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NC0023230_LV20140124_20141010
it � ' r North Carolina Department of Environment and Natural Resources Pat McCrory Governor Certified Mail # 70132630000207608179 Return Receipt Requested October 01, 2014 Billy Joe Farmer Onslow Water and Sewer Authority PO Box 1415 Jacksonville, NC 28540 -1415 SUBJECT: Notice of Violation and Assessment of Civil Penalty for Violations of North Carolina General Statute (G.S.) 143- 215.l(a)(6) and NPDES Permit No. NCO023230 Onslow Water and Sewer Authority Richlands WWTP Case No. LV- 2014 -0124 Onslow County Dear Permittee: John E. Skvarla, III Secretary RECEIVEDIDENRIDWR OCT 13 ?_014 water Quality on Permitting This letter transmits a Notice of Violation and assessment of civil penalty in the amount of $3,543.00 ($3,375.00 civil penalty + $168.00 enforcement costs) against Onslow Water and Sewer Authority. This assessment is based upon the following facts: a review has been conducted of the discharge monitoring report (DMR) submitted by Onslow Water and Sewer Authority for the month of June 2014. This review has shown the subject facility to be in violation of the discharge limitations and /or monitoring requirements found in NPDES Permit No. NC0023230. The violations, which occurred in June 2014, are summarized in Attachment A to this letter. Based upon the above facts, I conclude as a matter of law that Onslow Water and Sewer Authority violated the terms, conditions or requirements of NPDES Permit No. NCO023230 and G.S. 143- 215.1(a)(6) in the manner and extent shown in Attachment A. In accordance with the maximums established by G.S. 143- 215.6A(a)(2), a civil penalty may be assessed against any person who violates the terms, conditions or requirements of a permit required by G.S. 143- 215.1(a). Based upon the above findings of fact and conclusions of law, and in accordance with authority provided by the Secretary of the Department of Environment and Natural Resources and the Director of the Division of Water Resources, I, James H. Gregson, Regional Supervisor, Wilmington Regional Office hereby make the following civil penalty assessment against Onslow Water and Sewer Authority: 127 Cardinal Drive Extension. Wilmington. North Carolina 28405 Phone: 910- 796 -7215 \Internet: www. ncdenr .gov <http: / /vmw.ncdeiir.gov> An Fnual rinmutimiry ` Affimiative .Acainn Fmnlnver.Made in nan by rrcveled naner $1,125.00 1 of the 1 violations of 143- 215.1(a)(6) and NPDES Permit No.NC0023230, by discharging waste water into the waters of the State in violation of the Permit Monthly Average for BOD - Conc. $1,125.00 1 of the 1 violations of 143- 215.1(a)(6) and NPDES Permit No.NC0023230, by discharging waste water into the waters of the State in violation of the Permit Monthly Average for NH3 -N - Conc. $750.00 2 of the 2 violations of 143- 215.1(a)(6) and NPDES Permit No.NC0023230, by discharging waste water into the waters of the State in violation of the Permit Weekly Average for BOD - Conc. 375.00 l of the 1 violations of 143- 215.1(a)(6) and NPDES Permit No.NC0023230, by discharging waste water into the waters of the State in violation of the Permit Weekly Average for NH3 -N - Conc. $3,375.00 TOTAL CIVIL PENALTY 168.00 Enforcement Costs $3,543.00 TOTAL AMOUNT DUE Pursuant to G.S. 143- 215.6A(c), in determining the amount of the penalty I have taken into account the Findings of Fact and Conclusions of Law and the factors set forth at G.S. 14313- 282.1(b), which are: (1) The degree and extent of harm to the natural resources of the State, to the public health, or to private property resulting from the violation; (2) The duration and gravity of the violation; (3) The effect on ground or surface water quantity or quality or on air quality; (4) The cost of rectifying the damage; (5) The amount of money saved by noncompliance; (6) Whether the violation was committed willfully or intentionally; (7) The prior record of the violator in complying or failing to comply with programs over which the Environmental Management Commission has regulatory authority; and (8) The cost to the State of the enforcement procedures. 2 Within thirty (30) days of receipt of this notice, you must do one of the following: (1) Submit payment of the penalty, OR (2) Submit a written request for remission, OR (3) Submit a written request for an administrative hearing Option 1: Submit payment of the penalty: Payment should be made directly to the order of the Department of Environment and Natural Resources (do not include waiver form). Payment of the penalty will not foreclose further enforcement action for any continuing or new violation(s). Please submit payment to the attention of: NPDES Compliance /Enforcement Unit Division of Water Resources 1617 Mail Service Center Raleigh, North Carolina 27699 -1617 Option 2: Submit a written request for remission or mitigation including a detailed justification for such request: Please be aware that a request for remission is limited to consideration of the five factors listed below as they may relate to the reasonableness of the amount of the civil penalty assessed. Requesting remission is not the proper procedure for contesting whether the violation(s) occurred or the accuracy of any of the factual statements contained in the civil penalty assessment document. Because a remission request forecloses the option of an administrative hearing, such a request