)
8-12-2016
® Yes ❑ No
10-14-2016
® Yes ❑ No
5-1-2021
Sewer Use Ordinance (SUO)
1-26-2012
® Yes ❑ No
2-6-2012
® Yes ❑ No
Enforcement Response Plan (ERP)
1 8-4-2011
® Yes ❑ No
8-16-2011
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
1 7-15-2011
® Yes ❑ No
7-18-2011
® Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name
1. N/A 2.
3.
30. IUP Number
31. Does File Contain Current Permit?
❑ Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
32. Permit Expiration Date
33. Categorical Standard Applied I.E. 40 CFR, Etc.) Or N/A
34. Does File Contain Permit Application Completed Within One Year Prior
❑ Yes ❑ No
❑ Yes ❑ No
F
ElYes ❑ No
to Permit Issue Date?
I
35. Does File Contain an Inspection Completed Within Last Calendar Year?
I ❑ Yes ❑ No
❑ Yes ❑ No 11
❑ 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. ❑Yes []No
b. ❑Yes ❑No
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❑No❑N/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❑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
❑ No
Fl�
❑ Yes ❑ No
❑Yes ❑ No
1
its Sampling as Required b IUP, includingflow?
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
❑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
❑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❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
file include process/dilution flows as Required by IUP?
42b. For categorical IUs with Production based limits, does file include
❑Yes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
production rates and/or flows as Required b IUP?
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑ Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
All Limits Non -Compliance from Both POTW and SIU Sampling?
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑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❑No❑N/A
a.❑Yes❑No❑N/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❑No❑N/A
c. If applicable, Did POTW resample within 30 days of becoming aware
c.❑Yes❑No❑N/A
of SIU limit violations in the POTW's sampling of the SIU?
c.❑Yes❑No❑N/A
c.❑Yes❑No❑N/A
46. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
❑
Yes
❑
No 11
❑
Yes
❑ No 11
❑
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
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?
a.❑Yes❑No❑N/A
a.❑Yes❑No❑N/A
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
51. 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

DocuSign Envelope ID: BDE9DAF1 -B929-4E0E-8AC9-B726408C1 B9C
FILE REVIEW COMMENTS:
17. BOD and Ammonia violations have been issued since the last PCI due to mechanical issues with the Sequencing Batch Reactors (SBR)
which are currently being addressed through repairs.
22. The LTMP has been conducted at appropriate locations and frequencies since March 2019. Some quarters have been missed and the SBR
location was not sampled prior to that date. Lisa Cottle is working with the Municipal Unit -Pretreatment to sample the correct locations and
frequencies to be able to prepare and submit an updated HWA for approval.
25. Not all the LTMP data was reported on the DMR in 2017. Currently, 2018 and 2019 data is being reviewed.
26. The data not reported on the DMR are parameters that are not NPDES required pollutants and have no limits. There were no violations.
INDUSTRY INSPECTION ICIS CODING: N/A
Main Program Permit Number MM/DD/YY
1. Industry Inspected:
2. Industry Address:
3. Type of Industry/Product:
4. Industry Contact:
Phone:
Fax:
Title:
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:
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3

DocuSign Envelope ID: BDE9DAF1 -B929-4E0E-8AC9-B726408C1 B9C
OVERALL SUMMARY AND COMMENTS:
Comments: The Town of Wallace continues to have no SIU's or IUP's within the service area. The Town of Burgaw pumps their wastewater to
Wallace WWTP but maintains their own Pretreatment Program associated with their collection system permit. The Town of Burgaw and the
Town of Wallace are still in negotiations over the SUO and program components that would allow for surchar eg s and penalties for wastewater
allocations and exceedances. Since Lisa Cottle took over the Town of Wallace Pretreatment Program in 2019, she has reviewed the program in
detail and has discovered some issues. The HWA was due in August 2019, and there have not been enough LTMP data sets completed to update
the HWA. Lisa is working with the Municipal Unit -Pretreatment on this issue and the due date has been extended to January 2021.
Requirements:
Recommendations:
NOD: ❑ YES ®NO
NOV: ❑ YES ®NO
QNCR: ❑ YES ®NO
POTW Rating:
Satisfactory Marginal X UnSatisfactory
PCI COMPLETED BY: Helen Perez DATE: 09/23/2020
,.—DocuSigned by: DocuSigned by:
v 9/23/2020
E73B6F3456...
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 4