NC0001899_Response to Compliance Evaluation Inspection_20220707

Eco TIP West LLC
PO Drawer 9
Sanford, NC 27331
July 7, 2022
Vanessa E. Manuel
Assistant Regional Supervisor
Raleigh Regional Office
3800 Barrett Drive
Raleigh, North Carolina 27609
Title: Response to June 3, 2022 Compliance Evaluation Inspection
Eco TIP West LLC WWTP
NPDES Permit No. NC0001899
Chatham County
Dear Ms. Manuel,
This letter has been prepared to provide a formal response to the the North Carolina Department
of Environmental Quality (NCDEQ) Division of Water Resources' (DWR's) June 3, 2022
Compliance Evaluation Inspection letter ("letter") to Eco TIP West LLC (Eco TIP) regarding the
above-refereced facility. The letter provided a summary of a compliance evaluation inspection
(CEI) conducted by Cheng Zhang of the NCDEQ Raleigh Regional Office (RRO) on March 11,
2022. NCDEQ requested that Eco Tip provide a response to items 2, 3, and 6 identified in the
letter. Items 2, 3, and 6 from the June 3 letter are reproduced below, along with Eco TIP's
responses.
As a reminder, the Operator in Responsible Charge (ORC) for the wastewater treatment plant
transitioned from Withers Ravenel to Greener EHS during the timeframe from September 2021 to
October 2021 due to the retirement of long-term operational staff. Some of the items summarized
below concern information provided by the previous and the current ORC.
• Item #2: The facility stopped production in 2015 and has been in the process of demolition
since. There has been no process wastewater generated from the facility. There was a
process cooling water (containing ethylene glycol and antimony) spill in March 2014,
spilled material was contained in the stormwater pond. Discharge from the stormwater
pond to Outfall 002 was stopped (valve at the discharge pipe was closed) since the spill.
Water from the stormwater pond is pumped to the spill pond adjacent to the aeration basin.
Water from the spill pond is treated in the following treatment units: aeration basin,
secondary clarifier, polishing pond, contact chamber and discharged to Outfall 001. It was

noted that the original effluent pipe has been clogged significantly (with capacity of less
than 20 gallons/minute). When flow exceeds the capacity, effluent has to be pumped (with
a portable pump) to the water intake station (using the existing water intake pipe) and then
to Outfall 001 through layflat hose. It was noted that at the time of inspection the two
surface aerators were not operable. There was hardly any activated sludge in the aeration
basin.
Response to Item #2: According to the previous ORC, cessation of discharge of
stormwater from the stormwater pond and pumping of that stormwater to the wastewater
treatment plant was done under the direction of NCDEQ staff following the spill noted.
Regarding the effluent pipe and portable pump, work is underway to install a permanent
pump to replace the portable pump and streamline discharge operations.
Regarding the aerators, one aerator was installed on March 24, 2022, and has been
operating as intended. The second aerator was installed on May 18, 2022, but failed due to
electrical issues. The failed unit has been sent to an electrical shop for repair and is
projected to be ready in July 2022.
Regarding the presence of activated sludge, it was noted in the CEI that the facility no
longer generates process wastewater, which was the source of food for activated sludge
biomass. Therefore, large amounts of activated sludge biomass are no longer supported by
the wastewater, nor needed for treatment. Aeration needs are likewise significantly less due
to the absence of food that requires oxygen for consumption. Due to the lack of or reduction
in need for activated sludge and aeration to treat stormwater, it is intended that operation
will continue in a similar manner until the plant is taken offline.
• Item #3: It was noted that monitoring at Outfall 002 resumed since January 2019.
However, aluminum and zinc were analyzed only once (in January 2022) at the time of
inspection. It was also noted that upstream and downstream monitoring at Outfall 001 has
not been conducted since December 2017.
Response to Item #3: Aluminum and zinc are monitored quarterly at Outfall 002 according
to the NPDES permit requirement. The second quarter sample was analyzed on April 6,
2022, and will continue to be analyzed quarterly. In reviewing available monitoring
records, it appears that the quarterly monitoring of aluminum and zinc was not being
routinely performed by the previous ORC, and was not conducted during the transition to
the current ORC in Q4 2021. However, as noted above, quarterly aluminum and zinc
sampling at Outfall 002 was conducted in Q1 and Q2 2022, and will continue going
forward.
According to the previous ORC, upstream and downstream monitoring had not been
performed for more than seven years due to safety issues accessing the monitoring

locations. These safety concerns were discussed with Mr. Zhang during the inspection.
Additionally, the current ORC has noted that the eDMR form supplied by NCDEQ does
not include a data entry sheet for upstream or downstream monitoring data. Therefore, it is
not possible to report these data on the eDMR.
Eco TIP proposes an on -site meeting with NCDEQ staff to discuss upstream and
downstream monitoring locations and safe access, and to discuss the addition of a sheet to
the eDMR to facilitate reporting of these data. This will help evaluate the feasibility of
sampling of these locations and reporting of the data in accordance with the permit moving
forward.
• Item #6: It appears that the main purpose to keep the facility in operation is to slowly
mix/dilute the contaminated water contained in the stormwater pond with stormwater and
let it discharge into the Haw River. Therefore, it is strongly recommended that the facility
include antimony in the monthly monitoring at Outfall 001.
Response to Item #6: As previously noted, NCDEQ directed the previous ORC to cease
the discharge of stormwater from the stormwater basin via Outfall 002, and to pump this
stormwater to the wastewater treatment plant. The wastewater treatment plant continues to
operate to facilitate the discharge of this stormwater and drainage from process piping
connected to drains currently exposed to stormwater within the remaining building slab
(following demolition of the main facility building) in former process areas until the
facility's closure plan is implemented.
Including antimony in the monthly monitoring at Outfall 001 was also discussed during
the inspection. Monthly antimony sampling is a recommendation from NCDEQ and not a
requirement of the NPDES permit. Eco TIP will consider this recommendation in light of
activities and data collection that are also required and planned as part of the closure plan
for the facility.
Eco TIP West LLC appreciates your comments and inputs in your June 3, 2022 letter. Please
contact us with your availability to meet on -site to discuss upstream and downstream sampling
locations and reporting needs, and if there are any additional questions related to the responses
included in this letter. Please also note that decommissioning of the entire WWTP is anticipated
to occur in 2022 or 2023, depending on redevelopment timing for this area of the property.
Operation will continue until that time, when closure will occur in accordance with the NCDEQ-
approved closure plan.
Sincerely,
Kirk J. Bradley, Manager