NC0024201_Pretreatment Audit_20231030

DocuSign Envelope In A90CEBC8-7539-41A6-986D-C12D9ADC41C2
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Mr. R. Danieley Brown, CEO
Roanoke Rapids Sanitary District
P.O. Box 308
Roanoke Rapids, NC 27870
Subject: Pretreatment Audit
NORTH CAROLINA
Environmental Quality
October 30, 2023
Roanoke Rapids Sanitary District (RRSD)
NPDES Permit No. NCO024201
Halifax County
Dear Mr. Brown:
On July 20, 2023, Cheng Zhang of the Raleigh Regional Office (RRO) conducted a Pretreatment
Compliance Audit of Roanoke Rapids Sanitary District's pretreatment program. The assistance given
by Ms. Isabelle Wilcoxon, the pretreatment coordinator, was greatly appreciated. The audit report is
attached. Findings during the inspection were as follows:
There are three Significant Industrial Users (SIUs), two of which are also Categorical Industrial
Users (CIUs). It was noted that no SIUs were in Significant Non -Compliance (SNC) for the two
most recent semi-annual periods.
2. The pretreatment audit file review included Kennametal (Permit No. 002), Reser's Fine Food
(Permit No. 009), and Rosemary Power (Permit No. 007). The files needed for review were
available for inspection, contained all the required elements and were in excellent condition.
3. POTW and SlUs completed monitoring as required by the Industrial User Pretreatment Permits
(IUPs) during the most recent semi-annual period. Kennametal and Rosemary Power were in
compliance. Resers Fine Foods had two BOD violations and one flow violation, the POTW took
appropriate action to address these violations.
4. During the audit, Ms. Wilcoxon inspected one of the three SIUs, Kennametal. The inspection
was very thorough. It was evident that Ms. Wilcoxon has excellent relationship with the industry
representative, broad knowledge of pretreatment, great attention to details, and proactive attitude
to solve potential problems together with industrial users.
5. A review of the files containing the pretreatment program elements was conducted. These files
were very well organized. Update of Industrial Waste Survey, Sewer Use Ordinance, and Long
Term Monitoring Plan was submitted to the Division since the last inspection, all items are still
in review by the Division.
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office I 3800 BarrettDrive I Raleigh, North Carolina 27609
NORTH CAROLINA ^ 919.791.4200
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6. The review of Long Term Monitoring Plan (LTMP) data indicated that all locations were
sampled with required frequencies, and all samples were analyzed using correct detection limits
specified in the LTMP since last inspection.
Thank you for your continued support of the Pretreatment Program. If you have any questions or
comments, please call Cheng Zhang at [phone] (or email: [e-mail]).
Sincerely,
ocu Signed by:
E�D
a f. have �u,l,2916E6AB32144F...
Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Attachment(s): RRSD PT Audit Form
Cc: Laserfiche
Isabelle Wilcoxon, RRSD (Electronic copy only)
D � ��� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CAROLINA ��` 919.707.9000
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NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT AUDIT REPORT
Water Resources
ENVIRONMENTAL QUALITY
Background Information [Complete prior to audit; review Program Info Database Sheet(s)]
1. Control Authority (POTW) Name: RRSD
2. Control Authority Representative(s): Isabelle Wilcoxon
3. Title(s): Pretreatment Coordinator/ Lab Suuervisor
4. Address of POTW:
Mailing 135 Aqueduct Rd
City Weldon Zip Code 27890
Phone Number 2525364884 Fax Number 2525364885 E-Mail iwilcoxon(&rrsd.org
5. Audit Date 07/20/2023
6. Last Inspection Date: 08/26/2022 Inspection Type: ® PCI ❑ Audit
7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s) ? ® Yes ❑ No
If No, Explain.
8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? ® Yes ❑ No
If Yes, Explain. Missed ammonia nitrogen in the first week of August 2022
9. Is POTW under an Order That Includes Pretreatment Conditions? ❑ Yes ® No
Order Type and Number: Are Milestone Dates Being Met? ❑ Yes ❑ No ® NA
Parameters Covered Under Order
ICIS Coding
Main Program Permit Number
INIC101012 14 12 10 111
MM/DD/YY
07 120 � 23
10.
.................................................................
Current Number of Significant Industrial Users(SIUs)?...............................................................................................
3
11.
....................................................................................................................................................................................................................................................................................................
Number of SIUs with No IUP, or with an Expired IUP?
0
12.
....................................................................................................................................................................................................................................................................................................
Number of SIUs Not Inspected by POTW in Last Calendar Year?