must be accompanied by a waiver of your right to an administrative hearing and a stipulation and agreement that no factual or legal issues are in dispute. Please prepare a detailed statement that establishes why you believe the civil penalty should be remitted, and submit it to the Division of Water Resources at the address listed below. In determining whether a remission request will be approved, the following factors shall be considered: (1) whether one or more of the civil penalty assessment factors in NCGS 14313- 282.1(b) was wrongfully applied to the detriment of the petitioner; (2) whether the violator promptly abated continuing environmental damage resulting from the violation; (3) whether the violation was inadvertent or a result of an accident; (4) whether the violator had been assessed civil penalties for any previous violations; or (5) whether payment of the civil penalty will prevent payment for the remaining necessary remedial actions. Please note that all evidence presented in support of your request for remission must be submitted in writing. The Director of the Division of the Division of Water Resources will review your evidence and inform you of his decision in the matter of your remission request. The response will provide details regarding the case status, directions for payment, and provision for further appeal of the penalty to the Environmental Management Commission's Committee on Civil Penalty Remissions (Committee). Please be advised that the Committee cannot consider information that was not part of the original remission request considered by the Director. Therefore, it is very important that you prepare a complete and thorough statement in support of your request for remission. 3 In order to request remission you must complete and submit the enclosed "Request for Remission of Civil Penalties, Waiver of Right to an Administrative Hearing and Stipulation of Facts" form within thirty (30) days of receipt of this notice The Division of Water Resources also requests that you complete and submit the enclosed "Justification for Remission Request" Both forms should be submitted to the following address: NPDES Compliance/Enforcement Unit Division of Water Resources 1617 Mail Service Center Raleigh, North Carolina 27699 -1617 Option 3• File a petition for an administrative hearine with the Office of Administrative Hearines: If you wish to contest any statement in the attached assessment document you must file a petition for an administrative hearing. You may obtain the petition form from the Office of Administrative Hearings. You must file the petition with the Office of Administrative Hearings within thirty (30) days of receipt of this notice. A petition is considered filed when it is received in the Office of Administrative Hearings during normal office hours. The Office of Administrative Hearings accepts filings Monday through Friday between the hours of 8:00 am. and 5:00 p.m., except for official state holidays. The petition may be filed by facsimile (fax) or electronic mail by an attached file (with restrictions) - provided the signed original, one (1) copy and a filing fee (if a filing fee is required by NCGS §150B -23.2) is received in the Office of Administrative Hearings within seven (7) business days following the faxed or electronic transmission. You should contact the Office of Administrative Hearings with all questions regarding the filing fee and/or the details of the filing process. The mailing address and telephone and fax numbers for the Office of Administrative Hearings are as follows: Office of Administrative Hearings 6714 Mail Service Center Raleigh, NC 27699 -6714 Tel: (919) 733 -2698 Fax: (919) 733 -3478 One (1) copy of the petition must also be served on DENR as follows: Mr. John Evans, General Counsel Department of Environment and Natural Resources 1601 Mail Service Center Raleigh, North Carolina 27699 -1601 Please indicate the case number (as found on page one of this letter) on the petition. Failure to exercise one of the options above within thirty (30) days of receipt of this letter, as evidenced by an internal 4 date /time received stamp (not a postmark), will result in this matter being referred to the Attorney General's Office for collection of the penalty through a civil action. Please be advised that additional penalties may be assessed for violations that occur after the review period of this assessment. If you have any questions, please contact Dean Hunkele with the Division of Water Resources staff of the Wilmington Regional Office at (910) 796 -7215 or via email at dean.hunkele @ncdenr.gov. Sincerely, RECEIVEDIDENRIDWR OCT 13 2014 fo omas A. Reeder, Director Division of Water Resources, NCDENR WSW Quality Pem EMig Seebon By James H. Gregson, Regional Supervisor Water Quality Regional Operations Section Wilmington Regional Office Division of Water Resources, NCDENR ATTACHMENTS Cc: WQS Wilmington Regional Office - Enforcement File (w /attachments) NPDES Compliance/Enforcement Unit - Enforcement File (w /attachments) Central Files, Water Quality Section (w /attachments) JUSTIFICATION FOR REMISSION REQUEST Case Number: LV- 2014 -0124 County: Onslow Assessed Party: Onslow Water and Sewer Authority Permit No.: NCO023230 Amount Assessed: $3,543.00 Please use this form when requesting remission of this civil penalty. You must also complete the "Request For Remission, Waiver of Right to an