NC0020559_Pretreatment Compliance Inspection_20190723

ROY COOPER
Gov.:"rrrr
,MICHAEL S. REGAN
5rrr, nary
LINDA CULPEPPER
Drr. L:vr
NOPTH C-%rOLi*la
Environmental Quality
July 23, 2019
Mr. Lamont Allen
Director of Water Reclamation Facility
City of Henderson
P.O. Box 1434
Henderson, NC 27536
Subject: Pretreatment Compliance Inspection
City of Henderson Water Reclamation Facility
NPDES Permit No. NCO020559
Vance County
Dear Mr. Allen:
On July 17, 2019, Cheng Zhang of the Raleigh Regional Office (RRO) conducted a
Pretreatment Compliance Inspection of City of Henderson's pretreatment program. The
assistance given by Mr. Darrel Johnson, Pretreatment Coordinator of the facility, was
greatly appreciated. The inspection report is attached. Findings during the inspection
were as follows:
1. There is only one Significant Industrial User (SIU) discharging to the POTW,
which is not a Categorical Industrial User (CIU). It was noted that the SIU (Mars
Petcare) was not in Significant Nan -Compliance (SNC) for the two most recent
semi-annual periods.
2. The review of Long Tenn Monitoring Plan (LTINIP) data indicated that all
locations were sampled with required frequencies and all samples analyzed with
correct detection limits since last inspection. LTMP data were well maintained in
spreadsheets.
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3. A review of the files containing the pretreatment program elements was
conducted. All elements were up to date. Files were available and well organized.
The City may consider to update the Long Term Monitoring Plan (LTMP) since
lower detection limits are required for some metals.
4. Mars Petcare's pretreatment file (Permit No. 001 1) was reviewed during the
inspection. During the first semi-annual period of 2018, the SIU was in
compliance.
The City of Henderson's pretreatment program is very well managed. Thank you for your
continued support of the Pretreatment Program. If you have questions regarding to the
attached report or any of the findings, please contact Cheng Zhang at 919-791-4200 (or
email: cheng.zhang( ncdenr.gov).
Sincerely,
4 �
Rick Bolich, L.G.
Assistant Supervisor
Division of Water Resources
Raleigh Regional Office
Enclosure: City of Henderson PCl Form
CC: Monti Hassan, DWR - FPERCS Unit
Cheng Zhang - RRO
Central Files
Darrel Johnson - City of Henderson (electronic copy only)

NORTH CAROLINA DIVISION Or WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
BACKGROUND INFORMATIOti Wont lete Prior To PCI• Review Program Info Database Sheet S
I. Control Authority (POTW) Name. Cih• of Ilendersou
2. Control Authority Representative(s): Darrel Johnson 1 Lantont Allen
3. Title(s): Pretreatment Coordinator i Director, «'RF
4- Last Inspection Date; May 24, 2017 Inspection Type (Check One): ❑ PCI ® Audit
5- Has Program Completed All Requirements from the Pr"-ious 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 filet? ❑ YES ❑ NO
ICIS CODING
Main Pr ram Permit number %1.%l DD YN'
N I C 1 0 1 () 12 1 01 5 1 51 9 1 L-07 1 17 1 19
7. Current Number Of Significant Industrial Users (SI .-;)'?
I
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 Year'?
0
10. Number of SIUs Not Sampled B POTW in the Last Calendar Year?
0
11. Number of SIUs In SNC For Limits Violations Durin<e Either of the Last 2 Semi -Annual Periods?
0
12. Number of SIUs in SNC For Reporting During Either of the Last 2 Senhi-Annual Periods?
0
13. Number of SIUs in SNC with Pretreatment Schedule'?
0
14. Number ofSlUs on Schedules"
0
15. Current Number Of Categorical Industrial Users (CI Us)?
0
16. Number ofClUs in SNC?
0
POTW INTERVIEW
17. Since the Last PC[, has the POTW had any NPDES Limits Violations`?
® YES ❑ NO
If Yes, What are the Parameters and flow are these Problems Being Addressed?