0
13.
....................................................................................................................................................................................................................................................................................................
Number of SIUs Not Sampled by POTW in Last Calendar Year?
0
14.
....................................................................................................................................................................................................................................................................................................
Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi -Annual Periods?
0
15.
....................................................................................................................................................................................................................................................................................................
Number of SIUs in SNC for Reporting During Either of Last 2 Semi -Annual Periods?
0
16.
....................................................................................................................................................................................................................................................................................................
Number of SIUs in SNC with Pretreatment Schedule?
0
17.
....................................................................................................................................................................................................................................................................................................
Number of SIUs on Schedules?
0
18.
Current Number of Categorical Industrial Users..(CIUs)?............................................................................................
2
19.
Number of CIUs in SNC?
0
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20. PRETREATMENT PROGRAM ELEMENTS REVIEW- Review POTW files, verify POTW has copy of each Program Element
in their File, complete with all supporting documents and 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)
5/1/2019
® Yes ❑ No
11/5/2019
® Yes ❑ No
7/1/2025
Industrial Waste Survey (IWS)
1/11/2023
® Yes ❑ No
1/18/2018
® Yes ❑ No
2/1/2023
Sewer Use Ordinance (SUO)
8/22/2022
® Yes ❑ No
10/21/2011
® Yes ❑ No
Enforcement Response Plan (ERP)
1/28/2020
® Yes ❑ No
2/5/2020
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
8/26/2022
® Yes ❑ No
2/10/2020
® Yes ❑ No
Legal Authority (Sewer Use Ordinance-SUO)
21. Do you have any towns and/or areas from which you receive wastewater which are not in your annexed jurisdiction?
® Yes ❑ No If yes, Please list these towns and/or areas. City of Roanoke Rapids, Northampton County, Town of Gaston,
Halifax County
22. If yes to #21, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? ® Yes ❑ No ❑ NA
A copy, if not already submitted, should be sent to Division.
23. If yes to #21, Have you had any trouble working with these towns or districts? ❑ Yes ® No ❑ NA
If yes, Explain.
24. Date of Last SUO Adoption by Local Council 11/10/2011
25. Have you had any problems interpreting or enforcing any part of the SUO? ❑ Yes ® No
If yes, Explain.
Enforcement (Enforcement Response Plan-ERP)
26. Did you send a copy of the ERP to your industries? ® Yes ❑ No
If no, POTW must send copy within 30 days.
27. Have you had any problems interpreting or enforcing any part of the ERP (i.e. any adjudication, improper enforcement, etc?
❑ Yes ® No If yes, Explain.
28. List Industries under a Schedule or Order and Type of Schedule or Order
N/A
Resources
29. Please Rate the Followine: S=Satisfactory M=Marginal U=Unsatisfactory
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
®S ❑M ❑U
Access to POTW Vehicles for
Sampling, Inspections, and
®S ❑M ❑U
Emergencies
Access to Operable Sampling
Equipment
®S ❑ M Flu
Availability of Funds if Needed for
Additional Sampling and/or Analysis
®S ❑M ❑U
Reference Materials
®S ❑M ❑U
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
®S ❑M ❑U
Computer Equipment (Hardware and
Software)
®S ❑M ❑U
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30. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No
Explain Yes or No. Computer spreadsheets for sampling and monitoring data
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Annual permit fees, IUP renewal fees, BOD and TSS surcharges
Public Perception/ Participation
32. Are there any local issues affecting the pretreatment program (e.g.. odor, plant closing, new or proposed plants)?
❑ Yes ® No If yes, Explain.
33. Has any one from the public ever requested to review pretreatment program files? ❑ Yes ® No
If yes, Explain procedure. If no, how would the request be addressed? Pretreatment coordinator would review relevant files in
program with individual
34. Has any industry ever requested that certain information remain confidential from the public? ® Yes ❑ No If yes, Explain
procedure for determining whether information qualified for confidential status, as well as procedure for keeping files confidential
from public. If no how would the request be addressed? Kennametal request that their propriety product information is not
discussed outside of their plant site, and no photos are taken while in their manufacturing area. Effluent sampling data
would be released if requested.
35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? ® Yes ❑ No
36. Is the public notified about changes in the SUO or Local Limits? ® Yes ❑ No
37. Were all industries in SNC published in the last notice? ❑ Yes ❑ No N/A
Permitting (Industrial Waste Survey-IWS)
38. How does the POTW become aware of new or changed Users? When customers request water or ww services, they
are required to fill out a short form, kept on file at Admin office. City of RR sends Business Use Permit
Applications to RRSD, which are reviewed for follow up. Filed for use in IWS
39. Once the POTW becomes aware of new or changed Users, how does the POTW determine which industries have the
reasonable potential to adversely impact the WWTP and therefore require a new permit or a permit revision? (Who is an
SILT?) Review short form, phone survey, long form and/or site visit
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
❑Yes ®No If Yes, How many are there?
