NC0027103_NOV-2020-PC-0310_20200708

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NCDEQ — FAYETTEVILLE REGIONAL OFFICE
DIVISION OF WATER t?:
ATTN: TRENT ALLEN
225 GREEN STREET, SUITE 714
FAYETTEVILLE NC 28301 JUL z U 2020
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1. Article Addressed to:
TYLER THOMAS, TOWN MAN.
TOWN OF PEMBROKE
PO BOX 866
PEMBROKE, NC 28372
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ROY COOPER
Governor
MICHAEL S. RECAN
Secrerary
S. DANIEL SMITH
Director
NORTH CAROLINA
En vrronmen tal Quality
July 8th, 2020
Certified Mail#: 7019 0700 0000 3643 0987
Return Receipt Requested
Tyler Thomas, Town Manager
Town of Pembroke
PO Box 866
Pembroke, NC 28372
SUBJECT: Notice of Violation
NOV-2020-PC-0310
Failure to Implement Pretreatment Program
Town of Pembroke (NPDES Permit Number: NC0027103)
Robeson County
Dear Mr. Thomas:
Enclosed please find a copy of the Pretreatment Compliance Inspection (PCI) Report from the inspection
conducted on June 23rd, 2020. The Pretreatment Compliance Inspection was conducted by Kristen
Slodysko, an Environmental Specialist from the North Carolina Division of Water Resources (DWR)
Fayetteville Regional Office.
This report is being issued as a Notice of Violation (NOV) due to the Town's failure to properly implement
its Pretreatment Program as specified in 15A NCAC 2H .0905, 40 CFR 403.8(f)(5), and NPDES permit
conditions Part IV, Section D.9.
Violation
• The Town has failed to take appropriate enforcement actions against its Significant Industrial
User, Steven Robert's Original Desserts (IUP# 002) for limits violations. The Town's Enforcement
Response Plan (ERP) indicates that NOVs will be issued for all permit limit violations within 30
days of receiving analytical data. Steven Robert's Original Desserts had multiple BOD and TSS
violations in both the first and second halves of 2019 and the first half of 2020. The Town did not
issue any NOVs for these violations.
N-DrtF.tiarD raDepart rnentofEnvronrner..ta:QLa.Iy I QusbrpofWater Resources
Fsk•atts a Fi=g'op.a:Offte 12.253re2r.Street,Su-le 714 I Fwetteu0e, North Caro;;nsM301
$1:r-483-38.D.D

• As per 15A NCAC 02H.0908 (b)(4) and (5), the Town is required to publish public notice of all
SIUs in Significant Non -Compliance (SNC) on an annual basis and report SNC facilities to the
Division in its Pretreatment Annual Report. The Town has failed to determine if any of Steven
Robert's violations in 2019 have met the definition of either Chronic or Technical Review Criteria
(TRC) SNC limit's violations. A SNC determination must be made for this facility for 2019. If it is
determined that the facility was in SNC for the 2019 PAR year, public notice must be
published and an amended PAR must be submitted to the DEQ within 30 days upon
receipt of this letter. Proof of the public notice must be included in the amended PAR. The
definitions of Chronic and TRC SNC, as defined in 15A NCAC 02H .0903 (31), are:
"Chronic violations" of wastewater discharge limits, defined here as those in which 66
percent or more of all the measurements taken for the same pollutant parameter (not including
flow) during a six-month period exceed (by any magnitude) a numeric pretreatment standard or
requirement including instantaneous limits, as defined by 40 CFR 403.3(I);
"Technical Review Criteria" (TRC) violations, defined here as those in which 33 percent or
more of all the measurements taken for the same pollutant parameter during a six-month
period equal or exceed the product of the numeric pretreatment standard or requirement
including instantaneous limits, as defined by 40 CFR 403.3(I) multiplied by the applicable TRC;
(TRC = 1.4 for BOD, TSS, fats, oil, and grease, 1.2 for all other pollutants (except flow and
pH));
• The Town has failed to properly retain pretreatment records as per 15A NCAC 02H .0908(f).
During the inspection it was noted that the facility did not retain copies of Division approval
letters for program elements including the Head Works Analysis (HWA), Industrial Waste Survey
(IWS), Enforcement Response Plan (ERP), Short -Term Monitoring Plan (STMP), and Industrial
User Permits (IUP). Please retain copies of all Division approval letters for pretreatment
program elements as per 15A NCAC 02H .0908(f)(2):
(f) Records Retention:
(1) Control authorities and industrial users shall retain for three years records of
monitoring activities and results, along with supporting information including annual
pretreatment reports, general records, water quality records, and records of
industrial user impact on the POTW;
(2) Other documents required by any rule of this Section (including supporting
information) for other pretreatment program elements, such as pretreatment
permits (IUPs), HWAs, SUOs, ERPs, etc., shall be retained for three years after the
document has expired, been updated, or replaced;
(3) A summary of all significant industrial user effluent monitoring data reported to the
control authority by the industrial user or obtained by the control authority shall be
maintained on forms or in a format provided by the Division for review by the
Division; and
North �,s rD r.a Department of Env ronrner..ta: Qua!!ty I U usbrp of Water Resources
Fsyatts a Fi=g'op.a:Offte 1 2.253re2r.Street,SuRe 714 1 Fayetteu0e, North Caro!;nsM301

