NCG590017_NOV2018LV0129_20180209

Facility: Lake Townsend WTP
Parameter
TOTAL SUSPENDED SOLIDS
DMR & NDMR REVIEW RECORD
Permit#: NCG590017 Pipe#: MonthNear: NOVEMBER2017
Monthly Average Violations
Permit Limit DMRVaIue %Over Limit Action Amount
30 mg/1 101.6 239% ) /00 0
Weekly/Daily
Violations
Date
Parameter
Permit Limit
LimitTvoe
DMRVaIue %Over Limit
Action
Amount
1116/17
TSS
45 mgll
Daily Max Exceeded
146
224%
M CrT-
100
11/6117
Turbidity
50 ntu
Daily Me)( Exceeded
63.7
27%
0\J o 1
a v o
11/20/17
TSS
45mgll
Daily Max Exceeded
57.2
27%
j01-
rn
P%d
Total:
Monitorina Frequency Violations
# of # of
Of
Date
Parameter
PermitFreauency
Values Values
Violations
Action
Amount
Rard Rptd
Total:
Grand Total:
216/2018 C:\Users\jfgraznak\OneDrive - State of North Carolina\Working On\20170321 D&ND DMR Review Record Copy
1:10 PM 20170321 D&ND DMR Review Record Copy, With Formulas

past
Remarks:
'zpfaj-
N'/olat 0'
dQ & C
44�1 61, a,/-
Completed by: JENNY GRAZNAK
Assistant Regional
Supervisor Sign Off:
Regional Supervisor
Sign Off: -k kl��C'J-
VI-'4A"
� I cl I lycam„ t
-
Date: 216/18
Date:
Date: 7ZI
216/2018 C:\Users\jtraznak\OneDdve - State of North CarolinaMorking On\20170321 D&ND DIVIR Review Record Copy
1:10 PM 20170321 D&ND DIVIR Review Record Copy, With Formulas

§(((((��
|\|\0
\
\
\
\
\
\
§
]
|
«
z
z
«
w

Certified Mail # 7013 1710 0002 1865 6761
Return Receipt Requested
February 9, 2018
Steven Drew, Division Manager Operations
City of Greensboro
2602 S Elm -Eugene St
Greensboro, NC 27406-9787
SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY
Tracking Number: NOV-2018-LV-0129
Permit No. NCG590017
Lake Townsend WTP
Guilford County
Dear Permittee:
A review of the November 2017 Discharge Monitoring Report (DMR) for the subject facility revealed the
violation(s) indicated below:
Limit Exceedance Violation(s):
Sample
Location Parameter
Limit Reported
Date Value Value Type of Violation
001 Effluent Solids, Total Suspended - 11/6/2017 45 146 Daily Maximum Exceeded
Concentration (CO530)
001 Effluent Turbidity (00070) 11/6/2017 50 63.7 Daily Maximum Exceeded
001 Effluent Solids, Total Suspended - 11/20/2017 45 57.2 Daily Maximum Exceeded
Concentration (C0530)
001 Effluent Solids, Total Suspended - 11/30/2017 30 101.6 Monthly Average Exceeded
Concentration (CO530)
A Notice of Violation/Intent to Issue Civil Penalty is being issued for the noted violation of North Carolina General
Statute (G.S.) 143-215.1 and the facility's NPDES WW Permit. Pursuant to G.S. 143-215.6A, a civil penalty of
not more than twenty-five thousand dollars ($25,000.00) may be assessed against any person who violates or
fails to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S.
143-215.1.
State of North Carolina I Environmental Quality I Water Resources
450 West Hanes Mill Road, Suite 300, Winston-Salem, NC 27105
336-776-9800

If you wish to provide additional information regarding the noted violation, request technical assistance, or
discuss overall compliance please respond in writing within ten 10) business day after receipt of this Notice. A
review of your response will be considered along with any information provided on the submitted Monitoring
Report(s). You will then be notified of any civil penalties that may be assessed regarding the violations. If no
response is received in this Office within the 10-day period, a civil penalty assessment may be
prepared.
Remedial actions should have already been taken to correct this problem and prevent further occurrences in the
future. The Division of Water Resources may pursue enforcement action for this and any additional violations of
State law. If the violations are of a continuing nature, not related to operation and/or maintenance problems,
and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by
Consent.
Reminder: Pursuant to Permit Condition 6 in Section E, the Permittee is required to verbally notify the Regional
Office as soon as possible, not to exceed 24 hours, from first knowledge of any non-compliance at
the facility including limit violations, bypasses of, or failure of a treatment unit. A written report may
be required within 5 days if directed by Division staff. Prior notice should be given for anticipated or
potential problems due to plannedmaintenance activities, taking units off-line, etc.
If you have any questions concerning this matter or to apply for an SOC, please contact 3enny Graznak of
the Winston-Salem Regional Office at 336-776-9800.
Sincerely,
Sherri V. Knight, P.E., Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
Cc: WQS Winston-Salem Regional Office - Enforcement File
NPDES Compliance/Enforcement Unit - Enforcement File
State of North Carolina I Environmental Quality I Water Resources
- 450 West Hanes Iviill Road, Suite 300, Winston-Salem, NC 27105
336-776-9800

