WQ0033589_NOV-2019-LV-0701 & 0865 Response_20191202

DECEMBER 2, 2019
David May, L. G., Regional Supervisor
Water Quality Regional Operations Section
Washington Regional Office
Division of water Resources, NCDEQ
Dear Mr. May:
C�N
This letter is in response to the Notice of Violation for the July and August 2019 Non -Discharge
Monitoring Report for Jennette's Pier Wastewater System Permit No. WQ00335898.
The overage for Total Nitrogen Monthly Maximum Average reflected in the NDMR for the
month of July 2019, is due to an improper balance in the Carbon Feed System. To assure a
balance between High Total Nitrogen results and High BOD results, the Carbon Feed System
must be adjusted constantly. This is attributed to the fluctuation of the seasonal wastewater
flow associated with visitation to Jennette's Pier. This is a manual adjustment and must be
initiated in small increments. In most instances the results of the adjustments are not
noticeable for several days, making it very difficult during these incidences to meet the permit
limits.
The NDMR for August showed an overage for the Daily Limit on BOD (the Monthly Average
Limit was met) and a slight overage on Phosphorus Monthly Average. This was due in part to a
delayed chemical shipment. We were without the chemical that promotes settleability, for a
short period. Therefore, the settleability was not optimal, causing an increase in those
parameters. We showed recovery on the next sample for BOD and slight reduction in the
Phosphorus.
In the future we intend to monitor chemical shipments closely. Also, the seasonal fluctuation of
tourist causes increase and decrease in flow rates. As a result, we continually strive to reach the
optimal adjustments required for the best possible wastewater treatment.
Thank you for your consideration in this matter.
Sincerely,
Irvin W. Edwards, Jr.
Jennette's Pier Wastewater ORC

e[ a
ROY COOPER
Governor
MICHAEL S. REGAN
Secrrrary
LINDA CULPEPPER
Director
Certified Mail 70181830 0000 9509 8690
Return Receipt Requested
NORTH CAROLINA
Environmental Quality
November 26, 2019
Michael P. Remige, General Manager
North Carolina Department of Natural and Cultural Resources
P.O. Box 1445
Nags Head, NC 27959
SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY
Tracking Number: NOV-2019-LV-0701
Permit No. WQ0033589
Jennette's Pier WWTP
Dare County
Dear Mr. Remige:
A review of the July 2019 Non -Discharge Monitoring Report (NDMR) for the subject facility revealed the
violation(s) indicated below:
Limit Exceedance Violation(s):
Sample
Location Parameter
Limit Reported
Date Value Value Type of Violation
001 Nitrogen, Total (as N) (00600) 7/31/2019 7 11.82 Monthly Average Exceeded
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 Non -discharge 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.
- �bNlrthCato_EQ�na Department of Env:ronmentelQuslrty I Diusionof Water Resources
eS'�ash, rgtDn, Reg ora 4ffre 1 943 Washington Square Melt I Washington, North Groins 27889
•'=-'�a�!! � 252-945-6461

Michael P. Remige
November 26, 2019
Page 2 of 2
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.
If you have any questions regarding this Notice or need additional information, you may contact Robert Tankard at
[phone] or Randy Sipe at [phone].
Sincerely,
David May, L.G., Regional Supervisor
Water Quality Regional Operations Section
Washington Regional Office
Division of Water Resources, NCDEQ
Cc: Irvin Woodrow Edwards — ORC (electronic copy)
Laserfiche
North Carolna Department of Environmental Quality I Diu+sion of Water Resources
Washington Regional Offce 1943 Washington Square Mal, I Washington, North Carolina 27889
v 252-946-6381

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
Certified Mail 70181830 0000 9509 9062
Return Receipt Requested
NORTH CAROLINA
Environmental Quality
November 26, 2019
Michael P. Remige, General Manager
North Carolina Department of Natural and Cultural Resources
P.O. Box 1445
Nags Head, NC 27959
SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY
Tracking Number: NOV-2019-LV-0865
Permit No. WQ0033589
Jennette's Pier WWTP
Dare County
Dear Mr. Remige:
A review of the August 2019 Non -Discharge Monitoring Report (NDMR) 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 BOD, 5-Day (20 Deg. C)
8/8/2019 15 31 Daily Maximum Exceeded
(00310)
001 Phosphorus, Total (as P)
8/31/2019 3 3.8 Monthly Average Exceeded
(00665)
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 Non -discharge 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.
D �� North Caro,:na Department of Environments; Qusity I Division of Water Resources
Wash ngton Reg onat Offce 1943 Washingtonn Square Mats I Washington, North Caroa 27889
"►�� 252-e46-6481

Michael P. Remige
November 26, 2019
Page 2 of 2
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.
If you have any questions regarding this Notice or need additional information, you may contact Robert Tankard at
[phone] or Randy Sipe at [phone].
Sincerely,
David May, L.G., Regional Supervisor
Water Quality Regional Operations Section
Washington Regional Office
Division of Water Resources, NCDEQ
Cc: Irvin Woodrow Edwards — ORC (electronic copy)
Laser -fiche
D QNorth Caro:"na Depsrtrr�rt of Ervror.mental Quality I Divisor. of Water Resources
�.% Wash.ngton Reg ora 'rff.%- 1 943Wash ngton Squat* Mall I Wash mpon, North Can na 27899
. • _�-.. \ �� 252-946-6481