NC0020427_Pretreatment Audit_20240325

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Mr. Eric Maree, Pretreatment Coordinator
200 Byrd Dr.
Rockingham, NC 28379
Subject: Pretreatment Audit
City of Rockingham WWTP
NPDES Permit No. NCO020427
Richmond County
Mr. Maree:
NORTH CAROLINA
Environmental Quality
March 25th, 2024
A Pretreatment Audit of the City of Rockingham WWTP's Pretreatment Program was conducted by
Sharon Moran from this office on March 14th, 2024 in conjunction with Larry Cobler, ORC and Mr. Eric
Maree, Assistant Plant Director of City of Rockingham WWTP. The purpose of this audit 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.
City of Rockingham WWTP is currently a 9 MGD permitted facility and has six (6) Significant Industrial
Users (SIU); Perdue Foods LLC, Cascades Molded Pulp, Cascade Tissue Group, Marcal Cordova LLC,
Trinity Manufacturing, and Trans Carolina Products LLC. Three permit files were reviewed: Trinity
Manufacturing, Perdue Foods LLC, and Cascades Molded Pulp. During the routine POTW inspection,
performed at Marcal Cordova LLC, we met with Mitchell Luckie, Environmental Manager.
The City of Rockingham 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.
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,
Docu Signed by:
f?
E4E1A9691DB248E...
Mark Brantley, Regional Supervisor
Water Quality Regional Operations Section
Fayetteville Regional Office
Division of Water Resources, NCDEQ
Cc: Upload to Laserfiche
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 -
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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)l
1. Control Authority (POTW) Name: City of Rockingham WWTP
2. Control Authority Representative(s): Larry Cobler, Eric Maree
3. Title(s): plant director and assistant plant director
4. Address of POTW:
Mailing: 200 Byrd Dr.
City: Rockingham, NC Zip Code 28379
Phone Number [phone] E-Mail: [e-mail]
5. Audit Date March 141, 2024
6. Last Inspection Date:10/18/23 Inspection Type: d PCI ❑ Audit
7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s) ? L/Yes ❑ No
If No, Explain.
8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? ❑ Yes [1 No
If Yes, Explain.
9. Is POTW under an Order That Includes Pretreatment Conditions? ❑ Yes d No
Order Type and Number:
Parameters Covered Under Order:
ICIS Coding
Main Program Permit Number
NCO020427
Are Milestone Dates Being Met? ❑ Yes ❑ No ❑ NA
MM/DD/YY
March 14', 2024
10: Current Number of Significant Industrial Users (SIUs)?
11: Number of SIUs. with No IUP, or with an Expired IUP?
12 Number of SIUs Not Inspected by POTW in Last Calendar Year?
......................................................................................................
13 : Number of SIUs Not Sampled by POTW in Last Calendar Year?
................................................................................................
14: Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi -Annual Periods?
15: Number of SIUs in SNC for Reporting During Either of Last 2 Semi -Annual Periods?
....................................................................
16. Number of SIUs in SNC with Pretreatment Schedule?
................................................................................................................................................................................................
17. Number of SIUs on Schedules?
................................................................................................................................................................................................
18: Current Number of Categorical Industrial Users (C1Us)?
19. Number of CIUs in SNC?
................................................................................................................................................................................................
6
NC DWR Pretreatment Audit Form Revised: December 2016
Page 1

