NC0037508_Compliance Audit Report & NOV_20201008

ROSE 11th
Iretorivriardi
TOWN OF "ift ROSE HILL
NORTH CAROLINA
Homr of the Ytrortd's I.nrRest F►ving Pan
October 8, 2020 RECEIVED
Raleigh Mailing Address: OCT 1 2 2020
1617 Mail Service Center
Raleigh,NC 27699-1617 NCDEQ/DWR/NPDES
Wilmington Mailing Address
127 Cardinal Drive Ext.
Wilmington,NC 28405
REF: January 13, 2020
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. Jeff Poupart, Water Quality Permitting Section Chief:
I apologize for the tardiness in directly responding in writing to the above-referenced letter (copy
attached). A series of events occurred since the 26 SEP 2019 inspection visit. I shall be brief and list
them:
1.) Prior to the inspection occurring, the Town Administrator, Bobby Cavanaugh, who also had
closely worked with the pretreatment consultant, Jimmy Holland, left the Town's
employment on 21 AUG 2020;
2.) Mr. Ralph Clark was hired as Interim Administrator on 12 SEP 2019;
3.) I, John Bauer, was hired as Administrator on 22 JAN 2020;
4.) Prior to my appointment, during the NOV elections, there was a complete turnover in the
Town Board, except for one position.
5.) In short, there was five-month time frame when technical and administrative issues were in a
state of flux. In fact, it was only during early FEB 2020 that I became aware of the 13 JAN
2020 NOV letter which was addressed to Mr. Knowles, Public Utilities Director and Mr.
Wheeler. Mr. Wheeler is referenced in the letter as the "Pretreatment Coordinator"; he is
and has been the ORC for the Town's Class II Wastewater plant, but he has had no formal
pretreatment training.
Let me stop for one second and request DEQ officials to send future correspondence to Rose
Hill to the Town Administrator John Bauer, Mayor Clayton Herring, Jr., Mr. Ivey Knowles,
Director of Public Utilities, and Mr. Carl Wheeler, ORC-Wastewater Treatment. These
individuals will immediately act upon such correspondence after discussing amongst
themselves. I would also add David Honeycutt of McGill Associates to the cc list. This will
prevent a re-occurrence of this situation.
103 SE Railroad Street, P.O. Box 8, Rose Hill, N.C. 28458
Telephone [phone]-Fax [phone]
www.townofrosehilInc.com

•
After I became aware of the letter, action was initiated to answer its findings. In short,the Town
terminated the agreement with Jimmy Holland, the Consultant (who was present during the
inspection) due to non-performance and hired McGill Associates by Request for Qualifications;
this action took Town Board approval.
We then began issuing Task Orders to McGill (copies attached) to immediately address the
findings in the 13 JAN 2020 letter. I sign off on the task orders as does the Public Utilities
Director and the ORC. Everyone is more involved now and we intend to keep it that way to get
in compliance and stay there.
Toward that end,this is what McGill has done and the Town has compensated them for:
• Assist with preparing Pretreatment Annual Report and submitted report on March 31, 2020,
which was approved on May 27, 2020.
• Submitted a revised STMP on May 27, 2020, and additional revision on September 1, 2020
• Submitted updated Industrial Waste Survey on June 1, 2020, which was approved
on September 14, 2020.
• Worked with Town to locate the SIU permits and application files. Updated the previous
HWA with current SIU permit information. Assisted Town to drafting transmittal letters
since documentation of previous transmittal couldn't be located. Assembled all information
and submitted SIU Permits and supporting documents on August 19, 2020.
McGill plans, per the scope to modify the enforcement response plan to address the Dental
Amalgam rule. Since a current copy of the plan cannot be located, McGill will provide a new
enforcement response plan prior to October 21 for review and submittal.
I know we experienced certain delays caused by quarantining over COVID during MARCH and
APRIL; I personally worked from home for much of this time frame or came into the office and had
minimal contact with employees. Still work was accomplished by McGill and Mr. Wheeler.
On May 27, 2020, Mr. Wheeler received the Pretreatment 2019 Annual Report Review (copy
attached) which stated that this PAR"is in good order and satisfies the requirement of 15 A NCAC
2h.0908 (b)"
Mr. Wheeler has been responsible for operating the WWTP and previously solely taking
pretreatment samples while the Consultant (Mr. Holland) was supposed to perform the more
technical and administrative duties. We are now committed to having Mr. Wheeler work with
McGill as well as take formal pretreatment classroom training. He will also have all hard copies
electronically filed at the WWTP site. (His computer crashed a month ago; he has been supplied a
newer computer).
In 2020, Mr. Wheeler is pulling the HWA quarterly sampling required for permit renewal. The
samples have been pulled for the first 3 quarters of the year and submitted on the eDMR reports on
the dates as follows: (3/19/20, 4/30/20, 7/21/20). He still has to pull the last quarter HWA set. The
kit was delivered yesterday on 10/7/20 and will be submitted onto the October 2020 eDMR when he
gets the results.
103 SE Railroad Street, P.O. Box 8, Rose Hill, N.C. 28458
Telephone [phone]-Fax [phone]
www.townofrosehillnc.com

