NC0020559_Pretreatment Audit_20231010

DocuSign Envelope ID: C1 C501A8-7E1 1-4086-88F6-743EC3A25296
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
E. Terrell Blackmon, City Manager
City of Henderson
P.O. Box 1434
Henderson, NC 27536
Subject: Pretreatment Audit
NORTH CAROLINA
Environmental Quality
October 10, 2023
City of Henderson Water Reclamation Facility
NPDES Permit No. NCO020559
Vance County
Dear Mr. Blackmon:
On September 19, 2023, Cheng Zhang of the Raleigh Regional Office (RRO) conducted a
Pretreatment Audit of City of Henderson's pretreatment program. The assistance given by Mr.
Brandon Elliott, the Pretreatment Coordinator and Mr. Darrel Johnson, the former 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.
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. Update of Headwork
analysis was submitted to the Division on March 2, 2022, which is still in review by the
division.
4. Mars Petcare's pretreatment file (Permit No. 0011) was reviewed during the inspection.
During the first semi-annual period of 2023, the SIU had one TKN violation from POTW
sampling in May 2023. The POTW resampled the parameter and issued a Notice of
Violation and civil penalty assessment in August 2023. It was noted that both POTW
resampling and enforcement action were outside the required timeframe (within 30
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office I 3800 BarrettDrive I Raleigh, North Carolina 27609
NORTH CAROLINA ^ 919.791.4200
n�,Mo E,Amnm W1 Q. 1K,

DocuSign Envelope ID: C1 C501A8-7E1 1-4086-88F6-743EC3A25296
days). It was also noted that the POTW failed to inspect Mars Petcare in 2022, but
conducted additional inspection in May 2023.
5. During the audit, the inspector watched Mr. Elliott and Mr. Johnson inspect the lone SAT, Mars
Petcare. The inspection was thorough and covered all the required areas.
Thank you for your continued support of the Pretreatment Program. If you have questions
regarding the attached report or any of the findings, please contact Cheng Zhang at 919-791-
4200 (or email: [e-mail]).
Sincerely,
Docuftned by:
Vaunt,SSa. f.
62916HAB32144F...
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)
Brandon Elliot - City of Henderson (electronic copy only)
D � ��� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CAROLINA ��` 919.707.9000
nnpn .mo EnWromm�nfal nual

DocuSign Envelope ID: C1 C501A8-7E1 1-4086-88F6-743EC3A25296
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: City of Henderson
2. Control Authority Representative(s): Brandon Elliott
3. Title(s): Pretreatment Coordinator
4. Address of POTW:
Mailing PO Box 1434
City Henderson Zip Code 27536
Phone Number 252-431-6085 Fax Number 252-492-3324 E-Mail BrandonElliott(a,henderson.nc.gov
5. Audit Date 09/19/2023
6. Last Inspection Date: 08/24/2021 Inspection Type: ® PCI ❑ Audit
7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s) ? ®Yes❑No
8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? ®Yes❑No
If Yes, Explain. NH3, May 2022; Failed toxicity test, October 2022
9. Is POTW under an Order That Includes Pretreatment Conditions? ❑ Yes ® No
Order Type and Number: Are Milestone Dates Being Met? ❑Yes❑NoON/A
Parameters Covered Under Order
ICIS Coding
Main Program Permit Number
INICI0I0I2I0 Is I5I9 I
MM/DD/YY
109 119 123
10.
....................................................................................................................................................................................................................................................................................................
Current Number of Significant Industrial Users (SIUs)?
1
11.
....................................................................................................................................................................................................................................................................................................
Number of SIUs with No IUP, or with an Expired IUP?
0
12. Number of SIUs Not Inspected by POTW in Last Calendar Year?
.......................................... .................................................................................................................................................................
0
13.
..........................................
Number of SIUs Not Sampled by POTW in Last Calendar Year?
.......................................................................................................................................................
0
14.
....................................................................................................................................................................................................................................................................................................
Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi -Annual Periods?
0
15.
....................................................................................................................................................................................................................................................................................................
Number of SIUs in SNC for Reporting During Either of Last 2 Semi -Annual Periods?
0
16.
....................................................................................................................................................................................................................................................................................................
Number of SIUs in SNC with Pretreatment Schedule?
0
17.
....................................................................................................................................................................................................................................................................................................
Number of SIUs on Schedules?
0
18.
Current Number of Categorical Industrial Users (CIUs)?
0
19.
Number of CIUs in SNC?
0
NC DWR Pretreatment Audit Form Revised: December 2016
Page 1

