NC0020605_TSS over limit Response_20200122

RECEIVED fidoti
JAN 2 2 2020
Johnson
NCDEQ/DWR/NPDES Controls
December 13, 2019
Town of Tarboro, North Carolina
P.O. Box 220
Tarboro, NC 27886
Re: Notice of Violation: 4th consecutive TSS over limit. Significant non-compliance status
within a six-month period in 2019.
POTW NPDES #: NC0020605
IUP Number: TOT- 006
Dear Michael Allen:
On November 27, 2019, Johnson Controls was sent a Notice of Deficiency concerning the
requirements of 40 CFR 433.17 Pretreatment Standards for new Sources (PSNS) and the Industrial
User Pretreatment Permit (IUP) TOT—006.
The IUP describes the discharges as such:
Pipe #001 The wastewater discharged to the Tarboro WWTP from this pipe will consist of
domestic water.
Pipe #002 The wastewater discharged to the Tarboro W\)VTP from this pipe will consist of
process water used in the manufacturing of metal vents used in air ducts.
IUP,Part 1 Section F states that the TSS taken from the discharges above shall not exceed 300 mg/L
on a monthly average.
Any notice concerning an environmental deficiency at our facility is taken seriously. An investigation
was conducted to respond to the noted deficiency.
On September 9, 2019, the Johnson Controls Tarboro facility suffered a catastrophic partial roof
collapse that led to significant flooding in the main office during second shift. The flooding damaged
servers, computers, sheet rock, ceiling tiles, papers, files,insulation,and restroom supplies. The water
from the roof collapse drained through the sinks, toilets, and floor drains in the bathroom. One of
the main parts that collapsed was directly over the kitchen sink.

The second shift engineer,who was the only one in the office,did everything in his power to redirect
the water flow into buckets, coolers, trash cans, etc. to prevent the water from reaching the drains.
Ultimately,the volume of water was too heavy;therefore,water made it to the drains.
ServPro was immediately called out to start repairing the damage and get the water out of the building.
IUP Part II General Conditions states:
9. Upset Conditions
An "upset" means an exceptional incident in which there is an -unintentional and temporary
noncompliance with categorical Pretreatment Standards because of factors beyond the
reasonable control of the permittee. An upset does not include noncompliance to the extent
caused by operational error, improperly designed or inadequate treatment facilities, lack of
preventative maintenance, or careless or improper operations. An upset may constitute an
affirmative defense for action brought for the noncompliance. The permittee has the burden
of proof to provide evidence and demonstrate that none of the factors specifically listed
above were responsible for the noncompliance.
Johnson Controls feels as if this incident was a factor beyond control. Please see the pictures attached
to the end of this report.
Due to this event,the TSS has been above the permitted limits since the first sampling in September
of 2019. The TSS remained over until the second sampling in November.As shown below, the trend
line for the TSS has gone down significantly over time. Johnson Controls is currently under the
permitted limit and has been for the last two samplings.
TSS over Time
61x1
506 496
50(1 475
477
tUi 384
c
30(1 276
241
31
189
200 1
44
100 3 66 36 4
0
Oct
Month

To ensure compliance with the IUP,Johnson Controls has been rebuilding the front office.The roof
and air handling units on the roof have since been inspected to ensure that this will not happen in the
future.RotoRooter has also come in to the facility to clean the pipes of all of the debris from the initial
collapse.
Sincerely,
(7 ate-CC
Tara Carr
Manufacturing Engineer

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