Once these sampling requirements are met, the plan is to have everything that has been requested
and required to be updated by the deadline given of February 28, 2021.
I hope the above and the attachments adequately address the 13 JAN 2020 findings. We will not
have a repeat now that we are all communicating better. Our focus has been on getting in
compliance and I believe we are very close to achieving that status.
Respectfully, ,� )
eyelfIN)
John Bauer
Town Administrator
cc: Michael Montebello,NCDENR
Dana Folley,NCDENR
Tom Tharrington,NCDENR
Diana Yitbarek,NCDENR
Helen Perez,NCDENR
Bryan Lievre,NCDENR
Kristin Litzenberger,NCDENR
Jeff Pourpart,NCDENR
David Honeycutt, McGill&Associates
Carl Wheeler, Rose Hill WWTP
Ivey Knowles, Rose Hill Public Utilities Director
103 SE Railroad Street, P.O. Box 8, Rose Hill, N.C. 28458
Telephone [phone]-Fax [phone]
www.townofrosehillnc.com

TASK ORDER NO.3
This TASK ORDER NO. 3 dated the 28th, day of July, 2020, is a supplement to the MASTER
SERVICES AGREEMENT between the Town of Rose Hill, North Carolina, dated April 29,2020
hereinafter referred to as OWNER and McGill Associates, P.A., hereinafter referred to as
"ENGINEER". The purpose of this Task Order is to authorize the ENGINEER to provide services
for the "PROJECT"entitled: 2020-2021 Pretreatment Program Assistance.
SECTION 1 -PROJECT DESCRIPTION
The project can generally be described as: Assisting the Town on an as-needed basis in
managing the implementation of its Wastewater Treatment Plant Pretreatment Program.
SECTION 2 -SCOPE OF SERVICES
The Engineer shall provide all professional services (the "Services") for the Project including,
performance of the following:
• Assist Town to work with the North Carolina Department of Environmental Quality,
Pretreatment Emergency Response and Collection System (PERCS) Unit to address
revisions required for the Pretreatment Program.
• Update the Emergency Response Plan as required for the Dental Amalgam Rule.
• Update Headworks Analysis and Allocation Table and submit to the PERCS Unit for review.
• Assist with any revisions to Industrial User Permits Required based on completion of the
Headworks Analysis.
SECTION 3-COMPENSATION
Owner shall pay Engineer for services outlined in Task Order No. 3 on an Hourly Basis, Not-to-
Exceed $4,000 for a period from July 1, 2020 through June 30, 2021 in accordance with our
contracted Hourly Rate and Fee Schedule and based on the Scope of Services as outlined.
Alterations in scope will be addressed with Task Order modification.