nlnl/—�n)k_) v_nfa
■ Complete items 1, 2, and 3.
■ Print your name and address on the reverse
so that we can return the card to you.
■ Attach this card to the back of the mailpiece,
or on the front if space permits.
t. Article Addressed to:
Steven Drew
City of Greensboro
2602:S. Elm -Eugene Street
Greensboro, NC 27406-9787
❑Agent
❑Addressee
B. Received by ' ted Name) C. Date of Delivery
D. Is deIlvW.addi 3l&ai grii iit letn 17 ❑ Ye:
If 1'0gry{epgglip�'sfGrd%@I 4'L•j/ ❑ No
13A` AC
9590 9402 3174 7' 8404 43 0
❑a
2.p
7013 1710 0002 1865 6761
PS Form 3811, July 2015 PSN 7530-02-000-9053
na
VJirsion-. "n
EI
ivory ❑
m ❑
DellWly ❑
Domestic Return Receipt
ri
� F F tee 9a'Y t J S E
Ln
-n Postage $
ra Ceditied Fee
ru Postmark
Re tum Receipt Fee Here
(Endorsement Required)
C3
p Restricted Delivery Fee
yE_ndorsement Required)
C3 6,5(0
r9 Total Postage & Fees Cr
r`-
3eatTo Steven Drew
r9 Stieei,ApCNi City of Greensboro --
0 orPo6exNo. 2602 S. Elm -Eugene Street _
M1 ciry siere,-zil Greensboro, NC 27406-9787
Y

Graznak, Jenny
From: Harney, Dell <[e-mail]>
Sent: Monday, February 26, 2018 6:59 PM
To: Knight, Sherri
Cc: Graznak, Jenny
Subject: [External] City of Greensboro NOV
Attachments: Townsend Discharge NOV_Feb2018.docx
Sherri V. Knight,
Please seethe attached Word document for response to NOV-2018-LV-0045 & NOV-2018-LV-0129. I apologize for any
confusion created on my part. My office number is listed below and my cell phone number is 336-430-6240. Please call if
I can help in any way.
Dell L. Harney
Water Supply Manager
City of Greensboro Water Resources
1041 Battleground Ave
Greensboro, NC 27408
Phone: [phone]
Please note that email sent to and from this address is subject
to the North Carolina Public Records Law and may be disclosed to third parties.

Sherri V. Knight, P.E., Regional Supervisor 26February, 2018
Water Quality Regional Operations Section
I spoke with Jenny Graznak today regarding NOV's sent to the City of Greensboro for our discharge
permit NCG590017 at the Lake Townsend Water Treatment facility located at 6268 Bryan Park Road,
Greensboro, NC. She instructed me to send you this message documenting the circumstances regarding
NOV-2018-LV-0045 and NOV-2018-LV-0129.
I spoke with Mr. George Smith, Assistant Regional Supervisor, in Early October 2017 about normal
maintenance operations at the Lake Townsend facility involving dredging of the process waste lagoon.
We had exceeded the daily process Maximum values for total suspended solids concentration for our
October 4th, 2017 discharge sample. The dredging of the lagoon had commenced on 9/27/2017 and the
TSS exceedance was our first indication of the effect that the normal maintenance operation was having
on discharge quality. I described to Mr. Smith the proactive measures we had taken to reduce solids
carryover during the maintenance activity, which included multiple buoyed curtains deployed at the
discharge end of the lagoon and visual inspections of the discharge on weekdays while the dredging was
ongoing. Mr. Smith's instructions to me were to continue with our twice monthly compliance samples,
to take measures to reduce solids at the discharge to the best of our ability and to complete the
dredging as soon as practical. I sent Mr. Smith an email documenting all of this. He told me that he
would put the documentation in the "file" for our discharge Permit so that it would be flagged while the
dredging of the lagoon was in progress
The second compliance sample for the month of October, 2017 and both compliance samples for
November, 2017 had exceedances for TSS and Turbidity. On all of these occasions, we inspected the
buoyed curtain walls and asked the contractor dredging the lagoon to cease work so that the effluent
could clear up. For each of these exceedances, I was under the impression that the City of Greensboro
was required to file the monthly report, indicating non-compliance, but that verbal reporting of them
was not required due to the Flag Mr. Smith put into the permit file. I apologize and accept full
responsibility if this was done in error.
The December 2017 and the January 2018 monthly reports both show that we were in compliance. The
normal maintenance dredging ends on Wednesday, February 28th
The January 2018 report has been certified by the Townsend ORC but I cannot submit the report on the
electronic reporting system site. I do not know if this is due to the site issues that Rodney Darr emailed
us about or if it is due to the NOV's. I was able to submit the monthly report for our N.L. Mitchell Water
Treatment facility. Any help would be appreciated.
Respectfully,
Dell Harney
Desk 336-373-7900
Cell 336-430-6240
cc Jenny Graznak