NC0024201_Pretreatment Compliance Inspection_20200107

ROY COOPER
Coveotur
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Dirooc)
Danieley Brown, CEO
Roanoke Rapids Sanitary District
PO Box 308
Roanoke Rapids, North Carolina 27870
t r?TH CAre�'`r�
£rlwtronmcntal Quality
January 7, 2020
Subject: Pretreatment Compliance Inspection
Roanoke Rapids Sanitary District (RRSD)
NPDES Permit No. NCO02420I
Halifax County
Dear Mr. Brown:
M.11i ^ i #,
r
On December 5, 2019, Cheng Zhang of the Raleigh Regional Office, Division of Water
Resources conducted a Pretreatment Compliance Inspection of the Roanoke Rapids Sanitary
District's Pretreatment Program. The assistance of Ms. Isabelle Wilcoxon, the Pretreatment
Coordinator, was greatly appreciated as it facilitated the inspection process. The inspection
report is attached. Findings during the inspection were as follows:
1. 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) during the past two semi-annual periods.
2. A review of the files containing the pretreatment program elements was conducted.
These files were available and well organized. Update of Headwork Analysis was
approved by the Division on November 5, 2019. Update of Long Term Monitoring Plan
(LTMP) was submitted on November 20, 2019.
3. The review of LTMP data indicated that all locations were sampled with required
frequencies and detection limits since last inspection.
4. The pretreatment inspection file review included Rosemary Power Station (Permit No.
0007), Reser's Fine Food (Pen -nit No. 0009), and Kennametal (Pen -nit No. 0002). The
files needed for review were available for inspection, contained the required elements and
were in good condition. The POTW completed all required sampling. All SIUs completed
their monitoring and submitted monitoring reports on time as required by the Industrial
User Pretreatment Permits (IUDs). During the first semi-annual period of 2019, Rosemary
Power Station and Kennametal were in compliance. Rcser's Fine Food had one TSS
violation from POTW sampling in April 2019. The POTW took appropriate enforcement
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actions per Enforcement Response Plan (issuance of Notice of Violation and civil penalty
assessment).
The Roanoke Rapids Sanitary District's pretreatment program is well managed. 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�' ncdenr.gov).
Sincerely,
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources
Enclosure: 2019 Roanoke Rapids Sanitary District PCI Inspection Form
CC: Monti Hassan, DWR - PERCS Unit (Laserficlie)
Central Files (Laserfiche)
Cheng Zhang, RRO
Isabelle Wilcoxon, RRSD (electronic copy only)

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
BACKGROUND INFOILNIATION lComplete Prior To PCI: Review Program Info Database Sheet s
I . Control Authority (POTW) Name: Roanoke Rapids Sanitary District
2. Control Authority Representative(s): Isabelle Wilcoxon
3. Title(s): Pretreatment Coordinator
4. Last Inspection Date: Mav_11, 2018 Inspection Type (Check One)- ❑ PCI ® Audit
5. Has Program Completed All Requirements from (lie 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:
[CIS CODING
Alain Program Pennit Number ,SUM DD yy
N I C 1 O 10 121412 1 011 1 LU 05LI9!
Are Milestone Dates Being Met? ❑ YES ElNO
7. Current Number Of Significant Industrial Users (SIUs)? 3
8. Number of SIUs With No [UP, or With an Expired IUP? C
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? C
11. Number of S1Us In SNC For Limits Violations During Either of the Last 2 Semi -Annual Periods? C
12. Number of SIUs in SNC For Reporting During Either of the Last 2 Semi -Annual Periods? 0
13. Number ofSIUs in SNC with Pretreatment Schedule? C
14. Number of SIUs on Schedules? C
15. Current Number Of Categorical industrial Users (CIUs)? C
16. Number of CIUs in SNC? 0
POTW INTERVIEW
17. Since the Last PCI, has the POTW had any NPDES Limits Violations? ❑ YES ®NO
If Yes, What are the Parameters and How are these Problems Being Addressed`?
I8. Since the Last PCI, has the POTW had any Problems Related to an Industrial
❑ YES ® NO
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 SIC for Limits: None
either of the Last 2 Semi -Annual Periods? Not Been Published for SNC for
Reporting: None
Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not Published:
None
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?
N A
21, Are Any Permits or Civil Penalties Currently Under Adjudication'? If Yes, Which
Ones?
❑ YES ®NO
LTi`IP/STiyIP FILE REVIEW:
22. Is LTMP.:STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑ NO
23. Are Correct Detection Levels being used for all LTMP.'STNiP Monitoring? ®YES ❑ NO
24. Is LTMP:'STMP Data Maintained in a Table or Equivalent? ® YES ❑ NO Is Table Adequate? ® YES ❑ NO
25, All LTMP?'STMP effluent data reported on Discharge Monitoring Report? ® YES ❑ NO Division Inspector, please verifyyourselP
26. If NO to 23 - 26, list violations
27. Should any Pollutants of Concern'be Eliminated from or Added to LTMP/STNIP? ❑ YES ® NO
If yes, which ones? Eliminated: Added:
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page