SECTION 4-MISCELLANEOUS
Except as otherwise provided herein, this Task Order supersedes all prior written or oral
understanding of the parties and may only be changed by a written amendment executed by both
parties.
SECTION 5 -AUTHORIZATION TO PROCEED
IN WITNESS WHEREOF, and as AUTHORIZATION TO PROCEED the parties execute below
this Task Order No. 3 in duplicate originals:
EXECUTED this `day of July, 2020.
McGill Associates, P.A.
/.
Michael A. Norton, P:E.
Shallotte Office Manager
Town of Rose Hill
By: C _ attt-z-----
John Bauer
TowlkAdministrator
This instrument has been pre-audited in the manner required by the Local
Government Budget and Fiscal Control Act.
B :y.
Johf Bayer
Bu ge fficer
Page 2 of 2

•
PURCHASE ORDER PO Number
Town of Rose Hill
103 S E Railroad St 65
Rose Hill NC 28458 PO Date: 07/30/2020
Ship Date
Vendor: Ship To: Est Receipt
McGill Associates,P.A.
P.O.Box 2259
Asheville NC 28802
Dept: 7140-WASTEWATER MAINT. Group
Ship ShipVia: Num of Days:
Terms ShipOn: FOB:
Pay Due Timeframe If Days/Disc
Terms I Due/Days Discount
GL Acct Stock# Item Description Qty Price Item Total
30-7140-4500 I I Task Order#3 2020-2021 Pretreatment program I 1 I $4,000.00 I $4,000.00
Total Purchase Order Amount: $4,000.00
Additional Instructions `This disbursement has been approved a I1
requir ny the Local Government Budg N
and Fiscal Control Act."
This Instrument has been preaudited in the manner required bythe
e Local Government Budget and Fiscal Control Ac
t.

Invoice Information
Town of Rose Hill
10/07/2020 12:28 PM 1
Page: 1 of 1
Vendor: McGill McGill Associates,P.A.
Invoice: 20.07051-9338 pre-treatment program fy20/21
Manual PO: Batch 9153
Inv Date: 09/23/2020 QPSL Status: Closed Inv Amt: $650.50
Due Date: 09/23/2020 ❑1099 Dept: Tax Total: $0.00
Dist Date: 09/23/2020 ❑Tax Group: Inv Total: $650.50
Address: McGill Associates,P.A. P.O.Box 2259
Asheville NC 28802
Invoice Information
Source Code AP Post ID 2 Closed ID 2 Suspend ID
Source UserID Post Date 09/24/2020 Date Closed Date Suspend
Source Date 09/23/2020 Void Date Void ID Release Date
Invoice Amounts Open $0.00 Used $650.50 Cancelled
GL Account Description PO Num Amount Budget Avail
30-7140-4500 Task Order#3 2020-2021 Pretreatment 65 $650.50 $38,620.24
program

TASK ORDER NO. 2
This TASK ORDER NO. 2 dated the 4th, day of May, 2020, is a supplement to the MASTER
SERVICES AGREEMENT between the Town of Rose Hill, North Carolina, dated April 29, 2020
hereinafter referred to as OWNER and McGill Associates, P.A., hereinafter referred to as
"ENGINEER". The purpose of this Task Order is to authorize the ENGINEER to provide services
for the "PROJECT" entitled: 2019-2020 Pretreatment Program Assistance.
SECTION 1 - PROJECT DESCRIPTION:
The project can generally be described as: Assisting the Town on an as-needed basis in
managing the implementation of its Wastewater Treatment Plant Pretreatment Program.
SECTION 2 -SCOPE OF SERVICES:
The Engineer shall provide all professional services (the "Services") for the Project including,
performance of the following:
• Assist in Addressing Notice of Violation letters dated August 6, 2019 and January 13,
2020 including but not limited to the following:
o Update Short Term Monitoring Plan
o Review Industrial User Permits, revise as necessary and assist with state approval
and correct conveyance of permits
o Review Industrial Waste Survey information and update as required
o Work with the Town and the PERCS Unit to determine any other actions required
to bring the program into compliance.
• Note: Update of Headworks Analysis and Allocation Table are not included because these
tasks cannot be completed until all sampling for the Short Term Monitor Plan is completed
in the 4th quarter of 2020.
SECTION 3—COMPENSATION
Owner shall pay Engineer for services outlined in Task Order No. 2 on an Hourly Basis, Not-to-
Exceed $4,000 for a period from April 1, 2020 through June 30, 2020 in accordance with our
contracted Hourly Rate and Fee Schedule and based on the Scope of Services as outlined.
Alterations in scope will be addressed with Task Order modification.

