NC0020605_Report_Pretreatment Audit_20191105

ROY COOPER
Governor
MICHAEL S. REGAN
Serretory
LINDA CULPEPPER
Director
Mr. Troy Lewis, Town Manager
Town of Tarboro
PO Box 220
Tarboro, NC 27886-0221
NORTH CAROLINA
Environmental Quality
November 5, 2019
Subject: Pretreatment Audit
Town of Tarboro
NPDES Permit No. NCO020605
Edgecombe County
Dear Mr. Lewis:
On September 25, 2019, Vivien Zhong of Pretreatment, Emergency Response, and Collection
Systems (PERCS) Unit and Cheng Zhang of the Raleigh Regional Office (RRO) conducted a
Pretreatment Audit of Town of Tarboro's pretreatment program. The assistance given by Mr.
Michael Allen, the WWTP Supervisor, was greatly appreciated. The audit report is attached.
Findings during the inspection were as follows:
1. The County has three Significant Industrial Users (SIUs), one of which is also
Categorical Industrial Users (CIUs). It was noted that no SiUs were in Significant Non -
Compliance (SNC) in the two most recent semi-annual periods.
2. The pretreatment audit file review included Johnson Controls (Permit No. 006), Sara Lee
(Permit No. 001), and Mayo Knitting (Permit No. 003). The files needed for review were
available for inspection, contained all the required information.
3. POTW and SIUs completed monitoring as required by the Industrial User Pretreatment
Permits (IUPs) during the most recent semi-annual period. All SIUs were in compliance
in the first semi-annual period of 2019. It was noted that Johnson Controls has two
discharge pipes: Pipe 001 is combined waste stream, only conventional parameters are
required for monitoring; Pipe 002 is process wastewater only, monitoring of categorical
parameters (metals) are required. Please modify the IUP by separating Pipe 001 and
Pipe 002 limit pages and reflect said parameters. Please submit modified IUP to the
Division for review by December S, 2019.
NoithCar uliva f)cpas tment of Envborlinvrtial Quabty I Div Won of 44'a1cr Rc%uttrces
RaleigItRegioualbfiicu 1360UBat retlDriver 1101eigh,Not iItCajobna27fr0')
149.791.4200

=4. During the audit, Mr. Allen inspected one of the S1Us, Sara Lee. The inspection was very
thorough.
5. A review of the files containing the pretreatment program elements was conducted.
Industrial Waste Survey was updated and approved by the Division in July 2019.
6. The review of LTMP data indicated that all locations %%ere sampled with required
frequencies, and all samples were analyzed using correct detection limits specified in (lie
LIMP 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: cheng.zhang,u ncdenr.gov).
Sincerely,
S. Jay Zimmernian, P.G., Chief
Water Quality Regional Operations Section
Enclosure: 2019 Tarboro Audit Report
CC: Vivien Zhong, DWR - FPERCS Unit
Chong Zliang - RRO
Central Files
Michael Allen, Town of Tarboro (electronic copy only)

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATi1•IENT AUDIT REPORT
lilacl: round Information lConiplete prior to audit, review Program. Info Database Slteet s
1. Control Authority (POTW) Name: City of Tarboro
2. Control Authority Representative(s): Michael Allen
3. Tide(s). %%'►VTP Supervisor
a. Address of POTW:
Mailing PO Box 220
City Tarboro lip Code 27886
Phone Number 252-6414251 Fax Number E-Mail mallen-a turboro-ne.cota
5. Audit Date 09/25/2019
6. Last Inspection Date: 08 28 2018 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 ycar has the POTW experienced any NPDES or Sludge Permit compliance problems? ®Yes ❑ No
If Yes, Explain.
9. Is POTW under an Order That Includes Pretreatment Conditions'? ❑ Yes ® No
Order Type and Number: Are Milestone Dates Being Met? ❑ Yes ❑ No E) NA
Parameters Covered Under Order
IC1S Coding
Main Program Pennit Number
I N.1. C 101012 1 fl 16 10151
INIM DDI1'1'
09 2,- 1 19 1
10, Current Number of Significant Industrial Users (S1U5)?
11. Number of SIUs with No,IUIll, -or wit€t an Expired ]UP!
.12. Number of SIUs Nol lnspccted by POTW in Lail Calendar Year?
13. Number of SIUs Not Sampin Last Calendar Year?
14. Number of SIUs in SNC for Limits Violation~ During Either of Last 2 Scmi-Annual Periods?
15. Number of S1Us in SNC fvr Rcfsortin(y DurinLy Either oCLatit 2 Sesni•Annual Pcricad;?
.16. Number of SIUs in SNC with Pretreatment Schedule?
.17. Number of SIUs on Schedules?
18. Current Number of Categorical Industrial Users (CIUs)?
19. Number of aus in SNC`!
3
0
0
0
0
0
0
0