(4) Laboratory records shall be maintained as set forth in Rule .0805 of this Subchapter.
Additional Comments:
The IUP for Steven Roberts expires on 7/21/2020. The SIU has not submitted an application for
permit renewal. As per Part II Section 23 of the General Conditions of Steven Robert's IUP, the
SIU is required to submit an IUP renewal application at least 180 days prior to the active
permit's expiration date. Please ensure that Pembroke is adequately implementing its
pretreatment program by requiring SIUs to submit IUP renewals within this time frame. The
POTW should retain a copy of the completed permit application.
A COC (Chain of Custody) should be completed for all samples collected by the SIU and POTW.
This applies to samples that are collected at the SIU by the POTW and then analyzed in-house at
the Pembroke WWTP. Using a COC may increase the defensibility of data generated during
sampling events.
Please ensure that the STMP is being properly implemented. Report all STMP effluent data on
monthly Discharge Monitoring Reports. This includes parameters that are supplementary to
NPDES monitoring requirements. Ensure that all detection limits meet the minimum detection
limit listed in the STMP. During the inspection it was noted that detection limits for cadmium,
chromium, and silver did not meet the minimum detection limits required by the facility's STMP.
The Division recommends maintaining STMP data in a digital table. Data is currently maintained
by the POTW in paper copies of analytical reports. Maintaining the data in a digital table may
facilitate the data review process and help ensure that all sampling is completed at the correct
locations and frequencies and that minimum detection limits are being met by the analytical
laboratory.
To prevent further action, please respond in writing to this office within 30 days upon your receipt of this
Notice of Violation regarding your plans to address the indicated violations and other identified issues,
if applicable.
N-DrtF. �,s rD r.a Department of Env ronrner..ta: Qua!!ty I U usbrp of Water Resources
Fsyatts a Fi=g'op.a:Offte 1 2.253re2r.Street,Su-le 714 1 Fayetteu0e, North Caro!;ns23301

If you should have any questions, please do not hesitate to contact Kristen Slodysko with the Water
Quality Regional Operations Section in the Fayetteville Regional Office at 910-433-3300 or via email at
[e-mail].
Sincerely,
DocuSigned b(ywM1/.N}'�I,�'-
I
E4E1A9691 DB248E...
Mark Brantley, Assistant Supervisor
Water Quality Regional Operations Section
Fayetteville Regional Office
Division of Water Resources, NCDEQ
EC:
Mike Montebello, DEQ Municipal Unit
Kristen Slodysko, FRO
Charles Donnell, Environlink Consultant
Jason Deese, Pembroke ORC/Pretreatment Coordinator
North Carolina D"rtrnent of Enwonmentai 9ua!3y I Dimsioip of Water Resources
FayetteiAGe Regionai 0ff]D2 1 225 Green Street, Suite 714 1 Favetteuflle, North Cafoiina 25301
�-' � 910-0333300

