NC0023442_Limit Exceedance Response_20190806

SOUTHERN
dow"W
August, 6, 2019
North Carolina Department of Environmental Quality
Division of Water Quality
Raleigh Regional Office
3800 Barrett Drive, Suite 101
Raleigh, NC 27609
Re: Response to Notice of Violation
Permit No. NCO023442
Southern Veneer Specialty Products, LLC - Moncure
Moncure, Chatham County, North Carolina
To Whom It May Concern,
This letter is in response to the NOV regarding the limit excccdance reported on the April 2019 DMR.
On April 30, 20I9, total ammonia (as nitrogen) concentration was reported at 3.55 mg/L. Remedial
actions were taken immediately by the designated ORC, Randall Jarrell. His statement is included as
Attachment 1.
On April 161h samples were collected and transported to the laboratory by Randall Jarrell. On April 291h
Mr. Jarrell was notified by ENCO labs of a possible effluent ammonia as nitrogen violation. Jarrell
contacted Thomas Reams, the EHS Coordinator for the plant, to discuss the violation. On April 911,
planned decommissioning activities for the facultative pond were begun and the influent flow from the
facultative pond was decreased 65%. The 65% flow reduction resulted in a loss of organic and hydraulic
Ioading, which is required to manage the microorganisms for nitrogen fixation. The decrease in
microorganisms released biochemical oxygen demand and ammonia nitrogen back into the effluent.
Randall initially contacted ENCO Labs for a verbal verification while onsite, as is considered routine.
Randall received the preliminary result as 5.4 mg/L and immediately contacted the NC DWQ inspector
for the facility, Ray Milosh, who indicated that the appropriate contact, Mr. Cheng, would be informed
and would be contacting him regarding the incident. This was prior to the official ENCO excursion alert
at I6:54 on April 291h.
The system engineer, Gary McConnell, and the treatment system vendor, Carl Perry, were contacted to
evaluate the situation. Randall, Gary, and Carl agreed that the loss of flow and "food" to the system was
the direct cause of the ammonia nitrogen buildup within the treatment system. Immediate corrective action
was recommended to keep the treatment system operating and increase the recirculation. Subsequent
306 Corinth Rd.
Moncure, NC 27559

NCDEQ DWQ Response to NOV
August 6, 2019
Page 2 of 2
sampling results from May 61h were 0.085 mg/l and confirm that the system was again stable. Attachment
2 provides sampling results from May through July.
If there are any questions or if more information is required, please call Thomas Rcams, EHS Coordinator
at 910-605-9258.
Sincerely, 1`G/`
Rick Payne
PIant Manager
Attachments
306 Corinth Rd.
Moncure, NC 27559

WASTEWATER MANAGEMENT, L.L.C.
P.O. Box 578 Pittsboro, N.C. 27312 [phone] [e-mail]
aol.com
July 29, 2019
Southern Veneer Specialty Products, L.L.C.
Mr. Tom Reams,
Per our conversations I am writing this to help explain the non-compliance for the
effluent ammonia nitrogen exceedance in April 2019.
On the 4/16119 visit samples were collected and transported to the laboratory. On
4/25/19 I was contacted by ENCO labs notifying me of a possible effluent ammonia
nitrogen violation. Upon hearing the result, I evaluated the situation and contacted Mr.
Reams to discuss.
I explained that on 419/ 19 the influent flow decreased 65% due to cutting off the pond
flow the system was used to treating. The 65% decrease in flow resulted in a loss of both
the organic and hydraulic loading which feeds and keeps all of the microorganisms that
treat the wastewater alive. Thus, a portion of the microorganisms die and release
biochemical oxygen demand and ammonia nitrogen back into the effluent.
The ammonia nitrogen sample result for 4/16/19 was 5.4 mg/I. Our daily limit is 10 mg/l
and the monthly limit is 2.0 mg/l. The result of 5.4 averaged with the previous result of
1.7 mg/l elevated our monthly result to 3.6 mg/l.
Reducing the number of treatment pods was an idea to think about so
I advised us to call the system engineer for advice.
On 4/26/19 I called the system engineer, Mr. Gary McConnell [phone], and we
discussed the situation. I asked Mr. McConnell to ask Mr. Carl Perry [phone], the
owner of the easy treat system, for advice, and he did.
Mr. Perry and I talked and he and Mr. McConnell agreed that the loss of flow and food to
the system upset the treatment system. I was advised us to keep the system operating
with all treatment pods in service and to increase the recirculation. I increased the
recirculation as advised on 4/29/19. Mr. Perry said the system will stabilize in a few days
and start nitrifying/oxidizing ammonia nitrogen again.
The next sample result was 0.085 mg/l on 5/6/19. The system was again nitrifying and
stable.