3 19 ROD TSS; 119 pit: 4 18 BOD
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
S\C for Reporting:
Now
Public Notice?(May refer to PAR if Excessive SIUS in SNC)
Not Published:
None
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 [lie Division? None
J
21. Are Any Permits or Civil Penalties Currently Under Adjudication? I f Yes, Which ❑ YES 0 NO
Ones?
LT,NIP/ST1IP FILE REVIEW:
22. Is LTIVIP.:STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑ YO
23. Are Correct Detection Levels being used for all L-f MP1STNIP ivlonitoring? ® YES ❑ NO
24, Is LTNIP.;STIvIP Data Maintained in a Table or Equivalent? ® YES ❑ NO Is Table Adequate'? ® YES ❑ NO
25. All LIMP/STIVIP effluent data reported on Discharge Monitoring Report? ® YES ❑ NO Division Inspector, please verify- yourself?
26. If NO to 23 - 26, list violations
77• Should any Pollutants of Concern be Eliminated from or Added to LTNIP STNIV! ❑ VES ®NO
If yes, which ones? Eliminated: Added:
NC DWR Pretreatment Compliance Inspection (PCI) Forts Updawd December 2016 Page

28. PRETREATMENT PROCRAINT ELEINlENTS REVIEW- Piease rev-ievv POZ W files,,.•crify I'OTW has copy ofProbram Element in
their files, complete with supporting documents and cony of FRCS rknnroval Letter. and dates cansislent with Prnirrnni Infn-
Program Element
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Ileadworks Analysis (I1WA)
3/23/2017
Yes 0 No
6115/2017
0 Yes CTNO
4/1/2022
Industrial Waste Survey (RVS)
5/112017
Yes 0 No
6114/2017
El Yes 0 No
4/30/2022
Sewer Use Ordinance (SUO)
1 I/T2012
Yes No
11119/2012
Ye., No
Enforcement Response Plan (ERP)
10120.-2008
Yes No
1111912008
Yes No
Long Term Monitoring Plan (LEN].
1130.2017
Z Yes L1 No
4124/2017
Yes U No
INDUSTRIAL USER PERMIT (IUP) FILE REVIENV (3 IUP FILE REVIEWS OR I FILL REVILW AND l IU INSPECTION)
29. User Name
1. Mars Peteare
IF
2 IF
30. IUP Number
0011 IF
31. Does File Contain Current Permit'?
Yes No1.
Z Yes No 11
0 Yes Lj No
32. Permit Expiration Date
4i3/2022
33. Categorical Standard Applied (LE. 40 CFR. Etc,) Or N A
34. Does File Contain Pertnit Application Completed Within One Year Prior
® Yes NoFs"s
No
Yes No
to Permit Issue Date`?
35. Does File Contain an Inspection Completed Within Last Calendar Year?
Yes No
Z Yes Q No IFE
Yes 0 No
36, a. Does the File Contain a Slug/Spill Control Plan?
a. ®Yes ❑No
a. ®Yes ❑No
a. ®Yes QNo
b. If No, is One Needed'? (See Inspection Fonn from POTNV)
b. ❑1'es ❑No
b. ❑Yes ❑No
b. ❑Yes ❑No
37, For 40 CFR 413 and 433 TFO Certification, Does File Contain a Toxic
❑Yeti❑NoE 3
❑YccE)No®N A71
❑Yus❑NOON A
Organie Management Plan (TOMP)`?
38. a. Does File Contain Original Permit Review Letter from the Div ision?
a. ®Yes ON o
a. ®Yes ❑No
a. ®Yes ❑No
b. All Issues Resolved?
b.❑Yip❑�u❑� A
b ❑N uti❑`u❑N A
bzwoONo❑N A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
No
ti"es No
Yes No
its Sampling as Required b IUP, including flovy?
L��'e.,
40. Does File Contain POTW Sam limy Chain -Of -Custody Form;?
® Yes ❑ No
1'cs El No
Yes El No
41. During the Most Recent Semi -Annual Period, Did the SIU Complete its
l7Yuw❑No❑N
Ycs❑No❑` A
Sam ling as Required b [UP, including flow?
