NC0024201_pretreatment Compliance Inspection_20221122

DocuSign Envelope ID: F2C50C85-934B-440E-A98B-2ED3103B1DDA
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Danieley Brown, CEO
Roanoke Rapids Sanitary District
PO Box 308
Roanoke Rapids, North Carolina 27870
NORTH CAROLINA
Environmental Quality
November 22, 2022
Subject: Pretreatment Compliance Inspection
Roanoke Rapids Sanitary District (RRSD)
NPDES Permit No. NC0024201
Halifax County
Dear Mr. Brown:
On August 26, 2022, Cheng Zhang of the Raleigh Regional Office, Division of Water Resources
conducted a Pretreatment Compliance Inspection of the Roanoke Rapids Sanitary District's Pretreatment
Program. The assistance of Ms. Isabelle Wilcoxon, the Pretreatment Coordinator, was greatly
appreciated as it facilitated the inspection process. The inspection report is attached. Findings during the
inspection were as follows:
1. There are three Significant Industrial Users (Sills), two of which are also Categorical Industrial
Users (CIUs). It was noted that no Sills were in Significant Non -Compliance (SNC) during the
two most recent semi-annual periods.
2. A review of the files containing the pretreatment program elements was conducted. These files
were available and well organized. Update of Sewer Use Ordinance was submitted to the
Division on August 22, 2022 and is in review. It is recommended that the Long Term
Monitoring Plan (LTMP) be updated by using the updated PQLs for nickel and selenium.
3. The review of LTMP data indicated that all locations were sampled with required frequencies
and detection limits since last inspection.
4. The pretreatment inspection file review included Rosemary Power Station (Permit No. 0007),
Reser's Fine Food (Permit No. 0009), and Kennametal (Permit No. 0002). The files needed for
review were available for inspection, contained the required elements and were in good
condition. The POTW completed all required sampling. Rosemary has no flow in 2022.
Kennametal and Reser's Fine Food completed their monitoring and submitted monitoring reports
on time as required by the Industrial User Pretreatment Permits (IUPs). During the first semi-
annual period of 2022, Kennametal was in compliance. Reser's Fine Food had one cBOD
violation in June 2022. The POTW took appropriate enforcement actions per Enforcement
Response Plan (issuance of Notice of Violation and civil penalty assessment). At the time of
inspection, all three IUPs were renewed in June 2022, however, renewed IUPs were not
D_E Q 1
NORTH CAROLINA
DeperhneM of Environmental Oual�
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office I 3800 Barrett Drive I Raleigh, North Carolina 27609
919.791.4200

DocuSign Envelope ID: F2C50C85-934B-440E-A98B-2ED3103B1DDA
submitted to the Division for review. The facility submitted Kennametal and Reser's IUPs
to the Division on August 26, 2022, which were approved on October 24, 2022. Please
submit Rosemary's IUP renewal to the Division for review and approval within 30 days of
receipt of this letter.
The Roanoke Rapids Sanitary District's pretreatment program is well managed. 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]).
Enclosure: Roanoke Rapids Sanitary District PCI Inspection Form
CC: Laserfiche
Isabelle Wilcoxon, RRSD (electronic copy only)
D_E
NORTH CARCLINA
gaparhnanl of Environmental quality
Sincerely,
DocuSigned by:
bL1ssB(l.atAktt,L
B2916E6AB32144F...
Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11611 Mail Service Center I Raleigh, North Carolina 27699-1611
919.707.9000

DocuSign Envelope ID: F2C50C85-934B-440E-A98B-2ED3103B1DDA
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: Roanoke Rapids Sanitary District
2. Control Authority Representative(s): Isabelle Wilcoxon
3. Title(s): Pretreatment Coordinator
4. Last Inspection Date: 12/5/2019 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 MM/DD/YY
1 NICI0 L0 12141210111 J08I26I221
7. Current Number Of Significant Industrial Users (SIUs)?
3
8. Number of SIUs With No IUP, or With an Expired IUP?
2
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?
TSS, 3/2021, 2/2021 (minor exceedances)
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
❑ YES /1 NO
Limits: None
Reporting: None
fished: None
Reser's on consent order
❑ 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 effluent data reported on Discharge Monitoring Report? ® YES ❑ NO Division Inspector, please verify yourself!
26. IfNO to 23 - 26, list violations
❑ NO
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

