WQ0007569_NOV-2020-LV-0157_20200305

Strickland, Bev
From: Anthony Chilton <[e-mail]>
Sent: Thursday, March 5, 2020 1:52 PM
To: Perez, Helen I
Cc: Dana Hill; Jonathan Bryce Mendenhall; Stacy A. Goff, Brent Milliron
Subject: [External] NOV 2020-LV-0157 _ Brandywine Bay Response
Attachments: 200302_WQ0007569_NOV202OLV0157.docx.pdf
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[e-mail]
Helen,
Thank you for spending some time with me the other day on the phone.
In regards to the NOV 2020-LV-0157 at Brandywine I wanted to go into written detail of what we went through, what we
learned, and what we have done to rectify the issue.
As discussed on the phone,
Back some time ago, we learned that the state had lowered its amount of Sodium Thiosulfate in the sample bottle,
which in turn required us to lower our C12 levels in the sample. If the sample is >0.5 mg/l, the sample would be discarded
and we would have to resample. This is a non -issue in the first half of the week, but as the week ends we cannot afford
to pull a sample and have it rejected. We would not have time to resample before the lab closes. Then we would run
into issues with not having a representable sample as required by the state for that week. We had several samples that
were rejected due to high chlorine which sent us scrambling to resample to keep from violating the permit for no
sample.
Our first attempt to rectify this issue was to call the lab, in this case Environment 1. We questioned the new rules and
asked, what could be done to reduce the CL2 conc. in the sample to reduce rejections. It was concluded that since they
had reduced the Sodium Thio in the sample that we could just add some additional HACH packets of Sodium Thio from
our stock. We figured that would rectify the issue with the CL2 and reduce the possibility that we would get a violation
for not sampling on Thursday or Friday. We added a small amount of Sodium Thio to reduce the CL2 and it worked for a
while with apparently no detrimental effects to the BOD. We are assuming the CL2 conc. was strong enough to complete
a mass balance where the small amount of Sodium Thio was completely consumed.
Around that same time we started getting a spike in the CL2 concentration for our supplier. In these small systems we
do have the ability to flow pace or scale the C12 conc. run speed on the chemical feed. The Operators have to find a
dosage that is strong enough to have a 4-Log Removal of E.Coli while not over dosing as it waste chemicals and now
would increase the risk of a rejected sample. We set the pump at a typical range and had multiple rejections from the
lab. Again in an effort to keep from having a no -sample violation we added full packets of Sodium Thio to the samples.
As you will note one sample was collected on a Thursday (12/5) and the other, a day before the end of the month
(12/30). In both incidents we were running out of time to get a collectible, representable sample to report. I am fairly
sure the Operator added a full packet, if not more of Sodium Thio so that the sample would be accepted so we would
have reportable number to the State.
Based on the other sampled parameters on the Lab Report we were certain that the Sodium Thio. was adding to the
BOD. We took precautions to eliminate the need for Sodium Thio all together as we couldn't explain the results, and
were convinced that high CL2 conc. or the extra Sodium Thio were the root cause of the high BOD.

We have made some moves in the right direction to get in front of the C12 issue and the need for additional Sodium Thio
1. We now have two pumps inventory to combat high CL2 conc. One is for 7 g/d and the other 3 g/d. When we
have a spike in CL2 we will switch over to the smaller pump allowing us to reduce the over usage and the need
for additional Sodium Thio. The C12 conc. at one point was concentrated to a level that we could no longer run
the 7 g/d pump even at the lowest setting although this size pump has been used for quite a long time at 40 —
50% setting. This was the reasoning for the 3 g/d pump to be on standby.
2. We are now using a Chlorine Bleach Test Kit - 7105-03 - LaMotte Company [lamotte.coml, which is the same
titration test kit the chemical supplier uses to test the delivered C12. It also allow the Operator to monitor the
CL2 as the conc. starts to weaken over time, adjusting to offset. With this test kit it takes the guess work out of
which pump and what setting we need to use.
3. We also had Waterguard Reps onsite to explain away the spike in conc. We have seen that the CL2 being
delivered was approx. 15%, even after a week or more. Typically we have CL2 conc. of 12.5% which is the
justification for having the second, lower dosing pump available. Water guards QC/QA seem to be more stable
since the onsite meeting, which makes it easier for the Operators to pinpoint the needed dose.
4. We are also having the lab test a blank vs. sodium thiosulfate run on BOD to quantify the oxygen demand. This is
proving to be difficult, although they stated that they would make time to perform this test. We are still waiting
for some feedback on this.
Based on all of the other parameters, a naturally occurring higher than normal BOD is hard to understand. The addition
of the Sodium Thio post sampling seems to be the factor that is elevating the BOD. On our end we are getting a better
handle on what CL2 Conc. we are dosing as well as eliminating the need for the Sodium Thio. post sampling all together.
All of the BOD samples that have been taken since these changes have been implemented are well below the permitted
level.
Please let me know if you have any questions or need me to go into further detail on any of the above mentioned
information.
Thanks again,
Lane Chilton
From: Perez, Helen I <[e-mail]>
Sent: Tuesday, March 3, 2020 9:55 AM
To: Anthony Chilton <[e-mail]>
Subject: RE: [External] RE: WQ0007569
I sent a link yesterday after we talked. Must not have gone through, sorry. Use the permit number to search. Also,
attached is the NOV that is being mailed out today.
https://edocs.deg.nc.gov/WaterResources/WeIcome.aspx
Helen Perez
Environmental Specialist II
Water Quality Regional Operations Section

