NC0020427_Inspection_20190613

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
NORTH CAROLINA
Environmental Quality
June 18, 2019
la rrVPgorocki neham.com
Larry Cobler, Director of Public Utilities
City of Rockingham
514 Rockingham Road
Rockingham, NC 28379
SUBJECT: Pretreatment Audit Inspection
City of Rockingham
Permit No: NCO020427
Richmond County
Dear Mr. Cobler:
Enclosed please find a copy of the Pretreatment Audit Inspection form from the inspection conducted
on June 13, 2019. The Pretreatment Audit Inspection was conducted by Deborah Gore, PERCS Unit
Supervisor, and Monti Hassan, PERCS Environmental Engineer. Mr. Larry Cobler and Mr. Eric Maree
were present for the inspection and your time and cooperation was much appreciated.
The purpose of the pretreatment audit is to determine the effectiveness of the Pretreatment program
by reviewing the files, which include a review of PCITW 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 audit report is attached with findings and observations made during the inspection. Please review
for more detail.
Background
The City of Rockingham has 6 significant industrial users (SIU), one is considered categorical and is 9.0
MGD permitted facility.
Legal Authority
The Town receives wastewater from the Town of Ellerbe. An IJA is in place and Rockingham includes
Ellerbe in its industrial waste survey.
D Nn Q�� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11617 Mall Service Center I Ralelgh, North Carolina 27699-1617
919.707.9000

Industrial Waste Survey
The IWS summary has been submitted in advance of the June 30, 2019 due date.
Long Term Monitoring Plan
The City's engineering consultants maintain the data collected for the long term monitoring plan. Please
submit the data collected since January 2018 by July 15, 2019.
Industrial User Permit (IUP) File Review
The pretreatment audit file review included Cascade Molded Pulp, Perdue Farms and Trans Carolina. All
information was available. The Division recommends keeping the SIU data on spreadsheets to make it
easier to review and judge compliance. Generic data summary spreadsheets are available on our web
site.
[https:Hdeq. nc.gov/a bout/divisions/water-resources/water-resources-perm it-guidance/pretreatm a nt-
guide/headworks-analysis]
Industrial Inspection
A thorough inspection was conducted at Cascade Molded Pulp. All components of the inspection form
were covered.
Thank you for your continued cooperation with the Pretreatment Program. Please do not hesitate to
contact me at (919) 707--3624 [[e-mail]] or Monti Hassan at 919-707-3626
[[e-mail]] if you have any questions or concerns.
Sincerely,
Deborah Gore, PERCS Supervisor
Division of Water Resources
Enclosures: audit form
cc: Central Files
FRO Files
PERCS Files

K. r. NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT AUDIT REPORT
Water Resources
EN V IRONXEXTPI O V RLIi Y
Background Information [Complete prior to audit; review Program Info Database Sheet(s
1. Control Authority (POTW) Name: City of Rockingham
2. Control Authority Representative(s): Larry Cobler / Eric Maree
3. Title(s): Director, Public Utilities / ORC
4. Address of POTW:
Mailing 514 Rockingham Road
City Rockingham Zip Code 28379
Phone Number 910-895-9434 Fax Number 910-997-6617 E-Mail larry rt gorockingham.com
5. Audit Date 06/13/2019
6. Last Inspection Date: 05/26/17 Inspection Type: PCI
7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s) ? Yes
If No, Explain.
8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? No
If Yes, Explain.
9. Is POTW under an Order That Includes Pretreatment Conditions? No
Order Type and Number: _ Are Milestone Dates Being Met? NA
Parameters Covered Under Order_
ICIS Coding
Main Program Permit Number MM/DD/YY
INIC1010I2 IO 14 12 17 I 106I13I19I
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 su mortine documents and PERCS Avvroval Letter and dates consistent with Pro am Info•
Program Element
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
3/23/16
Yes
6/14/16
Yes
4/1/21
Industrial Waste Survey (IWS)
4/17/14
Yes
5/1/14
Yes
6/30/19
Sewer Use Ordinance (SUO)
9119/12
Yes
10/8/12
Yes
Enforcement Response Plan (ERP)
9/19/12
Yes
10/8/12
Yes
Long Term Monitoring Plan (LTMP)
8/29/11
Yes
8/31/11
Yes
IWS mailed last week
Legal Authority (Sewer Use Ordinance-SUO)
21. Do you have any towns and/or areas from which you receive wastewater which are not in your annexed jurisdiction? Yes
Please list these towns and/or areas. Ellerbe, NC (-2 MGD)
22. If yes to #21, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? Yes
23. If yes to #21, Have you had any trouble working with these towns or districts? No
24. Date of Last SUO Adoption by Local Council 09/11/2012
25. Have you had any problems interpreting or enforcing any part of the SUO? No
Enforcement (Enforcement Response Plan-ERP)
26. Did you send a copy of the ERP to your industries? Yes. Sends out with IUP renewals
If no, POTW must send copy within 30 days.
27. Have you had any problems interpreting or enforcing any part of the ERP (i.e. any adjudication, improper enforcement, etc? No
28. List Industries under a Schedule or Order and Type of Schedule or Order
None
9. Please Kate the rollowmg: S=Satistacto M=Mar inal
U=Unsatisfactory
Ratin9
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
S
Access to POTW Vehicles for
Sampling, Inspections, and
S
Emergencies
Access to Operable Sampling
Equipment
S
Availability of Funds if Needed for
Additional Sampling and/or Analysis
S
Reference Materials
S
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
S
Computer Equipment (Hardware and
Software)
S
NC DWR Pretreatment Audit Form Revised: December 2016 Paee 2