Please list each site and how it is permitted, if applicable.
41. Does the POTW accept waste by (mark if applicable) ® Truck ❑Dedicated Pipe ❑ NA
42. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples drawn,
manifests required) Haulers are registered with RRSD, request entry to plant site, waste added at head of plant,
ticket/documentation for each load accepted. Hauler certifications renewed annually.
43. How does the POTW allocate its loading to industries? Mark all that apply
❑ Uniform Limits ® Historical Industry Need ❑ By Surcharge ® Categorical Limits ❑ Other
Explain Other:
44. Review POTW's copies of current allocation tables for each WWTP. Are there any over allocations? ❑ Yes ® No
If yes, what parameters are over allocated?
45. If yes to #44, What is being done to address the over allocations? (short-term IUPs, HWA to be revised, pollutant study, etc.)
46. Does the POTW keep pollutant loading in reserve for future growth / safety? ® Yes ❑ No
If yes, what percentage of each parameter 20%
47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) ❑ Yes ® No
If yes, Explain.
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48. How does the POTW decide on which pollutants to limit in the permits? Monitor for? (for example: were only those pollutants
listed on the application limited; categorical parameters; NPDES Pollutants of Concern)
Local limits, NPDES limits, historical discharge, POC, Categorical limits, PPA
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
At least minimum requirements, historical industry performance
Permit Compliance
50. Does the POTW currently have or during the past year had any permits under adjudication? ❑ Yes ® No
If yes, which industries? What was (will be) the outcome of the adjudication?
51. Demonstrate how the POTW judges compliance. This should include compliance judgment on all violations of limits, reporting
requirements, and permit conditions, as well as for SNC. Data reviewed on receipt, entered into spreadsheets, limits formatted
into spreadsheets, violations highlighted. SNC calculated by/in spreadsheet
52. Does the POTW use the Division's model inspection form or equivalent? ® Yes ❑ No
If no, does the POTW form include all Division data? ❑ Yes ❑ No
53. Were all SIUs evaluated for the need of a slug/spill control plan during their most recent inspections? ® Yes ❑ No
If no, Explain.
54. What criteria are used to determine if a slug/spill control plan is needed?
Each industry has a S/S plan, reviewed annually with employees and training documented
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Review of industry during inspection, minimum requirement to comply to SUO and Permit criteria
56. How does the POTW decide where the sample point for an SIU should be located?
Safety, convenience, power availability, location, ww stream flow, Federal requirements
57. Has the POTW established a procedure to ensure that representative samples will be taken by the POTW or SIU each time?
(example: correct location; proper programming of sampler; clean equipment; swirling the sample bucket uniformly)
POTW: ® Yes ❑ No SIU: ® Yes ❑ No If yes, Explain. SOP outlines sampling requirements, ongoing
onsite training and review with industry personnel, (2 ind have certified WW operators). Most sampling for POTW is
performed by Pretreatment Coordinator
58. Who performs sample analysis for the POTW for Metals Meritech
Conventional Parameters RRSD
Organics Meritech
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
RRSD CofC & contract lab CofC, filed in each industry folder
Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis (HWA)
60a.
60b.
60c.
60d.
60e.
60f.
Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑ NO
Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ® YES ❑ NO
Is LTMP/STMP Data Maintained in Table or Equivalent? ® YES ❑ NO Is Table Adequate? ® YES ❑ NO
All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? ® YES ❑ NO Division Inspector, verify yourself!
If NO to any above, list violations
Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ® NO
If yes, which ones? Eliminated: Added:
61. Do you complete your own headworks analysis (HWA) ? ® Yes ❑ No
If no, who completes your HWA? Phone ( ) --
62. Do you have plans to revise your HWA in the near future? ® Yes ❑ No
If yes, what is the reason for the revision? (mark all that apply) ❑Increased average flow ❑NPDES limits change
❑More LTMP data available ❑Resolve over allocation ®5 year expiration ❑Other
Explain. HWA due 2020, unless NPDES (expired 3/31/17) permit renewal is received sooner. Available data has been
entered into HWA spreadsheet
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63. In general, what is the most limiting criteria of your HWA? ❑Inhibition ❑ Pass Through ®Sludge Quality
64. Do you see any way to increase your loading in the future (Example: obtaining more land for sludge disposal)? ❑ Yes ® No
Explain. Acreage permitted for Land App has changed, total remained the same
Summary
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
No
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INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION)
