NC0027103_Pretreatment_Annual_Report_20190306

POST OFFICE BOX S66
PEMBROKE, NORTH CAROLINA
28372
OFFICF OF THE MANAGER
March 6`1', 2019
NC DEQ
PERCS Unit
Vivien Zhong
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Town of Pembroke Pretreatment Program 2018 PAR
MUNICIPAL BUILDING
100 SOUTH UNION CHAPEL ROAD
Enclosed are an original and one copy of the Town of Pembroke's Pretreatment Annual Report
(PAR) for the period of January 1, 2018 through December 31, 2018.
The Town of Pembroke's Pretreatment Program is a modified program. As such, we are
submitting only a narrative that contains information on the SlUs, the Pretreatment Program
Information Database Form and the PPS Form.
Should you have any questions about this report, please contact me or Charles A. Donnell, PE at
910-322-6572.
Sincerely,
(U )
Tyler W. Thomas
Town Manager, Town of Pembroke
PHONE [phone] • FAX [phone]

Town of Pembroke, Pembroke WWTP (NC 0027103)
2018 Pretreatment Annual Report (PAR)
Narrative
GENERAL INFORMATION
Contact Information:
Town of Pembroke
Mr. Tyler W. Thomas, Town Manager
PO Box 866
Pembroke, NC 28372
Mr. Jason Deese, ORC Town of Pembroke WWTP
PO Box 866
Pembroke, NC 28372
Pretreatment Consultant
Mr. Charles A. Donnell, PE
Capital Projects manager, Envirolink, Inc.
4700 Homewood Court, Suite 108
Raleigh, NC 27609
General Program Information:
The Pretreatment Program is relatively new, having just issued its first IUPs in February 2017. These
permits were both subsequently modified in December 2017 to reflect conditions that the Town
desired.
Mr. Johnathan Watts completed a Pretreatment Compliance Inspection on February 15, 2018. Results
of that inspection have been reviewed and information included in this PAR.
The allocation table, short term monitoring plan, sewer use ordinance, enforcement response plan,
industrial waste surveys and industrial users permits are all up to date. Dates in the Pretreatment
Program Info Database (attached) have been updated and are correct.
A headworks analysis has been scheduled to be completed by a consultant not later than April 30, 2019.
General Permit Information:
• Trinity Frozen Foods IUP was issued to Trinity Frozen Foods on 02/21/17. It was modified on
12/11/17 and re -issued. It is effective until 07/31/2020.
• Steven Roberts Original Deserts IUP was issued to Steven Roberts Original Deserts on 02/21/17.
It was modified on 12/11/17 and re -issued. It is effective until 07/31/2020.

SIU Information:
Trinity Frozen Foods. Trinity Frozen Foods processes sweet potatoes into French Fries. Process
wastewater is separated from domestic sewage and is pumped from the main factory to a pretreatment
lagoon. Supernatant from the lagoon is pumped to the Town of Pembroke collection system. To
maintain pH between 6 and 8, caustic is added at the lagoon pump site. Sampling is completed at a
vault on Trinity's property.
Trinity has been in significant non-compliance for most of 2018. The new management team hired a
consultant to assist them with IUP compliance, specifically lagoon certification. The consultant listed
tasks necessary to assure compliance to include a boundary survey with accompanying setbacks. As of
the submission of this annual report, the lagoon remains uncertified per Trinity's IUP.
In April 2018, Trinity management alleged to the Town that it had been overcharged in monthly sewer
billing. This led to numerous letter and email exchanges where the Town defended its billing. The
refusal of Trinity to pay what it owed was one of the reasons for the Town issuing a "Show Cause
Hearing" letter on November 20, 2018. Other reasons included unresolved Notices of Violation (NOVs)
on July 12 and October 31.
The Show Cause Hearing was scheduled for November 30, 2018 for the following reasons that are
quoted from the letter:
1. Trinity has not certified its lagoon;
2. Trinity has not allowed access to its facilities for required inspections;
3. Trinity has not paid its sewage bill to the Town;
4. Trinity has not paid its sewage surcharges;
5. Trinity has not addressed the algae growth in the lagoon that is discharged to the POTW.
On November 28 Trinity conducted a phone conference with the Town. The Town agreed to postpone
the hearing until January 4, 2019 and temporarily reduce the freeboard requirement from 24 inches to
12. In return, Trinity agreed to pay one third of its outstanding balance on the sewage bill, complete the
boundary survey as the initial step in certifying the lagoon, and cease discharging to the Town's
collection system until the algae problem was eliminated. In a follow up email, the Town allowed Trinity
to discharge if it did not exceed 25,000 gpd and it kept its pH 6 and 8.
The difficulties continue into 2019. The Town of Pembroke desires to work with Trinity Frozen Foods for
its economic benefit to the community. Trinity makes some progress but then slips back into not
fulfilling its promises. The Town will continue to maintain pretreatment standards for the sake of the
POTW while being reasonable with Trinity.
Steven Roberts Original Desserts. Steven Roberts Original Desserts bakes cake products and distributes
them to various markets. Process wastewater is separate from domestic sewage and flow to a large
(10,000 gallon), pre -cast grease trap. Effluent from the grease trap flows to the Town's collection

