WQ0014756_Response to NOD-2020-PC-0205_20200528

"Practical Engineering &
Environmental Solutions"
May 28, 2020
Mr. Lou T Snider
Regional Supervisor
Water. Quality Regional Operation Section
Division of Water Resources NCDEQ-WSRO
NC Department of Environmental Quality
450 West Hanes Mill Road Suite 300
Winston-Salem, NC 27105
2050 Northpoint Drive • Suite A
Winston-Salem, NC 27106
Phone: [phone]
Fax: [phone]
[e-mail]
Department of www.geotec.com
Environmental Quality
Received
JUIN 01 2020
Winston-Salem
Regional Office
Re: Notice of Deficiency (NOD-20020-PC-0205 dated May 4, 2020
Trinity American Corporation OSWWT
Wastewater Irrigation System Permit #W00014756; Glenola, Randolph County, NC;
Dear Mr. Snider:
On behalf of Trinity American Corporation (TAC), Geoscience and Technology, P.A. (GeoSci)
respectfully submits the following information in response to deficiencies noted in the review of
the Non -Discharge monitoring Reports-NDMR, Non -Discharge Application Reports-NDAR,
and the Groundwater Monitoring Reports-GW-59, for the period January 2019 to December
2019. A copy of the Notice of Deficiency (Notice) is attached to this document for reference.
1. Missing Groundwater Sampling Parameter Results: The missing parameters were
inadvertently left off of the sampling instructions for the samples collected on July 25, 2019 for
the WWTP Effluent annual sample. This mistake was corrected with the collection of WWTP
Effluent samples on August 21, 2019. It is unclear how the correct sample results were not
delivered to the correct regulatory office. In any event, when we were notified of the missing
data, the sample results were delivered via email to Mr. James Gonsiewski with the Winston-
Salem Regional Office on April 17, 2020. Notations correcting the omissions were attached to
the files concerning future sampling events.
2. Exceeding Monthly Flow: The daily discharge for the OSWWT did exceed the permitted
quantity for the month of December 2019. This is due to higher than average water usage, likely
from increased production personnel at the manufacturing facility related to holiday demand. In
addition, a flow meter calibration error discovered during system maintenance may have
attributed to the error as well. Increased maintenance of the meter has been implemented, as well
as water usage oversight.
NC Engineering # C-1179 NC Geology # C-185

Please contact us with any questions regarding this response at 336-896-1300, or by email to
[e-mail]
Sincerely,
GEOSCIENCE AND TECHNOLOGY, P.A.
enclosures: copy of the NCDEQ letter dated May 4, 2020
cc: Mr. Eric Drye, Trinity American Corporation
Trinity American OSWWT

ROY COOPER
Govemor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Dfrecw
Mr. Eric M. Drye - President
Trinity America Corporation
601 Old Thomasville Road
High Point, North Carolina 27260
is
NORTH CAROLINA
Envlronmenlal Quallry
May 4, 2020
Subject: Notice of Deficiency (NOD-2020-PC-0205)
Permit No. WQ0014756
Trinity American Corporation W WTF, Wastewater Irrigation System
Randolph County
Dear Mr. Drye,
A review of the self -monitoring data for the subject facility has been completed. This included
review of the Non -Discharge Monitoring Reports (NDMR), Non -Discharge Application Reports
(NDAR), and Groundwater Monitoring Reports (GW-59) for the period of January 2019 through
December 2019. The violations indicated below were revealed during this review:
NDMRReoorting Violations:
Sample Location parameter
Date Type of Violation Tracking Number
001 Solids, Total Dissolved 07/31/2019 Parameter Missing NOD-2020-PC-0205
001 Chloride (as CI) 07/31/2019 Parameter Missing NOD-2020-PC-0205
Exceed Permitted
001 Flow 12/31/2019 Monthly Average NOD-2020-LV-0086
Remedial actions, if not already implemented, should be taken to correct any noted problems. The
Division of Water Resources may pursue enforcement actions for this and any additional violations.
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 (SOC).
Please provide a response to this letter within 60 days of receipt by your office indicating the
corrective actions taken to address this violation. As a reminder, your permit requires that you
notify the Winston-Salem Regional Office of any non-compliance as soon as possible, but in no
case more than 24 hours from first knowledge of occurrence.
CrV CL�,�
.North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1 450 West Hanes Mill Road, Suite 300I WinstonSalem. North Carolina 27105
336,776.9800

If you have any questions concerning this matter or wish to apply for an SOC, please contact Jim
Gonsiewski of the Winston-Salem Regional Office at 336-776-9800.
Sincerely,
OxuSl�tl by;
Lon'�`�gn c%r; Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ - WSRO
----ec —Randolph- County Environmental Health (Electronic Copy) - - - --
Jeff Wyatt - Geoscience & Technology, P.A. (Electronic Copy)
WSRO Electronic Files
Laserfiche Files
Page 2 of 2