20. PRETREATMENT PROGRAM. ELEMENTS REVIEW- Review POTW files, verify POTW has copy of each Program Element
in their File, complete with all supporiinn documents and PE RCS Annroval Leiter. and dates ennsistenr tirith Prnorrnm Inrn-
Program Element
Last Submittal
Date In rile"
Last Appro%al
Date In rile
pate Next Due,
If Applicable
Bead►forks Analysis (II11'A)
05/2112018
0 Ye, No
6/28/18
DQ Yes No
11/2/2023
Industrial Waste Survey (IWS)
03/27/2019
0 1'c71,No
73119
0 Yes 0 No
11/1/2024
Sever Use Ordinance (SUO)
10/19/2012
0 Yes No
10/212012
NYesU No
Enforcement Response Plan (ERP)
09124/2008
Z Yes Na
11/24/2008
)'es No
Long Term 1loniloring Plan (LT11 P)
07/11/2018
0 Yeti Ll No
11712/2018
0 Yeti 0 No
lira letter resent to file town on September 25, 2019
Legal Authority Sewer Use Ordinance-SUO
21. Do you have any lo►wns 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. Princeville, Speed. Plan to take Pinctops, Macclesrield
22. If yes to #21, Do you have current Inierjurisdictional Agreements (IJAs) or other Contracts? © Yes ❑ No ❑ NA
A copy, if not already submitted, should be sent to Division, expired, ►►orking on DA
23. If yes to #21, Have you had any trouble working with these towns or districtti'? ❑ Ycs © No ❑ NA
rf yes, Explain. Infiltrnttion from Princeville. Tile Woolen Compan► isworking to have that resulved.
24. Date of Last SUO Adoption by Local Council 09 10 2012
25. Have you had any problems interpreting or enforcing any part of the SUO? ❑ Yes ® No
If ycs, Explain.
Enforcement Enforcement Response Plan -ERN
26. Did you send a copy of the ERP to your indu%lrieti? ® Yes ❑ No
If no, POTW must send copy within 30 days.
27 Have you had any problems interpreting or enforcing any part ol-thc FRI' (i c. any adjudication, innproper enforcement, etc')
❑ Yes © No l f ycs, Explain.
28. List Industries under a Schedule or Order and Type ofSLhcdulc or Order
N/A
Resources
29. Please Rate the Following: S .Satisfactory NI -Marginal U Unsalislactory
Rating
Ex ilanntiun, if Unsatisfactory___ I
Personnel Available for Maintaining
POTW's Pretreatment Program
®S ❑,11 ❑U
_
Access to POTW Vehicles for
3 trucks
Sampling, Inspections, and
®S ❑,1i ❑U
Emergencies
Access to Operable Sampling
Equipment
®S 0.1 ❑U
Availability of Funds if Needed for
Additional Sam line and/or Analysis
®S ❑,81 ❑U
I
Reference Materials
®S ❑'NI ❑U
Staff Training (i.e. Annual and
All NN'11" 1'P staff are incorporated Into pretreatment training on
Regional Workshops, Etc.)
®S 1131 ❑U
sampling, chain of custodies, etc.
Computer Equipment (Hardware and
Soft►yare)
®S ❑,11 ❑U

