NC0020605_Pretreatment Compliance Inspection_20231121

DocuSign Envelope ID: 12BFE60E-707C-4815-AOB3-A4C2DA2F3C15
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
November 21, 2023
Via Electronic Mail @[e-mail])
Mr. Jason Nichols, Director of Public Works
Town of Tarboro
PO BOX 220
Tarboro, NC 27886-0220
Subject: Pretreatment Compliance Inspection
Town of Tarboro
Tarboro WWTP - NPDES Permit No. NCO020605
Edgecombe County
Dear Mr. Nichols:
On September 25, 2023, Cheng Zhang of the Raleigh Regional Office (RRO) conducted a
compliance inspection of Town of Tarboro's pretreatment program. The assistance given by Mr.
Kevin Peaden, the WWTP Supervisor, was greatly appreciated. The inspection report is attached.
Findings during the inspection were as follows:
1. The Town has three Significant Industrial Users (SIUs), one is also a Categorical Industrial
User (CIU). It was noted that no SIUs were in SNC for the most recent two semi-annual
periods.
2. A review of the files containing the pretreatment program elements was conducted. These
files were well organized and up to date.
3. Long Term Monitoring Plan (LTMP) data were reviewed during the inspection. It was
noted that all locations were sampled with required frequencies and all samples analyzed
with required detection levels since the last inspection.
4. The pretreatment inspection file review included Johnson Controls (Permit No. TOT-006)
and Sara Lee Frozen Bakery (Permit No. TOT-001), and Mayo Knitting Mill (Permit No.
TOT-003). During the most recent semi-annual period, Sara Lee Frozen Bakery and Mayo
Knitting Mill were in compliance. It was noted that Johnson Control's Industrial User
Permit (IUP) expired on June 24, 2023. The POTW renewed the IUP on October 15,
2023. The POTW submitted the renewed IUP to the Division for review and approval
on November 22, 2023.
NORTH CAROLINAD ���
Depa ,M NE,Amnm W1 Qu IR,
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office 1 3800 Barrett Drive I Raleigh, North Carolina 27609
919.791.4200

DocuSign Envelope ID: 12BFE60E-707C-4815-AOB3-A4C2DA2F3C15
If you have any questions or comments, please call Cheng Zhang at [phone] (or email:
[e-mail]).
Sincerely,
DxuSigned by:
Ua.t,SSa f.
B2916E6AB32144F...
Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources
Enclosure: Town of Tarboro PCI Form
Cc: Central Files (Laserfiche)
Kevin Peaden, Town of Tarboro (Electronic copy only)
Will Larsen ([e-mail]), The Wooten Company (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: 12BFE60E-707C-4815-AOB3-A4C2DA2F3C15
r C'. 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 Tarboro
2. Control Authority Representative(s): Kevin Peaden
3. Title(s): WWTP Supervisor
4. Last Inspection Date: August 30, 2021 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
IN IC 101012 10 16 1 01 51
1
Are Milestone Dates Being Met? ❑ YES ❑ NO
MM/DD/YY
109 125 123
7. Current Number Of Significant Industrial Users (SIUs)?
3
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)?
1
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?
Member of Tar -Pamlico Compliance Coalition
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 Pu
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
Total nitrogen annual load 2022
[I YES ®NO
Limits: None
Reporting: None
blished: None
None
❑ 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
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
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:
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1