Division of Water Resources
Department of Environmental Quality
910-796-7215 Reception Desk
910-796-7323 Direct
910-350-2004 Fax
[e-mail]
Wilmington Regional Office
127 Cardinal Drive Extension
Wilmington, NC 28405
From: Anthony Chilton [mailto:[e-mail]]
Sent: Tuesday, March 3, 2020 9:46 AM
To: Perez, Helen I <[e-mail]>; Stacy A. Goff <[e-mail]>
Subject: [External] RE: WQ0007569
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Helen,
Thank you for giving a few minutes of your time yesterday. I will address the non typical high BOD levels at Brandywine.
You stated yesterday that the Brandywine Permit was on Laser Fische and that you had a link to that particular website.
Do you have the link so we can go ahead and adjust any testing that we need with the third party lab.
Regards
Lane Chilton
From: Perez, Helen I <[e-mail]>
Sent: Monday, March 2, 2020 1:54 PM
To: Stacy A. Goff <Stacy.Goff@caroli nawaterservicenc.com>
Cc: Anthony Chilton <Lane.Chilton@carol inawaterservicenc.com>
Subject: WQ0007569
Stacy,
Just a reminder, that the new permit for Brandywine Bay became effective in December, 2019. There were new
parameters added to that permit (TKN, Total Nitrogen, Total Phosphorus for PPI 001 and Ammonia with a daily limit of
1.5 mg/I for monitoring wells). Contact me if you have any questions. Thanks.
Helen Perez
Environmental Specialist II
Water Quality Regional Operations Section
Division of Water Resources
Department of Environmental Quality
910-796-7215 Reception Desk
910-796-7323 Direct
910-350-2004 Fax

[e-mail]
Wilmington Regional Office
127 Cardinal Drive Extension
Wilmington, NC 28405

DocuSign Envelope ID: 64BO4E89-ODDF-47AA-946A-625E954394A6
ROY COOPER
Governor
MICHAEL 5. REGAN
SecrEfary
S. DANIEL SMITH
arecrnr
Certified Mail # 7018 2290 0001 8295 9793
Return Receipt Requested
J Bryce Mendenhall
Carolina Water Service Inc. of North Carolina
4944 Parkway Plaza Blvd
Suite 375
Charlotte, NC 28217
NORTH CAROLINA
ErrvFrwimentG1 QUality
March 2, 2020
SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY
Tracking Number: NOV-2020-LV-0157
Permit No. WQ0007569
Brandywine Bay WWTP
Carteret County
Dear Permittee:
A review of the December 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. Q 12/5/2019 15 29 Daily Maximum Exceeded
(00310)
001 BOD, 5-Day (20 Deg. C) 12/30/2019 15 18 Daily Maximum Exceeded
(00310)
001 BOD, 5-Day (20 Deg. Q 12/31/2019 10 23.5 Monthly Average Exceeded
(00310)
North CaroGnaDepart mentofEnvironmentalQLis! ity I MAsion of Water Resources
Vddm ngton Regional Office I = C.ardimi Drive fxteasoo I Wli4mington, North Caro: irks 25405
° " 910-796-7215

DocuSign Envelope ID: 64BO4E89-ODDF-47AA-946A-625E954394A6
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.
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 concerning this matter or to apply for an SOC, please contact Helen Perez of the
Wilmington Regional Office at 910-796-7215.
Sincerely,
DocuSigned by:
D
umi..�F141E73B6F3456... for
Morella Sanchez -King, Regional Supervisor
Water Quality Regional Operations Section
Wilmington Regional Office
Division of Water Resources, NCDEQ
Cc: Stacy Goff — electronic copy
North Carolins Departmar.t jf Erviroments Qus:`ty I D:v:son of Water Resources
V; rr ngtoo- Regom-Cff'D-_ 1 12.7 Cardina: Drava ExterLsort 114owrtgtoa, North Caro,ms229405
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