NC0027103_Compliance Report_20220614

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
June 14t", 2022
Tyler W Thomas
Town of Pembroke
100 Union Chapel Rd
Pembroke, NC 28372-0866
SUBJECT: Pretreatment Program Audit Report
Town of Pembroke
Robeson County, NPDES#: NC0027103
Dear Mr. Thomas,
Enclosed please find a copy of the Pretreatment Compliance Inspection (PCI) form from the audit
conducted on June 8th, 2022. The audit was conducted by Stephanie Zorio, an Environmental Specialist
from the North Carolina Division of Water Resources (DWR) Fayetteville Regional Office.
The findings and comments noted during this inspection are provided in the enclosed copy of the inspection
report entitled " Pretreatment Compliance Inspection".
Issues:
• Industries must submit a permit renewal application at least 180 days before the current permit expires.
• The SIU did not have a copy of the Enforcement Response Plan (ERP). Please send a digital copy to
Steven Roberts.
• Please follow-up with Steven Roberts regarding an updated Spill Control Plan if they do not contact you
within 60 days.
Comments:
• The ORC and Pretreatment Consultant were knowledgeable and well -organized. POTW staff
performs an excellent job of maintaining records and rapport with SIUs.
• Lisa Osthues was contracted to complete the Headworks Analysis for the POTW.
• Twice monthly sampling is performed by the POTW. None is conducted by Steven Charles.
Thank you for your continued support of the Pretreatment Program. If you should have any questions, please
do not hesitate to contact Stephanie Zorio with the Water Quality Regional Operations Section in the
D_EQ
North Carolina Department of Environmental Quality I Division of Water Resources
Fayetteville Regional Office 1 225 Green Street, Suite 714 I Fayetteville, North Carolina 28301
910.4333300

Fayetteville Regional Office at 910-433-3322 or via email at [e-mail].
ATTACHMENTS
Pretreatment Inspection Report
Cc: laserflche
D_E
Sincerely,
—DocuSigned by:
`—A99704FAE D5D494...
Dr. Stephanie Zorio, Environmental Specialist
Water Quality Regional Operations Section
Fayetteville Regional Office
Division of Water Resources, NCDEQ
North Carolina Department of Environmental Quality I Dtvlsion of Water Resources
Fayetteville Regional Office 1 225 Green Street, Suite 714 I Fayetteville, North Carolina 28301
910.4333300

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT AUDIT REPORT
Water Resources
ENVIRONMENTAL QUALITY
Background Information [Complete prior to audit; review Program Info Database Sheet(s)]
1. Control Authority (POTW) Name: Town of Pembroke WWTP
2. Control Authority Representative(s): Jason Deese, Charles Donnell
3. Title(s): WWTP ORC, Pretreatment Consultant
4. Address of POTW:
Mailing PO Box 866
City Pembroke Zip Code 28972
Phone Number Fax Number E-Mail jason@a,pembrokenc.com, [e-mail]
5. Audit Date 6/8/ 22
6. Last Inspection Date: 6/23/20 Inspection Type: ® PCI ❑ Audit
7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s) ? ® Yes ❑ No
If No, Explain.
8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? ❑ Yes ® No
If Yes, Explain.
9. Is POTW under an Order That Includes Pretreatment Conditions? ❑ Yes ® No
Order Type and Number: Are Milestone Dates Being Met? ❑ Yes El No ® NA
Parameters Covered Under Order
ICIS Coding
Main Program Permit Number
INIclolo
2 17 11 to
3
10. Current Number of Significant Industrial Users (SIUs)?
11. Number of SIUs with No IUP, or with an Expired IUP?
12. Number of SIUs Not Inspected by POTW in Last Calendar Year?
13. Number of SIUs Not Sampled by POTW in Last Calendar Year?
MM/DD/YY
7 1 31 1 19 I
14. Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi -Annual Periods?
15. Number of SIUs in SNC for Reporting During Either of Last 2 Semi -Annual Periods?
16. Number of SIUs in SNC with Pretreatment Schedule?
17. Number of SIUs on Schedules?
18. Current Number of Categorical Industrial Users (CIUs)?
19. Number of CIUs in SNC?
1
0
0
0
0
0
0
0
0
0
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 1

