NC0056863_Pretreatment_Audit_NOV_Letter_20200113

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
NOR'. 1 CAROLINA
Environmental Quality
January 13, 2020
CERTIFIED MAIL 7016 2140 0000 4371 1223
RETURN RECEIPT REQUESTED
Ivey Knowles, Director of Public Utilities
Town of Rose Hill
PO Box 8
Rose Hill, NC 28458
Subject: Pretreatment Compliance Audit Report and Notice of Violation
NOV-2019-PC-0774
Failure to implement the Short Term Monitoring Plan
Program: Town of Rose Hill (NC0037508); Duplin County
Mr. Knowles:
On September 26, 2019, Tom Tharrington and Brian Lievre of the Wilmington Region Office and
Vivien Zhong of PERCS Unit conducted a Pretreatment Audit Inspection at the above referenced
wastewater treatment system. Carl Wheeler, the Pretreatment Coordinator and Jimmy Holland,
the Consultant, were present for the inspection. The purpose of this inspection was to determine
the effectiveness of the pretreatment program, which included: a detailed file review, review of
the POTW facility performance, sampling and compliance judgement program, adherence to the
enforcement response plan, and observing an industrial user inspection.
Please see attached audit report for more detailed information about the inspection. Findings
during the inspection are as follows:
1. The town has two Significant Industrial Users (SIUs) and neither are Categorical Industrial
Users (CIUs). Valley Proteins (IUP No. RH001) has not been discharging since April 2016.
The Town has completed all the sampling, inspection requirement for both SIUs. It was
also noted that no SIUs were in Significant Non -Compliance (SNC) in the two most recent
semi-annual periods.
2. Pretreatment Program Elements were not available for review during the inspection.
Headworks Analysis (HWA) and Industrial Waste Survey (IWS) were submitted on April
30, 2019 and February 13, 2019 respectively. More information was requested and had
not yet received until this date. An NOV (NOV-2019-PC-0571) was sent on August 6, 2019
North Carolina Department of Environmental Quality I Division of Water Resources
.W 512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617
NORTH CAROUNn
919.707.9000

and no response has been received. The STMP needs to be updated in regards to sampling
requirements/frequency and detection limits.
3. The review of STMP data indicated that only NPDES required parameters were sampled
and the Town has failed to properly implement the approved STMP for establishing a site -
specific HWA. The Division of Water Resources (DWR) has determined that the Town's
Pretreatment Program has failed to meet the minimum requirements as specified in 15A
NCAC 21-1.0905, NPDES permit conditions Part IV, D3 and 40 CFR 403.8(f).
4. Inspection forms for both SIUs could not be located duringthe Industrial User Permit (IUP)
files review. It is recommended to revise the inspection form to address questions in
Division's model inspection form (enclosed). The application for Duplin Winery (Permit
No. 111-1002) were one year after the permit issue date. Additional information for both
permit was requested and had not yet received, see NOV-2019-PC-0571. The detection
levels for chromium and copper needs to be lowered in Duplin Winery's POTW sampling.
Carefully review this violation and respond in writing to this office before January 31, 2020. You
should address the causes of noncompliance and all actions that will be taken to prevent the
recurrence of similar situations. Additional program documents must also be submitted by
January 31, 2020, including IWS, STMP, IUP renewal packages (including the renewed permits
with IU transmittal letters, signed applications within a year of permit issuance, most recent on -
site inspections and updated allocation table). Start STMP sampling the 1st quarter of 2020 and
submit an updated HWA by February 28, 2021.
The Division is considering recommending to the Director that further enforcement actions be
taken, including penalty assessments. If you have any supporting documents as to why further
action should not be taken, please provide that information in the required response.
If you have any questions or comments, please contact me at 919-707-3600 [email:
[e-mail]] or Vivien Zhong at 919-707-3627 [email: [e-mail]].
Sincerely,
Jeff Poupaa
Water Quality Permitting Section Chief
vz/ Rose_ Hill_ Audit_2019_NOV
Enclosures: RoseHillAudit9-26-19
SIU Inspection Form
EC: Tom Tharrington, Wilmington Regional Office
Carl Wheeler, Pretreatment Coordinator
Central Files (LF)
PERCS Unit