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Home My WebLink AboutNCG590017_NOV-2018-LV-0129_20180209Certified Mail # 7013 1710 0002 1865 6761 Return Receipt Requested February 9, 2018 Steven Drew, Division Manager Operations City of Greensboro 2602 S Elm -Eugene St Greensboro, NC 27406-9787 SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY Tracking Number: NOV-2018-LV-0129 Permit No. NCG590017 Lake Townsend WTP Guilford County Dear Permittee: A review of the November 2017 Discharge Monitoring Report (DMR) 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 Effluent Solids, Total Suspended - 11/6/2017 45 146 Daily Maximum Exceeded Concentration (CO530) 001 Effluent Turbidity (00070) 11/6/2017 50 63.7 Daily Maximum Exceeded 001 Effluent Solids, Total Suspended - 11/20/2017 45 57.2 Daily Maximum Exceeded Concentration (C0530) 001 Effluent Solids, Total Suspended - 11/30/2017 30 101.6 Monthly Average Exceeded Concentration (CO530) 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 NPDES WIN 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. State of North Carolina I Environmental Quality I Water Resources 450 West Hanes Mill Road, Suite 300, Winston-Salem, NC 27105 336-776-9800 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. Reminder: Pursuant to Permit Condition 6 in Section E, the Permittee is required to verbally notify the Regional Office as soon as possible, not to exceed 24 hours, from first knowledge of any non-compliance at the facility including limit violations, bypasses of, or failure of a treatment unit. A written report may be required within 5 days if directed by Division staff. Prior notice should be given for anticipated or potential problems due to planned maintenance activities, taking units off-line, etc. If you have any questions concerning this matter or to apply for an SOC, please contact Jenny Graznak of the Winston-Salem Regional Office at 336-776-9800. Sincerely, Sherri V. Knight, P.E., Regional Supervisor Water Quality Regional Operations Section Winston-Salem Regional Office Division of Water Resources, NCDEQ Cc: WQS Winston-Salem Regional Office - Enforcement File NPDES Compliance/Enforcement Unit - Enforcement File State of North Carolina I Environmental Quality I Water Resources 450 West Hanes Mill Road, Suite 300, Winston-Salem, NC 27105 336-776-9800 Sherri V. Knight, P.E., Regional Supervisor 26February, 2018 Water Quality Regional Operations Section I spoke with Jenny Graznak today regarding NOV's sent to the City of Greensboro for our discharge permit NCG590017 at the Lake Townsend Water Treatment facility located at 6268 Bryan Park Road, Greensboro, NC. She instructed me to send you this message documenting the circumstances regarding NOV-2018-LV-0045 and NOV-2018-LV-0129. I spoke with Mr. George Smith, Assistant Regional Supervisor, in Early October 2017 about normal maintenance operations at the Lake Townsend facility involving dredging of the process waste lagoon. We had exceeded the daily process Maximum values for total suspended solids concentration for our October 41h, 2017 discharge sample. The dredging of the lagoon had commenced on 9/27/2017 and the TSS exceedance was our first indication of the effect that the normal maintenance operation was having on discharge quality. I described to Mr. Smith the proactive measures we had taken to reduce solids carryover during the maintenance activity, which included multiple buoyed curtains deployed at the discharge end of the lagoon and visual inspections of the discharge on weekdays while the dredging was ongoing. Mr. Smith's instructions to me were to continue with our twice monthly compliance samples, to take measures to reduce solids at the discharge to the best of our ability and to complete the dredging as soon as practical. I sent Mr. Smith an email documenting all of this. He told me that he would put the documentation in the "file" for our discharge Permit so that it would be flagged while the dredging of the lagoon was in progress. The second compliance sample for the month of October, 2017 and both compliance samples for November, 2017 had exceedances for TSS and Turbidity. On all of these occasions, we inspected the buoyed curtain walls and asked the contractor dredging the lagoon to cease work so that the effluent could clear up. For each of these exceedances, I was under the impression that the City of Greensboro was required to file the monthly report, indicating non-compliance, but that verbal reporting of them was not required due to the Flag Mr. Smith put into the permit file. I apologize and accept full responsibility if this was done in error. The December 2017 and the January 2018 monthly reports both show that we were in compliance. The normal maintenance dredging ends on Wednesday, February 28`n The January 2018 report has been certified by the Townsend ORC but I cannot submit the report on the electronic reporting system site. I do not know if this is due to the site issues that Rodney Darr emailed us about or if it is due to the NOV's. I was able to submit the monthly report for our N.L. Mitchell Water Treatment facility. Any help would be appreciated. Respectfully, Dell Harney Desk 336-373-7900 Cell 336-430-6240 cc Jenny Graznak Gramak, Jenny From: Harney, Dell <Dell.Harney@greensboro-nc.gov> Sent: Monday, February 26, 2018 6:59 PM To: Knight, Sherri Cc: Graznak, Jenny Subject: [External] City of Greensboro NOV Attachments: Townsend Discharge NOV-Feb2018.docx Sherri V. Knight, Please see the attached Word document for response to NOV-2018-LV-0045 & NOV-2018-LV-0129. I apologize for any confusion created on my part. My office number is listed below and my cell phone number is 336-430-6240. Please call if can help in any way. Dell L. Harney Water Supply Manager City of Greensboro Water Resources 1041 Battleground Ave Greensboro, NC 27408 Phone: 336-373-7900 ------------------------------------------------------- ------------------------------------------------------- Please note that email sent to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. &A( to Q� � 0 -0 -� iIvI-