30. Docs the POTW have an adequate data management system to run the pretreatment program'! ® Yes ❑ No
Explain Yes or No. Word/Excel
31. Flow does the POTW recover the cost of the Pretreatment Program from their industries! Explain.
$100 charge for monthly sampling of BOD, TSS, COD, N113; S75 ror each metals sampling event; surcharges for high
strength wasic►vater.
Public Perception/ Participation
33. Are there any local issues affecting the pretreatment program (e.g.. odor, plant closing, nc►v or proposed plants)".
❑ Yes ® No If yes, Explain.
33. Fins any one from the public ever requested to review pretreatment program Mcs! ❑ Yes ® No
If yes, Explain procedure. If no, how would the request be addressed? SUO copy maintained at Public Works Dept., all riles at
file W`WTP. Would call %N'WTP in order to view files.
34. Fins any industry ever mquested that certain information remain confidential !iom the public? ❑ Yes ® No If yes, Explain
procedure for determining whether information qualified for confidential status, as ►tell as procedure for keeping files confidential
from public. If no how would the request be addressed? Could Jeep separate if heeded
35. In addition to annual inspection, does the POTW periodically meet ►with industries to discuss pretreatment? ® Yes ❑ No
Phone calls if questions/problems
36. Is the public notified about changes in the SUO or Local Limits-'' ® Yes ❑ No
Town Council, public meetings and website
37. Were all industries in SNC published in the last notice'! ❑ Yes ❑ No N/,%
Permitting (Industrial Waste Survev-IWS)
38. Hon does the POTW become aware of new or changed Users'! Water billing department nolifies public -works
director
39. Once Cite POTW become!; aware of new or changed User+, hou does the POI W detenmine tthich industries hate the
reasonable potential to adversely impact the WWTP and therefore require a ne►t permit or a permit retisiort? (Who is an
SIM) Start with the short forms, discuss t-ith owner about process, long form --ould be requested If the short form
Indicates it potential SIU
40. Does the POTW receive waste from any groundt►ater remedtation projects (petroleum, CERCLA) or landfill leachate?
❑Yes No If Yes, Flow many are there?
Please list each site and how it is permitted, if applicable. City has issued a couple local permits to Edgecombe County
landfill but discharge has still not begun. Expecting npprox.. 5,000 gallons;' month
41. Does the POTW accept -waste by (mark if applicable) (D I ruck ❑Dedicated Pipe ❑ NA Vac truck
42. If the POTW accepts trucked -waste, -what controls are placed on this ttame! (example. designated point, samples drawn,
manifests required) a drying bed
43. Flow does llte POTW allocate its loading to industricO Mark all that apply
❑ Uniform Limits ®Flistorical lnduslry Need 0 By Surcharge ® Categorical Limits ❑ Other
Explain Other:
44. Review POTW's copies of current allocation tables ror each WWTP. Are there any over allocations? ❑ Yes ® No
If ycs, what parameters are over allocated?
45. If yes to #44, What is being done to address the of er allocations! (shorwerm I UPs, I IWA to be rct iscd, pollutant study, ctc. )
N/A
46. Does the POTW keep pollutant loading in reserve for future growill safety! ® Yew ❑ No
If yes, what percentage of each parameter ."u currently 40- - reserve for all pollutant~ of concerti. No specific percentage in
mind, there is currently plenty of capacity

47. Has the POTW experienced any difficulty in allocation'? (for example adjudication by an industry) ❑ Yeti ® No
Ifyes, Explain,
48. How does the POTW decide on which pollutants to limit to the permit...,e? Monitor for? (for example_ woru only those pollutants
listed on Else application limited; categorical parameters; NPDES Pollutants of Concern)
Metals sampling hvice/year. All UNIP POC's monitored at least onceryear at SIU's. Will put a limit on parameters that
are very likely to adversely impact WN17P.
49. Flow does the POTW decide what the monitoring frequency should be far the variou, pollutants in industry permit~? Explain,
Conventional parameters are more of concern and are sampled monthly. Metal twice per year due to cost using outside
source. Surcharge will be based on conventional testing that are perforated Its house.
Permit Corn fliance
50. Does the POTW currently have or during the past year had any perrntits under adjudication." ❑ Yes ® No
If yes, which industries-? What was (will be) the outcome of the adjudication'?
51. Demonstrate how (lie POTW judges compliance_ This should include compliance judgment on all violations of limits, reporting
requirements, and permit conditions, as well as for SNC. 'Manually input Into Mislon compliance Judgement worksheets
52. Does the POTW use [lie Division's model inspection form or equivalent? ® Yes ❑ No
If no, does the POTW fornt include all Division data'? ❑ Yes ❑ No
53. Were all SIUs evaluated for the need of a slug spill control plan during their most recent inspection;' ® Yeti ❑ No
If no, Explain.
54. What criteria are used to determine if a slug spill control plan is needed"
All SIU's required to have n slug/spill plan
55. What criteria does the POTW use to determine ii'a submitted slug spill control plan is adequate?
H.P.I. have copies onsite at the POTW
56. How does the POTW decide where the sample point for an SIU should be located"
Generally, are combined flow from the entire facility. ASC (40 Ct; R 433) has a separate pipe for process onl) now as well
57. Ilas the POTW established a procedure to ensure that representative samples x ill be taken by the POTW or SIU each time?
(example: correct location; proper programmin r ofsampler; clean equipment: sw irltng= the sample bucket uniformly)
POTW: ® Yes ❑ No SIU: ® Yes No If yes, Explain. POTW performs all sampling at SIU's
58. Who performs sample analysis for the POTW for Metals E.n%ironntent I
Conventional Parameters Pam
Organics Pace Analytical
59. Explain the Chain of Custody Procedure used for both in house: and commercial lab samples.
BOD, COD, TSS, NI13 — In house COC's; Separate commercial Inh COC samples are relinquished to Env.l
Lon ► Short Term Monitoring Plan (L/ST11P) and iieadworks Analvsis (IIWA)
60a. Is LTNIP STMP Monitoring Being Conducted at Appropriate Locations and I-requencies.' El YES ❑ NO
60b. Are Correct Detection Levels being; used for Ll LTMP STN1P Monitoring" © YES ❑ No
60c. Is LTMP.:STNIP Data Maintained in Table or I-quivalene ® S'ES ❑ O Is Table Adequate? ® YES ❑ NO
60d. All LTNIP. STNIP effluent data on Discharge Monitoring Itepon (DN1R)'' ® ITS ❑ NO Division Inspector, verily yoursclll
hoc. If NO to any above, list violations
60f. Should any Pollutants of Concern be Eliminated from or Added to LTMP MR? ❑ YES ID O
If yes, which ones'? Eliminated:_ Added:
61. Do you complete your own headvvorks analysis (I IWA) ? ❑ Yc% jD No
If no, who completes your I-IWA? The Wooten Company Phone (2a2 }7a7--U294
62. Do you have plans to revise your l IWA in the near future? ❑ Ycs © No
If yes, what is the reason far the revision? (marl: all that apply) ❑Increased average Rot% ❑NI'DES Iimits change
❑More LTNIP data available ❑Resolve over allocation ❑5 year expiration []Other
Explain,