PE'
7�oON-'A
41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports
®Yes❑No❑
®Yes❑No❑N A
®Yes❑NOON-A
on time'?
42a. For categorical IUs with Combined Wastestream 1=ortuula (C1\'1-), does
❑N'LNONoON A
®Yes❑No❑` A
®1'es❑No❑N A
file include rocessldifution flows as Required by IL1P?
1[
42b. For categorical IUs with Production based limits, does file include
❑) 4:,0tio®N-A
BYcs❑No❑N A
ON'es❑No❑N'-A
roduction rates and:or flows as Required by IUP:'
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑tins❑No©N A
❑Yes❑No®N A
❑1'es❑N'oON A
All Limits Non -Compliance from Both POTW and SIU Sampling"
43h. During the Most Recent Semi -Annual Period, Did the POTW Identify
0Ye4❑NuE1N A
❑Yes❑No®N' r1
pYcs❑Na®N A
All Re ortin r Non -Compliance from SIU Sampling!
44. a. Was (lie POTW Notified by SIU (Within 24 1fours) of -All Self-
a-0Yea0Not7\ A
a.❑N-es❑`oON A
a.❑Yes❑NoGN A
Monitoring Violations?
b. Did Industry Resample and submit results to POTW Within 30 Days''
b.❑Yes❑`'oON A
b.❑Yeti❑'wMN A
b ❑Yes❑NnON A
c. If applicable, Did POT W resample within 30 days of becoming a\%arc
g
of SIU limit violations in the POTW's sampling of the SIU'?
c ❑yes❑Noov A
r.❑�-`❑�����.�
c ❑1'cs❑NomN ��
46. During the Most Recent Semi -Annual Period. Was the SIU in SNC?
❑ Yes ® No 11
❑ Yes ® No11
❑ Yes ®No
47. During the Most Recent Semi -Annual Period, Was Enforcement Faken
❑5'es❑No®N A
I[
❑Yes❑NoO*
❑Yes❑No®N'A
as Specified in the POTW's ERP (NOVs, Penalties, timing*. etc-):'
48. Does the File Contain Penalty Assessment Notices'?
❑Yes❑NOON A
01'cs❑NOON -A
49. Does The File Contain Proof Of Penalty Collection'
❑l'es❑vo®N A
0Yes0NoM1 A
01'cs0No0N-A
50. a. Does the File Contain Any Current Enforcement Orders!
a-❑Yeti❑NoGN A
a.❑Yes❑`umN A
I
a.❑Yes❑No®N A
b. Is SIU in Com liance with Order'?
b.❑Yes❑NtMN A
b.❑Yes❑tio®N �
b ❑Yes❑NaMN A
51. Did the POTW Representative Ilave Difficulty in Obtaining Any of l his
D Yes ®No
❑ Ye, MNo
Yes ED No
Requested Information For You'? 11
NC DWR Pretreatment Compliance Inspection (PQ Font Updated Ducember 2016 Pa-C 2

FILE REVIEW COMMENTS:
INDUSTRYINSPECTION ICIS CODING:
Main Program Permit Number
1. Industry Inspected:
?. Industry Address:
3. Type of Industry Product;
4. Industry Contact; Title;
MINI DD )')'
Phone; rax:
5. Does the POTW Use the Division Model Inspection Font or Equi%alent? ❑ YES ❑ NO
6. Did the POTW Contact Conduct the Following Parts of -tic Industrial Inspection 'I'huroughly!
Comments:
A. Initial Interview ❑ YES (IN 0
R. Plant -four ❑ 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: The Protaram is well managed.
Requirements; lone
Recommendations; LT�IP might need to he updated detection limits for several metals since new \ PDES vertnitivasrecently issued
NOD: ❑ YES 0 NO
NOV: ❑ YES ®NO
QNCR: ❑ YES ®NO
POTw Racine:
® Satisfactory ❑ Marginal ❑ UnSatisfactory
PCI COMPLETED BI': Chen Zhan Ralei,h Re *ional Office DA'I*E: J_alv I7. Zt119
NC DWR Pretreatment Compliance; Inspection (PCI) Form Updated December 2016 I'aiw 3