20. PRETREATMENT PROGRAM ELEMENTS REVIEW- Review POTW files, verify POTW has copy of each Program Element
in their File, complete with all supporting documents and PERCS Approval Letter, and dates consistent with Program Info:
Program Element
Last Submittal
Last Approval
Date Next Due,
Date file?
Date file
If Applicable
Headworks Analysis (HWA)
March
9 Yes ❑ No
June 14, 2016
Yes ❑ No
April 1, 2021
23,2016
Industrial Waste Survey (IWS)
June 11,
M Yes ❑ No
August 30,
K4 Yes ❑ No
June 30, 2024
2019
2019
Sewer Use Ordinance (SUO)
Sept 19
Yes ❑ No
Oct 8, 2012
%YesE:l No
NA
2012
Enforcement Response Plan (ERP)
Sept 19
Yes ❑ No
Oct 8, 2012
Yes ❑ No
Na
2012
Long Term Monitoring Plan (LTMP)
Aug 29,
Yes ❑ No
Aug 31, 2011
M Yes ❑ No
Na
2011
Legal Authority (Sewer Use Ordinance-SUO)
21. ou have any towns and/or areas from which you receive wastewater which are not in your annexed jurisdiction?
Fes ❑ No If yes, Please list these towns and/or areas.
Ellerbe, interlocal agreement, October rate, 2010
22. If yes to #21, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? [/Yes ❑ No ❑ NA
A copy, if not already submitted, should be sent to Division.
23. If yes to #21, Have you had any trouble working with these towns or districts? ❑ Yes [.(No ❑ NA
If yes, Explain.
24. Date of Last SUO Adoption by Local Council: September 11, 2012
25. Have you had any problems interpreting or enforcing any part of the SUO? ❑ Yes EX
If yes, Explain.
Enforcement (Enforcement Response Plan-ERP)
26. Did you send a copy of the ERP to your industries? [Yes ❑ No
If no, POTW must send copy within 30 days.
27. Have you dad any problems interpreting or enforcing any part of the ERP (i.e. any adjudication, improper enforcement, etc?
❑ Yes 0 No If yes, Explain.
28. List Industries under a Schedule or Order and Type of Schedule or Order
N/A
Resources
29. Please Rate the Following: S=Satisfactory M=Marginal U=Unsatisfactory
NC DWR Pretreatment Audit Form Revised: December 2016 Page 2

Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
[4S ❑M ❑U
Access to POTW Vehicles for
ds
Sampling, Inspections, and
❑M ❑U
Emergencies
Access to Operable Sampling
Equipment
S ❑M ❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
S ❑M ❑U
Reference Materials
JS ❑M ❑U
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
S ❑M ❑U
Computer Equipment (Hardware and
Software)
,�
❑M ❑U
�S
30. Does the POTW have an adequate data management system to run the pretreatment program? [/Yes ❑ No
Explain Yes or No.
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Surcharges
Public Perception/ Participation
32. Are there y local issues affecting the pretreatment program (e.g.. odor, plant closing, new or proposed plants)?
❑ Yes hNo If yes, Explain.
33. Has any one from the public ever requested to review pretreatment program files? ❑ Yes &6No
If yes, Explain procedure. If no, how would the request be addressed?
All files are available to the public and available for review. Also annual report is at town hall to review.
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. If no how would the request be addressed?
Determine the need for confidentiality. Locked filing cabinets.
35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? Yes ❑ No
36. Is the public notified about changes in the SUO or Local Limits? EdYes ❑ No
NC DWR Pretreatment Audit Form Revised: December 2016 Page 3

37. Were all industries in SNC published in the last notice? dyes ❑ No
Permitting (Industrial Waste Survey-IWS)
38. How does the POTW become aware of new or changed Users?
City planner will notify POTW about new users.
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?)
Sampling for BOD, TSS,gathering information from similar industries.flow is a lesser factor.
40. Does th�TW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
❑ Yes No If Yes, How many are there?
Please list each site and how it is permitted, if applicable.
41. Does the POTW accept waste by (mark if applicable) ❑ Truck ❑Dedicated Pipe ❑ NA
42. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples drawn,
manifests required)
43. How does the POTW allocate its loading to industries? Mark all that apply
❑ Uniform Limits Historical Industry Need ❑ By Surcharge Categorical Limits ❑ Other
Explain Other:
BOD `s main limiting factor which affects all permits.
44. Review POTW's copies of current allocation tables for each WWTP. Are there any over allocations? ❑ Yes ZNo
If yes, what parameters are over allocated?
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 15%
47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) ❑ Yes INO
If yes, Explain.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 4