66. User Name
1. Kennametal
2. Rosemary Power
3. Resers Fine Foods
67. IUP Number
002
007
009
68. Does File Contain Current Permit?
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
69. Permit Expiration Date
5/31/202
5/31/202
5/31/202
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
40 CFR 471 J
40 CFR 423.17
NA
71. Does File Contain Permit Application Completed Within One Year Prior
® Yes ❑ No
®Yes ❑ No
® Yes ❑ No
to Permit Issue Date?
72. Does File Contain Inspection Completed Within Last Calendar Year?
® Yes ❑
I ® Yes ❑
I ® Yes ❑
No
73. a. Does File Contain 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 I
b. ❑Yes ❑No
74. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
❑Yes❑NoON/A
F
❑Yes❑No®N/A
❑Yes❑NoON/A
Organic Management Plan (TOMP)?
1
75. a. Does File Contain Original Permit Review Letter from 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
76. During Most Recent Semi -Annual Period, Did POTW Complete its
® Yes ElNo
F977E] No
® Yes ❑ No
Sampling as Required by IUP, including Flow?
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
78. During Most Recent Semi -Annual Period, Did SIU Complete its
®Yes❑No❑N/A
F
®Yes❑No❑N/A
®Yes❑No❑N/A
Sampling as Required b IUP, includingFlow?
1
79. During Most Recent Semi -Annual Period, Did SIU submit all reports on
®Yes❑No❑N/A
®Yes❑No❑N/A
®Yes❑No❑N/A
time?
80a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑No[D
❑Yes❑Noll
❑Yes❑NoON/A
file includeprocess/dilution flows as Required by IUP?
80b. For categorical lUs with Production based limits, does file include
❑Yes❑No[D
❑Yes❑No®N/A
❑Yes❑NoON/A
production rates and/or flows as Required by IUP?
81. During Most Recent Semi -Annual Period, Did POTW Identify All
❑Yes❑No®N/A
❑Yes❑No®N/A
®Yes❑No❑N/A
Limits Non -Compliance from Both POTW and SIU Sampling?
82. During Most Recent Semi -Annual Period, Did POTW Identify All
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑NoON/A
Re ortin Non -Compliance from SIU Sampling?
83. a. Was 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 and obtain results within 30 days of
becomingaware of SIU limit violations in the POTW's sampling of SIU?
❑ c.Yes❑No®N/A
c.❑Yes❑No®N/A
c.❑Yes❑No®N/A
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
❑
Yes
®
No
❑
Yes
®
No
❑
Yes
®
No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
❑Yes❑No®N/A
❑Yes❑No®N/A
®Yes❑No❑N/A
Specified in POTW's ERP (NOVs, Penalties, timing, etc.)?
86. Does File Contain Penalty Assessment Notices?
❑Yes❑NoON/A
❑Yes❑No®N/A
®Yes❑No❑N/A
87. Does File Contain Proof Of Penalty Collection?
❑Yes❑No®N/A
❑Yes❑No®N/A
®Yes❑No❑N/A
88. a. Does 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
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
❑ Yes ® No
❑ Yes ® No
❑ Yes ®No
Information For You?
IF
FILE REVIEW COMMENTS:
81— Resers Fine Foods Had two BOD violations and one flow violation.
85 & 86 — The POTW issued NOV to address Resers Fine Foods' violations and assessed civil penalty.
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INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
I N I C 1 0 IO I2 I4 12 10 11 I07 I20 I23 I
1. Industry Inspected: Kennametal
2. Industry Address: 100 Kennametal Rd, Weldon, NC 27890
3. Type of Industry/Product: Nonferrous Metals Forming & Metal Powders/Metal Cutting Tools
4. Industry Contact: Randy Griffin Title: EHS Manager Phone: [phone] Fax:
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:
The SIU inspection was very thorough and met the DWR requirements.
Audit SUMMARY AND COMMENTS:
Audit Comments: The Pretreatment program is well managed and implemented.
Requirements: None
Recommendations: None
NOD: ❑ Yes ® No
NOV: ❑ Yes ® No
QNCR: ❑ Yes ® No
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory ❑
Audit COMPLETED BY: Cheng Zhang, Raleigh Regional Office DATE: July 20, 2023
NC DWR Pretreatment Audit Form Revised: December 2016 Page 7