NC0024236_NOV-2022-LM-0016 Response_20220315

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March 15, 2022
NC DWQ-Washington Regional Office
Attn: Robert Bullock
943 Washington Square Mall
Washington, NC 27889
Re: Notice of Violation & Intent to Assess Civil Penalty Response from the City of Kinston
Tracking Number: NOV-2022-LM-0016
Dear Mr.Bullock:
Kinston
'ggji.'
2009
The City has received a Notice of Violation and Intent to Assess Civil Penalty from the Division of Water
Resources, NCDEQ, dated March 07, 2022. Based on that NOV, the City requests that the Division consider this
response letter in regards to the violations that occurred on January 4, 2022 (Weekly TSS Average Exceeded)
and January 29, 2022 (Ammonia frequency violation).
On January 4, 2022, the City of Kinston had to bypass part of its treatment process (the denitrification filters).
Flows fluctuated through the day and began to effect plant operations. All basins remained in service. We began
to experience heavy pin flocking from clarifier #3 only and by 6:23 pm, we had to start bypassing the filters. As
you are aware, the filters are the last stage of treatment prior to UV disinfection and final discharge to the Neuse
River.
The State (Mr. Bullock) was notified shortly after (� 6:42 pm).
Average influent flow for the 3`d was 8.09 MGD with flows continuing to fluctuate over the next 24 hours. The
average for the 4th was 3.65 MGD but rebounded with influent flows the remainder of the week between 4.41-
6.83 MGD.
We utilized our peak flow basins but unfortunately it was not enough. The temporary polymer feed system was
down so that could not be used (pump failure).
All filters were put back on line at 9:45 am, Monday, January 10, 2022
Daily composite effluent TSS results for the event are as follows:
• January 3, 2022:
• January 4, 2022:
• January 5, 2022:
• January 6, 2022:
• January 7, 2022:
• January 8, 2022:
• January 9, 2022:
• January 10, 2022:
<2.5 mg/L
<2.5 mg/L
46.8 mg/L
226 mg/L
217 mg/L
38.5 mg/L
7.7 mg/L
8.5 mg/L
Johnnie Mosley Regional Water Reclamation Facility
2101 Becton Farm Rd
Kinston, North Carolina 28501
Phone [phone] Fax [phone]

The January 2-8, 2022 weekly average limit value of 45 mg/L was exceeded for TSS. The average for the week
was 88.05 mg/L.
Sludge wasting data for that time period (January 1- 4, 2022) show that 298,299 gallons was wasted.
Rain in the area from January 1- 5, 2022 was just over 2.25 inches.
As you are aware, we continued over the weeks to look into other areas to see if adjustments could be made. We
did make some recent adjustments to the RAS valves in front of the BNR which receives flow from the RAS
pumps. In front of each train there are 3 valves which allow us to send return sludge to 3 different locations in
the pre -aeration chambers. The 2 fiont ones are the pre -anoxic chambers and an anaerobic chamber. The third
chamber is also an anaerobic chamber which can receive returns of aerated mix liquor flow via the oxic recycle
pump When our influent flows were high the first 6 months of 2021, we needed all of these valves open to mix
with the high flows we were encountering. Since the flows have dropped off and some I & I problems have been
repaired, we closed off all the valves that were returning sludge to the anaerobic chambers on each train to try
and maintain a decent ratio of return sludge and influent flow. That's especially needed at night when the flows
tend to drop low. This leaves one valve open to send flow to the pre -anoxic chambers on each train which is
mixing constantly. We now have seen a drop in sludge levels with all three clarifiers since making these
adjustments.
The City is working with a biosolids company to remove and offset the daily loading of the dryer. We currently
are hauling 2-3 truckloads Tuesday -Friday as weather permits. The press will continue to be ran as we also
continue our growing use of the Biosolids Dryer. We have expanded the press run times to 6 days a week with a
minimum 10 hour run time.
The City has received Wastewater AIA grant funds...The Wooten Company will be reviewing plant operations
and biosolids processes to improve our efficiency. Wooten has a vast knowledge of our system having performed
over 75 projects for the City over the past 54 years. The City believes Wooten has the capability to work
aggressively in developing a fundamental plan for us as we move forward in maintaining our NPDES permit
compliance and protecting our environment.
The monitoring frequency violation was the result of a "Laboratory Error". The Effluent samples were collected
for that day however the Ammonia sample was not ran. The Lab Supervisor began an investigation into what
happened that day. From that investigation, it was noted that the Lab Tech either inadvertently poured out the
sample and placed the empty bottle in the dishwasher as he was preparing to wash dishes or he misplaced the
ammonia bottle and didn't pour the sample in it. Disciplinary action was taken against the Lab Tech and our lab
checklist was updated to reflect a more thorough daily review.
If I can be of any further assistance, please call me at 252-939-3375 or email at
Kenneth.Stevens a ci.kinston.nc.us.
Sin
Kenneth R. Stevens,
Johnnie Mosley RWRF Superintendent
C:
Rhonda Barwick- Director of Public Services
Steve Miller- Assistant Director of Public Services
File
Johnnie Mosley Regional Water Reclamation Facility
2101 Becton Farm Rd Kinston, North Carolina 28501
Phone [phone] Fax [phone]