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Home My WebLink AboutWQ0035706_NOV-2019-LV-0681 to 0684 Response_20200131LNVIROLINK January 27, 2020 Mr. Roberts Tankard Assistant Regional Supervisor Water Quality Regional Operations Section Washington Regional Office Division of Water Resources, NCDEQ Dear Mr. Tankard, Thank you for the opportunity to respond to the following Notices of Violation for April, May, June and July 2019 as listed below: • Notice of Violation & Intent to Assess Civil Penalty related to limit violation for Fecal MF Coliform, MFC Broth, and Ammonia Nitrogen as reported on the April 2019 Non - discharge monitoring report. Issued January 16, 2020 (NOV-2019-LV-0681) • Notice of Violation & Intent to Assess Civil Penalty related to limit violation for Fecal MF Coliform, MFC Broth as reported on the May 2019 Non -discharge monitoring report. Issued January 16, 2020 (NOV-2019-LV-0682) • Notice of Violation & Intent to Assess Civil Penalty related to limit violation for Fecal MF Coliform, MFC Broth, and Ammonia Nitrogen as reported on the June 2019 Non - discharge monitoring report. issued January 16, 2020 (NOV-2019-LV-0683) • Notice of Violation & Intent to Assess Civil Penalty related to limit violation for Fecal MF Coliform, MFC Broth as reported on the July 2019 Non -discharge monitoring report. Issued January 16, 2020 (NOV-2019-LV-0684) As stated in our previous response: In 2019 we noted that several modifications from the original designed had been implemented at the facility and that plant performance was being impacted by several factors, including: 1. Modifications from the original design 2. Wastewater strength exceeding design parameters 3. Wastewater characteristic —specifically fibers 4. Nitrate recycling 5. Return activated sludge 6. Control issues 7. Electrical issues 8. Limitations on aeration 9. Misc other issues Fl50 iVED]NCDEN8/DWR JAN 3 ? �aQ o WaterQoatity Regional Operations Section Washington Regional Office Envirolink, Inc. 2�,wa 9 a ttu In `ZLh&* Ata�rtt 4700 Homewood Ct, Suite 108; Raleigh, North Carolina 27609 252-235-4900 (phone) 252-235-2132 (fax) nz L•NViROLENK The violation for ammonia and total nitrogen were caused by the April 11, 2019 sample results, which caused total nitrogen and ammonia to exceed the modified limits by 5.8% and 1.3%, respectively. It was noted that the organic nitrogen in this sample was approximately 19.8 mg/L. The increased levels of organic nitrogen impacted the performance of the plant by inhibiting nitrification and added organic nitrogen that is not easily degradable. Upon taking over operation, one of the issues was the lack of nitrifying bacteria in the mixed liquor that are vital to nitrification. The lack of nitrification was impacted by several issues: • Inability to properly return solids • The feed point for the return activated sludge • The characteristic of the wastewater The Moyock Regional Facility is particularly susceptible to high ammonia, low pH, temperature and high strength wastewater making the facility sensitive to thegrowth and maintenance of Nitrosomonas and Nitrobacter. As the nitrifying bacteria are lost it takes significant time for recovery as can be seen in the 2019 sample results. The other issue that we have noted over the past year is the impact of organic nitrogen on the plant performance. Since February 2019, there have been seven instances when TKN exceeded 40 mg/L and for six of those instances the organic nitrogen component of TKN exceed 10 mg/L. On average the plant treats 7.5 mg/L of organic nitrogen with optimal performance occurring when organic nitrogen is below 4-5 mg/L. A significant source of organic nitrogen is from fats, oil and grease. As such the County is reviewing its fats, oil & grease program in order to better control the amount of organic nitrogen being received by the plant. As should be apparent, significant resources and effort is being devoted to obtaining quality information and improve maintenance & performance of the facility. While we do not contest the violation, we would respectfully request that the Division consider the efforts and resources the County is allocating to improve the performance of the facility. Also, as these issues have been identified, significant resources and effort is being devoted to obtaining quality information and improve maintenance & performance of the facility. While we do not contest the violation, we would respectfully request that the Division consider the efforts and resources the County is allocating to improve the performance of the facility. The County would much rather utilize the available funding for addressing maintenance and upgrade of the wastewater facility than civil penalties. Envirolink, Inc. 4700 Homewood Ct, Suite 108; Raleigh, North Carolina 27509 252-235-4900 (phone) 252-235-2132 (fax) ENVIROLINK Conclusion: While there have been and continue to be multiple mechanical and process issues with this facility, the County has and continues to work to resolve these issues and bring this facility into compliance. The County has just completed significant maintenance work designed to improve the performance and reliability of the facility. We believe that additional level of reliability incorporated into this facility coupled with better control and enforcement of fats, oil and grease will improve the performance of this facility. We request that the Division recognize these efforts and the resources being devoted to improving the treatment and operation of this facility and not pursue further action. The County would rather use its budgeted funds towards improving the plant and not civil penalties. We recognize that civil penalties are meant to make violations punitive in order to ensure permittees aggressively implement corrective actions. We believe that this letter demonstrates the aggressive nature that the County has been implementing corrective actions and suggests that additional punitive measures are not warranted or necessary. Further, we would emphasize that payment of civil penalties requires the County to direct funds to paying civil penalties versus investment into the wastewater system. As you are aware, the County is making the necessary investment to improve the performance of the wastewater system and thus further civil penalties would only place a burden on the County's finances. Sincerely, Tracy Miller Area Manager Cc: Eric Weatherly, Currituck County Engineer Ben Stikeleather, Currituck County Manager Rebecca Manning, Envirolink Compliance Specialist John Pruitt, Envirolink Service Technician - Operations Dave Strum, Envirolink Director of Operations Envirolink, Inc. *W4 YM&N in `lltl 4 .Management 4700 Homewood Ct, Suite 108; Raleigh, North Carolina 27609 252-235-4900 (phone) 252-235-2132 (fax)