Nitrifying bacteria and very sensitive and it is not uncommon for them to go dormant or
die when their living environment is unstable. Keeping the bacteria's living environment
within their limits is what is strived for. Sometimes uncontrollable situations do happen
that cause a deviation from what the bacteria require and a violation may occur.
To gain faster effluent quality information. We started using a portable HACH Company
(NH3-N) ammonia nitrogen test kit to give us onsite laboratory data. This test kit is not
EPA compliant but is accurate enough and gives us an idea if we are compliant when we
collect the ammonia nitrogen sample.
This is to the best of my ability an account of what happened in April. Mr. Reams is
great to work with and we both share the common goal of maintaining compliance with
our permits. If anyone has any questions feel free to contact me anytime.
Sincerely,
Randall Jarrell, Environmental Biologist

�co
www.encolabs.com
ANALYTICAL RESULTS
Description: Southem Veneer Effluent Lab Sample ID:CC06314.01 Received: 05/06/19 13:50
Matrix: waste water Sampled:05/06119 12:05 Work Order: CC06314
Project: Southem Veneer - Week 1 and 3 Sampled By: RANDALL JARRELL
(Classical Chemistry Parameters
• lNCo Cal, Wfffl.d a.arrb !NC snt)
Analvte rCAS Numbed
Resells
f4 Units
1E
1UL
EQL
Bate
(Meth
Analne
UQI25
Ammonia as N [7664-41-7]A
0.085
J mg/L
1
0.045
0.10
9E15037
EPA 350.1
05/15/19 19:26
MKS
Biochemical Oxygen DemandA
< 2.0
mg/L
1
2.0
2.0
9E08002
SM 5210 8-2011
05/08/19 08:48
JOC 8-07
Total Suspended Solids'
< 4.2
mg/L
1.67
4.2
4.2
9E13019
SM 254OD•2011
05/14/19 12:40
AX LP-04
Microbiological Parameters
• fNCO Ca+Y CoWned.rtNrr. INC sae!
Analyte fCAS Numberl
gesul
flu vab
RE
Ea
Ad=b
Meth
Analyz
AM Notes
Coliform, FecelA
< 1.0
MPN/100
1
1.0
9E08013
CoOlert 18
05/07/19 10:04
MKS
mL
RNAL Ihs repot relate ody to the sample as receive try the laboratory, and may only be reprodumd In full I Page 4 of 9

(E-I e0
www.encolabs.com
ANALYTICAL RESULTS
Description: Southern Veneer Effluent Lab Sample ID: CC06705.01
Received: 06/17/19 14:30
Matrix: Waste Water Sampled.06/17/19 12:05
Work order: CC06705
Project: Southern Veneer - Week 1 and 3 Sampled By:RANDALL JARRELL
I Chemistry Parameters
• eNCO Ctty tttfdngg In Nytt /NC 59:1
Analvte rCAS Numberl
Resul
fig vain
DE
MIX
Z&
fiaLSb
Method
Anal d
$ Notei
Ammonia as N 17664-41-71A
0.23
mg/L
r
0.045
0.10
91`20045
EPA 350.1
O6/20/I9 16:18
MKS
Biochemical Oxygen DemandA
< 2.0
mg/L
1
2.0
2.0
9FI8035
SM 5210 B•2011
06/18/19 19:58
]OC
Total Suspended Solids^
< 2.5
mg/L
1
2.5
2.5
9FI9001
SM 2540D-2011
06/19/19 07:34
LG
Microbiological Parameters
fhCo Ctty ctrtofw tntlrtt INC 5911
Analvte rCAS Numberl
Resul
E614 Itnits
I&
P21.
Batch
Moth
Analyzed
Colitorm, FecalA
1.0
MPN/100
1
1.0
9F17037
Colilert 18
06/18/19 10:46
AKF
mL
Fl 4a This report relates only to the sample as received by the laboratory, and may Stay be reproduced in roll I Page 4 of 9

www.encolabs.com
ANALYTICAL RESULTS
Description: Southern Veneer Effluent
Lab Sample ID:0006706-01 Received: 06/03/19 15:00
Matrix: Waste Water
Sampled:06/03/19 12.05 Work Order: CC06706
Project: Southern Veneer - Week 1 and 3
Sampled By:RANDALL JARRELL
Classical Chemistry Parameters
^ FNCO CYry r.rtn.a.n.frt. INC Sol
Analda rCAS Numberl
Results
fft yam
RE
Hu
f2L
A=11
Method
Anal
ft Note
Ammonia as N [7664-41-7]^
0.38
mWL
1
0.045
0.10
9F11007
EPA 350.1
06/11/19 10:41
MKS
Biochemical Oxygen Demand,
< 2.0
mWL
1
2.0
2.0
9FO5001
SM 5210 0-2011
06/05/19 10:01
]DC
Total Suspended Solids^
< 2.5
ng/L
1
2.5
2.5
9F05002
SM 2540D-2011
06/05/19 07:15
LG
Microbiological Parameters
E&CO C.rr r.'an.e —44t. (NC $911
Analyte 1CAS Numberl
Results
fiffil 9111b
pE
E"
Batclr
M
gpal=d
BE H.=
Coliform, Fecal-
< 1.0
MPN/100
1
I.0
91`04004
GDOlert 18
06/04/I9 10:41
AKF
mL
FrN& This report relates only to the sample as received by the laboratory, and may onty be repoduced In ful! I Page 4 of 9