DocuSign Envelope ID: C1 C501A8-7E1 1-4086-88F6-743EC3A25296
20. PRETREATMENT PROGRAM ELEMENTS REVIEW- Review POTW files, verify POTW has copy of each Program Element
in their File. complete with all suDDortinc documents and PERCS ADDroval 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)
3/2/2022
® Yes ❑ No
6/15/2017
® Yes ❑ No
4/1/2022
Industrial Waste Survey (IWS)
4/14/2022
® Yes ❑ No
3/2/2023
® Yes ❑ No
4/30/2027
Sewer Use Ordinance (SUO)
11/9/2012
® Yes ❑ No
11/19/2012
® Yes ❑ No
Enforcement Response Plan (ERP)
1/24/2020
® Yes ❑ No
2/12/2020
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
12/11/2019
® Yes ❑ No
2/14/2020
® 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
22. If yes to #21, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? ❑Yes❑NoON/A
23. If yes to #21, Have you had any trouble working with these towns or districts? ❑Yes❑NoON/A
24. Date of Last SUO Adoption by Local Council 5/13/2013
25. Have you had any problems interpreting or enforcing any part of the SUO? ❑Yes®No
Enforcement (Enforcement Response Plan-ERP)
26. Did you send a copy of the ERP to your industries? ® Yes ❑ No
Copies of transmittal letters to SIUs in file.
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=Satisfactory M=Mareinal U=Unsatisfactory
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
Lab techs assist with sampling
POTW's Pretreatment Program
®S ❑M ❑U
Access to POTW Vehicles for
®S ❑M ❑U
Dedicated van
Sampling, Inspections, and
Emergencies
Access to Operable Sampling
®S ❑M ❑U
4 portable samplers available. SIUs required to provide
Equipment
refrigerated sampler
Availability of Funds if Needed for
®S ❑M ❑U
Additional Sampling and/or Analysis
Reference Materials
®S ❑M ❑U
Internet access
Staff Training (i.e. Annual and
®S ❑M ❑U
Regional Workshops, Etc.)
Computer Equipment (Hardware and
®S ❑M ❑U
Dedicated server on stie
Software)
30. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No
NC DWR Pretreatment Audit Form Revised: December 2016 Page 2

DocuSign Envelope ID: C1 C501A8-7E1 1-4086-88F6-743EC3A25296
Explain Yes or No. - Excel
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Annual fees — assessed 1/1211 of fee each month when City sends monthly reports; sampling fees, permitting fees. Fees are
voted on and approved by City Council.
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? All public records so would meet in conference room
with requested files.
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. Trade secret. Information kept in separate locked file cabinet.
35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? Yes, if they have a
request for modification.
36. Is the public notified about changes in the SUO or Local Limits? ® Yes ❑ No — posted on the City's website
37. Were all industries in SNC published in the last notice ❑Yes❑NoON/A —SILT not in SNC for 2022.
Permitting (Industrial Waste Survey-IWS)
38. How does the POTW become aware of new or changed Users? TRC Committee reviews request for new businesses.
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?) Short form survey; review water usage; follow-up with long form or inspection as needed.
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
❑ Yes ® No
41. Does the POTW accept waste by (mark if applicable) ® Truck ❑Dedicated Pipe ❑ NA
Occasionally will accept pump and haul (Novozymes, as needed)
42. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples drawn,
manifests required) The City only accepts pump and haul from Novozymes, sampling results available from
Novozymes.
43. How does the POTW allocate its loading to industries? Mark all that apply
❑ Uniform Limits ® Historical Industry Need ® By Surcharge ❑ Categorical Limits ❑ Other
44. Review POTW's copies of current allocation tables for each WWTP. Are there any over allocations? ❑ Yes ® No
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 50 % of the MAIL
47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) ❑ Yes ® No
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)
NPDES POCs, oil & grease, metals, IU specific
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Impact to plant, Surcharge parameters monthly.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 3

DocuSign Envelope ID: C1 C501A8-7E1 1-4086-88F6-743EC3A25296
Permit Compliance
50. Does the POTW currently have or during the past year had any permits under adjudication? ❑ Yes ® No
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. Data entered into spreadsheet as it is received. Violations flagged.
Reports are date stamped when received
52. Does the POTW use the Division's model inspection form or equivalent? ® Yes ❑ No
53. Were all SIUs evaluated for the need of a slug/spill control plan during their most recent inspections? ® Yes ❑ No
54. What criteria are used to determine if a slug/spill control plan is needed?
SIUs are required to have one
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Mainly if contact numbers are correct
56. How does the POTW decide where the sample point for an SILT should be located?
Try to get process wastewater only. A permanent sampling station is required.
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 — same 2 people perform sampling SIU: Mars uses MicroBact; discussed sampling SOP at inspection
58. Who performs sample analysis for the POTW for Metals Merritech
Conventional Parameters In house
Organics Merritech
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Internal form notes when sample transferred to Merritech. Merritech COCs kept in lab.
Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis (HWA)
60a.
60b.
60c.
60d.
60e.
60f.
Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® Yes ❑ No
Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ® Yes ❑ No
Is LTMP/STMP Data Maintained in Table or Equivalent? ® Yes ❑ No Is Table Adequate? ® Yes ❑ No
All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? ® Yes ❑ No
If NO to any above, list violations
Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ Yes ® No
61. Do you complete your own headworks analysis (HWA) ? ® Yes ❑ No
62. Do you have plans to revise your HWA in the near future? ❑Increased average flow ❑NPDES limits change
❑More LTMP data available ❑Resolve over allocation ®5 year expiration ❑Other
Explain. Currently under review
63. In general, what is the most limiting criteria of your HWA? ❑Inhibition ® Pass Through ❑Sludge Quality
64. Do you see any way to increase your loading in the future (Example: obtaining more land for sludge disposal)? ® Yes ❑ No
Working on plant operations to improve removal rate for BOD
Summary
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
❑ Yes ® No
NC DWR Pretreatment Audit Form Revised: December 2016 Page 4

