NC0027103_Pretreatment Compliance Inspection_20230928

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Mr. Tyler Thomas, Town Manager
Town of Pembroke
100 Union Chapel Rd
Pembroke, NC 28372
NORTH CAROLINA
Environmental Quality
September 28th, 2023
Subject: Pretreatment Compliance Inspection
Town of Pembroke WWTP
NPDES Permit No. NCO027103
Robeson County
Mr. Thomas:
A Pretreatment Compliance Inspection (PCI) of the Town of Pembroke WWTP's Pretreatment
Program was conducted by Sharon Moran from this office on September 1, 2023, in conjunction
with Jason Deese, ORC of Town of Pembroke WWTP and Charles A. Donnell, Pretreatment
Consultant with Envirolink. The purpose of this PCI is to determine the effectiveness of the
pretreatment program by reviewing various aspects of the program, which included files and
records, industrial user inspections and monitoring data, data management procedures and
adherence to the Enforcement Response Plan.
Town of Pembroke WWTP is currently a 1.33 MGD permitted facility and has one (1) Significant
Industrial User (SIU); Steven Roberts Original Desserts, LLC. One permit file was reviewed:
Steven Roberts Original Desserts, LLC. A site visit was not conducted during this inspection. Mr.
Deese noted during the inspection that the SIU does cause higher amounts of sludge production
than would otherwise occur. The WWTP recovers the cost of the sludge handling with increased
surcharges to the industry. It was noted during the inspection that a copy of the approval letter from
the state for the Sewer Use Ordinance was missing. It is recommended to check with the
Pretreatment Section of the Division to ensure that an approval is on file. All sampling required by
LTMP/STMP is required to be reported on eDMRs for associated months. Please revise eDMR to
include sampling from LTMP/STMP.
The Town of Pembroke WWTP continues to do an effective job of achieving the pretreatment
program goals. The findings and comments noted during this inspection are provided in the
enclosed copy of the audit report. There were no significant issues or findings noted during this
inspection thus a response to this inspection report is not required.
D E Q�� North Carolina Department of Environmental Quality I Division of Water Resources
Fayetteville Regional Office 1 225 Green Street I Suite 714 1 Fayetteville, North Carolina 28301
NORTH CAROLINA -
oeuaronemmemironmemaiauai\ p*O** 910.433.3300

Thank you for your continued support of the North Carolina Pretreatment Program. If you should
have any questions, please contact Sharon Moran at [phone] or at
[e-mail].
Sincerely,
Ek,
-1ed^, • �DocuuSigned by::..
1A96 D6248
Mark ran ey, ssistant Regional Supervisor
Water Quality Regional Operations Section
Fayetteville Regional Office
Division of Water Resources, NCDEQ
Cc: Upload to Laserfiche

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.
2.
3.
4.
5.
6.
Control Authority (POTW) Name:
Control Authority Representative(s):
Title(s):
Last Inspection Date
Town of Pembroke
Charles A Donnell, Jason Deese
Consultant from Envirolink, ORC of Pembroke WWTP
6/8/22 Inspection Type (Check One): ❑ PCI ® Audit
Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? ® YES ❑ NO
Is POTW under an Order That Includes Pretreatment Conditions? ❑ YES ® NO
Order Type, Number, Parameters:
ICIS CODING
Main Program Permit Number
NIC101012171110131
MM/DD/YY
1911123 J
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?
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?
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 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?
EYES ❑ NO
NOD for silver and fecal, flow
violation
EYES ❑ NO
High sludge production, being
offset by high surcharge
Limits: None
Reporting: None
dished:
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 Division Inspector, please verify
yourself!
26. If NO to 23 - 26, list violations Sampling for metals, etc were missing from eDMR
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1

27
Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP?
If yes, which ones? Eliminated: Added:
[—]YES ®NO
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)
10/1/19
® Yes ❑ No
4/9/20
® Yes ❑ No
10/1/24
Industrial Waste Survey IWS
12/12/22
® Yes ❑ No
3/2/23
® Yes ❑ No
12/13/27
Sewer Use Ordinance SUO
3/7/14
® Yes ❑ No
❑ Yes ❑ No
Enforcement Response Plan (EPP)
6/10/20
® Yes ❑ No
9/2/20
❑ Yes ❑ No
Long Term Monitoring Plan (LTMP)
10/1/19
❑ Yes ❑ No
4/9/20
❑ Yes ❑ No
INDUSTRIAL USER PERMIT IUP FILE REVIEW 3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION
29. User Name
Steven Roberts
__
2.
3.
F1.
Original Desserts, LLC
30. IUP Number
002
31. Does File Contain Current Permit?
® Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
32. Permit Expiration Date
2/29/24
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 ❑ No
❑ Yes ❑ 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
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
Yes❑No®N/A
P
❑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
❑ Yes ❑ No
its Sampling as Required by IUP, including flow?
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
® Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
41. During the Most Recent Semi -Annual Period, Did the SIU Complete its
❑Yes®No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
Sampling as Required by IUP, including flow?
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 IUs with Combined Wastestream Formula (CWF), does
❑Yes®No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
file include process/dilution flows as Required b 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?
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 Rc 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
c.❑Yes❑No❑N/A
of SIU limit violations in the POTW's sampling of the SIU?
c.❑Yes❑No❑N/A
c.❑Yes❑No❑N/A
46. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
❑
Yes
®
No
❑
Yes
❑
No
I
❑
Yes
❑
No
47. During the Most Recent Semi -Annual Period, Was Enforcement Taken IP
Yes❑No❑N/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 IFa.13Yes❑No❑N/A
a.❑Yes❑No❑N/A
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