28. PRETREATMENT PROCKAi I ELEMENTS REVIEW— Please review POTW files, verify POTW has copy of Program Element in
their files, complete with sueporting documents and copy of PERCS Approval Letter, and dates consistem with Program Info:
Program Element
Last Submittal
Date In tile?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis IIWA)
5/112019
Z YesEl No
111512019
Yes No
7412025
Industrial Waste Surve • (IWS)
12/2012017
Yes No
1/18/2018
Yes No
2f1/2023
Sewer Use Ordinance (5U0)
10/2112011
Yes No
1[1/2112011
Yes Na
Enforcement Response Plan (ERP)
1 101212012
Ye7EJ No
1015/2012
Zq Yes No
Long Term Monitoring Plan (LTVIP)
1 11/2002019
Yes 0 No
2/23/2017
El Yes EFNo
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR I FILE REVIEW AND 1 IU INSPECTION)
29, User Name
1. Rosemary Power Station 2. Kennametal
P. Reser's Fine Food
30. [UP Number
0007
1 00
1 0009
31. Does File Contain Current Permit?
0 Yes El No
Yes 0 No 11
El Yes El No
32. Permit Ex iration Date
5/31/2022
53112022
5/31/2022
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N'A
423.17
471J
NIA
34, Does File Contain Permit Application Completed Within One Year Prior
® Yes ❑ No
® Yes D No
0 Yes No
to Permit Issue Date?
35. Does File Contain an Inspection Completed Within Last Calendar Year'?
G3 Yes 0 No
I L<J Yes U No
Yes No
36. a. Does the File Contain a Slug/Spill Control Plan'?
a. ®Yes [IN o
a. ®Yes ❑No
1b.
a. ®Yes ❑No
b. If No, is One Needed`? (See Inspection Form from POTW)
b. ❑Yes ❑No
❑Ye.s ❑No
b. ❑Yes ❑No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
❑ti'es❑NoElN A
A
❑Yes❑NoEN A
Organic Mana ement Plan (TOMP)?
1[❑Ye5ONc!EI
11
38. a. Does File Contain Original Permit Review Letter from the Division?
a. ®Yes ❑No
a. ®Yes ❑No
a. ®Yes ❑No
b. All Issues Resolved?
b ❑Yes❑No❑N A
b.❑YLs❑No❑N A
b ❑Yes❑No❑N A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
® Yes ❑
Yes No
Yes No
its Sampling as Required b IUP, including flow?
Hm
40, Does File Contain POTW Sampling Chain-Of-Custod Forms?
21 Yes El No
UYes U No
11 U Yes INo
41. During the Most Recent Semi -Annual Period, Did the SIU Complete its
®Ycs❑tio❑` A
®Ycs❑NoQN'A
®Yes❑tio❑N:A
Sampling as Required by IUP, including flow?
4lb. During the Most Recent Semi -Annual Period, Did SIU submit all reports
EYes❑No❑` A
®Yes❑No❑NIA
EYcs❑No❑N'A
an time?
42a. For categorical [Us with Combined Wastestream Formula (CWF), does
❑Yes❑`oEN A
❑Yes❑NOON A
❑Ycs❑No®N`A
file include rocess,'dilution flows as Required by IUP?
42b. For categorical [Us with Production based limits, does File include
❑Y'cs❑NoEN-A
OYesO'NoON
❑Ycs❑NoON.:A
production rates and.:or flows as Required b [UP?
A
43a, During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑NoEN A
❑Yes❑tioEN A
Yes ElNo
All Limits Non -Compliance from Both POTW and SIU Sampling?
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Ycs❑tio®ti A7��
oEN.A
❑Yes❑NoEN A
All Re artin Non -Cam liance from SIU Sampling?
11
44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
a.❑Yes❑No®N' A
a.❑Ycs❑NoMN` A
a.❑Yes❑No®N A
Monitoring Violations?
b. Did Industry Resample and submit results to POTW Within 30 Days`?
b.❑tesONopN A
b ❑YoMoEN A
b.MYcs❑tio❑N A
c. If applicable, Did POTW resample within 30 days of becoming aware
=
of SIU limit violations in the POTW's sampling of the SIU?
c ❑ti c5❑NoEN A
c ❑Yes❑NOON A
c ❑Yes®No❑N A
46. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
I El Yes Z No
Yes Z No
11 0 Yes El No
47. During the Most Recent Semi -Annual Period, Was Enforcement Taken
ON es❑NoON A
1 ❑Yes❑No®N' A
®Ycs❑No❑N A
as Specified in the POTW's ERP (NOVs, Penalties, timing,etc.)?
48. Does the File Contain Penalty Assessment Notices?
❑Yes❑N,MN A
❑Ycs❑NoON-A
11 EYes❑No❑N-A
49. Does The File Contain Proof Of Penalty Collection?
❑Yes❑No®N A
❑Ycs❑NoEN A
®Ycs❑No❑N A
50. a. Does the File Contain Any Current Enforcement Orders?
a.❑YesONomN A
a.❑Yes❑ 'uON'A
a.❑Yes❑NoGN A
b. Is SIU in Com liance with Order?
b ❑Yes❑Nom ''A
b ❑Yes❑NoB14 A
b.❑Yes❑No0N A
51. Did the POTW Representative Have Difficulty in Obtaining Any of This
Yes ® No
El Yes ®No
❑ Yes Z No
Requested Information For You?
E
__p
I
NC DWR Pretreatment Compliance Inspection (PC[) Form Updated December 2016 Page 2

FILE REVIEW COMMENTS:
43a — Reser's Fine Food had one TSS violation from POT«' samplinb in April 2019.
47 & 48 — POTW issued a NON' with civil penalty assessment ($325) on May 24, 2019.
INDUSTRY INSPECTION [CIS CODING:
Main Program Permit Number NIM DD. N'Y
I. 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: The program was well managed
Requirements: None
Recommendations: None
NOD: ❑ YES ® NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ® NO
POTW Rating:
Satisfactory Z Marginal ❑ UnSatisfactory ❑
PCI COMPLETED BY: Cheng Zhang. DWR Raleigh Regional Office DATE: December 5. 2019
NC DWR Pretreatment Compliance Inspection (PCI) Form Updaied December 2016 Pag* 3