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HomeMy WebLinkAboutNC0006190_NOV-2022-PC-0213 Response_20220527South Fork Industries Inc. RECEIVED/NCDEQ/DWR MAY 2 7 2022 Telephone 828-428-9921 woRos Fax 828-428-9964 P.O. Box 742 100 West Pine Street MOORESVILLE REGIONAL OFFIC ,4aiden, North Carolina 28650 WES BELL NC DEQ- DIVISION OF WATER RESOURCES 610 EAST CENTER AVENUE SUITE 301 MOORESVILLE NC 28115 MAY 17,2022 WES BELL, I AM WRITING THIS LETTER IN RESPONSE TO THE NOTICE OF VIOLATIONS WE RECEIVED AFTER YOU COMPLETED THE COMPLIANCE EVALUATION INSPECTION ON APRIL 12,2022. FIRST OF ALL, I WOULD LIKE TO THANK YOU FOR ALL YOUR HELP AND COOPORATION WITH SOUTH FORK INDUSTRIES WASTEWATER FACILITY. I ALSO WANT TO ASSURE YOU WE WILL BE DOING EVERYTHING POSSIBLE TO RESPOND TO AND REPAIR EVERYTHING CONTAINED IN THE REPORT. THE FIRST AND MOST IMPORTANT ITEM IN YOUR INSPECTION EVALUATION WAS THE RELEASE OF OIL ONTO THE DRIVEWAY AND INTO THE DRAIN LOCATED IN THE AREA OF OIL RELEASE. WE IMMEDIATLEY ADDRESSED THE AREA AND CLEANED AND DISPOSED OF ALL OIL RESIDUE IN THE DRIVEWAY. THE OIL IS A DISCHARGE FROM OUR AIR ESP UNITS THAT WE COLLECT AND HAVE PICKED UP BY AN OIL RECYCLING FACILITY.WE HAVE RE-INFORCED THE CONTAINMENT AREA AROUND THE UNIT AND WE HAVE ORDERED NEW SEALS TO ELIMINATE THE UNIT DISCHARGING FROM AREAS ON THE UNIT OTHER THAN NORMAL DRAINS TO COLLECTION CONTAINERS.WE HAVE INITIATED A SITE EVALUATION CHECK TO BE DONE DAILY BY ASSIGNED MAINTENANCE PERSONNEL TO INSURE THAT NO DICHARGE DOES GET OUT OF UNIT CONTAINMENT AREA . THAT WILL BE A PRIORITY ITEM AND WILL BE FOLLOWED UP BY INSPECTIONS BY MANAGING PERSONNEL ALSO. I HAVE ATTACHED SOME PHOTOS OF THE AREA. South Fork Industries Inc. P.O. Box 742 100 West Pine Street Telephone 828-428-9921 Fax 828-428-9964 Maiden, North Carolina 28650 THE NEXT ITEM WE ARE ADDRESSING IS THE RUST AND DETERIORATION OF THE CLARIFIERS. DON BURKEY OUR ORC HAS CONTACTED CHARLES A UNDERWOOD CO. TO GET EVALUATION AND QUOTES TO BEGIN THE PROCESS OF RECONDITIONING OR REPLACING BOTH OF OUR CLARIFYING UNITS.DON WILL KEEP THE DIVISION INFORMED OF OUR PLAN OF ACTION FOR THIS PROJECT. THE NEXT ITEM ON THE LIST IS OUR BARSCREEN DUMPSTER LOCATED OUTSIDE OUR SHAKER FACILITY POSSIBLY DISCHARGING WASTEWATER ONTO DRIVEWAY WHEN BEING EMPTIED. WE HAVE BUILT AND MAINTAINED THE CONTAINMENT AREA AROUND THE DUMPSTER THAT IS WORKING WHEN UNIT IN SERVICE. WE HAVE THE DUMPSTER COMPANY PICKING THE DUMSTER MONTHLY ON FIRST MONDAY MORNING TO ALLOW THE DUMPSTER TO DRY OUT AND TO ALLOW IT TO CONTAIN AS LITTLE WATER RESIDUE AS POSSIBLE IN THE LINT. THEY ALSO HOLD IT UP OVER THE CONTAINMENT AREA TO ENSURE ANY DRAINAGE THAT DOES HAPPEN FALLS INTO THE CONTAINMENT AREA UNTIL DRAINAGE IS COMPLETE BEFORE PLACING INTO TRUCK. THIS HAS ELIMINATED WASTEWATER GETTING OUT OF CONTAINMENT AREA TO MY KNOWLEDGE.WE ALSO HAVE MAITENENCE PERSONNEL THERE DURING PICK UP TO INSURE PROPERLY COMPLETED. LAST ITEM TO BE ADDRESSED IS THE TOTAL NUMBER OF VIOLATIONS THAT HAVE OCCURRED OVER THE PAST COUPLE YEARS. WE HAVE BEEN AS CONCERNED ABOUT THESE ITEMS AND WHY THEY ARE OCCURING AS YOU HAVE. AS YOU KNOW COVID CHANGED EVERYHING DURING THAT TIME PERIOD INCLUDING HOW WE OPERATED AND THE MATERIALS THAT WE PROCESSED. WE SWITCHED OUR FACILITY OVER TO MOSTLY PPE SUPPLIES FOR THE FEDERAL AND STATE GOVERNMENT. WE ARE CONTRACTED BY THEM ON OVER FIFTY PERCENT OF OUR NORMAL PRODUCTION BUT DURING COVID WE RAN CLOSER TO 85 PERCENT FOR THE GOVERNMENT FOR PPE MATERIALS. THIS CHANGE AND THE LOWER VOLUMES OF PRODUCTION CREATED WASTEWATER ISSUES FOR US AS ALL LOW WASTEWATER DISCHARGE TIMES DO.WE ARE NOW BACK TO NORMAL PRODUCTION OPERATION ACTIVITIES AND WE WILL BE SEEING BETTER WATEWATER CONDITIONS AND VOLUMES. WE ALSO ARE TAKING STEPS TO ADDRESS THE ISSUES IN OTHER WAYS TO. FIRST, WE ARE EVALUATING AND MOVING FORWARD ON SWITCHING OUR BASINS AERATION SYSTEM FROM THE MECHANICAL FLOATING DEVICES TO AN AIR DEFUSED SYSTEM. DON AND HIS ASSISTANTS ARE