system. Samples are collected at the Town manhole where Steven Roberts effluents enters to collection
system.
Steven Roberts was in significant non-compliance for violating the BOD and TSS parameters from its IUP
during the September 26, 2018 sampling period. A Notice of Violation was issued by the Town to Steven
Roberts on October 30, 2018. The Town required Steven Roberts to establish a plan to reduce these
constituents to permitted standards. Steven Roberts has identified a consultant to assist them in
reducing BOD and TSS and has communicated this to the Town via email.
The Steven Roberts production facilities were inspected by the Town in December 2018. No deficiencies
were noted.
Proof of publication of the Public Notice of significant non-compliance will be provided to the PERCS
staff no later than April 1, 2018.
Attachments:
• Pretreatment Program Info Database
• PPS Form

Pretreatment Program Info Database
printed on: 12/13/2018
for Program Name Pembroke
z�
Stream Information IWC % at 7Q10 1.69
WWTP Name Town of Pembroke
7Q10 Flow cfs /mgd 120 / 77.52
Program Approval Date 04/07/2017
97.83 / 63.22
1Q10 Flow cfs /mgd
Pretreatment Status Modified
Stream Classification WS IV B SW HQW
Region FRO
Basin Number 03-07-51
County Robeson
Receiving Stream Name Lumber River
NPDES Number NCO027103
NPDES Effective Date 08/01 /2016
Last PAR Rec
PAR Due Date 03/01/2018 mercury
1631
NPDES Expire Date
P 07/31 /2019
Current Fiscal
Year PC] Done
required
POTW is Primary WWTP TRUE
Last Audit on
Audit Year Next
Design Flow mgd 1.3300 % Design mgd is SIU permitted F 5.41 Permitted SIU flow (mgd) [Pt—SIU) .072
WWTP SIU's Program SIUs
WWTP CIU's 0 Program CIUsl-1
HWA
LTMP IWS SUO ERP
date Inactive Date Next Due
04/30/2019
12/31/2022
Date Received by DWR
02/06/2014 01/26/2018 02/06/2014 09/18/2014
Date Approved
10/04/2016
02/20/2014 02/05/2018 02/20/2014 12/02/2014
Adopt Date Required
Date Adopted
04/07/2014
Info in this Box from Pt Contacts
PT Pro
Formal Name 9.Prime Phonel ext Fax
Mr. Tyler Thomas 1Prim 10 521-9758
[e-mail] I Town Manager
Mr. Charles Donnell Prim 10-322-6572
Capital Proiects Man
Date Date Date
Attended Attended Attended
HWA Wksp IUP Wksp PAR Wksj
PO BOX 866
Mr. Jason Deese I IP10 506-9529 1 1 11 1 1 1
[e-mail] I ORC I PO BOX 866 128372
Pretreatment Related NOVs from D
NOV-2017-PC-0705
DWR Central Office Contact Pivien Zhong
DWR Regional Contact ohnathan Watts

Chapter 9, PAR Guidance
Pretreatment Performance Summary (PPS)
1.
2.
Pretreatment Town Name: Town of Pembroke
"Primary" N PD ES Number N C00 27103
or N on_D i scharge Permi t# i f appl i cabl e =>
3.
PAR Begin Date, pl ease enter 01 /01 /yyyy
3. =>
1 / 1 /2018
4.
PAR End Date, pl ease enter 12/31 /yyyy
4. =>
12/31 /2018
5.
Total number of SI Us, includes Cl Us
5. _>
2
6.
Number of Cl Us
6. _>
0
7.
Number of SlUswith no lUP, or with an expired lUP
7.=>
0
8.
Number of SI Us not inspected by POTW
8. =>
1
9.
Number of SI Us not sampled by POTW
9. =>
0
10.
Number of Sl Us in SNC dueto I UP Limit violations
10.=>
2
11.
N umber of SI Us i n SNC due to Reporti ng vi of ati ons
11. =>
0
12.
Number of SIUs in SNC dueto violation of a Compliance Schedule, CO, AO or similar
12. =>
1
13.
Number ofClUsinSNC
13.=>
0
14.
Number of SlUsincluded in Public Notice
14. =>
2
15
Total number of SI Us on a compliance schedule, CO, AO or similar
15. =>
0
16.
Number of NOVs, NNCsor similar assesed to SIUs
16. =>
3
17.
Number of Civil Penalties assessed to SI Us
17. =>
0
18.
Number of Criminal Penalties assessed to SIUs
18. =>
0
19.
Total A mount of Ci vi I Penal ti es Col I ected 19. =>
$
0
20.
Number of lUsfrom which penalties collected
20.=>
0
dote&
AO A dmi nistrative Order IUP Industrial User Pretreatment Permit POTW
CIU Categorical Industrial User NNC Noticeof Non -Compliance SIU
Publicly Owned Treatment Works
Significant Industrial User
CO Consent Order NOV Noticeof Violation SNC
Significant
Non -Compliance
IU Industrial User PAR Pretreatment Annual Report
revised 1/2018: PAR PPS 2018