NC0027103_Compliance Evaluation Inspection_20180228

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4
o.
Water Resources
Environmental Quality
February 28, 2018
Tyler Thomas, Town Manager
Town of Pembroke
PO Box 866
Pembroke, NC 28327
SUBJECT: Pretreatment Compliance Inspection
Town of Pembroke
Permit No: NCO027103
Robeson County
Dear Mr. Thomas:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretory
LINDA CULPEPPER
Interim Director
RFCF
MAR0�2018
Nater ReSoUrcesection
perrKming
Enclosed please find a copy of the Pretreatment Compliance Inspection form from the inspection
conducted on February 15, 2018. The Pretreatment Compliance Inspection was conducted by
Johnathan Watts, Environmental Specialist. Mr. Tyler Thomas, Mr. Jason Deese, and Mr. Charles Donnell
were present for the inspection and your time and cooperation was much appreciated.
The purpose of the pretreatment Inspection is to determine the effectiveness of the Pretreatment
program by reviewing the files, which include a review of POTW plant performance, sampling and
compliance judgment program, adherence to the enforcement response plan (ERP), and evaluating how
the program performs an industrial user inspection.
The inspection report is attached with findings and observations made during the inspection. Please
review for more detail.
Background
Town of Pembroke has (2) significant industrial users (SIUs) Trinity Frozen Foods and Steven Roberts
Original Desserts, which are not considered categorical and is 1.33 MGD permitted facility.
Industrial User Permit (IUP) File Review
The pretreatment inspection file review included Trinity Frozen Foods and Steven Roberts Original
Desserts, which is in significant noncompliance (SNC) Pembroke must issue a NOV to both SIUs for
failure to submit monthly flow. NOVs for failure to monitor were issued in December. A Public Notice
of significant non-compliance must appear in the local newspaper. Provide copies of the affidavit of
publication no later than April 1, 2018.
Short Term Monitoring Plan
The sampling plan must be implemented for four quarters of 2018. Begin sampling prior to the end
March 2018. STMP data must be reported on eDMR.
-- "Nbthing Compares
State of North Carolina I Environmental Quality
225 Green Street, Suite 714, Fayetteville, North Carolina 28301-5095
910-433-3300

Industrial Inspection
Trinity Frozen Foods was not inspected. A documented inspection of Trinity is required to determine
compliance status. Send a copy of the ERP to all industrial users within 30 days.
Pretreatment Annual Report
The Pretreatment Annual Report (PAR) is due each year on March 1. Your PAR must include:
1. A Narrative discussing SIUs in SNC, detailing actions taken, or proposed, by the Permittee to
correct significant non-compliance and to ensure future compliance.
2. A Pretreatment Program Summary (PPS) form.
3. A Significant Non -Compliance Report (SNCR) form.
4. Copy of your current allocation table.
5. The affidavit of publication for, or a copy of, the Public Notice of significant non-compliance. If
the Notice cannot be accomplished prior to the March 1 due date for the PAR, please submit the
PAR and make note that the publication will be accomplished and the proof of publication
submitted no later than April 1, 2018.
Please see our web site for more information regarding the pretreatment annual report.
[https.//deq.nc.gov/about/divisions/water-resources/water-resources-permit-guidance/pretreatment-
guide/annual-report-guidance]
Thank you for your continued cooperation with the Pretreatment Program. Please do not hesitate to
contact me at [phone] [[e-mail]]
Sincerely, /
Johnathan C. Watts
Environmental Specialist
Division of Water Resources
Water Quality Regional Operations Section
Enclosures: HWA spreadsheets, STMP, IWS, example public notice, SNCR form, PPS form and
explanation
cc: Central Files
FRO Files
PERCS Files

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
:'rarer Rase;n is
VA RChNE4Tf (}_.l„TT
BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)l
1. Control Authority (POTW) Name- Town of Pembroke
2 Control Authority Representative(s): Tyler Thomas, Charles Donnell, Jason Deese
3 Title(s) Town Manager, Capital Proiects Manager, ORC
4 Last Inspection Date: New Program; I` Inspection Inspection Type (Check One) ❑ PCI ❑ Audit
5. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? N/A
6 Is POTW under an Order That Includes Pretreatment Conditions9 ❑ YES ® NO
Order Type, Number, Parameters.
ICIS CODING
Main Program Permit Number
MM/DD/YY
INIC10 10 12 17 11 10 13 1 102115118 1
Are Milestone Dates Being Met9 ❑ YES ❑ NO
7 Current Number Of Significant Industrial Users (SIUs)9
2
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 Year9
1
10 Number of SIUs Not Sampled By POTW in the Last Calendar Years
0
11 Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi -Annual Penods9
0
12 Number of SIUs in SNC For Reporting During Either of the Last 2 Semi -Annual Penods9
2
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)9
0
16 Number of CIUs in SNC9
6
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.)9
If Yes, How are these Problems Being Addressed?
19. Which Industries have been in SNC for Lmmts 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?
❑ YES ❑ NO
❑ YES ❑ NO
Limits 0
Reporting 2
dished: 2
None
❑ YES ®NO
LTMP/STMP FILE REVIEW: N/A: No STMT sampling has been performed at this time
22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies9 ❑ YES ❑ NO
23 Are Correct Detection Levels being used for all LTMP/STMP Monitoring9 ❑ YES ❑ NO
24 Is LTMP/STMP Data Maintained in a Table or Equivalent9 ❑ 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. IfNO 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

