WQ0035049_NOV-2019-OV-0001 Response_20190314

PENDER COUNTY UTILITIES Kenneth Keel, PE, Director
605 E. Fremont Street
P C P.O. Box 995
Pender Cou ty Utilities
'nmQnamy Burgaw, NC 28425
Phone - 910.259.1570
Fax - 910.259.1579
March 14, 2019
RE: Maple Hill WWTF
Permit#WQ0035049
NOV-2019-OV-0001
Response
Ms. Morella Sanchez-King, Acting Regional Supervisor
NCDEQ-Division of Water Resources
127 Cardinal Drive Extension
Wilmington,NC 28405
Ms. Sanchez-King,
I have reviewed the issues noted in the Notice of Violation dated February 20, 2018 for the
Maple Hill WWTF. Pender County Utilities is working on the resolution of these violations
as follows:
• Backup ORC for SI and WW-2: We are completing the paperwork to replace our
previous Backup ORC for WW-2. Sal Speziale will become the Backup ORC (WW-
2) for the facility. We do not currently have a Backup ORC for SI but should have
one in place following the June exams.
• No field lab certification for pH testing_ Chris Pickett(Maple Hill WWTF ORC) is
working on gaining the necessary field certification for pH testing. Until he has his
certification, we will be working with our Chemist (Amy Cox), who already has this
certification, to ensure that the testing is done in an appropriate and approved
manner. pH will be tested under field certification# 5630 SWTP or 694 WWTP.
Unfortunately, we did not realize that this field certification was required for the pH
testing at this facility until our inspection was held on February 14, 2019.
• No gauge installed to measure freeboard in storage lagoon: We have been trying to
utilize a depth marker device made in-house, but it has not worked out as planned.
We are currently sourcing a gauge to be installed as soon as possible upon delivery.
• No operational or maintenance logs present: Chris Pickett has begun keeping a
written daily log to address this issue.
• No ORC for SI: Pender County does not presently have a certified Surface Irrigation
Operator on staff. Bryan McCabe previously served as SI ORC until he left
employment in April 2018. When I took over as Utilities Director in June 2018 and

NOV response to Ms. Sanchez-King
March 14, 2019
Page 2
realized we did not have an SI Operator, I had our then-Assistant Director Margaret
Gray call DEQ in Raleigh to inquire about the requirements. She was told that we
could just have our WW-2 ORC sign-off on the monthly reports. Based on
information received from Helen Perez during our February 141h inspection, I
understand that was not a complete answer to our situation and was just meant as a
short-term solution. I am registered for Surface Irrigation System Operator Training
School in Raleigh next week. Chris Pickett has taken the SI school but has yet to sit
for the exam. In June both Chris and I will take the SI exam. After the exam is
completed and passed, Chris will serve as SI ORC, and I will serve as SI Backup
ORC. We ask that our facility be allowed to delay the designation of a SI ORC and
Backup ORC until that time. If that is not acceptable, we will seek a contract operator
to serve in that role for the interim period.
• Updated residual management plan not submitted: I submitted the Maple Hill
WWTF residual management plan to Helen Perez on March 12, 2019.
Please let me know if you have any questions or require additional information. Thanks.
Sincerely,
MCN>- 1[ q
Kenneth P. Keel, PE
Director
Cc: Helen Perez, Environmental Specialist II
Randell Woodruff, County Manager
Chad McEwen, Asst. County Manager
Chris Pickett, MH_WWTF Superintendent
Amy Cox, Chemist
File