CONTACTING AN ENGINEER TO BEGIN THE PROCESS OF DESIGNING AND INSTALLING THE NEW SYSTEM. South Fork Industries Inc. P.O. Box 742 100 West Pine Street Telephone 828-428-9921 Fax 828-428-9964 Maiden, North Carolina 28650 IT WILL TAKE SOME TIME BUT WE THINK IF WE DO THIS IT WILL HELP US IN MANY AREAS OF PARAMETERS OF OUR PERMIT. IT SHOULD HELP US INCREASE BOD, COD, AND TSS REMOVAL EFFICIENCY AND POTENTIALLY PREVENT FUTURE VIOLATIONS OF THESE PARAMETERS.WE ARE ALSO EVALUATING THE ADDITION OF SULFURIC ACID TO HELP LOWER PH LEVELS WHICH SHOULD HELP WITH THE PROCESS OF MICROORGINISM REPRODUCTION AND POSSIBLY PRODUCE A BROADER RANGE OF MICROORGINISMS. WE ARE ALSO DISCUSING IDEAS OF HOW TO MINIMIZE THE EFFECTS OF LACK OF PRODUCTION AND DISCHARGE OVER OUR WEEKEND SHUTDOWNS.WE ARE DISCUSSING POSSIBLE ALTERATIONS TO THE FLOW OF WASTEWATER INTO THE BASINS, POSSIBLY USING ONE BASIN AS A HOLDING BASIN AND PUMPING ATER FROM THE HOLDING BASIN INTO THE OTHER BASIN DURING LOW FLOW CONDITIONS. THIS IS A STRATEGY THAT WAS DISCUSSED WITH YOU RECENTLY DURING THE PLANT INSPECTION. AS YOU CAN SEE, WE HAVE A LOT TO DO BUT IT IS A PRIORITY FOR OUR COMPANY DURING THE REMAINDER OF THIS YEAR AND MOVING INTO THE FUTURE. WE ARE PREPARED TO FUND THESE ITEMS AND TO MAKE ROOM IN OUR BUDGET TO ENSURE THEIR COMPLETION.WE ARE OPEN TO ALL SUGGESTIONS AND RECOMENDTIONS FROM YOUR DIVISION TO HELP US MOVE FORWARD. I HOPE THIS LETTER ASSURES YOU THAT SOUTH FORK INDUSTRIES INC. TAKES THIS NOTICE OF VIOLATION VERY SERIOUSLY AND WILL MAKE ALL EFFORTS TO REMEDY ALL ITEMS IN AS TIMELY MANNER AS ALLOWED BY CONDITIONS AT THIS TIME. IF YOU FIND ANY ITEMS LISTED AND REPONDED TO INSUFFICIANT PLEASE CONTACT ME AT EVERETTE@a SOUTHFORKIND.COM OR 828-428-9921 AGAIN, THANK YOU FOR YOUR ASSISTANCE. EVERETTE OWENS PLANT MANAGER ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director Certified Mail # 7020 3160 0000 3277 0792 Return Receipt Requested Everette Owens, Plant Manager South Fork Industries, Inc. Post Office Box 742 Maiden, NC 28650-0742 SUBJECT: Notice of Violation Compliance Evaluation Inspection South Fork Industries, Inc. WWTP NPDES Permit No. NC0006190 Catawba County Tracking #: NOV-2022-PC-0213 Dear Mr. Owens: NORTH CAROLINA Environmental Quality April 20, 2022 Enclosed is a copy of the Compliance Evaluation Inspection (CEI) Report for the inspection conducted at the subject facility on April 12, 2022, by Mr. Wes Bell of this Office. Please advise the facility's Operator -in -Responsible Charge (ORC) of our findings by forwarding the enclosed report. This report is being issued as a Notice of Violation (NOV) due to the permittee's failure to provide proper operation and maintenance at the wastewater treatment system which led to the unpermitted discharges of oil into Clark Creek via effluent discharge. Please be advised that the failure to provide proper operation and maintenance and the unpermitted discharges of oil are violations of the subject NPDES Permit, North Carolina General Statute (G.S.) 143-215.1 and G.S. 143-215.83(a)/Unlawful Discharge of Oil. Please note that G.S. 143-215.6A provides for a civil penalty of not more than twenty-five thousand dollars ($25,000.00), or twenty-five thousand dollars ($25,000.00) per day when the violation is of a continuing nature, 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 Pursuant to G.S.143-215.88A, any person who is deemed to be in violation of G.S. 143-215.83, or who fails to comply with the clean-up requirements of G.S. 143-215.84, shall incur, in addition to any other penalty provided by law, a penalty in an amount not to exceed five thousand dollars ($5,000.00) for each such violation. Penalties may also be assessed for any damage to surface waters of the State that may result from the violation. North Carolina Department of Environmental Quality 1 Division of Water Resources Mooresville Regional Office 1 610 East Center Avenue. Suite 301 1 Mooresville, North Carolina 28115 704.663.1699