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 A
*Comments
❑ Yes ® No
10/04/2016
N/A
04/30/2019
Industrial Waste Survey S
01/26/2018
❑ Yes ® No
2/5/2018
❑ Yes ® No
12/31/2022
Sewer Use Ordinance SUO
02/06/2014
® Yes ❑ No
02/20/2014
❑ Yes ® No
®Yes ❑ No
Enforcement Response Plan RP
09/18/2014
® Yes ❑ No
12/02/2014
❑ Yes ® No
Long Term Monitoring Plan (LTMP)
1 02/06/2014
❑ Yes ® No 1
2/20/2014
N/A
a. []Yes ®No
1[b
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 ICT INSPECTION)
29. User Name
1. Trinity Frozen Foods
2. Steven Roberts
3.
30 IUP Number
001
002
31 Does File Contain Current Permit?
® Yes ❑ No 11
® Yes ❑ No
❑ Yes ❑ No
32. Permit Expiration Date
7/31/2020
7/31/2020
33 Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
N/A
N/A
34. Does File Contain Permit Application Completed Within One Year Prior
®Yes ❑ No
® Yes ❑ No
❑ Yes ❑ No
11
to Permit Issue Date?
35. Does File Contain an Inspection Completed Within Last Calendar Year?
El Ye ®NoI
® Yes ElNo
❑Yes ❑ No
36. a. Does the File Contain a Slug/Spill Control Plan?
a. []Yes ®No
1[b
a ®Yes ❑No
a. [Ell es ❑No
b. If No, is One Needed? (See Inspection Form from POTW)
b ❑Yes []No
[]Yes ❑No
b. ❑Yes []No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
❑Yes❑NoNN/A❑Yes❑No®N/A
❑Yes❑No❑N/A
Organic Management Plan (TOMP)9
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 El
El Yes ElNo
its Sampling as Required b IUP, including flow?
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
❑ Yes ® No
El ®No
❑ Yes ❑ No
41. During the Most Recent Semi -Annual Period, Did the SIU Complete its
IF
❑YesNNo❑N/A
❑Yes®No❑N/A
❑Yes❑No❑N/A
Sampling as Required b IUP, includingflow?
11
41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports
❑YesENo❑N/A
1
❑YesNNo❑N/A
❑Yes❑No❑N/A
11
on time
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑NoNN/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❑NoNN/A
11
❑Yes❑NoNN/A
1
❑Yes❑No❑N/A
production rates and/or flows as Required b IUP1
43a. During the Most Recent Serm-Annual Period, Did the POTW Identify
® Yes ❑ No
® Yes ❑ No
❑ Yes ❑ No
All Limits Non -Compliance from Both POTW and SILT Sampling?
43b During the Most Recent Semi -Annual Period, Did the POTW Identify
NYes❑No❑N/A
NYes❑No❑N/A
❑Yes❑No❑N/A
All Rg ortinNon-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 11
® Yes ❑ No
11 ❑ Yes ❑ No
47. During the Most Recent Semi -Annual Period, Was Enforcement Taken
NYes❑No❑N/A
NYes❑No❑N/A
11 11
❑Yes❑No❑N/A
11
as Specified in the POTW's ERP OVs, Penalties, timing, etc )9
48. Does the File Contain Penalty Assessment Notices?
I CYesONog
I ❑Yes❑NoNN/A
❑Yes❑No❑N/A
49. Does The File Contain Proof Of Penalty Collection?
❑Yes❑NoEN/A
❑Yes❑NoNN/A
❑Yes❑No❑N/A
50. a Does the File Contain Any Current Enforcement Orders?
a.❑Yes❑NoNN/A
a.❑Yes❑No®N/A
a.❑Yes❑No❑N/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 ®
Yes ® No
❑ Yes ❑ No
Requested Information For You?
!][E]
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

