HomeMy WebLinkAboutNC0026441_NOV-2022-SP-0009 Response_20220822RECEIVED
AUG 2 2 2022
NC DEQ/DWR
Central Office
Tam of *tier Cite
Public works and Utilities
August 10, 2022
Attn: Vanessa E. Manuel, Assistant Regional Supervisor
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY
Tracking Number: NOV-2022-SP-0009
NPDES Permit # NC0026441
Town of Siler City
Chatham County
Dear Vanessa E. Manuel,
This letter is in response to the NOV & Intent for Civil Penalty issues on July 25, 2022, for exceeding
the following parameters for May 2022:
• BOD, 5-Day — Weekly Limit = 7.5 mg/1 Reported Week 1 = 10.48 mg/1
• Nitrogen, Ammonia Total (as N) — Weekly Limit = 3 mg/1 Reported Week 1 = 7.78 mg/1
• Nitrogen, Ammonia Total (as N) — Monthly Limit = 1 mg/1 Reported = 1.97 mg/1
Monitoring Violation(s) for the following:
• Iron, Total (as Fe) — Monitoring Frequency = 5 x a week — Frequency Violation
• Iron, Total (as Fe) — Monitoring Frequency = 5 x a week — Frequency Violation
• Nitrate plus Nitrate total (as N) — Monitoring Frequency = 5 x a week — Frequency Violation
• Nitrogen, Kjeldahl, Total (as N) — Monitoring Frequency = 5 x a week — Frequency Violation
It is believed this parameter was exceeded due to still receiving the slug Toads from the WTP. We are working
with the WTP to minimize and eventually stop the slug loads. They have started a new recycling line for when they
wash down their sed basins to reduce the amount of flow that is sent to the lagoon in result reducing the flow that
comes to the WWTP. This process is still in the trial stage. In addition to the recycle line, the WTP is researching the
best possible ways to prevent the slug loads including adding baffle curtains to the lagoon to hold the solids in the
lagoon while still allowing the supernatant to flow to the wet well as designed.
We are still working with sludge haulers on a plan to reduce the solids in the lagoon at the WTP and the sludge
storage basins at the WWTP. We are on the schedule to be hauled every 3 weeks but no longer than 4 weeks. The
Town has also started the conversation to investigate resources and the ability to get a permanent press set up at
the WWTP to allow us to better regulate sludge.
We also found that Mountaire Farms has been sending high levels of CL2. We required them to start monitoring
and reporting the CL2 in their Effluent stream. We also are requiring them to start a dichlorination feed system. We
will continue to monitor and record the CL2 we receive in both the grab and composite samples we get daily.
As for the Monitoring Violation(s) that were on the NOV, we received the notice for Increased Monitoring on
Thursday 5/12/2022 (please see copy attached). We started conducting the sampling the following Monday
5/16/2022. The chemist was tasked with getting bench sheets prepared and sampling material to conduct the
required sampling. I don't believe the NOV portion for Monitoring Violation(s) is accurate, due to us not being
required to conduct the samples during the dates listed (5/7/2022 & 5/14/2022).
Should you have any questions please let me know.
Sincerely,
Brittany York
WWTP Superintendent
Town of Siler City
Cc: Hank Raper — Town Manager, Chris McCorquodale — Utility Director
Brittany York
WWTP Superintendent
PO Box 769.311 N Second Avenue
Siler City, NC 27344-0769
ovroInt cJl d
through tialii+'E ad governance, •
Brittany York
byork@silercity.org
Phone: 919-742-2939
www.silercity.org
DocuSign Envelope ID: 794E35A0-7630-46F8-98CA-5782B6805F6C
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Bill Zell, Interim Town Manager
Town of Siler City
PO Box 769
Siler City, NC 27344
Dear Mr. Zell:
NORTH CAROLINA
Environmental Quality
5/12/2022
Subject: Increased Monitoring
Siler City WWTP
NPDES Permit NC0026441
Grade IV Biological WPCS
Chatham County
t received
As a result of the continuing nature of the Town of Siler City's wastewater treatment plant non-compliance, the
Division of Water Resources is requiring that the Town begin increased wastewater treatment plant monitoring
[15A NCAC 02B .0508 (b)(2) and G.S. 143-215.66]. Effective upon receipt of this letter, the Town of Siler City
shall monitor at a minimum frequency of Daily for the following parameters from the wastewater treatment plant
effluent discharge: BOD5, TSS, and Fecal Coliform. Additionally, monitoring for Chronic WET testing shall be
increased to Monthly and will be performed as a multiple -concentration toxicity test, as described in "North
Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised- December 2010) or subsequent
versions. The Town shall also monitor for Total Iron, Ammonia Nitrogen, NO2-N + NO3-N, and TKN at the
influent to the wastewater treatment plant at the frequencies stated in Table 2.