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)
Historical use, industry problems.
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Standard of sampling 3 x week, more sampling completed if problems arise. If expensive testing is required, the POTW charges the
industry for the testing.
Permit Compliance
50. Does the POTW currently have or during the past year had any permits under adjudication? ❑ Yes 61 No
If yes, which industries? What was (will be) the outcome of the adjudication?
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.
Pretreatment coordinator examines all industry sampling and reports.
52. Does the POTW use the Division's model inspection form or equivalent'? dYes ❑ No
If no, does the POTW form include all Division data? ❑ Yes ❑ No
53. Were all SIUs evaluated for the need of a slug/spill control plan during their most recent inspections? 4Yes ❑ No
If no, Explain.
54. What criteria are used to determine if a slug/spill control plan is needed?
Standard for all industries to have a slug/spill.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
POTW and industry engineers cooperate to design spill plan.
56. How does the POTW decide where the sample point for an SIU should be located?
POTW Engineer decides place
57. Has the POTW established a procedure to ensure that representative samples will be taken by the POTW or SIU each time?
(example: rrect location; proper progr ming of sampler; clean equipment; swirling the sample bucket uniformly)
POTW: [Yes ❑ No SIU: Yes ❑ No If yes, Explain.
All industries use microbac except Perdue who uses Cameron testing services.
58. Who performs sample analysis for the POTW for
NC DWR Pretreatment Audit Form Revised: December 2016
Page 5

➢ Metals: Microbac
➢ Conventional Parameters: Microbac
➢ Organics: Microbac
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Ensure information is correct, sign relinquishing.
Long/Short Term Monitoring Plan (L/STMP) and Headworks Analvsis (HWA)
60a. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? [)YES ❑ NO
60b. Are Correct Detection Levels being used for all LTMP/STMP onitoring? ❑ YES E NO
60c. Is LTMP/STMP Data Maintained in Table or Equivalent? YES ❑ NO �s Table Adequate? ❑ YES ❑ NO
60d. All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? 9YES ❑ NO Division Inspector, verify yourself.
60e. If NO to any above, list violations
TSS for fourth quarter 2023, TSS testing was above approved limit. 2.5 not 2.
60f. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES VNO
If yes, which ones?
Eliminated:
Added:
61. Do you complete your own headworks analysis (HWA) ? ❑ YesyNo
If no, who completes your HWA?
Name/Company: Davis & Flyod (engineer contracted from SC)
Phone:
62. Do you have plans to revise your HWA in the near future? ❑ Yes d No
If yes, what is the reason for the revision? (mark all that apply) Diner ased average flow ❑NPDES limits change
❑More LTMP data available ❑Resolve over allocation 75 year expiration ❑Other
Explain.
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)? Xyes ❑ No
Explain.
Some plant upgrades possibly around a year or two.
65. Do you plan any significant changes to the pretreatment program or changes to the W WTP that may affect pretreatment?
Some plant upgrades possibly around a year or two.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 6

INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION)
66. User Name
FT rinity
2. Perdue
3. Cascades Molded Pulp
67. IUP Number
0009
0003
012
68. Does File Contain Current Permit?
0
Yes ❑ No 11
V Yes ❑ No
Yes ❑ No
69. Permit Expiration Date
June 30, 2026
June 30,2026
June 30, 2026
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
N/a, 002-
N/a
N/a
455.26
71. Does File Contain Permit Application Completed Within One Year Prior
Yes ❑ No
Yes ❑ No
Yes ElNo
to Permit Issue Date?
72. Does File Contain Inspection Completed Within Last Calendar Year?
Exes ❑ No
s ❑ No
s ❑ No
73. a. Does File Contain Slug/Spill Control Plan?
a. Yes ❑No
a. MYes ❑No
a. MYes ❑No
b. If No, is One Needed? See Inspection Form from POTW
b. ❑Yes ❑N
b. ❑Yes ON
b. ❑Yes EINt
74. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
❑Yes❑No /A
❑Yes❑No❑N/A
❑Yes❑No /A
Organic Management Plan TOMP ?
75. a. Does File Contain Original Permit Review Letter from Division?
a. Yes ❑No
a. tYes ❑No
a. Yes ❑No
b. All Issues Resolved?
bAVYcsEiNo
b. Yes❑No
b.WYesEiNo
❑N/A
❑N/A
z ❑N/A
76. During Most Recent Semi -Annual Period, Did POTW Complete its
Yes ❑ No
Yes ❑ No
91 Yes ❑ No
Sampling as Required by IUP, including Flow?
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
14yes ❑ No
Yes ❑ No
Yes ❑ No
78. During Most Recent Semi -Annual Period, Did SIU Complete its
❑Yes No❑N/A
Yes❑No❑N/A
Yes❑No❑N/A
Sampling as Required by IUP, including Flow?
79. During Most Recent Semi -Annual Period, Did SIU submit all reports on
❑Yes No❑N/A
Yes❑No❑N/A
Yes❑No❑N/A
time?
80a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes No❑N/A
❑Yes o❑N/A
❑Ye 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
❑Yes No❑N/A
❑Yes No❑N/A
production rates and/or flows as Required by IUP?
81. During Most Recent Semi -Annual Period, Did POTW Identify All
Ej Yes ❑ No
91 Yes ❑ No
Yes ❑ No
Limits Non -Compliance from Both POTW and SIU Sampling?
82. During Most Recent Semi -Annual Period, Did POTW Identify All
es❑No❑N/A
Yes❑No❑N/A
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. es❑No❑N/A
a.❑Yes❑No N/A
a.bYes❑No /A
Monitoring Violations?
b. Did Industry Resample and submit results to POTW within 30 Days?
b. es❑No❑rN/A
b.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
c. If applicable, did POTW resample and obtain results within 30 days of
becomingaware of SIU limit violations in the POTW's sampling of SIU?
c.❑Yes❑No�ty/A
c.❑Yes❑No❑N/A
c.❑Yes❑No❑ /A
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
L24es
❑
No I
❑
Yes
o
Yes
No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
es❑No❑N/A
❑Yes❑No /A
Yes❑No❑N/A
Specified in POTW's ERP OVs, Penalties, timing, etc.)?
86. Does File Contain Penalty Assessment Notices?
I ❑Yes o❑ /A
❑Yes❑No A
❑Yes❑No /A
87. Does File Contain Proof Of Penalty Collection?
❑Yes❑No /A
❑Yes❑No /A
❑Yes❑No /
88. a. Does File Contain Any Current Enforcement Orders?
a.❑Yes❑N /A
a.❑Yes❑No /A
a.❑Yes❑N /A
b. Is SIU in Compliance with Order?
b.❑Yes❑No❑N/A
b.❑Yes❑No❑ A
b.❑Yes❑No /A
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
❑ Yes WNo
[—]Yes No
❑ Yes KZ No
Information For You?
FILE REVIEW COMMENTS:
NC DWR Pretreatment Audit Form Revised: December 2016 Page 7

INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
NCO020427
1. Industry Inspected: Marcal Cordova LLC
2. Industry Address: 126 First St, Cordova NC 28330
3. Type of Industry/Product: paper products
4. Industry Contact:
Name: Mitchell Luckie
Title: Environmental Manager
Phone: [phone]
March 14,2024
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?
A. Initial Interview SdYes ❑ No
Comments:
B. Plant Tour
Comments:
C. Pretreatment Tour
Comments:
D. Sampling Review
Comments:
E. Exit Interview
Comments:
Industrial Inspection Comments:
Yes ❑ No
dyes ❑ No
dyes ❑ No sampling conducted exclusively by contract lab
IS/Yes ❑ No
Audit SUMMARY AND COMMENTS:
Audit Comments:
NC DWR Pretreatment Audit Form Revised: December 2016 Page 8

Requirements: TSS for fourth quarter sampling of 2023, TSS testing was above approved detection limit. Detection limit used
was 2.5 not 2. Mr. Marnee is in contact with the lab to ensure this is corrected.
Recommendations:
NOD: ❑ Yes
® No
NOV: ❑ Yes
® No
QNCR: ❑ Yes
® No
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory ❑
Docu Signed by:
Audit COMPLETED BY: FsLvbv,, ADrro, DATE: 3/25/2024
2BE17E499D6943D...
Sharon Moran, Fayetteville Regional Office
NC DWR Pretreatment Audit Form Revised: December 2016 Page 9