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Home My WebLink AboutWQ0033770_NOV-2020-LV-0871_20201216 (2)050lntegraWater, F I lit III S.dir JJ:. 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, 2 Ck DA y s-�V � Sean McMillan Vice President DmvSi9n Envelope ID: 755FBBCC490545FO-BAD2-IIEMlIC1512 ROY COOPER C.m' MICHAEL 5. REGAN St WM S. DANIEL SMITH DUxta 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 �Y a+n_NL 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 ($25,000.00) may be assessed against any person who violates or fails to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S. 143-215.1. e u 115's:x Bzswrrz �` 1 /' DocuSign Envelope ID: 755F$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: ?ou 'ih..Tr� do. 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 Ncrtn Gro��n•0epenmem es Env+cnmmu�puear Ousan nlwner gesa.rus Num.nrmn Rft-e Off 1.7um-1 Ogre Eaenwn I W+mneon, NnN Gm na 28405 u3 '^ 910-7%-7215 44) _ Water 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 #G !� !\rWIPS e aml { \ r ;;, C ! ,k) : r,\ ! i {|� •— ; `� !§! / \ ||:: R !11 ;9, / ( ) °| ( __ __ /:QUVONO \ �| } } !�■°` �!! 009 I| !!!##!!!«!KK«lE;a!■E§5#!*4,K! ! _ ...,.,;,..;.:;.,.,1..;;;,_.>_|. ) ,.,,,,,..:,,,.;.,,,,;, 5!g !� \ <!; 41E�i ,.. ,,,:;r;;;l;,;............................; ,,,,,,, §! 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