NC0001121_Corrective Action Plan_20180711

MATTH EW
LEWIS
EHS MANAGER
[e-mail]
910-308-6181
2100 WEST BROAD STREET
ELIZABETHTOWN NC 28337
ASST. REGIONAL SUPERVISOR
NORTH CAROLINA DIVISION OF AIR QUALITY
225 GREEN ST. SUITE 714
FAYETTEVILLE, NC 28301
Dear Asst. Regional Supervisor,
The following letter is SPT's response to the Notice of Violation &
Intent to Asses Civil Penalty we received from your office on
7/11/18.
Please see the letter for the corrective actions taken to comply with
our NPDES WW Permit.
Please contact me if you have any questions about this report.
Sincerely,
Matthew Lewis

Dear Asst. Regional Supervisor,
This letter is in response to the recently received notice of violation and intent to assess civil penalty. During
a recent review of our eDMR report DEQ flagged an exceedance that we self -reported on 1 1 /28/2017 for
Solids, Total suspended -concentration (CO530) and Quantity Daily (QD530). The sample was taken 1 1 / 17/ 17
and we notified Mark Brantley and Johnathan Watts at DEQ as soon as we received the results.
To correct this SPT reviewed all our recent tests and any recent activities in our waste water
treatment plant that could have contributed to this exceedance. What we found was two changes/events that
happened during the month of November could have contributed.
To provide you with better information preceding this exceedance SPT did analysis work on the Acute
Toxicity test in October with Chem Treat. We adjusted our treatment process to match their recommended
treatment process for the chemicals more closely. We began using the adjusted process in November, so the
operators were not yet completely familiar with it. We were also in the process of training and switching our
WWT operators since the original employee was scheduled to retire in December. The new operator had
recently started to work by himself in November 20 17. This operator received his PC-1 cert in September
2017 and continued his training in Q4 of 2017 to receive his final PC-2 cert in December. While neither of
these changes/events can be proven to directly tie to the occurrence on the NOV both could have affected
the TSS outcome.
In reviewing our records in the eDMR system, it shows that only two times in a year did we hit double digits
on our TSS testing and one of those was this NOV. The CO530 Limit value is 60 on our NPDES permit and

we average under 10 for the year 2018. We have not historically had any issues with falling under our
permitted TSS levels and have shown no continued issues.
Please take this information into consideration when you review our case and let us know if you have any
questions or concerns with our response.
Sincerely,
63aki Cuc-AkAi
Sally Creasy
Sr. Director of Operations
Specialty Product Technologies
Legal Entity: Dynapar Corporation
2 I 00 West Broad Street I Elizabethtown, NC 28337 I U.S.A.
Office: [phone]
Email: [e-mail]
airSPECIALTY
PRODUCT
TECHNOLOGIES
2

Water Resources
EN"vq.POIN, NT;a, QUAL5TY
Certified Mail # 7015 0640 0007 8168 9442
Return Receipt Requested
June 25, 2018
Jay Fuller, Director of Operations
Danaher Industrial Controls
2100 W Broad St
Elizabethtown, NC 28337
SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY
Tracking Number: NOV-2018-LV-0446
Permit No. NC0001121
Danaher Specialty Products WWTP
Bladen County
Dear Permittee:
ROY COOPER
Governor
MICH_A.EL S. REGAN
&'ecreta
LINDA CULPEPPER
Interim Dvector
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 Limit Reported
Location Parameter Date Value Value Type of Violation
001 Effluent Solids, Total Suspended - 11/14/2017 60 82 Daily Maximum Exceeded
Concentration (C0530)
001A Effluent Solids, Total Suspended - 11/14/2017 7.2 11.99 Daily Maximum Exceeded
Quantity Daily (QD530)
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 Environmental Quality l Water Resources
225 Green Street, Suite 714, Fayetteville, NC 28301-5043
910-433-3300

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