NC0034711_Response to NOV-2020-LV-0667, NOV-2020-LV-0619_20201009

Metwater, Inc.
1000 Wooddhurst Drive Monroe NC 28110 1704.506.4255 1draetwaterRaol.com
10-9-2020
Mr. Corey Basinger
North Carolina Department of Environmental Quality
Division of Water Resources, NCDEQ
610 East Center Avenue, Ste. 301
Mooresville, NC 28115
Ref: NOV-2020-LV-0667 (fecal)
NOV-2020-LV-0619 (Ammonia)
Cedar Park MHP WWTP
NC0034711
Cabarrus County
Dear Mr. Basinger,
This letter is intended to address the above reference violations at the Cedar Park MHP
WWTP. Its contents and attachments are not to be received as a vehicle to imply any wrong
doing or intentional malice by any party referred to herein.
This facility has routinely produced "less than" fecal results for many years barring the
inevitable system upset or power failure. We have not had to alter our sampling techniques
or protocol until recently due to this rash of fecal non-compliance. With that in mind, it is
this operators belief that, at least a portion of the sampling bottles during the months of
July through mid -September, were contaminated or at some point became that way prior to
or during sample collection but before analysis.
As your office is aware, this facility and two (2) others like it, concurrently received notices
for the same fecal non-compliance. This is an anomaly I cannot explain. We did however,
perform additional sampling and decided with some certainty that fecal sample bottles,
although still sealed from the vendor but containing a measurable amount of clear liquid,
we not sterile and were not be used for this purpose. I personally noticed this on occasions
but was assured by our 3rd party laboratory that would not affect the sample results. It
seemed this occurred more so when the sample cooler (containing the fecal sample bottles)
was exposed to rain events and weeklong storage in the bed of a pickup truck prior to the
next sampling event. See attachments 1 and 2 (pic).
In one phone call to Mr. Scheller, I shared with him the additional sampling data in
attachment 1 and the only viable conclusion that I could draw. It is at that time, He shared

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Cedar Park MHP WWTPNCO034711
Cabarrus County continued ... 10-9-2020
with me a similar experience he had once been through. From that conversation and
advice, we implemented the following:
1. Replaced "old red sampler cooler" that after rinsing and sampled, produced a fecal
concentration of >60,000. Attachment 1
2. Added an additional tablet feeder tube to each chemical dosing unit although we
never needed two (2) before.
3. We still transport the sample cooler in the pickup bed but make sure it is loaded and
stays loaded upside down to prevent rainwater intrusion prior to next sampling
event.
4. Pumped and washed down effluents tanks.
5. Thoroughly washout all tablet feeder units.
6. Switched to "whirl-paks" for fecal sampling and are experimenting with poles,
dippers and core samplers that sample without interference that may cause
sloughing or otherwise contaminate the sample during collection.
Unfortunately, we are not yet seeing the results at this facility like we are beginning to see
at the other two (2), but we do see an improvement. We are optimistic that will change for
the better once the repairs to the backup blower have been completed and it placed into
operation. At time of this letter and following yesterday's sampling event, the clarity of the
effluent is already improved with the cooler weather despite not having the additional
blower on-line yet.
Your office should be receiving a response letter from the facility owner regarding NOV-
2020-LV-0619 (Ammonia). Enclose for your reference is the timeline of April 14, 2020
through September 14, 2020 associated with this violation and the repair of the backup
blower. (See attachment 3) It is now believed, the lack of adequate aeration leading to
partially treated and cloudy effluent allowed fine particles ( i.e.: solids) to "hide" from
chlorination reducing its effectiveness and thereby contributing to the rash of fecal
violation at this one facility.
The owner has approved the blower repair and our mechanical contractor expects to be
completed by months end, barring any delays related to the delivery of parts caused by
Covid 19. (Attachment 4)
Our plan at this time, is to continue working with our client, 3rd party Laboratory and
mechanical contractor to effect the required improvements all around while keeping your
office apprised of our efforts as Metwater has done throughout.
We hope this response is adequate. Should you need any additional information please
contact me directly by calling 704-506-4255 or by emailing [e-mail]
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Cedar Park MHP WWTPNCO034711
Cabarrus County continued ... 10-9-2020
Thank you for your cooperation and professionalism as always. Should you need additional
information or follow up please contact me directly by calling 704-506-4255 or emailing
me at [e-mail].
Sincerely,
Dusty Metreyeon
Metwater, Inc.
1000 Woodhurst Drive
Monroe, NC 28110
CC: Robert Scheller (email)
Cedar Park Estates, Rick Obrien (email)
Cedar Park Estates Manager, Mendy Davolt (email)
w/Attachments
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