NC0063096_Pretreatment Compliance Evaluation Inspection_20200925

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
Mr. Seann Byrd
Water Quality Director
Town of Holly Springs
P.O. Box 8
Holly Springs, NC 27540
NORTH CAROLINA
Environmental Quality
September 25, 2020
Subject: Pretreatment Compliance Inspection
Town of Holly Springs
Utley Creek WWTP - NPDES Permit No. NCO063096
Wake County
Dear Mr. Byrd:
On September 4, 2020, Cheng Zhang of the Raleigh Regional Office (RRO) conducted a
Pretreatment Compliance Inspection of Town of Holly Springs' pretreatment program. The
assistance given by Ms. Debra Batten, the lab manager and pretreatment coordinator, was
greatly appreciated. The inspection report is attached. Findings during the inspection were as
follows:
1. Town of Holly Springs has two Significant Industrial Users (SIUs), one of which is also
Categorical Industrial Users (CIUs). It was noted that neither SIU was in SNC during the
two most recent semi-annual periods.
2. The pretreatment inspection file review included Seqirus, Inc. (Permit No. 002), and
South Wake Landfill (Permit No. 001). The files needed for review were available for
inspection, contained all the required elements and were in excellent condition.
3. The POTW and both SIUs completed monitoring as required by the IUPs during the first
semi-annual period of 2020, both SIUs were in compliance. Although South Wake
Landfill was in compliance in the past two semi-annual periods, it has been having
difficulty to remove ammonia in its pretreatment process, as a result, the facility's flow to
the POTW has been limited, and has to pump and haul its wastewater to another
wastewater treatment plant out of the region (Lumberton WWTP). Ms. Batten has been
discussing solutions to solve South Wake Landfill's pretreatment issues with
pretreatment staff in DWR Central Office.
4. A review of the files containing the pretreatment program elements was conducted. All
pretreatment program elements are up to date.
norDE Q�� North Carolina Department of Environmental Quality I Division of Water Resources
r rnani wa Raleigh Regional Office 13800 Barrett Drive I Raleigh, North Carolina 27609
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5. The review of Long Term Monitoring Plan (LTMP) data indicated that all locations were
sampled with required frequencies and detection limits since last inspection. It was noted
that LTMP data which were not available for review during the previous inspection were
successfully retrieved.
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: [e-mail]).
Sincerely,
DocuSigned by:
Ua.t,SSa f.
62916E6AB32144F...
Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources
Enclosure: Town of Holly Springs PCI Inspection Form
CC: Central Files w/attachment (Laserfiche)
Cheng Zhang, RRO
Debra Batten, Town of Holly Springs (Electronic copy only)

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
Water Resources
ENVIRONMENTAL QUALITY
BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)]
1. Control Authority (POTW) Name: Town of Holly Springs
2. Control Authority Representative(s): Debra Batten
3. Title(s): Pretreatment Coordinator
4. Last Inspection Date: September 26, 2018 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
I N I C 1 0 10 16131019161 1 091 041 20 1
7. Current Number Of Significant Industrial Users (SIUs)?
2
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 (CIUs)?
1
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?
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 Pul
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?
® YES [-]NO
Total phosphorous 11/2018
❑ YES ®NO
Limits: None
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
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.
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

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)
10/30/2017
® Yes ❑ No
2/23/2018
® Yes ❑ No
5/1/2022
Industrial Waste Survey (IWS)
9/26/2016
® Yes ❑ No
10/19/2016
® Yes ❑ No
9/30/2021
Sewer Use Ordinance (SUO)
11/8/2012
® Yes ❑ No
12/7/2013
® Yes ❑ No
Enforcement Response Plan (ERP)
1 6/22/2010
® Yes ❑ No
8/4/2010
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
1 8/31/2018
® Yes ❑ No
10/26/2018
® Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW 3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION
29.
User Name
1. South Wake Landfill 2. Segirus, Inc.
3.
30.
IUP Number
001
1 002
31.
Does File Contain Current Permit?
® Yes ❑ NoI
® Yes ❑ No
32.
Permit Expiration Date
12/31/2023
10/31/2022
33.
Categorical Standard Applied I.E. 40 CFR, Etc. Or N/A
N/A
439.17 & 47
34.
Does File Contain Permit Application Completed Within One Year Prior
® Yes ❑ No
977 ❑ No
F
to Permit Issue Date?
I
35.
Does File Contain an Inspection Completed Within Last Calendar Year?
® Yes ❑ N=ol
® Yes ❑ No
36.
a. Does the File Contain a Slug/Spill Control Plan?
a. ®Yes ❑No
a. ®Yes ❑No
b. If No, is One Needed? (See Inspection Form from POTW)
b. ❑Yes ❑No
b. ❑Yes ❑No
37.
For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
❑Yes❑No[g
❑Yes❑No®N/A
Organic Management Plan TOMP ?
38.
a. Does File Contain Original Permit Review Letter from the Division?
a. ®Yes ❑No
a. ®Yes ❑No
b. All Issues Resolved?
b.❑Yes❑No❑N/A
I b.❑Yes❑No❑N/A
39.
During the Most Recent Semi -Annual Period, Did the POTW Complete
® Yes ❑ No
977 ❑ No
its Sampling as Required by IUP, including flow?
40.
Does File Contain POTW Sampling Chain -Of -Custody Forms?
1 ® Yes ❑ No
® Yes ❑ No
41.
During the Most Recent Semi -Annual Period, Did the SIU Complete its
®Yes❑No❑N/A
®Yes❑No❑N/A
Sampling as Required by IUP, including flow?
41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports
®Yes❑No❑N/A
®Yes❑No❑N/A
on time?
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑NoON/A
❑Yes❑NOON/A
file include process/dilution flows as Required by IUP?
42b. For categorical IUs with Production based limits, does file include
❑Yes❑No®N/A
❑Yes❑NADN/A
production rates and/or flows as Required by IUP?
43a.
During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑No®N/A
❑Yes❑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❑No®N/A
❑Yes❑No®N/A
All Re ortin Non-Com liance from SIU Sampling?
44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
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
c. If applicable, Did POTW resample within 30 days of becoming aware
c.❑Yes❑No®N/A
c.❑Yes❑No®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
❑
Yes
®
No
47.
During the Most Recent Semi -Annual Period, Was Enforcement Taken
❑Yes❑No®N/A
❑Yes❑No®N/A
F_
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
48.
Does the File Contain Penalty Assessment Notices?
❑Yes❑No®N/A
❑Yes❑No®N/A
49.
Does The File Contain Proof Of Penalty Collection?
❑Yes❑No®N/A
❑Yes❑No®N/A
50.
a. Does the File Contain Any Current Enforcement Orders?
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
51.
Did the POTW Representative Have Difficulty in Obtaining Any of This
❑ Yes ® No
❑ Yes ® No
Requested Information For You?
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

FILE REVIEW COMMENTS:
Although South Wake Landfill was in compliance in the past two semi-annual periods, it has been having difficulty to remove ammonia
in its pretreatment process, as a result, the facility's flow to the POTW has been limited, and has to pump and haul its wastewater to
another wastewater treatment plant out of the region (Lumberton WWTP).
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
l ! 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: The program is well managed
Requirements: None
Recommendations: Discuss with DWR Central Office staff about o
NOD: ❑ YES ® NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ® NO
n (nitrification) at South Wake Landfill.
POTW Rating:
Satisfactory ® Marginal ❑ UnSatisfactory ❑
PCI COMPLETED BY: Cheng Zhang, Raleigh Regional Office DATE: September 04, 2020
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3