20. PRETREATMENT PROGRAM ELEMENTS REVIEW- Review POTW files, verify POTW has copy of each Program Element
in their File, complete with all supporting documents and 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)
10/1/19
A/ Yes ❑ No
4/13/20
0 Yes ❑ No
10/1/24
Industrial Waste Survey (IWS)
1/26/18
A/ Yes ❑ No
2/5/18
A/ Yes ❑ No
12/31/22
Sewer Use Ordinance (SUO)
2/6/14
0 Yes ❑ No
2/20/14
A/ Yes ❑ No
Enforcement Response Plan (ERP)
6/10/20
0 Yes ❑ No
9/20/20
A/ Yes ❑ No
Long Term Monitoring Plan (LTMP)
2/6/14
1 Yes ❑ No
2/20/14
0 Yes ❑ No
Legal Authority (Sewer Use Ordinance-SUO)
21. Do you have any towns and/or areas from which you receive wastewater which are not in your annexed jurisdiction?
❑ Yes ❑ No If yes, Please list these towns and/or areas.
22. If yes to #21, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? ❑ Yes ❑ No ® NA
A copy, if not already submitted, should be sent to Division.
23. If yes to #21, Have you had any trouble working with these towns or districts? ❑ Yes ❑ No ® NA
If yes, Explain.
24. Date of Last SUO Adoption by Local Council 2/20/2014
25. Have you had any problems interpreting or enforcing any part of the SUO? ❑ Yes ® No
If yes, Explain.
Enforcement (Enforcement Response Plan-ERP)
26. Did you send a copy of the ERP to your industries? ❑ Yes ® No
If no, POTW must send copy within 30 days.
27. Have you had any problems interpreting or enforcing any part of the ERP (i.e. any adjudication, improper enforcement, etc?
❑ Yes ® No If yes, Explain.
28. List Industries under a Schedule or Order and Type of Schedule or Order
none
Resources
29. Please Rate the Followine: S=Satisfacto
M=Mareinal U=Unsatisfacto
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
A/ S ❑M ❑U
Access to POTW Vehicles for
Sampling, Inspections, and
Emergencies
AS ❑M ❑U
Access to Operable Sampling
Equipment
1 S ❑M ❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
1 S ❑M ❑U
Reference Materials
1S❑M❑U
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
1 S ❑M ❑U
Computer Equipment (Hardware and
Software)
A/ S ❑M ❑U
NC DWR Pretreatment Audit Form
Revised: December 2016
Page 2

30. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No
Explain Yes or No. Yes, but would be interested in moving to storing sampling data in a digital format such as via an Excel
spreadsheet.
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Costs are recouped by monies collected through surcharges.
Public Perception/ Participation
32. Are there any local issues affecting the pretreatment program (e.g.. odor, plant closing, new or proposed plants)?
❑ Yes ® No If yes, Explain.
33. Has any one from the public ever requested to review pretreatment program files? ❑ Yes ❑ No
If yes, Explain procedure. If no, how would the request be addressed? The POTW would set up a meeting if requested, and/or
send digital copies of requested records.
34. Has any industry ever requested that certain information remain confidential from the public? ❑ Yes ® No If yes, Explain
procedure for determining whether information qualified for confidential status, as well as procedure for keeping files confidential
from public. If no how would the request be addressed? The request would be granted based on whether the information was
proprietary for the industry and was not related to pretreatment in general or enforcement of violations.
35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? ® Yes ❑ No
36. Is the public notified about changes in the SUO or Local Limits? ® Yes ❑ No
37. Were all industries in SNC published in the last notice? ® Yes ❑ No
Permitting (Industrial Waste Survey-IWS)
38. How does the POTW become aware of new or changed Users? Town Hall (business applications), word of mouth,
39. Once the POTW becomes aware of new or changed Users, how does the POTW determine which industries have the
reasonable potential to adversely impact the WWTP and therefore require a new permit or a permit revision? (Who is an
SIU?) Facilities that are in industry categozied by the EPA and release >25,000 gal/day to the POTW.
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
▪ Yes No If Yes, How many are there?
Please list each site and how it is permitted, if applicable.
41. Does the POTW accept waste by (mark if applicable) ❑ Truck Dedicated Pipe ® NA
42. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples drawn,
manifests required)
43. How does the POTW allocate its loading to industries? Mark all that apply
❑ Uniform Limits ❑ Historical Industry Need ® By Surcharge ❑ Categorical Limits ❑ Other
Explain Other:
44. Review POTW' s copies of current allocation tables for each WWTP. Are there any over allocations? ❑ Yes ❑ No N/A
If yes, what parameters are over allocated? *Note: Program is a modified program, no allocation tables are required.
45. If yes to #44, What is being done to address the over allocations? (short-term IUPs, HWA to be revised, pollutant study, etc.)
46. Does the POTW keep pollutant loading in reserve for future growth / safety? ® Yes ❑ No
If yes, what percentage of each parameter % *Note: The POTW doesn't focus specifically on percentages but pays close
attention to BOD and TSS.
47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) ® Yes ❑ No
If yes, Explain. Issues were mostly resolved in 2020. Trinity (sweet potato processer) stopped discharging to the POTW
thereby allowing limits to be increased for Steven Roberts without taxing the POTW.
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 3