b. Is SIU in Compliance with Order?
51. Did the POTW Representative Have Difficulty in Obtaining Any of This
Requested Information For You?
FILE REVIEW COMMENTS:
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number
1. Industry Inspected:
2. Industry Address:
3. Type of Industry/Product:
MM/DD/YY
b.[3Yes[3NoZ
I b.[3Yes[3No[3
I b.❑Yes❑No❑N/A
❑ Yes ®NoIF
M7 TeT ❑ !17
Yes ❑ No
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:
Requirements: All sampling required by LTMP/STMP is required to be reported on eDMRs for associated months. Please revise
eDMR to include sampling from LTMP/STMP. A copy of the approval letter from the state for the Sewer Use Ordinance was missing,
please follow up with the Division to ensure that the most of to date copy is on record.
Recommendations:
NOD: ❑ YES ❑ NO
NOV: ❑ YES ❑ NO
QNCR: ❑ YES ❑ NO
POTW Rating:
Satisfactory_
PCI COMPLETED BY:
Marginal X UnSatisfactory
/DocuSigned by:
Su,a. 6t& h6rajA,
2BE17E499D6943D...
DATE: 9/28/202 3
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3

United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040-0057
Water Compliance Inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 IN 1 2 u 3 I NC0027103 I11 121 23/09/01 I17 18I D I 19 I s I 201 I
211IIIII 111111III II III III1 I I IIIII IIIIIIIII II r6
Inspection
Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved -------------------
67
I 72 I n, I 71 I 74 79 I I I I I I I80
701� I 711 LL -1 I I
LJ
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES permit Number)
09:OOAM 23/09/01
22/10/01
Pembroke WWTP
NCSR 1339
Exit Time/Date
Permit Expiration Date
Pembroke NC 28372
01:OOPM 23/09/01
27/07/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Jason E Deese/ORC/910-521-2989/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Tyler W Thomas,100 Union Chapel Rd Pembroke NC 283720866/Town
Manager/910-521-9758/9105210492 No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Pretreatment
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Sharon Moran Docusigned by: DWR/FRO WQ/910-433-3300/
Lvbt& Aurm , 9/28/2023
EsME17E499D6943D...
Signature of Ma tgQ"-eviewer Agency/Office/Phone and Fax Numbers Date
Mark Bran!F brWR/Division Water Ext.727/ 9/28/2023
of Quality/910-433-3300
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

NPDES yr/mo/day Inspection Type
NCO027103 I11 12I 23/09/01 117 18 1 p I
(Cont.)
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
A Pretreatment Compliance Inspection (PCI) of the Town of Pembroke WWTP's Pretreatment
Program was conducted by Sharon Moran from this office on September 1, 2023, in conjunction with
Jason Deese, ORC of Town of Pembroke WWTP and Charles A. Donnell, Pretreatment Consultant
with Envirolink. The purpose of this PCI is to determine the effectiveness of the pretreatment program
by reviewing various aspects of the program, which included files and records, industrial user
inspections and monitoring data, data management procedures and adherence to the Enforcement
Response Plan.
Town of Pembroke WWTP is currently a 1.33 MGD permitted facility and has one (1) Significant
Industrial User (SIU); Steven Roberts Original Desserts, LLC. One permit file was reviewed: Steven
Roberts Original Desserts, LLC. A site visit was not conducted during this inspection. Mr. Deese
noted during the inspection that the SIU does cause higher amounts of sludge production than would
otherwise occur. The WWTP recovers the cost of the sludge handling with increased surcharges to
the industry. It was noted during the inspection that a copy of the approval letter from the state for the
Sewer Use Ordinance was missing. It is recommended to check with the Pretreatment Section of the
Division to ensure that an approval is on file. All sampling required by LTMP/STMP is required to be
reported on eDMRs for associated months. Please revise eDMR to include sampling from
LTMP/STMP.
Page#