NC0003450_NOV-2023-PC-0216 for PCI_20230517

DocuSign Envelope ID: 09EE4F46-401 B-4DDE-921 E-14F436185F36
ROY COOPER
Governor
ELIZABETH BISER
Secretary
RICHARD E. ROGERS, JR. NORTH CAROLINA
Director Errv0r0rrm#rrt&1 Quniiry
May 22, 2023
Lisa Cottle, Pretreatment Coordinator
Town of Wallace
316 East Murray Street
Wallace, NC 28466
Subject: Notice of Violation
Pretreatment Compliance Inspection
Town of Wallace
NPDES Permit No. NC0003450
Duplin County
Tracking No. NOV-2023-PC-0216
Dear Ms. Cottle:
Enclosed is a copy of the Pretreatment Compliance Inspection (PCI) Report for the Town of
Wallace's approved Industrial Pretreatment Program on May 10, 2023, by Helen Perez of this
Office.
This report is being issued as a Notice of Violation (NOV) due to the Town's failure to properly
implement the Pretreatment Program. Specifically, the Town failed to initiate enforcement
according to the Division -approved ERP due to the Town of Burgaw's unpermitted discharge
and failure to submit a SIU application by the due dates. Please respond in writing within thirty
30 days after receipt of this Notice regarding your plans or measures to be taken to address
the indicated violations.
127 Cardinal Drive Extension, Wilmington, North Carolina 28405
Phone: [phone]\ Internet: www.deg.nc.gov

DocuSign Envelope ID: 09EE4F46-401 B-41DDE-921 E-14F436185F36
If you should have any questions, please do not hesitate to contact Helen Perez at (910) 796-
7306 or at [e-mail] .
Sincerely,
DocuSigned by: I
E
�0 �-,,j, 1 i,
855460F62DE
Morella Sanchez -King, Regional Supervisor
Water Quality Regional Operations Section
Wilmington Regional Office
Division of Water Resources, NCDEQ
Cc: Robert Taylor — electronic copy
Upload to Laserfiche

DocuSign Envelope ID: 09EE4F46-401 B-4DDE-921E-14F436185F36
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 Wallace
2. Control Authority Representative(s): Lisa Cottle
3. Title(s): WWTP Superintendent, Pretreatment Coordinator
4. Last Inspection Date: 09/16/2020 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:
ICIS CODING
Main Program Permit Number
N I C 1 0 10 10 13 1 4 15 10 1
MM/DD/YY
1 05 1 10 1 2023 1
Are Milestone Dates Being Met? ❑ YES ❑ NO
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?
1
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 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 Put
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
*comment
® YES [:]NO
*comment
Limits: N/A
Reporting: N/A
dished: N/A
N/A
❑ 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 *comment
24. Is LTMP/STMP Data Maintained in a Table or Equivalent? ❑ YES ® NO Is Table Adequate? ❑ YES ❑ NO *comment
25. All LTMP/STMP effluent data reported on Discharge Monitoring Report? ® YES ❑ NO Division Inspector, please verify
yourself!
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1

DocuSign Envelope ID: 09EE4F46-401 B-4DDE-921E-14F436185F36
If NO to 23 - 26, list violations
26.
27.
Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ❑ NO *comment
If yes, which ones? Eliminated: Added:
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

DocuSign Envelope ID: 09EE4F46-401 B-4DDE-921E-14F436185F36
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)
01/08/2021
® Yes ❑ No
*comment
❑ Yes ❑ No
Industrial Waste Survey IWS
04/15/2021
® Yes ❑ No
05/03/2021
® Yes ❑ No
04/22/2026
Sewer Use Ordinance SUO
05/24/2021
® Yes ❑ No
09/20/2021
® Yes ❑ No
Enforcement Response Plan (ERP)
05/28/2020
® Yes ❑ No
08/18/2020
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
07/15/2011
® Yes ❑ No
07/18/2011
® Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW 3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION
29. User Name
1. Darling Ingredients, Inc
2. IF
3.
30. IUP Number
TOW-
001
31. Does File Contain Current Permit?
® Yes ❑ NoI
❑ Yes ❑ No
❑ Yes ❑ No
32. Permit Expiration Date
04/18/2026
33. Categorical Standard Applied I.E. 40 CFR, Etc. Or N/A
N/A
34. Does File Contain Permit Application Completed Within One Year Prior
® Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
to Permit Issue Date?
35. Does File Contain an Inspection Completed Within Last Calendar Year?
® Yes ElNo
El Yes El No
❑Yes ❑ No
36. a. Does the File Contain a Slug/Spill Control Plan?
a. ®Yes ❑No
a. ❑Yes ❑No
a. ❑Yes ❑No
b. If No, is One Needed? (See Inspection Form from POTW)
b. ❑Yes ❑No
b. ❑Yes []No
b. ❑Yes ❑No
*comment
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑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
a. ❑Yes []No
b. All Issues Resolved?
b.❑Yes❑No®N/A
b.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
❑ Yes ® No
❑ Yes ❑ No
l IF1
❑Yes ❑ No
its Sampling as Required b IUP, includingflow?
*comment
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
I ❑ Yes ® N=ol
❑ Yes ❑ No
❑ Yes ❑ No
41. During the Most Recent Semi -Annual Period, Did the SIU Complete itsYes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
flow?
Sampling as Required b IUP, includingP
*comment
41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports
®Yes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
on time?
42a. For categorical LUs with Combined Wastestream Formula (CWF), does
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
file includeprocess/dilution flows as Required by IUP?
42b. For categorical IUs with Production based limits, does file include
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
production rates and/or flows as Required by IUP?
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑ Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
All Limits Non -Compliance from Both POTW and SIU Sampling?
N/A
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
®Yes❑No❑N/A
❑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
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
b.❑Yes❑No❑N/A
c. If applicable, Did POTW resample within 30 days of becoming aware
of SIU limit violations in the POTW's sampling of the SIU?
c.❑Yes❑No®N/A
c.❑Yes❑No❑N/A
c.❑Yes❑No❑N/A
46. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
I
❑
Yes
®No
❑
Yes
❑
No
I
❑
Yes
❑
No
47. During the Most Recent Semi -Annual Period, Was Enforcement Taken
❑Yes❑NoON/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
as Specified in the POTW's ERP OVs, Penalties, timing, etc.)?
48. Does the File Contain Penalty Assessment Notices?
❑Yes❑No®N/A
❑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
❑Yes❑No❑N/A
50. a. Does the File Contain Any Current Enforcement Orders?
a.❑Yes❑No®N/A
a.❑Yes❑No❑N/A
a.❑Yes❑No❑N/A
b. IS SILT in Compliance with Order?
b.❑Yes❑No®N/A
b.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
51. Did the POTW Representative Have Difficulty in Obtaining Any of This
I [—]Yes ® No
❑ Yes ❑ No
❑ Yes ❑ No
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3

