NC0021253_NOV-2021-LV-0065, NOV-2021-LM-0003, NOV-2021-LV-0076, NOV-2021-LV-0077_20210302

February 18, 2021
Havelock Public Services
io4 Outer Banks Drive
Havelock, NC 28532'96)
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CERTIFIED MAIL # 7010 3090 0000 0578 9771
RETURN RECEIPT REQUESTED
Robert Tankard
Assistant Regional Supervisor
Water Quality Regional Operations Section
Washington Regional Office
Division of Water Resources, NCDEQ
943 Washington Square Mall
Washington, NC 27889
SUBJECT: NOTICE OF VIOLATION Tracking Number NOV-2021-LV-0065
NOTICE OF VIOLATION Tracking Number NOV-2021-LM-0003
NOTICE OF VIOLATION Tracking Number NOV-2021-LV-0076
NOTICE OF VIOLATION Tracking Number NOV-2021-LV-0077
Permit No. NC0021253
Havelock WWTP
Craven County
Dear Mr. Tankard:
This letter is in reference to the Notice of Violation letters received February 16, 2021 for the
above referenced numbers.
Limit Exceedance Violations:
BOD for week ending 05/02/2020 —
BOD for week ending 05/09/2020 —
BOD for week ending 05/16/2020 —
BOD for month ending 05/31/2020
NOV 2021-LV-0065
8.42 reported - 8.42 matches our records
10.9 reported - 10.9 matches our records.
12.34 reported — 12.34 matches our records.
— 6.44 reported — 6.44 matches our records.
Regarding BOD levels, the City received extreme excessive rain amounts in May 2020, totaling
over 13.16 inches, potentially explaining elevated flows and higher BOD levels. Additionally,
during this period, we feel there were significant inconsistencies at the contract laboratory testing

level. This is seen in wide range of BOD (a composite sample), from less than 2 to 19, skewing
the monthly average disproportionately. We continue close review of lab results.
NOV 2021-LM-0003
Limit Exceedance Violation:
BOD for week ending 06/13/2020 — 8.52 reported — 8.52 matches our records.
Regarding BOD levels, only three days of the entire month had elevated BOD levels. The City
received extreme excessive rain amounts in June 2020, totaling over 7.45 inches, potentially
explaining elevated flows and higher BOD levels. Inspection of daily BOD results showed
significant improvement in BOD levels from previous month.
Frequency Monitoring Violation:
Nitrogen totals for month ending 6/30/2020 —. Regarding the frequency monitoring violation, our
records indicate that the total monthly nitrogen (CM600) was submitted in the June EDMR. Prior
to submission a validation report was run, showing no errors for CM600. For clarity, the value
for nitrogen loading was 2302.16 lbs. for June 2020. This is supported by our 2020 annual report
that shows the total nitrogen loading for the year 2020, see below.
January
891.35 lbs.
June
2302.16 lbs.
November
356.97 lbs.
February
1602.73 lbs.
July
1351.00 lbs.
December
536.94 lbs.
March
2781.781bs.
August
1094.271bs.
April
1046.47 lbs.
September
1021.40 lbs.
May
1648.28 lbs.
October
1262.25 lbs.
Total
15913.591bs•(')
(1) Reported value includes June 2302.16 lbs.
NOV 2021-LV- 0076
Limit Exceedance Violations:
BOD for week ending 07/18/2020 — 12.7 reported — 12.7 matches our records.
BOD for week ending 07/25/2020 — 7.56 reported — 7.56 matches our records.
BOD for month ending 07/31/2020 — 6.7 reported — 6.7 matches our records.
During this period, we feel there were significant inconsistencies at the contract laboratory
testing level. This is seen in wide range of BOD (composite sample), from less than 2 to greater
than 24. We continue close review of lab results.

NOV 2021-LV-0077
Limit Exceedance Violations:
BOD for week ending 08/01/2020 — 8.58 reported — This does not match our records. There
were no BOD readings for this week, August 1st was a Saturday.
BOD for week ending 08/29/2020 — 15.32 reported —15.32 matches our records.
BOD for month ending 08/31/2020 — 6.11 reported — 6.11 matches our records.
Similar to May and June, the City received extreme excessive rain amounts in August 2020,
totaling over 12.44 inches, potentially explaining elevated flows and higher BOD levels.
Additionally, during this period, we feel there were significant inconsistencies at the contract
laboratory testing level. This is seen in wide range of BOD (composite sample), from less than
two to 51, skewing the monthly average disproportionately. We continue close review of lab
results.
CONCLUSION
As discussed and identified in the submitted EDMRs, the City of Havelock has enforced many
new procedures to eliminate potential sources of contamination affecting BOD testing results,
such as improving sampling protocol. Additionally, the City has enlisted consultant services to
standardize back wash filter and methanol loading rates, which identified issues within the
Denora algorithm and panel. Further, the City has conducted a thorough inspection and
calibration of the chem scan equipment which determines the methanol dosing rates. To further
standardized BOD results, the City reviews methanol usage on an hourly basis to eliminate
overdosing. The City has achieved success. Per lab results, from January 19, 2021 effluent
BOD levels have been less than 5 mg/1.
Susan H. Sayger, PhD, PE
Director, Public Services Department
104 Outer Banks Drive
Havelock, NC 28532
252-444-6409
Cc: Sarah Toppen, Water Quality Section, Washington Regional Office
Frank Bottorff, City Manager, City of Havelock
Cindy Morgan, City Clerk, City of Havelock