NC0003450_Pretreatment Audit Report_20240820

Docusign Envelope ID: 1A7B9687-6016-43DD-9314-019287AOEB1A
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: Town of Wallace
2. Control Authority Representative(s): Lisa Cottle
3. Title(s): WWTP Superintendent, Pretreatment Coordinator
4. Address of POTW: 851 Old Wilmington Road, Wallace
Mailing 316 East Murray Street
City Wallace, NC Zip Code 28466
Phone Number 910-665-2091 Fax Number E-Mail lcottle(&wallacenc.gov
5. Audit Date 08/20/2024
6. Last Inspection Date: 05/10/2023 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. In 2/24, facility had a monthly average limit exceedance for ammonia.
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 4
MM/DD/YY
INIC1010I0 I3 14 Is IO 1
I08I20I24�
10.
....................................................................................................................................................................................................................................................................................................
Current Number of Significant Industrial Users (SIUs)?
2
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?
1
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)?
0
19.
Number of CIUs in SNC?
N/A
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Docusign Envelope ID: lA7B9687-6016-43DD-9314-019287AOEB1A
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)
08/20/24
® Yes ❑ No
*
❑ Yes ❑ No
Industrial Waste Survey (IWS)
04/15/21
® Yes ❑ No
05/03/21
® Yes ❑ No
Sewer Use Ordinance (SUO)
5/24/21
® Yes ❑ No
09/20/21
® Yes ❑ No
Enforcement Response Plan (ERP)
05/28/20
® Yes ❑ No
08/18/20
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
08/20/24
® Yes ❑ No
*
❑ 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. Burgaw, Greenevers, Teachey. Pender County is allocated but has
not sent any flow to date.
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. Past issues with the Town of Burgaw have been resolved with the issue of a SIU permit on 8/1/23.
24. Date of Last SUO Adoption by Local Council 10/14/21
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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Docusign Envelope ID: lA7B9687-6016-43DD-9314-019287AOEBIA
30. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No
Explain Yes or No. Spreadsheets
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Pretreatment fees for SIUs.
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? Access could be granted through the town hall
administration.
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? Confidential information would be left out of any files viewed by the
public.
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? The Short Form has been added to the Town's water
usuage application packet. These are reviewed by the Pretreatment Coordinator for possible SIUs.
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
SIU?) The POTW reviews type of industry, flow volumes, POCs and contacts industry for additional information if
needed.
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) The POTW accepts septic hauler waste at a designated location and pH is monitored before
acceptance.
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? The HWA submitted on 08/20/24 shows no parameters over allocated.
The HWA has not been review and approve to date.
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 Pretreatment coordinator is in the training process to learn how to determine the
percentage for each parameter.
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Docusign Envelope ID: 1A7B9687-6016-43DD-9314-019287AOEB1A
47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) ❑ Yes ® No
If yes, Explain.
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)
NPDES Permit limits and historical limits.
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Depends of the industry process and if there have been issues with the industry.
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. A spreadsheet is formulated to flag limit exceedances and SNC.
Reporting requirements and permit conditions are determined through regular monitoring of reports and facility
inspections. The ERP is then used to determine the violations.
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?
Potential for a spill or slug to reach the POTW.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
If the plan includes procedures to stop the flow, remediation procedures, contact information. The Town of Burgaw has
spill plans on file from each of their SIUs as part of their Pretreatment Program. They are also in the process of modifying
their Emergency Response Plan to add the Town of Wallace's contact information.
56. How does the POTW decide where the sample point for an SILT should be located?
At the discharge point to the collection system.
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. The SIU permits explain the location and
representative sample requirements. Envirochem labs currently perform all the sampling for the POTW. The POTW is in
the process of developing a SOP for sampling.
58. Who performs sample analysis for the POTW for Metals Envirochem
Conventional Parameters Envirochem
Organics Envirochem
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Envirochem COCs are used.
Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis (HWA)
60a. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑ NO
60b. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ® YES ❑ NO
60c. Is LTMP/STMP Data Maintained in Table or Equivalent? ® YES ❑ NO Is Table Adequate? ® YES ❑ NO
60d. All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? ® YES ❑ NO Division Inspector, verify yourself!
60e. If NO to any above, list violations
60f. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ® NO
If yes, which ones? Eliminated: Added:
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Docusign Envelope ID: 1A7B9687-6016-43DD-9314-019287AOEB1A
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.
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.
Summary
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
No
NC DWR Pretreatment Audit Form Revised: December 2016 Page 5