DocuSign Envelope ID: C1 C501A8-7E1 1-4086-88F6-743EC3A25296
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION)
66.
User Name
1. Mars Pet Care
2.
3.
67.
IUP Number
0011
68.
Does File Contain Current Permit?
® Yes ❑ No
69.
Permit Expiration Date
4/3/2027
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
® Yes ❑ No
to Permit Issue Date?
72.
Does File Contain Inspection Completed Within Last Calendar Year?
❑ Yes ®No
73.
a. Does File Contain Slug/Spill Control Plan?
a. ®Yes []No
b. If No, is One Needed? See Inspection Form from POTW)
b. [-]Yes [-]No
74.
For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
❑Yes❑No®N/A
Organic Management Plan (TOMP)?
75.
a. Does File Contain Original Permit Review Letter from Division?
a. ®Yes ❑No
I
b. All Issues Resolved?
b.❑Yes❑No®N/A
76.
During Most Recent Semi -Annual Period, Did POTW Complete its
® Yes ❑ No
Sampling as Required by IUP, including Flow?
77.
Does File Contain POTW Sampling Chain -Of -Custody Forms?
® Yes ❑ No
78.
During Most Recent Semi -Annual Period, Did SIU Complete its
®Yes❑No❑N/A
F
Sampling as Required b IUP, includingFlow?
11
79.
During Most Recent Semi -Annual Period, Did SIU submit all reports on
®Yes❑No❑N/A
I
F
time?
80a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑No®N/A
file includeprocess/dilution flows as Required by IUP?
80b. For categorical IUs with Production based limits, does file include
❑Yes❑No®N/A
production rates and/or flows as Required by IUP?
81.
During Most Recent Semi -Annual Period, Did POTW Identify All
®Yes❑No❑N/A
Limits Non -Compliance from Both POTW and SIU Sampling?
82.
During Most Recent Semi -Annual Period, Did POTW Identify All
❑Yes❑No®N/A
Re ortin Non -Compliance from SIU Sampling?
83. a. Was POTW Notified by SIU (Within 24 Hours) of All Self-
a.❑Yes❑NosN/A
Monitoring Violations?
b. Did Industry Resample and submit results to POTW within 30 Days?
b.®Yes❑No❑N/A
c. If applicable, did POTW resample and obtain results within 30 days of
c.®Yes❑No❑N/A
becoming aware of SIU limit violations in the POTW's sampling of SIU?
84.
During Most Recent Semi -Annual Period, Was SIU in SNC?
❑
Yes
®
No
85.
During Most Recent Semi -Annual Period, Was Enforcement Taken as
®Yes❑No❑N/A
Specified in POTW's ERP (NOVs, Penalties, timing, etc.)?
86.
Does File Contain Penalty Assessment Notices?
®Yes❑No❑N/A
87.
Does File Contain Proof Of Penalty Collection?
OYes❑No❑N/A
88.
a. Does File Contain Any Current Enforcement Orders?
a.❑Yes❑NosN/A
b. Is SIU in Compliance with Order?
b.❑Yes❑NosN/A
89.
Did POTW Representative Have Difficulty in Obtaining Any Requested
❑ Yes ® No
Information For You?
FILE REVIEW COMMENTS:
72 — The POTW failed to inspect Mars Pet Care in 2022, but made a makeup inspection on May 19, 2023.
81 — Mars Pet Care had one TKN violation from POTW sampling in May 2023
85 — The POTW issued a NOV and assessed $50 civil penalty to Mars Pet Care on August 20, 2023, and resampled TKN in August.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 5

DocuSign Envelope ID: C1 C501A8-7E1 1-4086-88F6-743EC3A25296
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
I N I C 1 0 I0 I2 I0 I5 I5 I9 I I09 I19 I23
1. Industry Inspected: Mars Pet Care
2. Industry Address: 845 Commercial Drive, Henderson 27537
3. Type of Industry/Product: Pet food
4. Industry Contact: Sam Scherff, HSE Manager
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:
Very thorough industrial inspection
Audit SUMMARY AND COMMENTS:
Audit Comments: Organized files. Very thorough industrial inspection.
Requirements:
Recommendations: Take enforcement against violations within the timeframe specified in the ERP.
NOD: ❑ Yes ® No
NOV: ❑ Yes ® No
QNCR: ❑ Yes ® No
POTW Rating:
Satisfactory ❑ Marginal ® Unsatisfactory ❑
Audit COMPLETED BY: Chen2 Zhan2, RRO DATE: 9/19/2023
NC DWR Pretreatment Audit Form Revised: December 2016 Page 6