NC0024201_Compliance Inspection_20151012

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North Carolina Department of Environmental Quality
Pat McCrory Donald R. van der Vaart
Governor Secretary
October 12, 2015
Mr. Danieley Brown, CEO RECEIVEDI(�ENR/DWR
Roanoke Rapids Sanitary District
P.O. Box 308
Roanoke Rapids,NC 27870 OCT 14 �fjj j
Water Quality
Subject: Pretreatment Compliance Inspection Permitting SPrfin,
Roanoke Rapids Sanitary District(RRSD)
NPDES Permit No. NCO024201
Halifax County
Dear Mr. Brown:
On September 23, 2015, 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. Greta Glover, the Pretreatment Coordinator, and Ms.
Isabelle Wilcoxon,the assistant lab supervisor, 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 (SIUs), one of which is also a Categorical
Industrial User (CIU). It was noted that no SIUs were in Significant Non-Compliance
(SNC) during the past two semi-annual periods.
2. A review of the files containing the pretreatment program elements was conducted. These
files were available and well organized. The Headworks analysis (HWA) was updated and
approved in August 2015.
3. The review of Long Term Monitoring Plan(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. All SIUs completed their
monitoring and submitted monitoring reports on time as required by the Industrial User
North Carolina Division of Water Resources 1628 Mail Service Center Raleigh,NC 27699-1628 Phone[phone] Customer Service
Internet: www.ncwaterquality.org Location:3800 Barrett Drive Raleigh,NC 27609 Fax [phone] 1-877-623-6748
An Equal Opportunity/Affirmative Action Employer—50%Recycled/10%Post Consumer Paper

Pretreatment Permits (IVPs). During the first semi-annual period of 2015, Rosemary Power
Station was in compliance. Reser's Fine Food had two BOD violations. Kennametal had one
BOD violation. The POTW took appropriate enforcement against these violations pursuant
to the Enforcement Response Plan (ERP).
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(919) 791-4200 (or email:
[e-mail]).
r
S'nce ly,
Danny S
Surface ater Protection Supervisor
Raleigh Regional Office
Enclosure: 2015 Roanoke Rapids Sanitary District PCI Inspection Form
CC: Monti Hassan,DWR-PERCS Unit
Central Files
Cheng Zhang,RRO
Greta Glover,RRSD

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NORTH CAROLINA DIVISION OF WATER QUALITY
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
BACKGROUND INFORMATION [Complete Prior To PCI;Review Program Info Database Sheet(s)]
1. Control Authority(POTW)Name: Roanoke Rapids Sanitary District WWTP
2. Control Authority Representative(s):Greta Glover&Isabelle Wilcoxon
3. Title(s): Laboratory Supervisor/Pretreatment Coordinator, Assistant Lab Supervisor
4. Last Inspection Date: 09/20/2013 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
PCS CODING
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac.Type
NL I NICI010I2141210111 1091231151 L-Pi I S I t i l
(DTIA) (TYPI) (INSP (FACC)
7. Current Number Of Significant Industrial Users(SIUs)? 3 SNS
8. Current Number Of Categorical Industrial Users(CIUs)? 1 CNS
9. Number of SNs Not Inspected By POTW in the Last Calendar Year? 0
10.Number of SNs Not Sampled By POTW in the Last Calendar Year? 0
11.Enter the Higher Number of 9 or 10 0 NOIN
12.Number of SNs With No IUP,or With an Expired IUP 0 NOCM
13.Number of SNs in SNC for Either Reporting or Limits Violations During Either of the Last 2 0
Semi-Annual Periods(Total Number of SNs in SNC) PSNC
14.Number of SNs in SNC For Reporting During Either of the Last 2 Semi•Annual Periods 0 MSNC
15.Number of SIUs In SNC For Limits Violations During Either of the Last 2 SemiAnnual Periods 0 SNPS
16.Number of SNs In SNC For Both Reporting and Limits Violations During Either of the Last 2 0
Semi-annual Periods
POTW INTERVIEW
17. Since the Last PCI,has the POTW had any NPDES Limits Violations? ®YES [:]NO
If Yes, What are the Parameters and How are these Problems Being Addressed? Multiple TSS and fecal,during high
flow situations
18. Since the Last PCI,has the POTW had any Problems Related to an Industrial ❑YES ®NO
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 Limits:None
either of the Last 2 Semi-Annual Periods?Not Been Published for SNC for Reporting:None
Public Notice?(May refer to PAR if Excessive SNs in SNC) Not Published:None
20. Which Industries are on Compliance Schedules or Orders?For all SNs 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 ❑YES ®NO
Ones?
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 DWQ Inspector,please verify yourself
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 DWQ Pretreatment Compliance Inspection(PCI)Form Updated 7/25/07 Page 1