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
Warer Resources
�N`lt?t�!N Ni.it, CV/J.!!v
BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)1
1. Control Authority(POTW)Name: Pembroke WWTP, Town of Pembroke
2. Control Authority Representative(s): Jason Deese, Charles Donnell, Cashual Lynch
3. Title(s): ORC/Pretreatment Coordinator, Environlink Capital Projects Manager, Environlink Project Manager
4. Last Inspection Date: 2/15/18 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: Are Milestone Dates Being Met? ❑ YES ❑ NO
ICIS CODING
Main Program Permit Number MM/DD/YY
J N I C 1 0 1 0 1 2 1 7 1 1 1 0 1, 3 f 6 I 23 I 20 1
7. Current Number Of Significant Industrial Users (SIUs)?
1
8. Number of SIUs With No IUP, or With an Expired IUP?
0
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. Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi -Annual Periods?
0
12. Number of SIUs in SNC For Reporting During Either of the Last 2 Semi -Annual Periods?
0
13. Number. of SIUs in SNC with Pretreatment Schedule?
0
14. Number of SIUs on Schedules?
0
15. Current Number Of Categorical Industrial Users (C1Us)?
0
16. Number of CIUs in SNC?
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?
• Flow (monthly average) 2/29/20, 1/31/19, 12/31/18, 11/30/18
• TSS (monthly) 1/31/19
• TSS (weekly) 1/26/2019, 11/03/2018
The POTW reports that TSS and flow violations were due to discharge from Trinity
Frozen Foods. Trinity also had low pH effluent, which caused upsets at the POTW.
POTW required Trinity to implement pH adjustments to the discharge to raise the
pH. Trinity no longer discharges to the POTW. Trinity now has their waste pumped
and hauled to Lumberton.
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?
Steven Roberts produces fats and oils that have caused buildups in the sewer system.
The facility reports that they have been cleaning the sewers to address the situation.
19. Which Industries have been in SNC for Limits or Reporting during
either of the Last 2 Semi -Annual Periods? Not Been Published for
Public Notice?(May refer to PAR if Excessive SIUs in SNC)
®YES ❑NO
SNC for Limits:
SNC for Reporting:
Not Published:
The POTW did not report any SIUs in SNC in the 2019 PAR. However, the
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1

POTW reports that Steven Roberts had multiple limits violations for BOD
and TSS during 2019. They facility reports that they did not make a
determination if the violations met the criteria of Significate Non -
Compliance.
The facility reports that they are considering raising Steven Robert's BOD
and TSS limits to reduce the number of violations.
20. Which Industries are on Compliance Schedules or Orders? For all Sills on an
Order, Has a Signed Copy of the Order been sent to the Division?
None.
21. Are Any Permits or Civil Penalties Currently Under Adjudication? If Yes, Which
Ones?
El YES ®NO
LTMP/STMP 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/STMP 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 verify yourself!
• Metals effluent data collected was not included on DMRs.
26. If NO to 23 - 26, list violations
• POTW does not currently store analytical data from the STMP in a table. Data is maintained in analytical reports only.
• Detection limits for cadmium, chromium, and silver do not meet the minimum detection limits listed in the STMP.
o Detection limit for cadmium was <0.01mg/L. STMP requires 0.002 mg/L.
o Detection limit for chromium was <0.01 mg/L. STMP requires 0.005 mg/L.
o Detection limit for silver <0.01mg/L. STMP requires 0.005 mg/L.
• HWA approval letter from 4/9/2020 indicated that "STMP should be monitored for once a quarter instead of in four executive
months."
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 2

