NC0027103_Pretreatment_Annual_Report_20210226

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POST OFFICE BOX 866
PEMBROKE, NORTH CAROLINA
28372
OFFICE OF THE MANAGER
February 26th, 2021
NC DEQ
PERCS Unit
Kristin Litzenberger
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Town of Pembroke Pretreatment Program 2020 PAR
MUNICIPAL BUILDING
100 SOUTH UNION CHAPEL ROAD
Enclosed are an original and one copy of the Town of Pembroke's Pretreatment Annual Report (PAR) for
the period of January 1, 2020 through December 31, 2020.
The Town of Pembroke's Pretreatment Program is a modified program. As such, we are submitting a
narrative that contains information on the only SIU, the Pretreatment Program Information Database
Form, the PPS Form and the Historical SNC Report.
Should you have any questions about this report, please contact me or Charles A. Donnell, PE at 910-
322-6572.
Sincerely,
Tyler W. Thomas
Town Manager, Town of Pembroke
PHONE [phone] • FAX [phone]

Town of Pembroke, Pembroke WWTP (NC 0027103)
2020 Pretreatment Annual Report (PAR)
Narrative
GENERAL INFORMATION
Contact Information:
Town of Pembroke
Mr. Tyler W. Thomas, Town Manager
PO Box 866
Pembroke, NC 28372
Mr. Jason Deese, ORC Town of Pembroke WWTP
PO Box 866
Pembroke, NC 28372
Pretreatment Consultant
Mr. Charles A. Donnell, PE
Capital Projects Manager, Envirolink, Inc.
4700 Homewood Court, Suite 108
Raleigh, NC 27609
General Program Information:
In 2020 the Town of Pembroke had only one SIU — Steven Roberts Original Deserts. The Town
recognized that Steven Roberts was violating its IUP limits for BOD and TSS regularly and intended to use
the recently completed HWA to adjust the limits so that it would be less likely to violate them. As a
result of this decision, the Town did not issue notices of violation to Steven Roberts for the limit
violations. This was not in keeping with the approved ERP and Pembroke retroactively identified
individual violations and issued Steven Roberts a single NOV for the period of January 2020 to June of
2020 on July 20, 2020.
Based on the violations from January 2020 to June 2020, Pembroke determined that Steven Roberts was
in Significant Noncompliance (SNC) for the Chronic Violations criteria for monthly average BOD. As
required, the Town will publish this information in the newspaper as a record of yearly performance for
all of 2020.
The consultant who prepared the HWA was asked to evaluate conditions at the treatment plant and to
recommend maximum limits for Steven Roberts that would not adversely affect the plant's efficacy. The
study revealed that BOD limits could be increased from previous limits. The IUP issued in December
2017 contained BOD limits as follows:
• Samples taken twice per month
• Daily Maximum: 6,000 mg/I
• Monthly Average: 5,000 mg/I

These limits were modified so that Daily Maximum limits were eliminated, and Monthly Average limits
were increased to 7,500 mg/I. Similarly, TSS limits were modified to eliminate Daily Maximums and
increase Monthly Averages to 2,500 mg/I. The revised IUP was issued to Steven Roberts in July 2020 but
was not approved by the NC Division of Water Resources until 11/12/20 following receipt of additional
information.
A pretreatment compliance inspection for the Town of Pembroke was completed on June 23, 2020.
Several items were identified that needed to be corrected. A brief description of those corrections is
listed below:
1. The POTW intends to store STMP analytical data in a table for future reviews. An example table
has been requested for use as a model for Pembroke's table.
2. Detection limits for cadmium, chromium and silver have been modified to correspond with the
detection limits listed in the STMP.
3. Per the HWA approval letter from 4/9/2020 the next STMP will be started not later than August
1, 2023 and will be monitored once a quarter.
4. The POTW has copies of approval letters from the Division for current versions of the HWA,
SUO, IWS, ERP and STMP.
5. STMP data will be reported on DMRs during the next STMP sampling event.
As a result of these deficiencies and the failure of the Town to "take appropriate enforcement actions"
against Steven Roberts, the Town was issued an NOV on July 8, 2020. The Town responded to the NOV
on July 24, 2020 and indicated that deficiencies were corrected.
The HWA, short term monitoring plan, sewer use ordinance, enforcement response plan, industrial
waste surveys and industrial users permits are all up to date. Dates in the Pretreatment Program Info
Database (attached) are correct.
The Town's incorporation of provisions of the Dental Amalgam Rule into the ERP was approved by DEQ
on September 2, 2020. The two dentists that discharge wastewater to the POTW were required to
submit a One -Time Compliance Report by October 12, 2020. As of January 1, 2021, no reports had been
received by the Control Authority (CA). The CA therefore delivered a Dental Amalgam Rule fact sheet
and a suggested format for the One -Time Compliance Report to each of two dental facilities in
Pembroke and requested a response. Responses in the format of a "One -Time Compliance Report for
Dental Discharges" were received in January 2021 for a 100% return rate. Both use the Solmetex NXT
Hg5 separator.
The PPS was completed and attached to this report. The historical SNC report was changed to indicate
that Steven Roberts was in Significant Non -Compliance for all of 2019 (this was reported in the
Amended 2019 PAR required by the July 24, 2020 NOV and approved on September 22, 2020).