SECTION 4 -MISCELLANEOUS
Except as otherwise provided herein, this Task Order supersedes all prior written or oral
understanding of the parties and may only be changed by a written amendment executed by both
parties.
SECTION 5—AUTHORIZATION TO PROCEED
IN WITNESS WHEREOF, and as AUTHORIZATION TO PROCEED the parties execute below
this Task Order No. 2 in duplicate originals:
EXECUTED this /.�'j'-k'day of May, 2020.
McGill Associates, P.A.
/
Michael A. Norton, P E.
Shallotte Office Manager
Town of Rose Hill
By:
JJ n BaUer
Tpwn Ajministrator
This instrument has been pre-audited in the manner required by the Local
Government Budget and Fiscal Control Act.
By: �� 1
Joh ler
B gfficer
,
Page 2 of 2

TASK ORDER NO. 1
This TASK ORDER NO. 1 dated the 30th, day of April, 2020, is a supplement to the MASTER
SERVICES AGREEMENT between the Town of Rose Hill, North Carolina, dated April 29,2020
hereinafter referred to as OWNER and McGill Associates, P.A., hereinafter referred to as
"ENGINEER". The purpose of this Task Order is to authorize the ENGINEER to provide services
for the "PROJECT" entitled: Pretreatment Annual Report Assistance.
SECTION 1 - PROJECT DESCRIPTION:
The project can generally be described as: Assisting the Town with Pretreatment Annual Report
submission.
SECTION 2 -SCOPE OF SERVICES:
The Engineer shall provide all professional services (the "Services") for the Project including,
performance of the following:
• Review Pretreatment Program with Town Staff and NCDEQ.
• Assist Town with preparation of Pretreatment Annual Report (PAR).
• Review completed documents with Town Staff and submit report to NCDEQ.
SECTION 3—COMPENSATION
Owner shall pay Engineer for services outlined in Task Order No. 1 on a lump sum amount of
$680.00.
SECTION 4 -MISCELLANEOUS
Except as otherwise provided herein, this Task Order supersedes all prior written or oral
understanding of the parties and may only be changed by a written amendment executed by both
parties.

SECTION 5—AUTHORIZATION TO PROCEED
IN WITNESS WHEREOF, and as AUTHORIZATION TO PROCEED the parties execute below
this Task Order No. 1 in duplicate originals:
EXECUTED this-36A day of April, 2020.
McGill Associates, P.A.
By: ,, �°r�r',� � r,%4
Michael A. Norton, RE:
Shallotte Office Manager
Town of Rose Hill
By: �Vt--- �C,L
J9Q n Ba er
Tbwn A ministrator
This instrument has been pre-audited in the manner required by the Local
Government Budget and Fiscal Control Act.
By:
IL.- 0 F _---
Jol}n Bab er
Budget Officer
Page 2 of 2

;iOY COOPER i ` !� 'el
Go;-error *A.3-1- 2MICHAEL S.REGAN . -'
•
Secretary 'Qrpy,,0
LINDA CULPEPPER NORTH CAROLINA
Director 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 harrington 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 r p etreatment 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 (SlUs) 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 SlUs. 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
I
North Carolina Department of Etwii or nientai Quality Um-i:.t,of Water 12esourcs
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1 n�v�,..mwewa.rrwb 9I9.707.9000

and no response has been received.The STMP needs to be updated in regards to sampling
requirements/frequency and detectionlimit
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 2H .0905, NPDES permit conditions Part IV, D3 and 40 CFR 403.8(f).
4. Inspection forms for both SIUs could not be located during the 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. RH002) 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.
he 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 Poupart
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