28 PRETREATMENT PROGRAM ELEMENTS REVIEW— Please review POTW files, verify POTW has copy of Program Element in
()gram Info:
their files, complete with supporting documents and copy of PERCS Approval Letter, and dates consistent with Pr
Last Approval
Date In file
Program Element
Last Submittal
Date In file?
Headworks Analysis (HWA)
Industrial Waste Survey (IWS)
Sewer Use Ordinance (SUO)
10/1/19
1/26/2018
®Yes❑ No
® Yes ❑ No
4/9/2020
2/5/2018
❑ Yes ® No
Date Next Due,
If Applicable
❑ Yes ® No
Enforcement Response Plan (ERP)
Long Term Monitoring Plan (LTMP)
3/7/2014
9/18/2014
2/6/2014
® Yes ❑ No
® Yes In No
® Yes ❑ No
2/20/2014
12/2/2014
2/20/2014
® Yes ❑ No
10/1/2024
12/31/2022
❑ Yes ® No
❑ Yes ® No
W AND 1 IU INSPECTION)
INDUS'I IAL USEtt rrAtivut tturp KILN, ,...,.,_.:,.. k., lt, a .......a,._..........29.
User Name
1. Steven Roberts Original
Dessert LLC
2.
3.
30. IUP Number
002
31. Does File Contain Current Permit?
►4 Yes ❑ No
❑ Yes ❑ No
❑
Yes ❑ No
32. Permit Expiration Date
7/21/2020
33. Categorical Standard Applied (LE. 40 CFR, Etc.) Or N/A
NA
34. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
❑ Yes A. No
❑.Yes ❑ No
❑ Yes ❑ No
35. Does File Contain an Inspection Completed Within Last Calendar Year?
Yes ❑ No
❑ Yes ❑
No
❑ Yes ❑ No
36. a. Does the File Contain a Slug/Spill Control Plan?
One Needed? (See Inspection Form from POTW)
a. Yes ■No
b. ■Yes ■No
a. ■Yes ■No
b. ■Yes No
a. ■Yes ■No
b. ■Yes ■No
b. If No, is
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
Organic Management Plan (TOMP)?
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
38. a. Does File Contain Original Permit Review Letter from the Division?
b. All Issues Resolved?
a. 0Yes ■No
b.❑Yes ❑No ON/A
a. Yes ■No
b.❑Yes ❑No❑N/A
a. ■Yes ■No
b.❑Yes ❑No❑N/A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
its Sampling as Required by IUP, including flow?
Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
❑ Yes ►4 No
❑ Yes ❑ No
❑ Yes ❑ No
41. During the Most Recent Semi -Annual Period, Did the SIU Complete its
Sampling as Required by IUP, including flow?
®Yes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports
time?
®Yes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
on
42a. For categorical Ms with Combined Wastestream Formula (CWF), does
file include process/dilution flows as Required by IUP?
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
42b. For categorical Ills with Production based limits, does file include
rates and/or flows as Required by IUP?
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
production
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Limits Non -Compliance from Both POTW and SIU Sampling?
❑ Yes
No
❑ Yes ❑ No
❑ Yes ❑ No
❑Yes❑No❑N/A
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Reporting Non -Compliance from SIU Sampling?
❑Yes❑No®N/A
❑Yes❑No❑N/A
44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
Monitoring Violations?
b. Did Industry Resample and submit results to POTW Within 30 Days?
c. If applicable, Did POTW resample within 30 days of becoming aware
limit in the POTW's sampling of the SIU?
a.❑Yes❑No®N/A
b. ❑Yes❑No®N/A
c.®Yes ❑No❑N/A
a.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
c,❑yes❑No❑N/A
a.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
c.❑Yes❑No❑N!A
of SIU violations
❑ Yes
❑
No
❑
Yes
❑ No
46. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
►4
Yes ❑ No
47. During the Most Recent Semi -Annual Period, Was Enforcement Taken
in the POTW's ERP (NOVs, Penalties, timing, etc.)?
❑Yes®No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
as Specified
File Contain Penalty Assessment Notices?
❑Yes®No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
48. Does the
The File Contain Proof Of Penalty Collection?
❑Yes®No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
49. Does
50. a. Does the File Contain Any Current Enforcement Orders?
b. Is SIU in Compliance with Order?
a.❑Yes®No❑N/A
b.❑Yes❑No®N/A
a.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
a.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
51. Did the POTW Representative Have Difficulty in Obtaining Any of This
Requested Information For You?
►1 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
NC DWR Pretreatment Compliance Inspection (PCI) Form
Updated December 2016
Page 3

