NC0025721_Pretreatment Compliance Inspection_20240919

Docusign Envelope ID: OCAEOE47-8639-436C-A582-48A3F4466289
ROY COOPER
Governor
MARY PENNY KELLEY
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
September 19, 2024
Sent via email: [e-mail]
Mayor Hugh C. Credle
Town of Weldon
PO Box 551
Weldon, NC 27890
Subject: Pretreatment Compliance Inspection
Town of Weldon
NPDES Permit No. NCO025721
Halifax County
Dear Mayor Credle:
On August 30, 2024, Cheng Zhang of the Raleigh Regional Office, Division of Water Resources
conducted a Pretreatment Compliance Inspection of the Town of Weldon's Pretreatment
Program. The assistance of Mr. Donald Crowder, the WWTP ORC and Pretreatment
Coordinator, was greatly appreciated as it facilitated the inspection process. The inspection
report is enclosed. Findings during the inspection were as follows:
1. There is one Significant Industrial User (SIUs), which is also a Categorical Industrial
User (CIU). It was noted that the SILT was in Significant Non -Compliance (SNC) during
the two most recent semi-annual periods.
2. A review of the files containing the pretreatment program elements was conducted.
These files were available and well organized. The Town request to the Division to
reactivate its pretreatment program on April 26, 2023. Since the reactivation of the
program, the Town has submitted updates of Industrial Waste Survey (IWS),
Enforcement Response Plan (ERP), and Short Term Monitoring Plan (STMP), these
updates were approved by the Division. The Town will submit update of Headworks
Analysis once it completes the sampling specified in the STMP. It was noted that
sampling frequency was not specified in the STMP, the Town needs to modify the
STMP by clearly indicating sampling frequency at all locations and submit the
modified STMP to the Division for review and approval.
DEQ
�North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office 13800 Barrett Drive I Raleigh, North Carolina 27609
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Docusign Envelope ID: OCAEOE47-8639-436C-A582-48A3F4466289
3. STMP sampling is still ongoing. Available STMP data were reviewed during the
inspection. All locations were sampled at required frequencies and samples analyzed
using required detection limits.
4. The pretreatment inspection file review included Roseburg Forest Products (Permit No.
0002). The files needed for review were available for inspection, contained the required
elements and in good condition. The Town issued Industrial User Pretreatment Permit
(IUP) to the industry on April 21, 2023 (effective June 1, 2023). The SIU started to
discharge to the POTW in February 2024. It was noted that the SIU was in SNC for
permit conditions violation during the second half of 2023. During the first half of 2024,
the SIU experienced multiple permit limit violations for BOD, pH, and ammonia, and
was in SNC for BOD and pH violations. The SIU is authorized by the Town to install a
pH adjustment system. The Town is considering modifying the IUP by changing the
BOD limits from concentration based limits to mass based limits.
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: cheng zhangkdeq.nc. og_v).
Sincerely,
ISigned by:
Va vu'ss.'e. kaunA'a
B2916HAB32144F...
Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources
Enclosure: Town of Weldon PCI Inspection Form
Cc: Laserfiche
Donald Crowder, Town of Weldon (electronic copy only)
D E Q�� North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office f 3800 Barrett Drive I Raleigh, North Carolina 27609
WORTH CARouNA
nea.bemme.w—.wQ..mv 919,791.4200

Docusign Envelope ID: OCAEOE47-8639-436C-A582-48A3F4466289
`' NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
Water Resources
ENVIRONMENTAL OVAL I TV
BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)l
1. Control Authority (POTW) Name: Town of Weldon
2. Control Authority Representative(s): Donald Crowder
3. Title(s): Pretreatment Coordinator/WWTP ORC
4. Last Inspection Date: 07/27/17 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
INIC101012151712111
MM/DD/YY
1081301241
Are Milestone Dates Being Met? ❑ YES ❑ NO
7. Current Number Of Significant Industrial Users SIUs ?
1
8. Current Number Of Categorical Industrial Users (CIUs)?
1
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?
0
11. Enter the Higher Number of 9 or 10
0
12. Number of SIUs With No IUP, or With an Expired IUP
0
13. Number of SIUs in SNC for Either Reporting or Limits Violations During Either of the Last 2
Semi -Annual Periods Total Number of SIUs in SNC
0
14. Number of SIUs in SNC For Reporting During Either of the Last 2 Semi -Annual Periods
0
15. Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi -Annual Periods
1
16. Number of SIUs In SNC For Both Reporting and Limits Violations During Either of the Last 2
Semi-annual Periods
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?
77ES ®NO
❑ YES ® NO
Limits: Roseburg Forest Products
Reporting: None
Ilished: None
None
❑ YES ® NO
LTMP/STMP FILE REVIEW:
22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑ NO ❑ N/A
23. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ® YES ❑ NO ❑ N/A
24. Is LTMP/STMP Data Maintained in a Table or Equivalent? ® YES ❑ N/A Is Table Adequate? ® YES ❑ NO ❑ N/A
25. All LTMP/STMP effluent data reported on Discharge Monitoring Report? ❑ YES ® N/A DWQ Inspector, please verify yourselfl
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 December 2016 Page 1