These samples shall be analyzed and the results of the analyses reported at the end of each month on the facility's
Discharge Monitoring Report form.
In addition, the Town of Siler City is required to increase monitoring in the pretreatment permit for Industrial
User Mountaire Farms Inc. (IUP 004). The following parameters shall be monitored at a minimum frequency of
Daily: BOD, TSS, Ammonia Nitrogen, Total Nitrogen and Total Phosphorous.
A summary of the requirements for all increased and additional monitoring are detailed in Tables 1-3 on page
three of this letter.
This supplemental self -monitoring shall begin immediately and shall continue until the DWR notifies the Town in
writing that the increased monitoring is no longer required. The monitoring requirements listed in this
notification exist as a supplement to the monitoring required in the Town's NPDES permit (NC0026441), and
does not remove any requirements stated in the NPDES permit.
The condition of the wastewater treatment plant for the Town of Siler City is a serious concern to the Division of
Water Resources and steps must be taken immediately to return the facility to compliance with the NPDES permit
and prevent ongoing water quality standards violations that are occurring downstream of the discharge.
North Carolina Department of Environmental Quality I Division of Water Resources
5 2 North Salisbury Street i 1617 Mail Service Center I Raleigh, North Carolina 27699-1617
919 707.9000
DocuSign Envelope ID: 794E35A0-7630-46FB-98CA-57B2B6805F6C
Increases] Monitoring
Siler City WWTP — NC0026441
Page 3 of 3
Table 1. Effluent Monitoring Requirements — Siler City WWTP
PARAMETER
[eDMR Code]
MONITORING REQUIREMENTS
Measurement
Frequency
Sample Type
Sample Location
BOD, 5-day, 20°C (mg/I)
[C0310]
Daily
Composite
Effluent
Total Suspended Solids (TSS) (mg/L)
[C0530]
Daily
Composite
I Effluent
Fecal Coliform (geometric mean)
[316161
Daily
Grab
Effluent
Chronic Toxicity
[THP3B]
Monthly
Composite
Effluent
Table 2. Influent Monitoring Requirements — Siler City WWTP
PARAMETER
[eDMR Code]
MONITORING REQUIREMENTS
Measurement
Frequency
Sample Type
Sample Location
Total Iron (as Fe) (ug/L)
[01045]
Daily
Composite
Influent
Ammonia (NH3 as N) (mg/L]
[C0610]
Weekly
Composite
Influent
NO2-N + NO3-N (mg/L)
[00630]
Weekly
Composite
Influent
TKN (mg/L)
[00625]
Weekly
Composite
Influent
Table 3. Pretreatment Monitoring Requirements — Mountaire Farms Inc.
PARAMETER
MONITORING REQUIREMENTS
Measurement
Frequency
Sample Type
Sample Location
BOD (mg/I)
Daily
Composite
Effluent
Total Suspended Solids (TSS) (mg/L)
Daily
Composite
Effluent
Ammonia (NH3 as N) (mg/L)
Daily
Composite
Effluent
Total Phosphorous (TP) (mg/L) _
Daily
Composite
Effluent
Total Nitrogen (TN) (mg/L)
Daily
Composite
Effluent