NC0035866_LV-2018-0082 Response_20180419

CHATHAM COUNTY PUBLIC UTILITIES & WATER
UTILITIES—Public Works Division �P�� M.C�Gyj. Phone [phone]
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RECEIVED/DEN F,,OWR
POST OFFICE BOX 910
PITTSBORO,N C 27312-0910 APR 24 2018
April 19, 2018 mi.Resources
`°nq Section
Wastewater Branch
Division of Water Resources,NCDEQ
1617 Mail Service Center, Raleigh,NC 27699-1617
Subject: Notice of Violation(NOV) and Assessment of Civil Penalty for
Violations of NC General Statute (G.S.) 143-215.1 (a)(6) and
NPDES WW Permit No.NC0035866
Bynum WWTP
Case No. LV-2018-0082
Chatham County
This letter is in response to the Notice of Violation(NOV) and Assessment of Civil Penalty for
Violations of NC General Statute (G.S.) 143-215.1 (a)(6) and NPDES WW Permit No.
NC0035866, Bynum WWTP, Case No. LV-2018-0082 dated Apri113, 2018 that our office
received the week of April 16, 2018.
The Fecal Coliform was sampled on 11/21/2017 and was out of compliance (1,600#/100ML).
The Fecal Coliform samples before and after that date returned to levels less than 1.0#/100ML.
A new bucket of chlorine tablets purchased through Promag Enviro Systems (British Columbia,
Canada) was opened and being used prior to the two non-compliance sample dates. The county
determined it could be a bad batch of the chlorine tablets. The tablets were dissolving at a very
slow rate. The county opened a new bucket and stop using the bad batch of chlorine tablets. The
Fecal Coliform sampling results have been less than 1#/100ML since disposing of the bad batch
of chlorine tablets. As a precaution the county hired Clark's Septic Service to pump out the
basins and the Aerobic Digester and reseeded the plant with healthy microorganisms from the
Town of Siler City's WWTP. We also re-trained our sampling staff on proper sampling
procedures to minimize the risk of outside contamination during the acquisition of the effluent
samples.
Chatham County's mission and goal is to properly and successfully treat the wastewater that
enters our Bynum WWTP and to stay in compliance with the rules and regulations set forth by
NCDEQ. Through continual evaluation and improvement of our standard operating procedures

CHATHAM COUNTY PUBLIC UTILITIES & WATER
UTILITIES—Public Works Division (4.,—M C�Gi1), Phone [phone]
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and best management practices the County will strive to consistently achieve this goal. Thank
you for your time.
Chatham County respectfully requests that any civil penalty be remitted due to the error in
manufacturing of the chlorine tablets.
Sincerely,
10
ty
Larry Bridges
Public Utilities Director

JUSTIFICATION FOR REMISSION REQUEST
Case Number: LV-2018-0082 County: Chatham
Assessed Party: Chatham County
Permit No.: NC0035866 Amount Assessed: $137 78
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
detnment 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 remaimng necessary remedial actions (i e, explain
how payment of the civil penalty will prevent you from performing the activities necessary to achieve
compliance)
EXPLANATION: 5 e Pr-TTA c.H Q Lt -T

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
COUNTY OF CHATHAM
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
) STIPULATION OF FACTS
Chatham County )
Bynum WWTP )
)
PERMIT NO NC0035866 ) CASE NO. LV-2018-0082
Having been assessed civil penalties totaling$137 78 for violation(s) as set forth in the assessment document of the Division
of Water Resources dated April 13,2018,the undersigned, desiring to seek remission of the civil penalty, does hereby waive
the nght 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
4 �V DD
This the 4 day of 6�� L , 20
1
ISIGNATURE 1
ADDRESS
9 tO DIST- 5 i,
50 2a
21 31 L
TELEPHONE
9 \cit. - LI2 - 7,3S

