NC0020559_Pretreatment Compliance Inspection_20211201

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ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
E. Terrell Blackmon, City Manager
City of Henderson
P.O. Box 1434
Henderson, NC 27536
NORTH CAROLINA
Environmental Quality
December 1, 2021
Subject: Pretreatment Compliance Inspection
City of Henderson Water Reclamation Facility
NPDES Permit No. NC0020559
Vance County
Dear Mr. Blackmon:
On August 24, 2021, Cheng Zhang of the Raleigh Regional Office (RRO) conducted a
Pretreatment Compliance Inspection of City of Henderson's pretreatment program. The
assistance given by Mr. Darrel Johnson, Pretreatment Coordinator of the facility, was
greatly appreciated. The inspection report is attached. Findings during the inspection
were as follows:
1. There is only one Significant Industrial User (SIU) discharging to the POTW,
which is not a Categorical Industrial User (CIU). It was noted that the SIU (Mars
Petcare) was not in Significant Non -Compliance (SNC) for the two most recent
semi-annual periods.
2. The review of Long Term Monitoring Plan (LTMP) data indicated that all
locations were sampled with required frequencies and all samples analyzed with
correct detection limits since last inspection. LTMP data were well maintained in
spreadsheets.
3. A review of the files containing the pretreatment program elements was
conducted. All elements were up to date. Files were available and well organized.
Long Term Monitoring Plan (LTMP) and Enforcement Response Plan (ERP) were
updated and approved by the Division in 2020. Please be reminded that
Headworks Analysis and Industrial Waster Survey are due to be updated in April,
2022.
NOR�D_E
�eeabnenl al EnNrvnmenlel 9uellly
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office 13800 Barrett Drive I Raleigh, North Carolina 27609
919.791.4200

DocuSign Envelope ID: D51A1261-D163-486D-8828-44A272B79AC5
4. Mars Petcare's pretreatment file (Permit No. 0011) was reviewed during the
inspection. During the first semi-annual period of 2021, the SIU was in
compliance.
The City of Henderson's pretreatment program is very well managed. Thank you for your
continued support of the Pretreatment Program. If you have questions regarding to the
attached report or any of the findings, please contact Cheng Zhang at 919-791-4200 (or
email: [e-mail]).
Sincerely,
by:
UatAi-ssa t, hatiutd,
B2916E6AB32144F...
Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources
Enclosure: City of Henderson PCI Form
Cc: Central Files (Laserfiche)
Darrel Johnson - City of Henderson (electronic copy only)
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NGR`H CAROLINA ������
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North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office f 3800 Barrett Drive I Raleigh, North Carolina 27609
919,791.4200

DocuSign Envelope ID: D51A1261-D163-486D-8828-44A272B79AC5
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
1. Control Authority (POTW) Name: City of Henderson
2. Control Authority Representative(s): Darrel Johnson
3. Title(s): Pretreatment Coordinator
4. Last Inspection Date: July 17, 2019 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
J NICIO 10 12101515191
MM/DD/YY
I08I24I211
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 (CIUs)?
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?
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
either of the Last 2 Semi -Annual Periods? Not Been Published for
Public Notice?(May refer to PAR if Excessive SIUs in SNC)
SNC for
SNC for
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?
/1 YES ❑ NO
6/21, 5/21 BOD; 1/21, 3/21 toxicity
❑ YES a NO
Limits: None
Reporting: None
lished: None
None
❑ YES /1 NO
LTMP/STMP FILE REVIEW:
22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES
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:
❑ NO
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1

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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 Approva 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)
8/6/2019
a Yes ❑ No
11/4/2019
a Yes ❑ No
4/1/2022
Industrial Waste Survey (IWS)
5/1/2017
/1 Yes ❑ No
6/14/2017
/1 Yes ❑ No
4/30/2022
Sewer Use Ordinance (SUO)
11/9/2012
a Yes ❑ No
11/19/2012
r Yes ❑ No
Enforcement Response Plan (ERP)
1/24/2020
a Yes ❑ No
2/12/2020
r Yes ❑ No
Long Term Monitoring Plan (LTMP)
12/11/2019
a Yes ❑ No
2/14/2020
r Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION
29. User Name 1. Mars Petcare 2.
3.
30. IUP Number
0011
31. Does File Contain Current Permit?
/1 Yes ❑ No
32. Permit Expiration Date
4/3/2022
33. Categorical Standard Applied (LE. 40 CFR, Etc.) Or N/A
N/A
34. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
/1 Yes ❑ No
35. Does File Contain an Inspection Completed Within Last Calendar Year?
A Yes ❑ No
36. a. Does the File Contain a Slug/Spill Control Plan?
b. If No, is One Needed? (See Inspection Form from POTW)
a. ►Yes ■No
b. •Yes ■ No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
Organic Management Plan (TOMP)?
❑Yes❑NoEN/A
38. a. Does File Contain Original Permit Review Letter from the Division?
b. All Issues Resolved?
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?
A Yes ❑ No
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
/1 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
41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports
on time?
®Yes❑No❑N/A
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
file include process/dilution flows as Required by IUP?
❑Yes❑NoEN/A
42b. For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
❑Yes❑NoEN/A
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Limits Non -Compliance from Both POTW and SIU Sampling?
❑Yes❑NoEN/A
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Reporting Non -Compliance from SIU Sampling?
❑Yes❑NoEN/A
44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
a.❑Yes❑NoEN/A
b.❑Yes❑NoDN/A
a❑Yes❑NoDN/A
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
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 /1 No
47. During the Most Recent Semi -Annual Period, Was Enforcement Taken
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
❑Yes❑NoEN/A
48. Does the File Contain Penalty Assessment Notices?
❑Yes❑NoEN/A
49. Does The File Contain Proof Of Penalty Collection?
❑Yes❑NoEN/A
50. a. Does the File Contain Any Current Enforcement Orders?
b. Is SIU in Compliance with Order?
a.❑Yes❑NoEN/A
b.❑Yes❑NoEN/A
51. Did the POTW Representative Have Difficulty in Obtaining Any of This
Requested Information For You?
❑ Yes /1 No
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

DocuSign Envelope ID: D51A1261-D163-486D-8828-44A272B79AC5
FILE REVIEW COMMENTS:
Mars Petcare was in compliance during the most recent semi-annual period.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
J I I I I I I I 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 El YES ❑ NO
C. Pretreatment Tour ❑ YES ❑ NO
D. Sampling Review ❑ YES ❑ NO
E. Exit Interview El YES ❑ NO
Industrial Inspection Comments:
OVERALL SUMMARY AND COMMENTS:
Comments: The program is well managed; files are well organized.
Requirements: None
Recommendations: None
NOD: ❑ YES ® NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ® NO
POTW Rating:
® Satisfactory ❑ Marginal ❑ UnSatisfactory
PCI COMPLETED BY: Cheng Zhang, Raleigh Regional Office DATE: August 24, 2021
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3