DocuSign Envelope ID: 12BFE60E-707C-4815-AOB3-A4C2DA2F3C15
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)
5/2/2018
® Yes ❑ No
6/28/2018
® Yes ❑ No
11/1/2023
Industrial Waste Survey (IWS)
5/29/2019
® Yes ❑ No
7/3/2019
® Yes ❑ No
11/1/2024
Sewer Use Ordinance (SUO)
10/19/2012
® Yes ❑ No
10/22/2012
® Yes ❑ No
Enforcement Response Plan (ERP)
1/2/2020
® Yes ❑ No
2/12/2020
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
7/11/2018
® Yes ❑ No
7/12/2018
® Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name
1. Johnson Controls 2. Sara Lee Frozen Bakery
3. Mayo Knitting Mill
30. IUP Number
TOT-006
TOT-001
I TOT-003
31. Does File Contain Current Permit?
® Yes ❑ No
® Yes ❑ NoI
® Yes ❑ No
32. Permit Expiration Date
6/24/2023
12/31/2026
12/31/2026
33. Categorical Standard Applied I.E. 40 CFR, Etc. Or N/A
433.17
N/A
410.50
34. Does File Contain Permit Application Completed Within One Year Prior
® Yes ❑ No
® Yes ❑ No
F
® Yes ❑ No
to Permit Issue Date?
I
35. Does File Contain an Inspection Completed Within Last Calendar Year?
I ® Yes ❑ No
® Yes ❑ No 11
® 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. [I es []No
b. ❑Yes ❑No
b. []Yes []No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
®Yes❑No❑N/A
❑Yes❑NoEN/A
❑Yes❑NoEN/A
Organic Management Plan TOMP ?
38. a. Does File Contain Original Permit Review Letter from the Division?
a. ®Yes ❑No
a. ®Yes []No
I
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
1 ® Yes ❑ No
® Yes ElNo
its Sampling as Required b IUP, includingflow?
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
® Yes ❑ NoI
® Yes ❑
__1F
No
® Yes ❑
No
41. During the Most Recent Semi -Annual Period, Did the SIU Complete its
❑Yes❑NoEN/A
®Yes❑No❑N/A
❑Yes❑NoEN/A
Sampling as Required by IUP, including flow?
41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports
❑Yes❑NoEN/A
®Yes❑No❑N/A
❑Yes❑NoEN/A
on time?
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑NoEN/A
file include process/dilution flows as Required by IUP?
42b. For categorical IUs with Production based limits, does file include
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑NoEN/A
production rates and/or flows as Required b IUP?
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑NoEN/A
All Limits Non -Compliance from Both POTW and SIU Sampling?
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑NoEN/A
All Reporting_Non-Compliance from SIU Sampling?
44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
a.❑Yes❑NoEN/A
a.❑Yes❑NoEN/A
a.❑Yes❑NoEN/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
c.❑Yes❑NoEN/A
c.❑Yes❑NoEN/A
c.❑Yes❑NoEN/A
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
®
No
❑
Yes
®
No
❑
Yes
®
No
47. During the Most Recent Semi -Annual Period, Was Enforcement Taken
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑NoEN/A
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
48. Does the File Contain Penalty Assessment Notices?
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑NoEN/A
49. Does The File Contain Proof Of Penalty Collection?
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑NoEN/A
50. a. Does the File Contain Any Current Enforcement Orders?
a.❑Yes❑NoEN/A
a.❑Yes❑NoEN/A
a.❑Yes❑NoEN/A
b. Is SIU 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
❑ Yes ®No
ElYes ®No
❑Yes ® No
Requested Information For You?
11
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

DocuSign Envelope ID: 12BFE60E-707C-4815-AOB3-A4C2DA2F3C15
FILE REVIEW COMMENTS:
41— At the time of inspection, Johnson Control's IUP expired on 6/24/2023. The POTW issued the renewed IUP to Johnson Control on
October 15, 2023, and submitted the IUP to the Division for review and approval on November 27, 2023.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
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
❑ 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: Johnson Control's IUP expired on June 24, 2023, the The POTW issued the renewed IUP to Johnson Control on October
15, 2023, and summited the IUP to the Division for review and approval on November 22, 2023.
Requirements: None
Recommendations: Update LTMP by using the updated PQL table
NOD: ❑ YES ® NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ® NO
POTW Rating:
Satisfactory ❑ Marginal ❑ UnSatisfactory
PCI COMPLETED BY: Chen Zhang, Raleigh Regional Office DATE: September 25, 2023
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3