NC0034452_staff comments_20190210

Weaver, Charles
From: Graznak, Jenny
Sent: Sunday, February 10, 2019 2:16 PM
To: Weaver, Charles
Subject: RE: Sand Filter at plant not maintained - Willow Creek NCO034452
As always, thank you, Charles. You are the wind beneath my wings Q
From: Weaver, Charles
Sent: Friday, February 8, 2019 2:38 PM
To: Graznak, Jenny <[e-mail]>; DiMatteo, Paul <[e-mail]>; Corporon, Joe
<[e-mail]>
Cc: Snider, Lon <[e-mail]>
Subject: RE: Sand Filter at plant not maintained - Willow Creek NCO034452
They need to fix and use the tertiary treatment. Otherwise they should request a permit mod.
If they don't fix it, it could change the facility rating. Check with Steve Reid / Maureen Kinney to discuss that.
CHW
From: Graznak, Jenny
Sent: Friday, February 8, 2019 1:24 PM
To: Weaver, Charles <[e-mail]>; DiMatteo, Paul <[e-mail]>; Corporon, Joe
<joe.corporon@ncdenr.�ov>
Cc: Snider, Lon <[e-mail]>
Subject: RE: Sand Filter at plant not maintained - Willow Creek NCO034452
Charles:
Are we correct in assuming that they will either need to fix and utilize the tertiary treatment or request for a permit
modification to remove the sand filter from their permit? Or would a permit mod not be required for that step?
Jenny Graznak
Environmental Specialist
Winston Salem Regional Office
Division of Water Resources
336-776-9695 office
336-403-7388 mobile
jenny.graznak(d_)ncdenr.gov
450 W Hanes Mill Road
Winston Salem NC 27105
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North Carolina Public Records Law and may be disclosed to third parties.
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From: Weaver, Charles
Sent: Friday, February 8, 2019 1:04 PM

To: DiMatteo, Paul <[e-mail]>; Corporon, Joe <[e-mail]>
Cc: Snider, Lon <[e-mail]>; Graznak, Jenny <[e-mail]>
Subject: RE: Sand Filter at plant not maintained - Willow Creek NC0034452
Paul —Joe has been out of the office for a couple of weeks. He's had surgery for an abdominal hernia and won't be back
for a while.
It sounds like the permittee is definitely not doing proper O&M. Both the lack of O&M and the bypass should be
addressed in the inspection report.
Send them an NOV for the bypass/O&M violations. They need to fix what they have and operate it properly.
You can use this issue as a factor when doing enforcements for limit / monitoring violations.
CHW
From: DiMatteo, Paul
Sent: Friday, February 8, 2019 10:41 AM
To: Corporon, Joe <[e-mail]>
Cc: Snider, Lon <[e-mail]>; Graznak, Jenny <[e-mail]>; Weaver, Charles
<[e-mail]>
Subject: Sand Filter at plant not maintained - Willow Creek NC0034452
Hi Joe,
I have a small plant with a tertiary sand filter (the only one for the plant) that has been bypassed/not maintained since
at least 2016. My thought is that they need to either request a permit modification to have the sand filter removed from
the treatment processes, or they need to maintain the component and use it. I think this is rightfully considered a bypass
("The known diversion of waste streams from any portion of a treatment facility ... which is not a designed or established
or operating mode for the facility.") and the permit prohibits bypasses except for those that do not cause effluent limits
to be exceeded "only if it is also for essential maintenance to assure efficient operation." Additionally, under Proper
Operation and Maintenance, the Permit requires them to "at all times properly operate and maintain all facilities and
systems of treatment and control (and related appurtenances) which are installed or used by the Permittee to achieve
compliance with the conditions of this permit."
Basically I'm wondering if you agree that this is something I should address in my inspection report.
Thank you!
Paul DiMatteo
Environmental Specialist
Division of Water Resources
Department of Environmental Quality
Winston-Salem Regional Office
450 W. Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
[phone] office
[phone] mobile
[e-mail]

N-C
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Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.