FILE REVIEW COMMENTS:
• Steven Roberts has had repeated violations for TSS and BOD. The POTW has not issued NOVs for the violations. The POTW has
also not assessed whether the violations constitute either Chronic or Technical Review Criteria (TRC) Significant Non -Compliance
(SNC). Violations should be issued following the POTW's Division approved Enforcement Response Plan.
• The IUP for Steven Roberts expires on 7/21/2020. The SIU has not submitted an application for permit renewal. The POTW reports
that they do not require the SIU to submit IUP applications and that the current permit was issued without an application. As per
Steven Robert's IUP, the SIU is required to submit an application for IUP renewal at least 180 prior to the active permit's expiration
date. The POTW should retain a copy of the completed permit.
• Sampling at SIU is completedbyPOTW. POTW collects BOD and TSS, which are analyzed in-house at the Pembroke WWTP. The
POTW has not been using a COC during sampling since the samples are analyzed in house. A COC should be used to document
sample collection and custody transfers even if samples are analyzed in house.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
1 1 I I I 1 I I I I 1 1 I
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 El NO
E. Exit Interview ❑ YES ❑ NO
Industrial Inspection Comments:
OVERALL SUMMARY AND COMMENTS:
Comments:
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 4

Requirements:
• The POTW is required to follow its Division approved ERP. Notices of violation should be issued in a timely manner for
all SIU violations following the ERP.
• Significant Non -Compliance (SNC) determinations need to be made for facilities that have had violations. As per 15A
NCAC 02H.0908 (b)(4) and (5), the Town is required to publish public notice of all SIUs in SNC on an annual basis and
report SNC facilities to the Division in its Pretreatment Annual Report. A SNC determination must be made for this
facility for 2019. If it is determined that the facility was in SNC for the 2019 PAR year, public notice must be
published and an amended PAR must be submitted to the DEQ within 30 days upon receipt of this letter. Proof of
the public notice must be included in the amended PAR.
• The POTW should keep copies of approval letters from the Division for program elements including the Head Works
Analysis, Sewer Use Ordinance, Industrial Waste Survey, Enforcement Response Plan, and Short -Term Monitoring Plan.
• As per Part If Section 23 of the General Conditions of Steven Robert's IUP, the SIU is required to submit an IUP renewal
application at least 180 prior to the active permit's expiration date. Please ensure that Pembroke is adequately
implementing its pretreatment program by requiring SIUs to submit IUP renewals within this time frame. The POTW
should retain a copy of the completed permit application.
• A COC should be used for all sampling events. This applies to samples that are collected at the SIU and then analyzed in-
house at the Pembroke WWTP. Using a COC may increase the defensibility of data generated during sampling events.
• Please ensure that the STMP is being properly implemented. Report all STMP effluent data on monthly Discharge
Monitoring Reports. This includes parameters that are supplementary to NPDES monitoring requirements. Ensure that all
detection limits meet the minimum detection limit listed in the STMP.
Recommendations:
• The Division recommends maintaining STMP data in a digital table. Data is currently maintained by the POTW through
paper copies of analytical reports. Maintaining the data in a digital table facilitates the data review process and may help
ensure that all sampling is completed at the correct locations and frequencies and that minimum detection limits are being
met by the analytical laboratory.
NOD: ❑ YES ❑ NO
NOV: ® YES ❑ NO
QNCR: ❑ YES ❑ NO
POTW Rating: _
Satisfactory Marginal Unsa.tisffetned by: X
PCJ CRNIAIXTED BY: Kristen Slodysko DATE: 7/6/2020
ILt y . f jrtut ui 7/13/2020
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NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 5