INDUSTRIAL USER PERMIT (IUPI FILE REVIE« (3 iuP FILE REVIEWS AND I IU 1NSPECTION)
66. User Name 11 I. Johnston Controls 2. Mayo Knitting 11 3. Sara Lee
67. IUP Number
TOT-006 TOT-003
TOT-001
68. Does Fite Contain Current Permit'?
I N Yeti U Nu J1 N Yes U No
Yes No
69. Permit Ex iration Date
E06124121123 12131 '21
12 31 21
70. Cate Sorical Standard Applied (I.E. 40 CFR, Etc.) Or N A
433.17
1./A
NIA
71. Does File Contain Permit Application Completed Within One Year Prior
10 Yes 0Nu
Yes Lj No
Z Yes C No
to Permit Issue Date?
72. Does File Contain Inspection Completed Within Last Calendar Year'
Yeti UNo
l'cs No
Yes No
73. a. Does File Contain Slug/Spill Control Plan?
a. ElYes ONo a. ®Yes ONo
a. ®Yes QNo
b. If No, is One Needed? (See Ins ction Form from POTW
b ❑Yes ONo b. OYes ONo
b. ❑Yes ONo
74. For 40 CFR 413 and 433 TTO Certification, Does rile Contain a Toxic
OYCSONO❑NI Y
❑Ycs❑No®N A
CIYesOVo®\ A
Or Uanic Management Plan (TOMP)?
75. a. Does File Contain Original Permit Review Letter from Division'?
a ®Ycs [:]No a. ®Yes ❑No
a. (!Ycs ❑No
b. All Issues Resolved'?
b oY._,oL%,aNI-1 b 0Ycs0vo0N A
b OYcsONoO, A
76. During Most Recent Semi -Annual Period, Did POTW Complete its
Yes Na Yes No
Ycs No
Sam lin g as Required b [UP, includin g Flow'?
77. Docs File Contain POTW Sampling Chain -Of' Cusiod y Form~!
Yes No Yes No
Yes No
73. During Most Recent Semi -Annual Period, Did SIU Complete its
©YewOtiv0t\/ �
❑Ycs0No0W,%
OYes❑tio®\ A
Sampling as Required b IUP. including,Flow'?
79. During Most Recent Semi -Annual Period, Did SIU submit all reports on
®Ye:❑tin❑NIA
❑Yew❑tiu®N A
❑N'LN0%o[BN A
time?
80a. For categorical IUs with Combined Wastestream romiuta (cwF), does
❑Yw0N()E)\/ \
❑Yr_s0No0N `A
❑Ye-s❑\o0% A
File include: process/dilution flows as Required b IUP?
80h. For categorical lUs with Production based limits, does file include
❑YewONn®\Y \
❑Ye,❑`n0N A
QYes©No®N A
production rates and/or flows as Required b • JUP'!
St. During; Most Recent Scmi-Annual Period, Did POTW Identify All
N 1'es 0 No
"'C' No
Yes No
Limits Non -Compliance from Botli POTW and SIU Sampling!
NIA
N/A
82 During Most Recent Semi -Annual Period, Did POTW ldemilj All
0Yes0Nq)GN' A
0YeK0No0N'A
❑Yes❑,No0N A
Rt grtin Non-Com liancc from SIU Sampling!
83. a Was POTW Notified by SIU (Within 24 hours) of All Sclf-
a,Ol LsO%ooti A
a.0i'«Cl1,'ooN A
a.0Y��s[]NnBN A
Monitoring Violations?
b- Did Industry Rexamplc and submit results to Parw within 30 Days!
KoYmON(eoN A
b 0Yvi0NnOti A
KDN'eso.NEMN A
c. If applicable, did POTW resample and obtain results %%itlun 30 days of
bccomin � aware of SIU limit violations in the POT%%"s sam hng ofSIU".
` oi'eXl%oQ% A
c OYesONntdN'A
� Ol'4s0Nn@� A
84. Duna g Most Recent Semi -Annual Period, Was SIU in SNC?
0 Ycs Z Nn 11
U Yes No
0 Yes No
85. During Most Recent Semi -Annual Period, Was Lnforcemcni 'l alien as
Yes©�n❑v A
❑Yes❑NoON A
QYe�s❑NoON A
g
Specified in POTW's ERl' (NOVs, Penalties, timing, etc.)'! 1 \ N01,
86. Does File Contain PenaltyAssessment Notices?
Yei[3No0`'A
❑Yes❑NnM;r A
ClYesONoGN A
87. Does File Contain Proof Of Pcnalt Collection!
1 csONapN A
fb.igVt.-.1VSo0\
❑Yee❑No0N'A
0Yew©Nn®N A
88. a. Does file Contain Any Current Enforcement Order~?
0ti c%0%n0N A
a.0Yrs0NnEN A
a.0Yex0Nn®1 A
b. Is SIU in Compliance ttith Order?
A
b OYcsONDON A
b MoONnON A
89. Did POTW Representative Have Difficulty- in Obtaining Any Requested
LJ )'es 0 No
0 1'cs Na
Yes - No
Information For You'?
rtL,r, icr.vrr,w LUMAJUNTS:
Johnson Control: Pipe 001 is combined, convemional parameters only, including COD. Pipe 002 is process water only and contains metals.
Plcaye modify the 1UP to separate pipe 001 and pipe 002 limit pages and reflect said parameters.