30. Does the POTW have an adequate data management system to run the pretreatment program? Yes
31. How does the POTW recover the cost of the Pretreatment Program from then industries? Explain.
Surcharges for BOD and TSS over 250 mg/1
Public Perception/ Participation
32. Are there any local issues affecting the pretreatment program (e.g.. odor, plant closing, new or proposed plants)? No
33. Has any one from the public ever requested to review pretreatment program files? No
If yes, Explain procedure. If no, how would the request be addressed? Ask for written request.
34. Has any industry ever requested that certain information remain confidential from the public? 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? Make sure trade secret. Keep in separate file.
35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? As necessary.
Collects surcharge samples each month
36. Is the public notified about changes in the SUO or Local Limits? Yes
37. Were all industries in SNC published in the last notice? Yes
Permitting (Industrial Waste Survey-IWS)
38. How does the POTW become aware of new or changed Users? Contacted by City Hall
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 W WTP and therefore require a new permit or a permit revision? ( Who is an
SIU?) IWS, sampling, request similar data. Existing sources > wants to see actual data
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate? No
41. Does the POTW accept waste by (mark if applicable) NA
42. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples drawn,
manifests required) N/A
43. How does the POTW allocate its loading to industries? Historical Industry Need
44. Review POTW's copies of current allocation tables for each W WTP. Are there any over allocations? No
45. If yes to #44, What is being done to address the over allocations? (short-term IUPs, HWA to be revised, pollutant study, etc.)
N/A
46. Does the POTW keep pollutant loading in reserve for future growth / safety? Yes
If yes, what percentage of each parameter 20% No need for most. Have taken some back from IUs not using allocation
47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) No
If yes, Explain.
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)
Any NPDES limited paraments, POCs that have caused concern (e.g. surfactants), categorical
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Meet minimum. 3x/month for surcharge parameters, quarterly for LTMP POCs
NC DWR Pretreatment Audit Form Revised: December 2016 Page 3

Permit Compliance
50. Does the POTW currently have or during the past year had any permits under adjudication? 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. Results compared to limits as data comes in — NOVs sent as
necessary. Every 6 months do calculation for SNC and review all data again to make sure no violations were missed.
52. Does the POTW use the Division's model inspection form or equivalent? Yes
53. Were all SIUs evaluated for the need of a slug/spill control plan during their most recent inspections? Yes
54. What criteria are used to determine if a slug/spill control plan is needed?
Flow, waste type, waste concentration, type and method of storage for stored materials
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Reviewed by City's contract engineers
56. How does the POTW decide where the sample point for an SIU should be located?
Reviewed by contract engineers to make sure all wastewater is accounted for. Only that IU's flow, safety.
57. Has the POTW established a procedure to ensure that representative samples will be taken by the POTW or SIU each time?
(example: correct location; proper programming of sampler; clean equipment; swirling the sample bucket uniformly)
POTW: Yes SIU: ❑ Yes ❑ No If yes, Explain. Employees are trained on procedures
58. Who performs sample analysis for the POTW for Metals Microbac
Conventional Parameters Microbac
Organics Microbac
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Employees that collect samples fill out COC and place on sample coolers in lave for pickup by Micorbac.
Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis (HWA)
60a.
60b.
60c.
60d.
60e.
60f.
Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? Unknown
Are Correct Detection Levels being used for all LTMP/STMP Monitoring? Unknown
Is LTMP/STMP Data Maintained in Table or Equivalent? YES Is Table Adequate? Contract engineers keep
All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? YES
If NO to any above, list violations
Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? NO
If yes, which ones? Eliminated: Added:
61. Do you complete your own headworks analysis (HWA) ? No
If no, who completes your HWA? Davis and Floyd Phone [phone]
62. Do you have plans to revise your HWA in the near future? No
63. In general, what is the most limiting criteria of your HWA? Inhibition
64. Do you see any way to increase your loading in the future (Example: obtaining more land for sludge disposal)? Yes
Explain. Have plans already prepared to increase aeration capacity for increased BOD and TSS
65. Do you plan any significant changes to the pretreatment program or changes to the W WTP that may affect pretreatment?
Not now, but when necessary will implement plans to increase aeration capacity.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 4