FILE REVIEW COMMENTS:
Trinity was not inspected If access is denied or the POTW experiences unusual delays, document the situation and follow SUO entry
procedures.
1. Pembroke has requested that Trinity Frozen foods remove by pass from treatment unit. Note any instances of interference or upset from
an SIU's discharge, can result the SIU to be in SNC.
s. A documented inspection of all SIUs is required once per year and a maximum of 12 months prior to permit issuance.
i. Slug/spill Control Plan provides a way to evaluate industries for the need for slug/spill control mechanisms, to avoid slug discharges and
take preventative actions in the event of an accidental spill, which would have reasonable potential to cause interference or in any other
way violate the POTW's permit conditions.
1. A record of monitoring activities of the POTW is required to show proper collection and handling. Without proper documentation, the
control authority may not be able to take necessary action or demonstrate industry responsibility and therefore may be responsible for
rectifying the damage.
1. IUPs for both SIUs were modified to reflect current sampling protocol.
1b. NOVs have been sent to both SIUs for failure to meet required sampling.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
1. Industry Inspected:
2. Industry Address:_
3. Type of Industry/Product:
4. Industry Contact:
Phone -
Fax
Title:
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:
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 ' Page 3

OVERALL SUMMARY AND COMMENTS:
Comments:
1. The design HWA was updated by DVM in 2016 to allow the use of the 1.5X design option for BOD and TSS. No formal
approval letter was provided.
Requirements -
1. Trinity Frozen Foods and Steven Roberts are in significant non-compliance for reporting violations. These violations are
considered significant non-compliance and Pembroke must issue NOVs and a publication in the local newspaper.
2. Perform on-site inspection to determine compliance status of Trinity.
3. Send a copy of the ERP to all SIUs within 30 days. Allows all industry users to receive fair treatment and makes them aware of
what to expect in the case of a violation.
S
4. Submit PAR by March 1, 2018.
5. Start short term monitoring plan sampling before the end of the first quarter of 2018. Collect quarterly samples through 2018
to complete HWA by April 30, 2019. 1
Recommendations:
NOD: ❑ YES ❑ NO
NOV: ❑ YES ❑ NO
QNCR: ❑ YES ❑ NO
POTW Rating:
Satisfactory Marginal UnSatisfactory
PCI COMPLETED BY: Johnathan Watts, FRO DATE: 02/15/2018
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 4

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 15 I 3 I NCO027103 I11 12 18/02/15 17 18 d 19 I c I 201 I
16
211 1 1 1 1 1 1 1 1 1 11 1 1 1 1 1 1 1 1 1 1 1 1 I 1 1 1 1 1 1 1 1 1 1 11 1 1 1 1, I f6
Inspection Work Days Facility Self -Monitoring Evaluation Rating 131 QA -------------Reserved----- -
67 70 71 1 I 72 1 N 1 731 I 174 751 III I I I 180
l_J I I I
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 Dermit Number)
09 00AM 18/02/15
16/08/01
Pembroke WWTP
Exit Time/Date
Permit Expiration Date
NCSR 1339
12 30PM 18/02/15
19/07/31
Pembroke NC 28372
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 28372/Town
No
Manager/910-521-9758/9105210492
Section C Areas Evaluated During Inspection (Check only those areas evaluated)
Other
Section D Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
i
(See attachment summary)
Name(s) and Signature( of Inspector(s) Agency/Office/Phone and Fax Numbers Date
gq
Johnathan C Watts FRO WQ//910-433-3300/ p I rJ
nRAgency/Office/Phone and Fax Numbers Date
Signature of Man:�:�
Trent Allen RO WOH910-433-3300/
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete
Page#

NPDES yr/mo/day Inspection Type
31 NCO027103 111 121 18/02/15 117 18 IpI
LJ
Section D Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Page#

Permit NCO027103
Inspection Date 02/15/2018
Other
Comment
Owner - Facility Pembroke WWTP
Inspection Type Pretreatment Compliance
Yes No NA NE
Page#

- PUBLIC NOTICE
OF SIGNIFICANT INDUSTRIAL
WASTEWATER PERMIT
VIOLATIONS
The Town of Typicalville, in accordance
with Federal and State Regulations is
hereby giving Public Notice. Listed below
are Significant Industrial Users that were in
significant noncompliance (SNC) with
national pretreatment regulations, 40 CFR
Part 403, and state pretreatment
regulations, 15 NCAC 2H .0900, and local
pretreatment regulations during the period
of January 1 thru June 30, 2012; Will
Plateit Metal Finishers, Inc. -Cadmium and
Chicken Pluckers, Inc. -BOD, Reporting.
And July 1 thru December 31, 2012; Will
Plateit Metal Finishers, Inc. -Cadmium
A continuing effort is being made by all the
listed industries to achieve compliance,
including installation of new equipment
and upgrading of existing equipment and
continued progress is expected until full
compliance can be attained.
Town of Typicalville, Department of Public
Utilities, Jane Wastewater, Director.
January 17, 2013
Affidavit of Publication
The Typicalville Herald
Typicalville, N.C.
Personally appeared before me, a Notary Public of the
County of Typical, State of North Carolina, on
this the 17 day of January 2013
Suz 5N ew
of The Typicalville Herald, who, bring duly sworn, state
that
the notice entitled
PUBLIC NOTICE OF SIGNIFICANT
INDUSTRIAL WASTEWATER PERMIT VIOLATIONS
a true copy of which is attached hereto, appeared in The
Typicalville Herald, a newspaper published in the Town
of
Typicalville, County of Typical,
State of North Carolina, once a week for
one week(s), on the following dates:
January 17 20 13
20
20
20
The Typicalville (N.C.) Herald
of January 2013
Notary Public

