HomeMy WebLinkAboutWQ0033770_NOV-2020-LV-0871_20201216050lntegraWater,
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December 16, 2020
Morelia Sanchez -King, Regional Supervisor
Water Quality Regional Operations Section
Wilmington Regional Office
Division of Water Resources, NCDEQ
Re: Notice of Violation & Intent to Issue Civil Penalty
Tracking No: NOV-2020-LV-0871
Permit No: WO0033770
Carolina Plantation WWTP
Onslow County
Dear Morelia Sanchez -King,
I am in receipt of the above referenced NOV dated December 8, 2020 and wanted to respond as to what
actions we have taken to correct the monthly average flow at the W WTP of Carolina Plantations. It is
worth mentioning, Envirolink (Mike Myers and his team) were the only contact representatives listed in
your data base for ONSWC for communications of NOV's or any other communication coming from
NCDEQ. I was able to work with Dean Hankler at the end of September to make the necessary contact
changes in your database so we would receive notifications rather than Mike Myers and his team. I feel
we have responded promptly after receiving notice of the first NOV's we received. As mentioned
previously in our October 5, 2020 NOV response, we installed an Air Vent T on the discharge line on
October 1, 2020 to allow the water to flow smoothly and evenly from the discharge. I have included the
October 12, 2020 response from John McDonald referencing this change for the October 5, 2020 Notice
of Violation.
I have also included the most up to date average monthly flow data for October 2020 and November
2020 and as you can see the Air Vent T appears to be working because we have not exceeded our
monthly average flow limit of 150,000 since the Air Vent T was installed. The monthly average flow for
October was 139,601 GIRD and the monthly average flow for November was 147,315 GPD.
Please reconsider the enforcement of the civil penalty, as we are working diligently to solve the issues.
Thank you for any consideration and please reach out with questions or concerns at the address above,
email at smcmillan2inteerawater com or give me a call directly at 205-719-7795.
Sincerely,
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Sean McMillan
Vice President
DmvSi9n Envelope ID: 755FBBCC490545FO-BAD2-IIEMlIC1512
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MICHAEL 5. REGAN
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S. DANIEL SMITH
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Certified Mail #7018 2290 0001 8295 9694
Return Receipt Requested
John L McDonald
Old North State Water Company LLC
PO Box 10127
Birmingham, AL 35202-0127
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NORTH CAROLINA
Envlronmenral Quallry
December 8, 2020
SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY
Tracking Number: NOV-2020-LV-0871
Permit No. W00033770
Carolina Plantation WWTP
Onslow County
Dear Permittee:
A review of the September 2020 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 %notation
001 Flow, in conduit or thru 9/30/2020 150,000 166,025.33 Monthly Average Exceeded
treatment plant (50050)
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 Nan -discharge Permit. Pursuant to G.S. 143-215.6A, a civil penalty of
not more than twenty-five thousand dollars ($25,000.00) may be assessed against any person who violates or
fails to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S.
143-215.1.
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DocuSign Envelope ID: 755F$BCC-490545FD-$AD2-BOE2A43C3512
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,
CoocuSNned by:
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71`141E7396F3453... for
Morella Sanchez -King, Regional Supervisor
Water Quality Regional Operations Section
Wilmington Regional Office
Division of Water Resources, NCDEQ
Cc: Sean McMillan — electronic copy
Upload to Laser fiche
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October 12, 2020
Ms. Morelia Sanchez -King, Regional Supervisor
Water Quality Regional Operations Section
Wilmington Regional Office
Division of Water Resources, NCDEQ
Re: Notice of Violation & Intent to Assess Civil Penalty
Tracking Number NOV-2020-LV-731
Permit No. WQ0033770
Carolina Plantation WWiP
Onslow County
Dear Ms. Sanchez -King:
I am in receipt of the above referenced NOV dated October 5, 2020 and wanted to make you aware of
some modifications we are either planning or have made at the facility. The discharge line had a 90
degree elbow on the discharge line, just after the effluent box inside the plant. The elbow was not
allowing a smooth flow of water through the meter because of the vacuum created in the pipe. A'T"
was installed on the discharge line and allows the water to flow smoothly and evenly from the
discharge. Here are the before and after pictures:
before after
It is our theory that the intermittent flows and backups caused by the vacuum caused the flow meter to
read artificially high flows. The data since the installation of the Tr seems to confirm the theory. Here
are the flows since the installation of the'T":
Flows
9/25-164300 Gallons
9/26-172,200
9/27-184,300
9/28-172,100
9/29-164,900
10/1-153,500
After Tee was installed
10/2-138,DD0
10/3-139,000
10/4-155,700
10/5-156,500
10/6-142,600
10/7—138,750
10/8— 142,900
10/9-146,700
10/10-155,300
10/11-162,5D0
10/12 147,000
In addition to the above -mentioned improvements, we have engaged a professional engineer to
evaluate the feasibility of rerating the plant. We are watching the new flow data, and the engineer is
working to determine if rerating the plant is feasible or if additional improvements will be required to
address both the flows, and the permit exceedances.
Last, Old North State has terminated its relationship with Envirolink, Inc. for contract operations the last
week of September. We were receiving poor service and very little information related to performance,
compliance, and maintenance. We believe you will see improved communications, operations and
maintenance from Old North State moving forward. We would ask for some limited leeway to study the
flows and determine if the Installation of the "T" will allow compliance or rerating of the W WTP, or if
further improvements will be required. Please reconsider the enforcement of the civil penalty, as we
are working diligently to solve the issues.
Thank you for any consideration and please reach out with questions or concerns at the address above,
email at imcdonald2integrawater com or give me a call directly at 205.326.3355.
Sincerely,
John L. McDonald
Manager
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