NC0021156_Correspondence_20221012

L serfiche
CITY of MOUNT HOLLY
400 East Central Avenue
Post Office Box 406
Mount Holly, NC 28120
704-827-4261
704-827-6306 Fax
Website: www.mtholly.us
Tuesday, October 11, 2022
To whom it may concern,
RECEIVED/NCDEQ/DWR
OCT 12 2022
WQROS
MOORESVILLE REGIONAL OFFICE
We have received the Notice of Violation dated October 4th, 2022. This letter is to address the NOV regarding the fecal exceedances
for (1) weekly average and the monthly average.
As stated in the July NOV letter:
On July 28th we received the first notice of a high fecal reading. This was weeks after the numbers started trending upwards. This was
due to the laboratory having a long lead time on reports, due to staffing issues. When we received the notification we took action and
increased the chlorine feed to the chlorine contact basins to help with high uptake of chlorine in the basin. We did notice at that same
time frame that the amount of nitrogen coming into the plant was elevated as well. We took action immediately and made changes to
fix this issue through the beginning of September of 2022.
When we made the changes at the end of July into August we were still receiving higher than normal fecal results from the lab. We
asked the lab for all the QC results for the fecal tests. At this time, we began using two laboratories for comparison checks to verify
that the lab data was correct and that there were no issues. After the first week of August we started using a spare aerator in the basins
to add more oxygen to the system to combat the amount of nitrogen corning into the plant at the time to see if that would help.
We continued to use multiple laboratories for fecal testing through the month of August so we have a comparison of results to show if
what changes that were made were working. Towards the end of the month after speaking with the lab representative we starting
testing and making flow proportional adjustments to see if the laboratory was getting false positives due to high chlorine feed rate.
At the end of August, we brought in equipment to clean the chlorine basins and while cleaning them we found a fair amount of algae
in the bottom of the basins. The algae was cleaned out and we put the basins back in service. We returned the basins to normal
operations. The following week after the cleaning we kept a close eye on the basins and started seeing higher than normal solids
numbers again and decided to bring the equipment back the following weeks and cleaned both chlorine basins again. With the second
cleaning events of each contact basin we verified bare concrete cleanliness.
While we had chlorine basins down for cleaning we brought in Piedmont chlorinators to help asses any possible issues with the
chlorine feed system and/or line leading to the basin. They found a fitting that had an issue and repaired the fitting and gave the
approval for the system.
The immediate actions that were taken were testing of individual chlorine contact chambers, quality checking the lab, using multiple
labs to verify results, multiple cleanings of the chlorine contact basins, check and repairs of chlorine and sulfur feed system.
Since these actions we have received fecal results from lab analysis for the month of September and the results show a back to
compliance trend for the months following this issue.
When we became aware that we would be out of compliance we made the phone call necessary to inform our state representative and
had to leave a voicemail. In addition, we followed that call with an email to verify the call. We have yet to receive a return email or
call regarding this issue
If you have any questions please feel free to contact me.
Best Regards,
Doug Shoutd
Division Manager orwastewater
City of Mount Holly
Office: (704)-827-4261
E-Mail Doug.shoutd@a,mtholly.us

ROY COOPER
Governor
ELIZABETH S, BISER.
Secretary
RICHARD E. ROGERS, JR.
Director
Certified Mail # 7018 3090 0001 2323 0744
Return Receipt Requested
Miles Braswell, City Manager
City of Mount Holly
PO Box 406
Mt Holly, NC 28120-0406
NORTH CAROLINA
Environmental Quality
October 4, 2022
SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY
Tracking Number: NOV-2022-LV-0708
Permit No. NC0021156
Mount Holly WWTP
Gaston County
Dear Mr. Braswell:
A review of the August 2022 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 Coliform, Fecal MF, MFC Broth, 8/20/2022 400 839.04 Weekly Geometric Mean Exceeded
44.5 C (31616)
001 Effluent Coliform, Fecal MF, MFC Broth, 8/31/2022 200 277.17 Monthly Geometric Mean Exceeded
44.5 C (31616)
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.
North Carolina Department or Environmental Quality 1 Division or Water Resources
Mooresville Regional Office' MO East Center Avenue, Suite 3011 Mooresville. North Carolina 28115
704.663,1699

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 Ori Tuvia of the
Mooresville Regional Office at 704-663-1699 or via Ori.TuviaPncdenr.gov.
Sincerely,
p' DocuSIgned by:
Ai 4Guw H P4444
"—F161 FB6DA2D84A3...
Andrew Pitner, P.G.
Assistant Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
Cc: WQS Mooresville Regional Office - Enforcement File
NPDES Compliance/Enforcement Unit - Enforcement File
North Carolina Department of Envhvnmental quality I Division of Water Resources
MoaresvIlleRegional Office I GIOEast Center Avenue,Suite 301I Mooresville. North Carolina28115
704.663,1699