NC0021849_NOV-2021-PC-0177 Response_20210324

EARNELL BROWN
MAYOR
PAMELA W.HURDLE
TOWN MANAGER
BENJAMIN M. GALLOP
TOWN ATTORNEY
Date: March 24, 2021
COMMIEDZIED
Robert Tankard, Assistant Regional Supervisor
Division of Water Resources
Washington Regional Office
943 Washington Square Mall
Washington NC 27889
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QUENTIN JACKSON
FRANK NORMAN
JERRY MIMLITSCH
SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY
NOV-2021-PC-0177
Town of Hertford WWTP Permit No. NC0021849
Dear Mr. Tankard:
In response to the violations noted in the NOV dated March l I, 2021, we offer the following
comments:
• Violation for unauthorized bypass
o During the Compliance Evaluation inspection, dried sludge was noted on the
ground near the digested sludge storage tank. The Town had used a portable
pump and lay -flat hose to pump digested sludge from the storage tank to tanker
trucks for disposal. During the pumping operation, the pump became clogged.
In the required maintenance event to return the pump to operation, the
discharge hose had to be disconnected and the pump housing opened. Both
activities resulted in drainage from the hose and pump to the ground. The
drainage did not reach any waters of the state and was confined to the
immediate area of the digesters on the site of the Wastewater Treatment Plant.
The calculated discharge based upon the diameter (6 inches) of the piping and
length of the pipe (200 feet) was approximately 500 gallons.
o In the NOV, the event was described as a "bypass". Based upon our
understanding of the permit definition and intent, we do not think the discharge
caused by a maintenance event meets the criteria of a bypass. Generally, a
bypass would be considered the flow going around a treatment unit to the next
treatment unit. In this case no treatment units were bypassed.
Town of Hertford • P.O. Box 32. 114 West Grubb • Hertford, North Carolina 27944
Phone [phone] • Fax [phone] • [e-mail]
202,

o We do acknowledge that the area of the discharge should have been more
thoroughly cleaned, but due to the unusually wet weather, this was not able to
be done.
• Violation for bypassing disk filter
o During the Compliance Evaluation inspection, it was noted that one of the
filters was out of service and that a portion of the flow was bypassing the
operational filter. The bypassing of the operational filter was a direct result of
the other filter being out of service and ongoing high flow events due to the
excessive amounts of rain in the first months of 2021. The unit is designed to
handle 1.1 MGD. The flow into the plant at the time was in excess of 1.4
MGD. The bypass of the unit is part of the design to allow treated effluent to
still reach the chlorine contact tank. Even with the bypass, the effluent still
met all permit limits. The parts to repair the filter have been purchased, at a
cost of $5,000.00, and are on -site. The Town staff had planned to make the
repairs, but with staff shortages and other staffing concerns related to the
Covid-19 virus, the repairs had not yet been finished. The Town is now in the
process of contracting with the manufacturer to have their people come in and
repair both disk filters. This repair is at a cost of $30,000.00.
The levy of a civil penalty on the Town at this time would present a financial hardship and
would seriously impact our ability to continue operation and repairs of the Treatment Facility.
As anticipated revenues are down due to the virus, upkeep and lack of financial resources, the
Town is experiencing a cash flow issue; we gratefully thank you for your consideration in this
matter.
Sincerely,
a
Pamela Hurdle
Town Manager
Town of Hertford • P.O. Box 32. 114 West Grubb • Hertford, North Carolina 27944
Phone [phone] • Fax [phone] • [e-mail]