NC0026042_Pretreatment_Program_Letter_20220909

DocuSign Envelope ID: D44FEFBC-B875-48FC-B509-D37A90CB373F
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
9/9/2022
Via Electronic Mail ([e-mail])
Mr. James P. Duncan
Town Manager
Town of Robersonville
P.O. Box 487
Robersonville, NC 27871-0487
Subject:
Immediate Actions Needed to Restart Pretreatment Program
Currently Inactive Program: Town of Robersonville,
Town of Robersonville WWTP,
NPDES # NC0026042,
Martin County
Dear Mr. Duncan:
The Division of Water Resources received a copy of an invalid industrial user permit for Flagstone Foods, LLC
on 8/29/22. The reason this permit submission is invalid as an Industrial User Permit (IUP) is because the Town's
pretreatment program is still under an inactive status - having been as such since the 2010 through 2014 NPDES
permit cycle. For an IUP to be issued "under the industrial pretreatment program" (as it says on the front page of
Town's submission) there must be an ACTIVE pretreatment program for an IUP to become an enforceable
instrument.
The Division's letter to the Town dated 2/17/2022 refers to Part IV, Special Conditions for Municipal Facilities
and requests submission of "a timeline of how the Town plans to move forward with establishing a Pretreatment
Program." All the responsibilities for maintaining a pretreatment program are detailed in Part IV - please do
carefully read this part of the Town's NPDES Permit for guidance.
The Division's NOV & Intent to Assess Civil Penalty letter, dated 8/10/22, stated: "A timeline of how the Town
of Robersonville plans to move forward with Establishing a Pretreatment Program is required within ten (10)
business days after receipt of this notice." This was not submitted to the Division. Please re -read the 8/10/22 letter
and complete the required response by September 30, 2022. The Division recognizes that maintaining a fully
compliant pretreatment.program requires staff having specialized training and experience.
Federal and State pretreatment regulations require the local delegated pretreatment program to effectively control
and document the discharge of wastewater from Significant/Categorical Industrial Users to the POTW. It is the
POTW' s responsibility to ensure that these objectives are consistently met (15A NCAC 02H .0900, Local
Pretreatment Programs).
DE
NORTH CAROLINA
oeo.m.ei of Environmental W.i�
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11611 Mail Service Center I Raleigh, North Carolina 27699-1611
919.707.9000

DocuSign Envelope ID: D44FEFBC-B875-48FC-B509-D37A90CB373F
If you have any questions or comments, please contact Keyes McGee at [phone] [email:
keyes. mcgee@ncdenr. gov] .
tkm/Robersonville_PT 001
Ec: Rebecca Manning, EnviroLink
([e-mail])
Municipal Unit File
Keyes.McGee, Municipal Unit
Robbie Bullock, WaRO
Central Files (Laserfische)
D_E
NORTH CAROLINA
gaparhneM of Environment,/quay
Sincerely,
Ltb/y�:, -. L'
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C464531431644FE...
Michael Montebello,
NPDES Permitting Branch Chief
Division of Water Resources
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11611 Mail Service Center I Raleigh, North Carolina 27699-1611
919.707.9000