General IUP Information:
Steven Roberts Original Deserts IUP was issued to Steven Roberts Original Deserts on 02/21/17. It was
modified on 12/11/17 and re -issued. That permit was effective until 07/31/2020. Steven Roberts
requested that its IUP be re -issued on July 31, 2020. The permit was issued to Steven Roberts effective
August 1, 2020 and will remain effective until February 29, 2024.
SIU Information:
Steven Roberts Original Deserts.
Steven Roberts Original Deserts bakes cake products and distributes them to various markets. Process
wastewater is separate from domestic sewage and flows to a large (10,000 gallon), pre -cast grease trap.
Effluent from the grease trap flows to the Town's collection system. Samples are collected at the Town
manhole where Steven Roberts effluent enters the collection system.
A single NOV was issued to Steven Roberts for sampling violations in the first six months of 2020 as
enumerated above.
On November 10, 2020, the POTW ORC noticed a large amount of oil in the treatment plant influent.
The ORC drove to Steven Roberts and requested and received permission to inspect the facility's grease
trap. He determined that oil in the effluent from the trap was the same color and consistency as the oil
entering the POTW. On November 16, 2020, the Town sent a letter to Steven Roberts with an extract of
the Town's FOG ordinance that, among other things, requires that grease traps be emptied and serviced
every 30 days at a minimum.
Routine sampling conducted by the POTW ORC in November 2020 identified violations of the revised
permit limits for Steven Roberts for both BOD (8,550 mg/I monthly average) and TSS (2,715 mg/I
monthly average). Accordingly, an NOV was issued to Steven Roberts on December 15, 2020. The NOV
letter reiterated the requirement to service grease traps. Steven Roberts pumped out the grease trap
on December 21st with the POTW ORC observing. Following a slight period of time required for the
grease trap to refill and stabilize, BOD and TSS samples were again taken. Results were well within limits
(BOD was 3,463 mg/I and TSS was 1,095 mg/I). This result was passed along to the Steven Roberts
maintenance supervisor who agreed to continue to clean the grease trap every three weeks.
On December 16, 2020, the production facilities at Steven Roberts were inspected for compliance with
provisions of the IUP. No violations were identified.
Attachments:
• Pretreatment Program Info Database
• PPS Form
• Historic SNC Report

Pretreatment Program Info Database
for Program Name Pembroke
WWTP Name Town of Pembroke
Program Approval Date
Pretreatment Status
Region
County
NPDES Number
NPDES Effective Date
NPDES Expire Date
POTW is Primary WWTP
Design Flow mgd
WWTP SIU's
WWTP CIU's
date Inactive
1
0
04/07/2017
Modified
FRO
Robeson
NC0027103
08/01/2016
07/31/2019
TRUE
1 3300
Program SlUs
Program ClUs
printed on: 12/22/2020
ri
Stream Information 7
7i 0 Flow cfs / mgd
1Q10 Flow cfs / mgd
Stream Classification
Basin Number
Receiving Stream Name
IWC % at 7Q10 1.69
120
/ 77.52
97.83 / 63 22
WS IV B SW HQW
03-07-51
Lumber River
Last PAR Rec 02/25/2020
Current Fiscal 06/23/2020
Year PCI Done
Last Audit on
% Design mgd is SIU permitted
1
Date Next Due
Date Received by DWR
Date Approved
Adopt Date Required
Date Adopted
301
10/01 /2024
10/01 /2019 02/06/2014
04/13/2020 02/20/2014
PAR Due Date 03/01/2021
Audit Year Next
Permitted SIU flow (mgd) [Pt_SIU)
IWS
12/31/2022
01/26/2018 02/06/2014 06/10/2020
02/05/2018 02/20/2014 09/02/2020
mercury
1631
required
1
04
04/07/2014
rInfo in this Box from Pt_Contacts
PT_Pro
g.Prime Phonel
Formal Name
ext
Fax
Date Date Date
Attended Attended Attended
HWA Wksp lUP Wksp PAR Wksp
Mr. Tyler Thomas IPrim 11910 521-9758 I
[e-mail]
Town Manager
PO BOX 866
28372
Mr. Charles Donnell (Prim 1(910-322-6572 J
sdonnel I ' envirol in kinc.com
Capital Projects Manager
Mr. Jason Deese I 11910 506-9529 ! I
[e-mail]
ORC
PO BOX 866
28372
alk
[ Pretreatment Related NOVs from DWQ
11/28/2017 NOV-2017-PC-0705
DWR Central Office Contact
DWR Regional Contact
Vivien Zhong
!Stephanie Zorio