Pretreatment Annual Report (PAR)
Significant Non -Compliance Report (SNCR)
WWTP = Wastewater Treatment Plant, use separate form for each WWTP.
SIU = Significant Industrial User
SNC = Significant Non -Compliance
PAR covers this calendar year =>
Control Authority--Program--Town Name =>
WWTP Name =>
NPDES # =>
A CNC.R Fnrm must be submitted with every PAR. please write "None " if you had No SIUs in SNC during calendar year
IUP
#
Pipe
#
Industry Name
Parameter
or "Reporting"
SNC? ( Yes / No)
for each 6 -month period.
Jan. - June
July - Dec.
Attach a copy of the Division's "SIUs in SNC Historical Report" for your Yui w's plus miuna tors page .
Is the database correct ? Notify the Division of any errors ! Database indicates SNC history for previous years.
EVERY SNC MUST be explained in the Narrative, How was, is, or will it be resolved?
REPEAT SNCs are serious matters that MUST be explained in the Narrative.
Form name PAP SNCR,2001
Date Revised 1/4/2001

Form name PAR,SNCR,2001
Date Revised 1/4/2001

Chapter 9, PAR Guidance
Pretreatment Performance Summary (PPS)
1
2
Pretreatment Town Name:
"Primary" NPDES Number NC00
or Non Discharge Permit # if applicable =>
3.
PAR Begin Date, please enter 01/01/yyyy
3 =>
4
PAR End Date, please enter 12/31/yyyy
4. =>
5.
Total number of SIUs, includes CIUs
5 =>
6
Number of CIUs
6 =>
7
Number of SIUs with no IUP, or with an expired IUP
7. =>
8
Number of SIUs not inspected by POTW
8 =>
9.
Number of SIUs not sampled by POTW
9. =>
10
Number of SIUs in SNC due to IUP Limit violations
10. =>
11
Number of SIUs in SNC due to Reporting violations
11. =>
12
Number of SIUs in SNC due to violation of a Compliance Schedule, CO, AO or similar
12. =>
13
Number of CIUs in SNC
13 =>
14
Number of SIUs included in Public Notice
14. =>
15
Total number of SIUs on a compliance schedule, CO, AO or similar
15. =>
16.
Number of NOVs, NNCs or similar assesed to SIUs
16 =>
17.
Number of Civil Penalties assessed to SIUs
17 =>
18
Number of Criminal Penalties assessed to SIUs
18. =>
19.
Total Amount of Civil Penalties Collected 19. =>
$
20.
Number of IUs from which penalties collected
20. =>
dotes'
AO Administrative Order IUP Industrial User Pretreatment Permit POTW
CIU Categorical Industrial User NNC Notice of Non -Compliance SIU
Publicly Owned Treatment Works
Significant Industrial User
CO Consent Order NOV Notice of Violation SNC
Significant Non -Compliance
IU Industrial User PAR Pretreatment Annual Report
revised 1/2018 PAR -PPS -2018

Pretreatment Performance Summary (PPS) -Explanations
Line # 5. Number of SIUs permitted and/or discharged during PAR year. Discuss new or dropped
SIUs in narrative.
Line # 12. A SIU is in SNC if they fail to meet a compliance schedule milestone within 90 days of
the scheduled date for starting construction, completing construction or attaining final
compliance; if progress reports required by the compliance schedule are over 45 days late; or
there are violations of any interim limits meeting the chronic or TRC definition of SNC.
Line # 15. This is the total number of industries on a compliance schedule as part of an
enforcement action during the reporting period. if the compliance schedule was entered into in
July 2016, it would be counted on the PPS form in 2016 and 2017 and subsequent PARS until
the schedule is completed or expires. These schedules are issued outside of, or separate from,
the IUP. If an industry is on a compliance schedule that is part of an IUP, this is not included in
the PAR. This type of compliance schedule is not considered an enforcement action that
includes stipulated penalties, and it should therefore not be included.
Lines # 16,17,18,19, 20. are based on number of events during PAR year, and do not include events
occurring after PAR year.
Line # 19. Total amount of Civil Penalties collected: This is the actual amount in fines that was
collected from the industries during this twelve month period. This can include collection of
penalties assessed during prior reporting periods.
Line # 20. Number of SIUs from which penalties collected. This is the total number of industries that
actually paid penalties during the year.