PERQUIMANS COUNTY
Perq arts Office of the Manager
„350th
P.O. BOX 45
166'8-2i118 " HERTFORD NORTH CAROLINA 27944
W.FRANK HEATH,III
TELEPHONE. [phone] COUNTY MANAGER
April 16, 2018
RECEIVED/DENR/DWR
State of North Carolina
Department of Environmental Quality APR 2018
Water Resources
Division of Water Resources Permitting Section
1611 Mail Service Center
Raleigh,NC 27699-1611
Re: NPDES Permit- Draft Review Comments
Permit NC0068861
Perquimans County WTP#1- PC-1
Bethel WTP
Perquimans County
Gentlemen:
While we realize the official time period for our comments on the referenced draft permit have
come and gone, we just recently realized that this proposed permit has a new chloride limit we
will not be able to meet. Our missing the official comment period is our mistake, but we wanted
to respond anyway.
We have reviewed the referenced draft NPDES permit and we have the following comments.
1. The proposed monitoring and limit for chlorides with a monthly average and daily
maximum of 230 mg/1 will require that we eliminate the ion exchange treatment process
at this water plant. We use mixed bed resin technology that utilizes a blend of cation and
anion resins that remove calcium and magnesium (hardness), as well as reducing the
Total Organic Carbon (TOC). The reduction in TOC allows us to comply with the 80 ppb
TTHM regulations. This proposed elimination of our ion exchange process constitutes an
enormous change in our ability to produce the quality of drinking water our customers
have been supplied for over 40 years, and while we are specifically requesting that this
Perquimans County's Vision:
To be a community of opportunity in which to live, learn, work,prosper and play

chloride limit be removed from the proposed permit, at the very least we would hope for
some extended period of time for compliance. The proposed permit does allow 4 years
for compliance, but while 4 years may seem like a reasonable time for compliance, a
change of this magnitude will take many years for us to analyze various options and to
design, fund, and construct.
We would like a response from DEQ, Water Resources that all ion exchange plants in
North Carolina that discharge into fresh water receiving streams will have the same
chloride limit as is proposed for this facility. We are asking for this assurance because we
have received two draft permits in the past few months (this subject one and the one for
our Winfall plant) and even they conflict on the time for compliance with this chloride
limit; they were apparently written by two different permit writers. If all the ion exchange
plants in the state receive these same chloride limits, it is our opinion that the state has
taken the position that ion exchange plants in this state will be eliminated at some time in
the very near future.
2. As regards the Discharge Alternatives Evaluation, Special Condition A.(3.), we have
asked on numerous occasions, both orally and in writing, for a list of ion exchange plants
in the state that discharge into fresh water receiving streams and which are successfully
passing the WET test. When we have asked, we have been assured that some are, and that
we will be receiving such a list in the near future. We have been asking for this list since
November 2, 2004 and have never received this list, and again, we are asking for this list.
We fully acknowledge that we do not know how to modify our ion exchange process or
the operation of it to pass a test which subjects a fresh water test organism to a 90%
concentration of our saline discharge. We have been told that 25% of the ion exchange
plants in the state are failing this WET test; apparently then, 75%must be passing it. If
you will send us this list, we will go visit some of these passing plants and see what they
are doing to comply.
Back in 2004, when this WET test was initially proposed in our draft permit, one of our
comments in the November 2, 2004 letter sent to your agency was to state that we were
sure we were going to fail this test; that we did not know how to modify our process to
meet it; and that we were specifically requesting technical assistance from your unit
advising us how to modify our plant to pass it. The referenced letter went on to request
that if technical assistance from your unit would not be forthcoming,that we were
specifically requesting that the WET test not be made a part of the permit. While we
received no detailed response to this comment, we did receive a permit that included the
WET test, which we have been regularly failing and for which we have received no
technical assistance from your unit. At the very least, a list of plants like ours that are
passing this test would be very helpful.
S. cerely /
'i1
ank Heath, ounty Manager
CC: Dyke Luben, P.E., PWS