Chapter 9, PAR Guidance
Pretreatment Performance Summary (PPS)
1. Pretreatment Town Name: Pembroke, NC
2. "Primary" NPDES Number NCO() 27103
or Non Discharge Permit # if applicable =>
3. PAR Begin Date, please enter 01/01/yyyy
4. PAR End Date, please enter 12/3 1/yyyy
5. Total number of SIUs, includes CIUs
6. Number of CIUs
7. Number of SIUs with no IUP, or with an expired IUP
8. Number of SIUs not inspected by POTW
9. Number of SIUs not sampled by POTW
10. Number of SIUs in SNC due to IUP Limit violations
11. Number of SIUs in SNC due to Reporting violations
12. Number of SIUs in SNC due to violation of a Compliance Schedule, CO, AO or similar
13. Number of CIUs in SNC
14. Number of SIUs included in Public Notice
15 Total number of SIUs on a compliance schedule, CO, AO or similar
16. Number of NOVs, NNCs or similar assesed to SIUs
17. Number of Civil Penalties assessed to SIUs
18. Number of Criminal Penalties assessed to SIUs
19. Total Amount of Civil Penalties Collected
20. Number of IUs from which penalties collected
[Foot Notes:
19. =>
3. =>
4. =>
5. =>
6. =>
7. =>
8. =>
9. =>
10. =>
11. =>
12. =>
13. =>
14. =>
15. =>
16. =>
17. =>
18. =>
20. =>
1/1/2020
12/31/2020
1
0
0
0
0
0
0
0
1
0
2
0
0
0
0
AO
CIU
CO
IU
Administrative Order
Categorical Industrial User
Consent Order
Industrial User
IUP Industrial User Pretreatment Permit
NNC Notice of Non -Compliance
NOV Notice of Violation
PAR Pretreatment Annual Report
POTW Publicly Owned Treatment Works
SIU Significant Industrial User
SNC Significant Non -Compliance
revised 1/2018: PAR PPS 2018

histgr61,04
P1 REPORT
Pembroke
2013 2014 2015
2016
2017
2018
2019
1st half 2nd half 1st half 12nd half 1st half 12nd half
Steven Roberts Original Desserts, LLC PreviousNames:
IUP # 002
IUP_Status: Active
PRINTED ON: 12/16/2020
Pipe # 001
BOD
Reporting
TSS
1st half 12nd half 1st half 12nd half
SIU Word Description:
High end desserts
1st half 12nd half 1st half 1 2nd half
I I I Ix x Ix
I I I XIX I I
I I I I Ix yIx
An 'X' in a semi-annual period indicates snc for the period for the respective parameter.
This information is compiled from many sources, and has not been verified.
Contact the local pretreatment coordinator or state pretreatment staff if errors are noted.
PAGE 55

PUBLIC NOTICE OF SIGNIFICANT
INDUSTRIAL WASTEWATER PERMIT
VIOLATIONS
The Town of Pembroke, in accordance
with Federal and State Regulations is
hereby giving Public Notice. Listed below
are Significant Industrial Users that were
in significant noncompliance (SNC) with
national pretreatment regulations, 40
CFR Part 403, and state pretreatment
regulations, 15 NCAC 2H .0900, and loc-
al pretreatment regulations during the
period of January 1 through June 30,
2020; Steven Roberts Desserts —Indus-
trial User Pretreatment Permit Limits Viol-
ations. A continuing effort is being made
by the industry listed to achieve compli-
ance, including installation of new equip-
ment and upgrading of existing equip-
ment and continued progress is expec-
ted until full compliance is attained. Town
of Pembroke, POTW, Tyler W. Thomas,
Town Manager. February 18th, 2021.