Docusign Envelope ID: 1A7B9687-6016-43DD-9314-019287AOEB1A
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION)
66. User Name
1. Darling Ingredients
2. Town of Burgaw
3.
67. IUP Number
001
002
68. Does File Contain Current Permit?
® Yes ❑ No
® Yes ❑ No
[—]Yes ❑ No
69. Permit Expiration Date
4/18/26
7/31/28
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
N/A
N/A
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❑No❑N/A
Organic Management Plan (TOMP)?
1
75. a. Does File Contain Original Permit Review Letter from Division?
a. ®Yes []No
1b.[3Yes[iNoEgN/A
a. ®Yes ❑No
a. ❑Yes []No
b. All Issues Resolved?
b.❑Yes❑No®N/A
b.❑Yes❑No❑N/A
76. During Most Recent Semi -Annual Period, Did POTW Complete its
❑ Yes ®No
® Yes ❑ 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
®Yes❑No❑N/A
❑Yes❑No❑N/A
Sampling as Required by IUP, including Flow?
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❑No®N/A
❑Yes❑No❑N/A
file include process/dilution flows as Required b IUP?
80b. 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 by IUP?
81. During Most Recent Semi -Annual Period, Did POTW Identify All
❑ Yes ❑ No
® Yes ❑ No
❑ Yes ❑ No
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❑No❑N/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❑
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Docusign Envelope ID: lA7B9687-6016-43DD-9314-019287AOEB1A
FILE REVIEW COMMENTS:
13. Darling Ingredients has not sent any flow to the Town of Wallace to date.
20. The HWA and the LTMP were submitted on 8/20/24 and is in the review process. The HWA was originally submitted on
1/8/21 but was never reviewed and approved. The Town's new permit was issued on 10/2/23 and the HWA was modified and
resubmitted for approval.
62. The HWA was originally submitted on 1/8/21 but was never reviewed and approved. The Town's new permit was issued on
10/2/23 and the HWA was modified and resubmitted for approval on 8/20/24.
Darling Ingredients:
72. Inspected on 12/11/23.
76. Was not sampled because the Town of Wallace has not received flow to date.
Town of Burgaw:
72. Inspected on 12/1/23.
73. The Town of Burgaw has spill plans on file from each of their SIUs as part of their Pretreatment Program. They are also in
the process of modifying their Emergency Response Plan to add the Town of Wallace's contact information.
76. Sampling was completed on 6/13/24.
83. The Town of Burgaw communicates with the Pretreatment Coordinator of any Burgaw SIU violations.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 7

Docusign Envelope ID: lA7B9687-6016-43DD-9314-019287AOEB1A
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
I N I C 1 0 10 10 1-3 14 15 10 I I081201241
1. Industry Inspected: Town of Burgaw
2. Industry Address: 109 N. Walker Street Burgaw, NC 28425
3. Type of Industry/Product: Municipality
with domestic, commercial and industrial wastewater
4. Industry Contact: Lisa Osthues Title:
Pretreatment Consultant 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 Town of Burgaw was permitted as a SIU in August 2023. They have their own Pretreatment Program under their Collection
System Permit, WQCS00150, that consists of 2 SIUs. A thorough inspection of the site and records were completed during the
inspection.
Audit SUMMARY AND COMMENTS:
Audit Comments: Comments listed throughout Audit report.
Requirements: None
Recommendations: None
NOD: ❑ Yes ® No
NOV: ❑ Yes ® No
QNCR: ❑ Yes ® No
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory ❑
DOCUSigned by:
Audit COMPLETED BY: Helen Perez 461M �VIC25 DATE: 08/20/2024
Wilmington Regiona�B�l ice E...
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