63. In general, what is the most limiting criteria of your HWA7 ©Inhibition ❑ Pass Through ❑Sludge Quality
61. Do you see any way to increase your loading in the future (Example: obtaining more land For sludge disposal)-? ® Yes ❑ No
Explain. Obtained additional hind - 12 acres grass field In October 21117.
Summary
65. Do you plan any significant change-% to the pretreatment program or changes to the Ww [ 1, that may affect pretreatment?
Replacing (lie niNers in the lagoon ► •ill take shout z years to see the results and will be able to take more sludge

INDUSTRY iNSPECTIO` ICIS CODING:
Nlain Pwgram Permit Numher AINI DO N Y
LNIC101912 10 16 10 1.5 1 1 Q9 1_25.1 19 f
1. Industry Inspected: Sara 1 ee Frozen Baker
2. Industry Address: 110 Sara Lee Rd, Tarboro, NC 27886
3. Type of Industry Product: Food/frozen bakery
4. Industry Contact: Jahn Chapman Title: Environmental Manager I'lione. 252-641-2200 Fax:
5. Does the POTW Use the Division Model Inspection Corm or Equi%alent" 9 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 thorough and met the Division's renuirements.
Audit SULMMARV AND CO\INTENTS:
Audit Comments- The Promnt Is %%'ell matte ld.
Requirement%: Send a co of I.IAs to PERCS Unit ►$hen tltc%� pre read%. Modify Johnson Control,,;lUP in . mate I pe
001 camhined comvenlionnl Parameters onto and pipe 002(Process onl% and contains metals limit waaes and reflect said
)parameters
Recommendattons-
INOD: ❑ Yes
® No
,Nov: ❑ Yes
ED No
QNCR: ❑ 1'es
ED No
POTW Itttting:
Sallsfactor) ® 'Marginal ❑ Unsntisfnctorti ❑
Audit COtiIPI.ETED BY: %'i%iett Ziione, PERCS. and Chong„Zllnne Raleieh Itenional Office D,1'C'E: September 25. 2019