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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) External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to report.spam@nc.gov 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