NC0023337_LV-2020-0216_20200831

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TOWN OF SCOTLAND NECK
P.O. Box 537
1310 MAIN STREET
SCOTLAND NECK, NC 27874 RECEIVED
August 31, 2020 SEP I 1 1010
Wastewater Branch NCDEQ/DWR/NPDES
Division of Water Resources
1617 Mail Service Center
Raleigh,NC 27699-1617
Subject: Remission Request
Town of Scotland Neck
Case No LV-2020-2014
Case No LV-2020-0216
Case No LV-2020-2018
NC0023337
Halifax County
Dear Wastewater Branch:
The Town of Scotland Neck is in receipt of three separate NOVs and Assessment of Civil Penalty
letters dated August 17, 2020. The NOVs were for the months of February, March and April of
2020. Because the violations in all three months are due to the same circumstances, the Town is
making a single response for the remission of the civil penalties. your letter of June 04,2019 that
transmits a NOV and assessment of civil penalty. We are requesting remission of the penalties
because we feel the violations was inadvertent and resulted in no environmental harm. To support
the remission request, we offer the following comments:
• The operation and maintenance of the wastewater treatment plant (WWTP) has been
contracted to a contract operations firm for approximately 16 years. The Town had relied
on their expertise and guidance, along with contract obligations,to maintain the WWTP in
good working order. The Town made the decision to terminate the operations contract
effective February 1, 2020. The Town had limited time to work with the contractor staff
and review WWTP operations prior to taking responsibility for the WWTP operations.
The Town quickly realized that there were major issues with the condition of the WWTP
and immediately began the process of identifying and correcting the deficiencies. Some of
the major issues identified after resuming operations of the WWTP include:
o Influent pump out-of-service
o Excessive Mixed Liquor Suspended Solids(MLSS)inventory in the oxidation ditch
o Brush Aerator in the Oxidation Ditch out-of-service and inoperable
"This Institution is an equal opportunity provider and employer"
www.townofscotlandneck.com
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o Return Activated Sludge (RAS)pump station out-of-service
o One Final Clarifier out-of-service
o Various components of the Tertiary Filters not operating properly
o Alkaline feed pump out-of-service
o Sludge Digester completely full of solids
o Several other system components and appurtenances were also either inoperable or
not in service.
With these many operational and mechanical challenges, the WWTP was having
compliance issues from the very first days of resuming operational control of the facility.
• The following comments pertain to the specific areas of violations listed in the three NOVs:
o Fecal Coliform — Upon resuming operations the WWTP, Town staff initially
continued the same operations as the contract firm which included operating only
one chamber of the chlorine contact basin. After receiving high fecal counts, the
second chamber was put in operation to extend contact time and the settled sludge
in the contact chamber removed. It was later discovered the chlorine feed line
between the chlorine pump and the chlorine contact basin had a hole in it,
preventing the proper amount of chlorine to be feed.
o Ammonia Nitrogen—The reduction of Ammonia Nitrogen(NH3)is very dependent
on Dissolved Oxygen levels, Alkalinity, and detention time. When the Town
assumed operations, the MLSS concentration in the Oxidation Ditch was over
8,000 mg/L and the digester was completely full of thickened solids. The Town
was not able to waste solids out of the system until arrangements were made to land
apply the accumulated solids. Running the aeration system continuously at the high
MLSS concentration would cause the clarifier sludge blanket to washout. Because
of this condition, the aeration system was operated at a reduced level that caused a
low dissolved level that negatively affected the nitrification rate. Staff also realized
that the caustic feed system was operating irregularly and not maintaining the
proper alkalinity residual for complete nitrification.
Now that the solids inventory has been reduced and the caustic system replaced,
ammonia nitrogen is now compliant.
o BOD5 — The reduction of BOD5 is also heavily dependent on dissolved oxygen
levels. Because of the same conditions as listed above for ammonia nitrogen,
proper dissolved oxygen levels could not be maintained in the oxidation ditch until
the solids inventory was reduced. Once the MLSS levels were reduced to a level
that allowed the aeration system to be run as needed, the BOD5 results have been
compliant.
• Since resuming operation in February,the Town has funded the following projects:
o $14,000.00 Control Panel and RAS Pump
o $ 4,500.00 Tertiary Filter Pump Repair

