NC0024210_Illegal_Discharge_NaOCl_NOV2021DV0234_20210503

ROY COOPER
Governor
DIONNE DELLI-GATTI
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
May 03, 2021
City of High Point
Attn: Terry L. Houk, Public Services Director
P.O. Box 230
High Point, NC 27261-0230
SUBJECT: Notice of Violation NOV-2021-DV-0234
City of High Point East Side Wastewater Treatment Plant
NPDES Permit NC0024210
Illegal Discharge of Sodium Hypochlorite
Guilford County
Dear Mr. Houk:
The NC Division of Water Resources (NCDWR), Winston-Salem Regional Office (WSRO),
was notified on April 21sY, 2021, of the accidental release of 1,330 gallons of approximately
six percent Sodium Hypochlorite solution, into the polishing filters of the City of High
Point's East Side Wastewater Treatment Plant (WWTP). The cause of the accidental release
was operator error when an operator mistakenly turned on the chemical injection pump.
The pump was promptly turned off the following day when it was discovered it had been
mistakenly activated. The chemical was injected into the plant's filters and then discharged
directly into Deep River, which is currently classified as a water supply IV, critical
watershed area.
The filters are the final treatment process before the effluent is discharged to the receiving
water. It is therefore believed the receiving water body likely received the chemical at high
strength, prompting concerns for fish and other wildlife in the area near the outfall. Mr.
John Thomas, the operator in responsible charge (ORC) of the plant, called Mr. Ron Boone,
of our office, to report further developments about the mishap the day after it occurred. Mr.
Boone asked Mr. Thomas if any samples had been taken to assess the chlorine residual in
the effluent or whether the receiving water body had been evaluated for any negative
effects. Mr. Thomas informed Mr. Boone that only one sample had been taken and its
chlorine residual was measured using the facility's low-level chlorine meter. Because the
chlorine level of the sample was so high, the only thing that could be determined was that
the chlorine level was beyond the meter's maximum limit, or >100 micrograms per liter.
The sample was also analyzed beyond the maximum holding time for a chlorine residual
grab sample, thereby indicating the chlorine residual would have been even higher at the
time the sample was taken.
D_E
NORTH nARfEnviro
Department of EnvironmentalOpAi
North Carolina Department of Environmental Quality 1 Division of Water Resources
Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105
336.776.9800

Mr. Thomas also informed Mr. Boone that the receiving water body had not yet been
evaluated for damages at which point Mr. Boone requested he travel to the outfall to assess
it. Mr. Thomas later reported that he observed no fish kill or other negative indicators,
which is likely due to dilution from the lake.
Regardless, this unauthorized discharge represents a serious violation of State law,
regulations, and permit conditions, and the City needs to act with more urgency when
similar incidents occur in the future.
Please reply to this letter, in writing, within 10 days of receiving it, to provide any further
information regarding the cause and circumstances surrounding the incident and what the
city has done or will do to prevent such unfortunate incidents in the future.
Please feel free to contact Mr. Boone by phone at 336.776.9690, or by email at
[e-mail]. Thank you in advance for your prompt attention to this matter.
cc: Laserfiche
LD_E
NORTH CAROLINA
Department of Environmental quaky
Sincerely,
DocuSigned by:
0D2D3CE3F1B7456_.
Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
North Carolina Department of Environmental Quality j Division of Water Resources
Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105
336.776.9800