DoouSign Envelope ID:CDC8D25E-02EE-445F-94B8-323FAA4FB17C
ROY COOPER ti4
Governor , ,.
MICHAEL S.REGAN { T"
Secretory akeotkvigiA
S.DANIEL SMITH NORTH CAROLINA
Director Environmental Quality
May 27, 2020
Mr. Carl Wheeler, Pretreatment Coordinator
Town of Rose Hill
P.O. Box 8
Rose Hill, NC 28458
Subject: Pretreatment 2019 Annual Report Review
Program: Town of Rose Hill
Permit No. NC0056863
Duplin County
Dear Mr. Wheeler:
The Town of Rose Hill Pretreatment Annual Report (PAR) covering activities from January
through December 2019 was received on March 31, 2020. Our review indicates that this PAR is
in good order and satisfies the requirement of 15A NCAC 2H .0908(b) and the
Comprehensive Guidance for North Carolina Pretreatment Programs The next PAR will be due
on March 1, 2021.
Thank you for your continued support of the North Carolina Pretreatment Program. If you
should have any questions, please contact Helen Perez at [phone] or at
helen.perez(a�ncdenr.gov
Sincerely,
DocuSigned by;
7F 141E7386F3456.
Tom Tharrington, Assistant Regional Supervisor
Water Quality Regional Operations Section
Wilmington Regional Office
Division of Water Resources, NCDEQ
Cc: Upload to Laserfiche
North Carolina Department of Environmental Quality ! Division of Water Resources
. DE -;,-) Wilmington Regional Office 1127 Cardinal Drive Extension; Wilmington.North Carolina 28405
°4 1..alalGrdro r.taa dh /� 910.796.7215

DocuSign Envelope ID:57A9103A-B08C-4129-13BC3-D5ODB707DD42
Regional Pretreatment Annual Report (PAR) Review
Is the PAR on time? Does it have two copies?
Did they send any other submissions with it?
Included? ADEQUATE ? POTW noted Corrections? Regional Office: WIRO
Narrative ® YES ❑ NO ❑ NA ® YES ❑ NO ❑ NA POTW: Rose Hill WWTP
PPS Form ® YES ❑ NO ® YES ❑ NO NPDES Permit No. NC0056863
SNCR ® YES ❑ NO ® YES ❑ NO Report Period: 01/01/2019 to 12/31/2019
IDSF ❑ YES ❑ NO ❑ YES ❑ NO
Allocation Table ❑ YES ❑ NO ❑ YES ❑ NO LI Full ® Modified
Compliance Schedules ❑ YES ® NO ❑ NA ® YES ❑ NO ❑ NA For modified programs evaluate shaded
Public Notice ❑ YES ® NO ❑ NA ® YES ❑ NO ❑ NA items only. A Narrative is required for a
Program Information ® YES ❑ NO ® YES ❑ NO ® YES ❑ NO modified program only if there are SIUs
Historical SNC ® YES ❑ NO ❑ NA ® YES ❑ NO ❑ NA ❑ YES ® NO ❑ NA in SNC.
If No, check recommendation below;
1. Have at least 90% of SIU permits been issued within 180 ® Yes ❑ No ❑ Not req'd ❑ NOV ❑ QNCR ❑ NCP
days of expiration? (See Allocation Table). ❑ Civil Penalty
2. Were at least 80% of SIUs inspected? (See PPS Form) Yes No Assessment
❑ ❑ Not req'd ❑ NOV ❑ QNCR ❑ NCP
❑ Civil Penalty
3. Has effective enforcement been taken against industries in ❑ Yes Assessment
those causin ❑ No ® NA ❑ NOV ❑ QNCR ❑ NCP ❑ Civil Penalty
SNC, including g pass-through or interference? (See Assessment
Narrative and SNCR Form)
4. Does public notice cover all SIUs in SNC? ❑ Yes ❑ No ® NA ❑ NOV ❑ QNCR ❑ NCP
❑ Civil Penalty
Assessment _
Note: Exceptions should be explained in the comment section below:
h PAR complete. PPI needs to be updated as noted.
Fill in Values from PPS Form
. . (PCS data)
SSNC 0
FENF 0
JUDI 0
SVPU 0
IUPN 0
Reviewed By: Helen Perez I SOCS 0
Date: 05-27-2020
�_DocuS$gnec by:
44„1„,, Witt. 5/27/2020
10845B4A39694BE
Regional Pretreatment Annual Report Review
$cdccac598dbc$58FB2D0605744A76AAD384D4F30B56DF.docx 12