DocuSign Envelope ID: 09EE4F46-401 B-4DDE-921 E-14F436185F36
Requested Information For You?
FILE REVIEW COMMENTS:
17. Limit violations since the last PCI (09/16/2020):
6/21 BOD
7/21 BOD, Ammonia
8/21 BOD, Ammonia, DO
9/21 BOD, Ammonia
10/21 BOD, Ammonia
12/21 BOD
1/22 BOD
4/22 BOD
6/22 BOD, Ammonia
10/22 DO
There has been an upgrade to the diffusers to address the BOD and Ammonia non-compliance issues.
18. An upset occurred on 09/30/22 at the Wallace WWTP because of high BOD and TSS from a permitted SIU under the Town of
Burgaw's Pretreatment Program. On 10/O1/22, the DO average was below the daily limit. A letter was sent to Burgaw on 10/11/22 by
the Pretreatment Coordinator designating the Town of Burgaw as a SIU per the Town of Wallace's SUO, section 14-202(a)(47)(h). An
application was enclosed with the letter and due by 01/09/22. Burgaw requested and received an extension to 01/31/23. No application
was received. The Town of Wallace's Manager extended the due date to 04/05/23, but the application was not received until 05/02/23.
23. Correct detection levels were used when analyzed, but the Pretreatment Coordinator is in the process with Envirochem Lab to
revise the lab result reports with the correct unit of measure.
24. The quarterly LTMP data is not in a table format yet. The Town is waiting on the approval of the HWA before constructing a
table.
27. The Town is waiting for the issuance of the permit renewal to evaluate if any POCs should be eliminated from or added to the
LTMP.
28. The HWA was submitted on O1/08/2021 and the Town is waiting for review and approval.
36. The current Spill Control Plan is for pump and haul activities. An updated plan will be needed when the dedicated pipe connection
is constructed.
39. The POTW has not sampled because Darling Ingredients has not sent any flow since receiving their permit. Monthly reports are
submitted as required reporting zero flow.
41. Darling Ingredients has not sampled because they have not sent any flow since receiving their permit. Monthly reports are
submitted as required reporting zero flow.
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 4

DocuSign Envelope ID: 09EE4F46-401 B-4DDE-921E-14F436185F36
INDUSTRY INSPECTION ICIS CODING: N/A
Main Program Permit Number MM/DD/YY
1 1 1 I I I I I I I J
Industry Inspected:
2. Industry Address:
Type of Industry/Product:
4. Industry Contact:
Phone:
Fax:
Title:
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:
SUMMARY AND COMMENTS:
The records reviewed duringthe inspection were organized and well maintained. In regard to comment #18 above: According to the Town of
Wallace's ERP, a NOV should have been issued for the pass -through event from the Town of Burgaw's SIU on September 30, 2022, along
with the notice of SIU designation and permit application requirement. In addition, escalated or continuing enforcement actions should have
been taken for not submitting the permit application by the due dates. Keyes Mcgee and Octavio Henriquez, from the Central Office, were
present during the inspection to discuss the importance of following the Town's SUO and permitting the Town of Burgaw as a SIU with the
Town of Wallace's Manager, Robert Taylor. The Central Office has sent the Pretreatment Coordinator samples of pretreatment programs that
permit satellite programs and surcharge examples for rcfcrcnce.
NOD: ❑ YES ❑ NO
NOV: ® YES ❑ NO
QNCR: ❑ YES ❑ NO
POTW RatinE:
Satisfactory X Marginal Unsatisfactory
DocuSigned by:
F
PCI COMPLETED BY: DATE:
1D645B4A39694BE...
5/22/2023
DocuSigned by:
M.bVLUA SM ' J 5/22/2023
PCI REVIEWED BY: 6554BOFMED464... DATE:
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 5