NC0044423_NOI2021LV0818_Case_Response_20211109

Recommend proceed with enforcement - TL 11/9/2021
From:
To:
Subject:
Date:
Attachments:
Daniel Gryder
Lowery, Patricia
[External] ASU Water Plant NOV-2021-LV-0818
Thursday, November 4, 2021 11:19:59 AM
NOV 11-2-21.pdf
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Ms. Lowery,
I am writing to you regarding the NOV we recently received for our wastewater discharge. As
we have previously discussed, below I have outlined the steps ASU is taking to remedy the
problem.
1. ASU has implemented a new discharge schedule to avoid running the plant during a waste
water discharge. When the backwash from the plant runs into the basin, the basin water gets
stirred up. ASU is now performing discharges when the plant is not running Additionally
this will help with the copper as ASU's wastewater discharge is located in close proximity to
the intake structure. It is believed that giving the wastewater time to disperse instead of
immediately pulling it back into the intake will help keep the copper from being recycled.
2. ASU has hired Dewberry Engineers to help come up with a solution to the high copper
problem. Dewberry has assisted ASU in forming 3 valid solutions to remove the copper from
the wastewater, or to keep from concentrating the copper in the lake around the intake
structure. These solutions are outlined in the permit modification request that was sent to
DEQ in July. During a recent discussion with DEQ, ASU and Dewberry decided that further
permit modifications would be required to attain compliance. An alternate proposal for
wastewater solutions was submitted by Dewberry to ASU and was accepted by ASU.
Dewberry is set to deliver the results of the new study in approximately 5 weeks. The
resulting information will then promptly be submitted to DEQ for review.
3. ASU recently had a meeting with several members from DEQ onsite at the water treatment
plant. During the meeting DEQ suggested a change in the sampling location. ASU has now
installed a sampling port that will be more in line with DEQ's suggestion.
4. Upon receiving notice from the plant operators that turbidity would be above the limits for
the month of August, ASU took action and installed a new turbidimeter in the wastewater
settling basin. ASU also purchased a YSI data logger to continuously log the turbidity in
NTU. The meter has been recording data since October 11. Once a baseline is established, an
aeration line will be added to the basin in an attempt to decrease the water density and drop
out suspended solids. The aeration line will not be installed until after November 11. It is
believed that this combined with the new sampling location will stabilize the turbidity levels in
the basin.
5. ASU has recently hired a wastewater management company to pump and remove the CIP
backwash water from the plant. This wash cycle contains the most highly concentrated copper
and zinc. In the past, this CIP wastewater has been added to the regular plant backwash
water. ASU will no longer release the CIP wastewater into the wastewater basin as long as the
removal cost can be justified. In time, the net removal of metals from the system is expected
to help bring the copper and zinc levels into compliance.

We at the ASU Water Plant are highly committed to protecting the water quality of our basin,
and will continue to strive for excellence in all aspects of water treatment.
Please let me know if there is any other information I can provide for you.
Thanks,
Daniel Gryder

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Dale Street
1e, NC 28608
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ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Qualify
Certified Mail # 7018-1130-0000-1612-5037
Return Receipt Requested
November 2, 2021
Daniel Gryder
Appalachian State University
265 Dale St
Boone, NC 28608
SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY
Tracking Number: NOV-2021-LV-0818
Permit No. NC0044423
Appalachian State WTP
Watauga County
Dear Permittee:
A review of the August 2021 Discharge Monitoring Report (DMR) for the subject facility revealed the violation(s)
indicated below:
Limit Exceedance Violation(s):
Sample
Location Parameter Date
Limit Reported
Value Value Type of Violation
001 Effluent Copper, Total (as Cu) (01042) 8/18/2021 5.2 10 Daily Maximum Exceeded
001 Effluent Turbidity (00070)
8/18/2021 10 16.3 Daily Maximum Exceeded
001 Effluent Zinc, Total (as Zn) (01092) 8/18/2021 63 74 Daily Maximum Exceeded
001 Effluent Copper, Total (as Cu) (01042) 8/31/2021 4 10 Monthly Average Exceeded
001 Effluent Turbidity (00070)
8/31/2021 10 11.1 Daily Maximum Exceeded
001 Effluent Zinc, Total (as Zn) (01092) 8/31/2021 63 74 Monthly Average Exceeded
D_E
North Carolina Department of Environmental Quality I Division of Water Resources
Wlnsmo-SalemRegional Office 1450 West Hanes Mill Road Suite 300 Winston-Salem, North Carolina 27105
336.776,g800

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.
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 days 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 planned maintenance activities, taking units off-line, etc.
If you have any questions concerning this matter or to apply for an SOC, please contact Tricia Lowery of the
Winston-Salem Regional Office at 336-776-9691.
Sincerely,
1- DocuSigned by:G
145B49E225C94EA...
Lon T. Snider, 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
Laserfiche
DQ
North Carolina Department of Environmental Quality I Crrision of Water Resources
Winston-Salem Regional Office 1450 West Hanes Mill Road, Svire 300 1 W Insmn-Salem, North Carolina 27105
336.7769800