Docusign Envelope ID: OCAEOE47-8639-436C-A582-48A3F4466289
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)
® Yes ❑ No
6/16/2017
® Yes ❑ No
Industrial Waste Survey (IWS)
5/30/2023
® Yes ❑ No
6/16/2023
® Yes ❑ No
6/11/2028
Sewer Use Ordinance (SUO)
3/27/2013
® Yes ❑ No
4/2/2013
® Yes ❑ No
Enforcement Response Plan (ERP)
6/9/2023
® Yes ❑ No
7/3/2023
® Yes ❑ No
Short Term Monitoring Plan (STMP)
14/4/2023
® Yes ❑ No
5/11/2023
® Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29.
User Name
1. Roseburg Forest Products 2.
3
30.
IUP Number
0002
31.
Does File Contain Current Permit?
® Yes ❑ No
32.
Permit Expiration Date
5/31/2028
33.
Categorical Standard Applied I.E. 40 CFR, Etc. Or N/A
429
34.
Does File Contain Permit Application Completed Within One Year Prior
® Yes ❑ No
to Permit Issue Date?
35.
Does File Contain an Inspection Completed Within Last Calendar Year?
I ❑Yes❑NoEN/A
36.
a. Does the File Contain a Slug/Spill Control Plan?
a. ®Yes ❑No
b. If No, is One Needed? (See Inspection Form from POTW)
b. ❑Yes ❑No
37.
For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
❑Yes❑NoEN/A
Organic Management Plan TOMP ?
38.
a. Does File Contain Original Permit Review Letter from the Division?
a. ®Yes ❑No
b. All Issues Resolved?
b.❑Yes❑No❑N/A
39.
During the Most Recent Semi -Annual Period, Did the POTW Complete
®Yes ❑ No
its Sampling as Required by IUP, including flow?
40.
Does File Contain POTW Sampling Chain -Of -Custody Forms?
® Yes ❑
No
41.
During the Most Recent Semi -Annual Period, Did the SIU Complete its
®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
on time?
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑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
production rates and/or flows as Required by IUP?
43a.
During the Most Recent Semi -Annual Period, Did the POTW Identify
EYes❑No❑N/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
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
Monitoring Violations?
b. Did Industry Resample and submit results to POTW Within 30 Days?
b.®Yes❑No❑N/A
c. If applicable, Did POTW resample within 30 days of becoming aware
c.❑YeslZNo❑N/A
of SIU limit violations in the POTW's sampling of the SIU?
46.
During the Most Recent Semi -Annual Period, Was the SIU in SNC?
®
Yes
❑
No
47.
During the Most Recent Semi -Annual Period, Was Enforcement Taken
EYes❑No❑N/A
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
48.
Does the File Contain Penalty Assessment Notices?
EYes❑No❑N/A
49.
Does The File Contain Proof Of Penalty Collection?
❑YesONo❑N/A
50.
a. Does the File Contain Any Current Enforcement Orders?
a.❑Yes❑NoEN/A
b. Is SIU in Compliance with Order?
b.❑Yes❑NoEN/A
51.
Did the POTW Representative Have Difficulty in Obtaining Any of This
❑ Yes ®No
Requested Information For You?
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

Docusign Envelope ID: OCAEOE47-8639-436C-A582-48A3F4466289
FILE REVIEW COMMENTS:
35 — The SIU did not discharge in 2023, POTW did not inspect the SIU in 2023.
41— The SIU had multiple limit violations for pH, BOD, and ammonia.
46 — The SIU was in SNC for BOD and pH violations.
47 — The POTW took proper enforcement against these limit violations.
INDUSTRY INSPECTION PCS CODING:
Main Program Permit Number MM/DD/YY
l 1 I I l
1. Industry Inspected:
2. Industry Address:
3. Type of Industry/Product:
4. Industry Contact: Title: 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:
OVERALL SUMMARY AND COMMENTS:
Comments:
Town of Weldon's pretreatment program is well managed.
Requirements: Submit modification for STMP to include sampling frequency to the Division for review and approval.
Recommendations: Keep proof of penalty collection in pretreatment file.
NOD: [—]YES ®NO
NOV: [—]YES ®NO
QNCR: ❑ YES ®NO
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory ❑
PCI COMPLETED BY: Chen2 Zhan2 DATE: August 30, 2024
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3