HomeMy WebLinkAboutNC0063762_Violation Response_20201130Strickland, Bev
From: dmetwater@aol.com
Sent: Monday, November 30, 2020 9:37 AM
To: Scheller, Roberto
Cc: Emmett Conneely; zgatica@horizonlm.com; Mayra Orellana
Subject: [External] Re: Carolina Village... Additional Information... NOV-2020-LV-0778 (fecal)
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11-30-20
Ref: NOV-2020-LV-0778 (fecal)
Carolina Village MHP WWTP
NCO063762
Cabarrus County
Dear Mr. Scheller,
Thank you for the additional time to respond. This email mirrors the position of my 10-9-2020 letter to your
office for a similar violation, known as NOV-2020-LV-0666. Its' contents 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).
Following your advice we performed:
i. 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.
s. 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.
These challenges were a trial by fire and change has taken time to employ and to determine their effectiveness.
We worked closely 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 and we have seen consistent fecal
compliance over the last two months.
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. The
facility is operating as intended as you witnessed during our recent inspection, however, should you need
additional information or follow up please contact me directly by calling 704-506-4255 or emailing me at
dmetwater(cr�,aol. co m.
Sincerely,
Dusty Metreyeon
Metwater, Inc.
1000 Woodhurst Drive
Monroe, NC 28110
Sent from Windows Mail
From: dmetwater
Sent: Tuesday, November 10, 2020 3:38 PM
To: roberto.scheller@ncdenr.gov
Cc: Emmett Conneely
Roberto, as we discussed on the phone... this NOV went to my client's office staff and their company project
manager. I just received a copy this morning and respectfully request an extension to respond so that I may
collect and submit additional information related to this non compliance.
Dusty Metreyeon
Metwater, Inc.
704.506.4255
Begin forwarded message:
From: Mayra Orellana <morellana@horizon landco.com>
Date: Nov 10, 2020 at 8:42 AM
To: dmetwater <dmetwater(@aol.com>
Cc: Emmet Conneely <econneely@horizonlm.com>, Zulema Gatica <zgatica@horizonlm.com>
Subject: Carolina Village notice
Dusty,
Was there a response for this one as well? If so can you please forward to myself and Emmett.
Thankyou
Mayra Orellana, ACM
Regional Property Director
Horizon Land Co., LLC
2138 Espey Court — Suite 1
Crofton, MD 21114
Office: 410.721.3374 x12 11 Fax: 443.332.0055
morel lanaAhorizonlandco.com 11 www.horizoniandmgmt.com