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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)
5/1/2019
0 Yes ❑ No
11/5/2019
r Yes ❑ No
7/1/2025
Industrial Waste Survey (IWS)
12/20/2017
' Yes ❑ No
1/18/2018
/1 Yes ❑ No
2/1/2023
Sewer Use Ordinance (SUO)
8/22/2022
/1 Yes ❑ No
10/21/2011
/1 Yes ❑ No
Enforcement Response Plan (ERP)
1/28/2020
/1 Yes ❑ No
2/5/2020
/1 Yes ❑ No
Long Term Monitoring Plan (LTMP)
11/20/2019
a Yes ❑ No
2/23/2017
/1 Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION
29. User Name
1. Rosemary Power Station
2. Kennametal
3. Reser's Fine Food
30. IUP Number
0007
0002
0009
31. Does File Contain Current Permit?
/1 Yes ❑ No
/1 Yes ❑ No
/1 Yes ❑ No
32. Permit Expiration Date
5/31/2027
5/31/2027
5/31/2027
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
423.17
471.J
N/A
34. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?
/1 Yes ❑ No
@ Yes ❑ No
A Yes ❑ No
35. Does File Contain an Inspection Completed Within Last Calendar Year?
/1 Yes ❑ No
r Yes ❑ No
11 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. ►1Yes •No
b. •Yes ■No
a. ►NYes •No
b. •Yes •No
a. AYes •No
b. •Yes •No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
Organic Management Plan (TOMP)?
❑Yes❑NoNN/A
❑Yes❑NoNN/A
❑Yes❑NoNN/A
38. a. Does File Contain Original Permit Review Letter from the Division?
b. All Issues Resolved?
a. •Yes ANo
b.❑Yes❑No❑N/A
a. ►NYes •No
b.❑Yes ❑No❑N/A
a. AYes •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❑NoNN/A
// Yes ❑ No
11 Yes ❑ No
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
❑Yes❑NoNN/A
/1 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❑NoNN/A
®Yes❑No❑N/A
®Yes❑No❑N/A
41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports
on time?
❑Yes❑NoNN/A
NYes❑No❑N/A
®Yes❑No❑N/A
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
file include process/dilution flows as Required by IUP?
❑Yes❑NoNN/A
❑Yes❑NoNN/A
❑ Yes ❑NoNN/A
42b. For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
❑Yes❑NoNN/A
❑Yes❑NoNN/A
❑Yes❑NoNN/A
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Limits Non -Compliance from Both POTW and SIU Sampling?
❑Yes❑NoNN/A
❑Ycs❑NoNN/A
11 Yes ❑ No
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
All Reporting Non -Compliance from SIU Sampling?
❑Yes❑NoNN/A
❑Yes❑NoNN/A
❑Yes❑NoNN/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
of SIU limit violations in the POTW's sampling of the SIU?
a.❑Yes❑NoNN/A
b.❑Yes❑NoNN/A
o ❑Yes❑No®N/A
a.❑Yes❑NOON/A
b.❑Yes❑NoON/A
c.❑Yes❑No®N/A
a.®Yes❑No❑N/A
b.El Yes ❑No❑N/A
c.❑Yes❑NoDN/A
46. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
❑
Yes
/1
No
❑
Yes
r
No
❑
Yes
I
No
47. During the Most Recent Semi -Annual Period, Was Enforcement Taken
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
❑Yes❑NoNN/A
❑Yes❑NoNN/A
NYes❑No❑N/A
48. Does the File Contain Penalty Assessment Notices?
❑Yes❑NoNN/A
❑Yes❑NoNN/A
NYes❑No❑N/A
49. Does The File Contain Proof Of Penalty Collection?
❑Yes❑NoNN/A
❑Yes❑NoNN/A
NYes❑No❑N/A
50. a. Does the File Contain Any Current Enforcement Orders?
b. Is SIU in Compliance with Order?
a.❑Yes ❑NoNN/A
b.❑Yes❑No®N/A
a.❑Yes❑No®N/A
b.❑Yes ❑NoNN/A
a.El 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?
❑ Yes /1 No
❑ Yes L No
❑ Yes /1 No
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DocuSign Envelope ID: F2C50C85-934B-440E-A98B-2ED3103B1DDA
FILE REVIEW COMMENTS:
38 — At the time of inspection, all IUPs were renewed, however, renewed IUPs were not submitted to the Division for review. The
facility submitted Kennametal and Reser's IUPs to the Division on August 26, 2022, which were approved on October 24, 2022.
39 and 41 — Rosemary has no flow in 2022.
43a — Reser's Fine Food had one cBOD violation from SIU sampling on June 15, 2022.
47 & 48 — POTW issued a NOV with civil penalty assessment ($225) on July 17, 2022.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
1 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 was well managed
Requirements: Submit Rosemary's renewed IUP to the Division for review and approval.
Recommendations: Update LTMP by using the updated PQLs for nickel and selenium.
NOD: ❑ YES ® NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ® NO
POTW Rating:
Satisfactory ® Marginal ❑ UnSatisfactory
PCI COMPLETED BY: Cheng Zhang, DWR Raleigh Regional Office DATE: August 26, 2022
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3