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 Pro ramInfo:
Program Element Last Submittal Last Approval Date Next Due,
Date In file? Date In file If Applicable
Headworks Analysis(HWA) 5/8/2015 ®Yes ❑ No 8/14/2015 ®Yes❑ No 7/1/2020
Industrial Waste Survey(IWS) 1/30/2013 ®Yes❑ No 2/19/2013 ®Yes❑ No 2/1/2018
Sewer Use Ordinance SUO 10/21/2011 ®Yes❑ No 10/21/2011 ®Yes❑ No
Enforcement Response Plan(ERP) 10/12/2012 ® Yes❑ No 10/15/2012 ®Yes❑ No
Long Term Monitoring Plan(LTMP) 7/16/2014 ®Yes ❑ No 8/15/2014 ®Yes❑ No
INDUSTRIAL USER PERMIT(IUP)FILE REVIEW(3 1UP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name 1.Rosemary Power Station 2.Kennametal Reser's Fine Food
30. P Number 0007 0002 0009
N
31. Does File Contain Current Permit? ®Yes ❑ No 11 ®Yes ❑ NoI ®Yes ❑ No
32. Permit Expiration Date 05/31/2017 05/31/2017 5/31/2017
33. Categorical Standard Applied(I.E.40 CFR,Etc.)Or N/A NA 471.J NA
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❑NoON/A ❑Yes❑No®N/A ❑Yes❑No®N/A
Organic Management Plan(TOMP)? 11
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? I ®Yes ❑ No ®Yes ❑ No ®Yes ❑ No
41a. During the Most Recent Semi-Annual Period,Did the SIU Complete its ®Yes❑No❑N/A ®Yes❑No❑N/A OYes❑No❑N/A
Sampling as Required b IUP, includingflow?
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41 b. 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 witfi Combined Wastestream Formula(CWF),does ❑Yes❑No®N/A ❑Yes❑NoON/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❑NoON/A ❑Yes❑No®N/A ❑Yes❑No®N/A
production rates and/or flows as Required b NP?
43a. During the Most Recent Semi-Annual Period,Did the POTW Identify ❑Yes❑NoON/A ®Yes❑No❑N/A ®Yes❑No❑N/A
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❑NoON/A ❑Yes❑No®N/A
All Re---;--mon-Compliance 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 aaYes❑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 c.®Yes❑No❑N/A c.❑Yes❑No®N/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? I El es ® No 11 ❑Yes ® No 11 ❑Yes ® No
47. During the Most Recent Semi-Annual Period,Was Enforcement Taken ❑Yes❑No®N/A ®Yes❑No❑N/A ®Yes❑No❑N/A
as Specified in the POTW's ERP(NOVs,Penalties,timing,etc.)? I ir
48. Does the File Contain Penalty Assessment Notices? ❑Yes❑NOON/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 Fb.[3Yes[3No0N/A
❑Yes❑No®N/A
b. Is SIU in Compliance with Order? b.❑Yes❑No®N/A b.❑Yes❑No®N/A
51. Did the POTW Representative Have Difficulty in Obtaining Any of This ❑Yes ® No ❑Yes ® No ElYes ® No
Requested Information For You?
NC DWQ Pretreatment Compliance Inspection(PCI)Form Updated 7/25/07 Page 2

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FILE REVIEW COMMENTS:
#43 and 44—Reser's Fine Food had two BOD violations in May 2015.A NOV was issued and additional samples taken and analyzed.
Kennametal had one BOD violation in April 2015 from POTW sampling.The POTW took an additional sample issued a NOV in May
2015.
INDUSTRY INSPECTION PCS CODING:
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac.Type
Nl L I I I I I I I I I I I I L_1_j 1 SJ 1?l
(DTIA) (TYPI) (INSP) (FACC)
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:
Requirements:
Recommendations:
NOD: ❑ YES ®NO
NOV: ❑ YES ®NO
QNCR: ❑ YES ® NO
POTW Rating:
Satisfactory ' X Marginal UnSatisfactory
PCI COMPLETED BY: Cheng ZhangDATE: 9/23/2015
NC DWQ Pretreatment Compliance Inspection(PCI)Form Updated 7/25/07 Page 3

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