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POST OFFICE BOX 866
PEMBROKE, NORTH CAROLINA
28372
OFFICE of THE MANAGER
Certified Mail
Return Receipt Requested
December 15`1i, 2020
Mrs. Mabel Hall, Plant Manager
Steven Roberts Original Desserts, LLC
701 South Jones Street
Pembroke, NC 28372
Subject: NOTICE OF VIOLATION
Dear Mrs. Hall:
MUNICIPAL BUILDING
100 SOUTH UNION CHAPEL ROAD
As you are aware, The Town of Pembroke issued a revised Industrial User Pretreatment Permit
(IUP) for your facility in August 2020. At your request and following much discussion, this permit
was modified to allow Steven Roberts to discharge wastewater at concentrations that are greater
than those in the previous IUP. The Town increased the concentrations for the sole purpose of
helping Steven Roberts avoid violations.
Unfortunately, Steven Roberts has not met the new limits as noted below:
- Part I, Section F establishes monthly average limits for both BOD and TSS. POTW
personnel monitor these items by sampling twice per month and averaging the results.
Steven Roberts exceeded the maximum monthly average limits for both BOD and TSS
based on sampling completed in November 2020.
- The monthly average limits for BOD and TSS are 7,500 mg/1 and 2,500 mg/l respectively.
The monthly averages measured by POTW personnel were 8,550 mg/1 and 2,715 mg/l
respectively.
PHONE [phone] • FAX [phone]

Steven Roberts needs to establish a plan to reduce these constituents to allow Pembroke's POTW
to continue to meet its limits established by the State of North Carolina. The Town believes that
Steven Roberts would be able to greatly improve its performance by pumping out its grease traps
monthly as required by the Town's FOG ordinance and as enumerated in our letter to you dated
November 16, 2020. Our POTW operator has requested that he be notified when pumping is
scheduled so that he will be able observe the pumping operations.
A Notice of Violation is being issued for this violation. Pursuant to Section 8.2 (a) of the SUO, a
civil penalty of not more than $25,000 may be assessed against any person who violates the SUO.
Please respond to this notice within 10 business days of receipt with your plan to comply with the
provisions.
Sincerely,
Tyler W. Thomas
Cc: Jason Deese, WWTP ORC
Archie McMillan, Sanitation Supervisor, Steven Roberts Original Desserts

dil01,142 10/ene
POST OFFICE BOX 866
PEMBROKE, NORTH CAROLINA
28372
OFFICE of THE MANAGER
July 20th, 2020
Mrs. Mabel Hall
Steven Roberts Original Desserts, LLC
701 South Jones Street
Pembroke, NC 28372
Subject: NOTICE OF VIOLATION
Dear Permittee:
MUNICIPAL BUILDING
100 SOUTH UNION CHAPEL ROAD
An Industrial User Pretreatment Permit (IUP) was issued for your facility on February 21st, 2017. This
permit allows Steven Roberts to discharge wastewater into the Pembroke sanitary sewer system
providing certain stipulations are met. Steven Roberts has not maintained the required agreement by
violating the stipulations listed below:
Part I, Section F of your permit establishes daily maximum limits for both BOD and TSS. Town personnel
monitor these standards by sampling twice per month. From the monitoring and sampling process it has
been discovered that Steven Roberts has violated both of these maximum limits. Listed below are the
violations and dates,
• January - BOD exceeded the monthly average at 5418. (Average is 5000)
• February - BOD exceeded the daily maximum on 2/28 at 9040. (6000 is max)
• February - BOD exceeded the monthly average at 7028.
• February - TSS exceeded the monthly average at 2810. (Average is 2000)
• March - BOD exceeded the monthly average at 6374.
• June - BOD exceeded the daily maximum 6/2 at 7860.
• June - BOD exceeded the monthly average at 6890.
• June - TSS exceeded the daily max on 6/2 at 3020. (2500 is max)
• June - TSS exceeded the monthly average at 2585.
We are requesting that you will take measures to resolve these issues, as the Town re-evaluates its
position in order to keep the treatment plant in compliance with State and local guidelines. Pursuant to
Section 8.2 (a) of the Town's Sewer Use Ordinance (SUO), a civil penalty of not more than $25,000 may be
assessed against any person who violates the SUO.
Please give me a call to discuss at your convenience, at 910-521-9758. The Town will be scheduling a
meeting soon to review this letter with you.
Respectfully,
Tyler W. Tho'las
Town Manager
PHONE [phone] • FAX [phone]