48. How does the POTW decide on which pollutants to limit in the permits? Monitor for? (for example: were only those pollutants
listed on the application limited; categorical parameters; NPDES Pollutants of Concern)
The POTW uses the Headworks Analysis and their permit as a guide.
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Recommendations from the EPA/DEQ and historical need.
Permit Compliance
50. Does the POTW currently have or during the past year had any permits under adjudication? ❑ Yes ® No
If yes, which industries? What was (will be) the outcome of the adjudication?
51. Demonstrate how the POTW judges compliance. This should include compliance judgment on all violations of limits, reporting
requirements, and permit conditions, as well as for SNC. The POTW samples industries 2x/month and determines limit
violations via a monthly average. The POTW follows guidelines set in state Pretreatment regulations, ERP, and IUPs.
52. Does the POTW use the Division's model inspection form or equivalent? ® Yes ❑ No
If no, does the POTW form include all Division data? ❑ Yes ❑ No
53. Were all SIUs evaluated for the need of a slug/spill control plan during their most recent inspections? ® Yes ❑ No
If no, Explain.
54. What criteria are used to determine if a slug/spill control plan is needed?
Type of materials used in processing.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
The POTW compares the plan to what is observed during an inspection.
56. How does the POTW decide where the sample point for an SIU should be located?
The POTW samples at the point where the process water leaves the plant but before joining the main line.
57. Has the POTW established a procedure to ensure that representative samples will be taken by the POTW or SIU each time?
(example: correct location; proper programming of sampler; clean equipment; swirling the sample bucket uniformly)
POTW: ® Yes ❑ No SIU: ❑ Yes ® No If yes, Explain. The SIU does not sample. The OOTW collects a
sample from the same manhole each time and uses a POTW-owned composite sampler.
58. Who performs sample analysis for the POTW for Metals TBL
Conventional Parameters TBL
Organics TBL
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Forms must be legibly completed in full including test type, container size, time/date, and sampler. Samples should be
properly relinquished and received with signature and date.
Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis (HWA)
60a. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑ NO
60b. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ® YES ❑ NO *See Comment
60c. Is LTMP/STMP Data Maintained in Table or Equivalent? ® YES ❑ NO Is Table Adequate? ® YES ❑ NO
60d. All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? ® YES ❑ NO Division Inspector, verify yourself!
60e. If NO to any above, list violations
60f. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ® NO
If yes, which ones? Eliminated: Added:
61. Do you complete your own headworks analysis (HWA) ? ❑ Yes ® No
If no, who completes your HWA? Lisa Osthues Email: [e-mail]
62. Do you have plans to revise your HWA in the near future? ® Yes ❑ No
If yes, what is the reason for the revision? (mark all that apply) ❑Increased average flow ❑NPDES limits change
❑More LTMP data available ['Resolve over allocation ®5 year expiration ['Other
Explain.
63. In general, what is the most limiting criteria of your HWA? ®Inhibition ❑ Pass Through ['Sludge Quality
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 4

64. Do you see any way to increase your loading in the future (Example: obtaining more land for sludge disposal)? ® Yes ❑ No
Explain. Planned hydraulic expansion of the WWTP.
Summary
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
Expansion of the plant may necessitate changes to the pretreatment program in terms of Headworks Analysis etc.
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 5

INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION
66. User Name
1. Steven Roberts Original
Desserts
2.
3.
67. IUP Number
002
68. Does File Contain Current Permit?
// Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
69. Permit Expiration Date
2/29/24
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
N/A
71. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date? Previous application was approx. a month
before expiration.
❑ Yes /1 No
❑ Yes ❑ No
❑ Yes ❑ No
72. Does File Contain Inspection Completed Within Last Calendar Year?
i1 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
73. a. Does File Contain Slug/Spill Control Plan? Requires updates
b. If No, is 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
74. 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
75. a. Does File Contain Original Permit Review Letter from Division?
b. All Issues Resolved?
a. Yes •No
b.❑Yes❑No®N/A
a. •Yes ■No
b.❑Yes❑No❑N/A
a. •Yes •No
b.❑Yes❑No❑N/A
76. During Most Recent Semi -Annual Period, Did POTW Complete its
Sampling as Required by IUP, including Flow?
i1 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
/1 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
78. During Most Recent Semi -Annual Period, Did SIU Complete its
Sampling as Required by IUP, including Flow?
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
79. During Most Recent Semi -Annual Period, Did SIU submit all reports on
time?
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
80a. For categorical IUs 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
80b. For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
81. During Most Recent Semi -Annual Period, Did POTW Identify All
Limits Non -Compliance from Both POTW and SIU Sampling?
/1 Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
82. During Most Recent Semi -Annual Period, Did POTW Identify All
Reporting Non -Compliance from SIU Sampling?
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
83. a. Was 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 and obtain results within 30 days of
becoming aware of SIU limit violations in the POTW's sampling of 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
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
❑ Yes 0 No
❑ Yes ❑ No
❑ Yes ❑ No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
Specified in POTW's ERP (NOVs, Penalties, timing, etc.)?
®Yes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
86. Does File Contain Penalty Assessment Notices?
®Yes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
87. Does File Contain Proof Of Penalty Collection?
®Yes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
88. a. Does 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
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
Information For You?
❑ Yes /1 No
❑ Yes ❑ No
❑ Yes ❑ No
FILE REVIEW COMMENTS:
NC DWR Pretreatment Audit Form Revised: December 2016
Page 6

INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
INICIO I0 12 17 11 I0 13 17 I31 1191
1. Industry Inspected: Steven Roberts Original Desserts
2. Industry Address: 701 S. Jans St. Pembroke NC 28372
3. Type of Industry/Product: Food
4. Industry Contact: Archie McMillian Title: Sanitation Manger Phone: [phone]
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:
• The SIU did not have a copy of the Enforcement Response Plan (ERP). Please send a digital copy to Steven Roberts.
• The emergency contacts in the Spill Control Plan needs to be updated and signed by the current plant manager.
• An oil storage tank was leaking during the inspection. The facility was aware, leaked oil was within secondary
containment.
• A flow meter was broken at the time of the inspection.
• Two barrels of sanitizing chemicals were hanging over the lip of the containment pallets.
Audit SUMMARY AND COMMENTS:
Audit Comments:
• Quarterly sampling resumes in August.
• The ORC and Pretreatment Consultant were knowledgeable and well -organized. POTW staff performs an excellent job
of maintaining records and rapport with SIUs.
• Lisa Osthues was contracted to complete the Headworks Analysis for the POTW.
• Twice monthly sampling is performed by the POTW. None is conducted by Steven Charles.
Requirements:
• Industries must submit a permit renewal application at least 180 days before the current permit expires.
• The SIU did not have a copy of the Enforcement Response Plan (ERP). Please send a digital copy to Steven Roberts.
• Please follow-up with Steven Roberts regarding an updated Spill Control Plan if they do not contact you within 60 days.
Recommendations: Submit a copy of detection limits for STMP parameters to the contract lab to ensure they are aware of the
minimum detection level requirements.
NOD: ❑ Yes ® No
NOV: ❑ Yes ® No
QNCR: ❑ Yes ® No
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 7

POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory ❑
Audit COMPLETED BY: Stephanie Zorio DATE: 6/8/22
Fayetteville Regional Office
NC DWR Pretreatment Audit Form
Revised: December 2016 Page 8