NC0063762_Response to NOV-2020-LV-0666_20201009

Metwater, Inc.
1000 Wooddhurst Drive Monroe NC 28110 1704.506.4255 1dmetwaterPaol.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-0666 (fecal)
Carolina Village MHP WWTP
NC0063762
Cabarrus County
Dear Mr. Basinger,
This letter is intended to address the above reference violation at the Carolina Village 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, flood 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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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.
We are beginning to see an improvement and are optimistic that we will soon produce
consistent compliance. These challenges have been a trial by fire and the changes have
taken time to employ and to determine their effectiveness.
Our plan at this time, is to continue working with our client and 3rd party Laboratory to
effect the required improvements needed while keeping your office apprised of our efforts
as Metwater has done throughout. Should are efforts prove to be less than effective, we
welcome on -site consultation or split sampling that you may feel would be helpful in
resolving this issue.
We hope this response is adequate and negates the need for monetary penalty, as we do
believe that the violation(s) stem from sample contamination are not indicative of the
actual effluent quality at this facility. Should you need any additional information please
contact me directly by calling 704-506-4255 or by emailing [e-mail]
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)
Horizon Land Management, Tracy and Z (email)
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