INDUSTRIAL USER PERMIT IUP FILE REVIEW 3 IUP FILE REVIEWS AND I IU INSPECTION)
66. User Name
1. Cascade Molded Pulp
2. Perdue Farms
3. Trans Carolina
67. IUP Number
0012
0003
0014
68. Does File Contain Current Permit?
Yes
Yes
Yes
69. Permit Expiration Date
6/30/2021
6/30/2021
6/30/ 0021
70. Categorical Standard Applied I.E. 40 CFR, Etc. Or N/A
71. Does File Contain Permit Application Completed Within One Year Prior
Yes
Yes
Yes
to Permit Issue Date?
72. Does File Contain Inspection Completed Within Last Calendar Year?
Yes
Yes
Yes
73. a. Does File Contain Slug/Spill Control Plan?
a. Yes
a. Yes
a. Yes
b. If No, is One Needed? See Inspection Form from POTW
b. QYes ❑No
b. QYes ❑No
b. ❑Yes ❑No
74. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
Organic Management Plan TOMP ?
75. a. Does File Contain Original Permit Review Letter from Division?
a. Yes
a. Yes
a. Yes
b. All Issues Resolved?
b. N/A
b. N/A
b. N/A
76. During Most Recent Semi -Annual Period, Did POTW Complete its
Yes
Yes
Yes
Sampling as Required by IUP, including Flow?
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
Yes
Yes
Yes
78. During Most Recent Semi -Annual Period, Did SIU Complete its
Yes
Yes
Yes
Sampling as Required b HIP, including Flow?
79. During Most Recent Semi -Annual Period, Did SIU submit all reports on
Yes
Yes
Yes
time?
80a. For categorical IUs with Combined Wastestream Formula (CWF), does
file includeprocess/dilution flows as Required by IUP?
80b. For categorical IUs with Production based limits, does file include
production rates and/or flows as Required by IUP?
81. During Most Recent Semi -Annual Period, Did POTW Identify All
Yes
None
None
Limits Non -Compliance from Both POTW and SIU Sampling?
82. During Most Recent Semi -Annual Period, Did POTW Identify All
N/A
N/A
N/A
Re ortin Non-Com liance from SIU Sampling?
83. a. Was POTW Notified by SIU (Within 24 Hours) of All Self-
a.sometimes
a. N/A
a. N/A
Monitoring Violations?
b. Did Industry Resample and submit results to POTW within 30 Days?
b. Yes
b. N/A
b. N/A
c. If applicable, did POTW resample and obtain results within 30 days of
c. N/A
becomingaware of SIU limit violations in the POTW's sampling of SIU?
N/A
c. N /A
84. During Most Recent Semi -Annual Period Was SIU in SNC?
No
No
No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
Yes
N/A
N/A
Specified in POTW's ERP OVs, Penalties, timing, etc.)?
86. Does File Contain Penalty Assessment Notices?
N/A
N/A
NIA
87. Does File Contain Proof Of Penalty Collection?
88. a. Does File Contain Any Current Enforcement Orders?
a. N/A
a. N/A
a. N/A
b. Is SIU in Compliance with Order?
b.N/A
b.N/A
b.N/A
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
No
No
No
Information For You?
FILE REVIEW COMMENTS:
73. Cascade and Perdue last updated 2008; Trans Carolina updated 2011
89. Little bit on sampling data.
NC DWR Pretreatment Audit Form Revised: December 2016 Paee 5

INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
I NI CIO 10 12 10 14 17 17 1 16 111 119I
1. Industry Inspected: Cascade Molded Pulp
2. Industry Address:
3. Type of Industry/Product: pulp paper products (Drink trays and egg cartons)
4. Industry Contact: Jamie Mendoza Title: _ Phone: Fax:
5. Does the POTW Use the Division Model Inspection Form or Equivalent? Yes
6. Did the POTW Contact Conduct the Following Parts of the Industrial Inspection Thoroughly?
Comments:
A.
Initial Interview
Yes
_
B.
Plant Tour
Yes
evervthine goes to puloer
C.
Pretreatment Tour
Yes
clarifier > overflow water to dump tank, scum to vulper
D.
Sampling Review
Yes
_
E.
Exit Interview
Yes
Went over emergency notification: signs are posted Discussed Spill control plan —
Jamie working on updates to 2017 version. POTW has older version
Industrial Inspection Comments:
Post consumer raw material (newspaper, etc)
Had increase in BOD > traced to raw materials. Since China has stopped taking US solid waste, materials have more starch.
Have taken steps to ensure better grade of raw materials.
Audit SUMMARY AND COMMENTS:
Audit Comments:
Requirements: Provide LTMP data
Recommendations: Use spreadsheets to maintain SIU data.
NOD: No
NOV: No
QNCR: No
POTW Rating:
Satisfactory
Audit COMPLETED BY: Deborah Gore & Mond Hassan DATE: 6/13/2019
NC DWR Pretreatment Audit Form Revised: December 2016 Page.6