o $20,000.00 Sludge Removal via Land Application
o $14,000.00 Influent Pump
o $ 1,200.00 Consultant Fees
o $ 1,200.00 Caustic Pump
o $200,000.00 Generator
o The approved budget for this fiscal year includes $75,000.00 for repairs and
maintenance. We are currently receiving quotes for the following:
• $13,000.00 Digester recirculation pump
• $ 1,100.00 Final Clarifier worm drive
• Pending Aerator repairs/replacement
When the Town resumed operations of the WWTP, we had no idea that so many components
needed repair or replacement. Once we realized the severity of the situation, we have moved
forward in identifying and correcting problems. Our goal is to maintain compliance and to have
the WWTP operate as designed. Our efforts have been complicated to the COVID-19 restrictions
in both funding and scheduling on-site activities. Executive Order 124 has greatly impacted the
income into the Enterprise Fund and our available monies. Payment of the three civil assessments,
totaling $10,375.07,would greatly impact our ability to continue making needed improvements at
the WWTP. As you can see from the listed expenditures already incurred by the Town, we are
committed to making all needed improvements.
We thank you for your consideration in this matter. If you have any questions or comments,please
call Parks Boyd, WWTP Superintendent, at: 252/813-0873.
Sincerely,
ddie Braxton, Mayor
Town of Scotland Neck

JUSTIFICATION FOR REMISSION REOUEST
Case Number: LV-2020-0216 County: Halifax
Assessed Party: Town of Scotland Neck
Permit No.: NC0023337 Amount Assessed: $3,541.69
Please use this form when requesting remission of this civil penalty. You must also complete the "Request For Remission,
Waiver of Right to an Administrative Hearing, and Stipulation of Facts"form to request remission of this civil penalty.
You should attach any documents that you believe support your request and are necessary for the Director to consider in
evaluating your request for remission. Please be aware that a request for remission is limited to consideration of the five
factors listed below as they may relate to the reasonableness of the amount of the civil penalty assessed. Requesting
remission is not the proper procedure for contesting whether the violation(s)occurred or the accuracy of any of the factual
statements contained in the civil penalty assessment document. Pursuant to N.C.G.S. § 143B-282.1(c),remission of a civil
penalty may be granted only when one or more of the following five factors apply. Please check each factor that you
believe applies to your case and provide a detailed explanation,including copies of supporting documents,as to why the
factor applies(attach additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C.G.S. 143B-282.1(b)were wrongfully applied to the
detriment of the petitioner(the assessment factors are listed in the civil penalty assessment document);
(b) the violator promptly abated continuing environmental damage resulting from the violation(i.e., explain the
steps that you took to correct the violation and prevent future occurrences);
(c) the violation was inadvertent or a result of an accident(i.e., explain why the violation was unavoidable or
something you could not prevent or prepare for);
(d) the violator had not been assessed civil penalties for any previous violations;
( (e) payment of the civil penalty will prevent payment for the remaining necessary remedial actions(i.e., explain
how payment of the civil penalty will prevent you from performing the activities necessary to achieve
compliance).
EXPLANATION:

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
COUNTY OF HALIFAX
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
) STIPULATION OF FACTS
Town of Scotland Neck )
Scotland Neck WWTP )
)
PERMIT NO.NC0023337 ) CASE NO. LV-2020-0216
Having been assessed civil penalties totaling$3,541.69 for violation(s)as set forth in the assessment document of the
Division of Water Resources dated August 17,2020,the undersigned,desiring to seek remission of the civil penalty, does
hereby waive the right to an administrative hearing in the above-stated matter and does stipulate that the facts are as
alleged in the assessment document. The undersigned further understands that all evidence presented in support of
remission of this civil penalty must be submitted to the Director of the Division of Water Resources within thirty(30)days
of receipt of the notice of assessment. No new evidence in support of a remission request will be allowed after(30)days
from the receipt of the notice of assessment.
This the '61'4 day of , 20
SIGNA URE
ADDRESS
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