Administrative Hearing, and Stipulation of Facts" form to request remission of this civil penalty. You should attach any documents that you believe support your request and are necessary for the Director to consider in evaluating your request for remission. Please be aware that a request for remission is limited to consideration of the five factors listed below as they may relate to the reasonableness of the amount of the civil penalty assessed. Requesting remission is not the proper procedure for contesting whether the violation(s) occurred or the accuracy of any of the factual statements contained in the civil penalty assessment document. Pursuant to N.C.G.S. § 143B- 282.1(c), remission of a civil penalty may be granted only when one or more of the following five factors apply. Please check each factor that you believe applies to your case and provide a detailed explanation, including copies of supporting documents, as to why the factor applies (attach additional pages as needed). (a) one or more of the civil penalty assessment factors in N.C.G.S. 143B- 282.1(b) were wrongfully applied to the detriment of the petitioner (the assessment factors are listed in the civil penalty assessment document); (b) the violator promptly abated continuing environmental damage resulting from the violation (i.e., explain the steps that you took to correct the violation and prevent future occurrences); (c) the violation was inadvertent or a result of an accident (i.e., explain why the violation was unavoidable or something you could not prevent or prepare for); (d) the violator had not been assessed civil penalties for any previous violations; (e) payment of the civil penalty will prevent payment for the remaining necessary remedial actions (i.e., explain how payment of the civil penalty will prevent you from performing the activities necessary to achieve compliance). EXPLANATION: STATE OF NORTH CAROLINA COUNTY OF ONSLOW IN THE MATTER OF ASSESSMENT ) OF CIVIL PENALTIES AGAINST ) Onslow Water and Sewer Authority ) Richlands WWTP ) DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES WAIVER OF RIGHT TO AN ADMINISTRATIVE HEARING AND STIPULATION OF FACTS PERMIT NO. NCO023230 ) CASE NO. LV- 2014 -0124 Having been assessed civil penalties totaling $3,543.00 for violation(s) as set forth in the assessment document of the Division of Water Resources dated October 01, 2014, the undersigned, desiring to seek remission of the civil penalty, does hereby waive the right to an administrative hearing in the above - stated matter and does stipulate that the facts are as alleged in the assessment document. The undersigned further understands that all evidence presented in support of remission of this civil penalty must be submitted to the Director of the Division of Water Resources within thirty (30) days of receipt of the notice of assessment. No new evidence in support of a remission request will be allowed after (30) days from the receipt of the notice of assessment. This the day of , 20 SIGNATURE ADDRESS TELEPHONE ATTACHMENT A Onslow Water and Sewer Authority CASE NUMBER LV- 2014 -0124 PERMIT: NCO023230 FACILITY: Richlands WWTP COUNTY: Onslow REGION: Wilmington Limit Violations MONITORING OUTFALL / VIOLATION UNIT OF CALCULATED % OVER PENALTY REPORT PPI LOCATION PARAMETER DATE FREQUENCY MEASURE LIMIT VALUE LIMIT VIOLATION TYPE $375.00 6 -2014 001 Effluent BOD - Conc 6/21114 Weekly mg /I 7.50 33.90 352.0 Weekly Average Exceeded $375.00 6 -2014 001 Effluent BOD - Conc 6/28114 Weekly mg /I 7.50 35.70 376.0 Weekly Average Exceeded $1,125.00 6 -2014 001 Effluent BOD - Conc 6/30/14 Weekly mg /I 5 19.50 289.5 Monthly Average Exceeded $375.00 6 -2014 001 Effluent NH3 -N - Conc 6/14/14 Weekly mg /I 6 15.00 149.4 Weekly Average Exceeded $1,125.00 6 -2014 001 Effluent NI-13 -N - Conc 6/30/14 Weekly mg /I 2 8.50 323.1 Monthly Average Exceeded DIVISION OF WATER RESOURCES - CIVIL PENALTY ASSESSMENT Violator: Onslow Water and Sewer Authority Facility Name: Richlands WWTP Permit Number: NCO023230 County: Onslow Case Number: LV- 2014 -0124 ASSESSMENT FACTORS 1) The degree and extent of harm to the natural resources of the State, to the public health, or to private property resulting from the violation; 2) The duration and gravity of thhee violation; > 3) The effect on ground or su>< cc water quantity or quality or on air quality; 4) The cost of rectifying the damage; G 5) The amount of money saved by noncompliance; 6) Whether the violation was committed willfully or intentionally; 7) The prior record of the violator in complying or failing to comply with programs over which the Environmental Management Commission has regulatory authority; and 8) The cost to the State of the enforcement procedures. $168.00 Date J mes �aliy . son, Regional S erviso hter Regional Oper ions Section Wilmington Regional Office Division of Water Resources, NCDENR • Member Governmenis Holly Ridge Jacksonville WA Ulllilies and Plannine Norlo Topsoil Beach Ochlan Cororq' ON S ThnoUry Webb Srrpet' lendent Swarisboro S%wirs or twebbaarwasa.conr Onslow Water & Sewer Authority 910.937 7509 Tel 910.347.0793 Fray September 12, 2014 Mister James H. Gregson Supervisor Division of Water Quality Surface Water Protection Section 127 Cardinal Drive Extension Wilmington, North Carolina 28405 Dear Mr. Gregson Subject: Notice of Violation & Intent to Issue Civil Penalty Tracking No.NOV- 2014-LV -0411 ONWASA is in receipt of the NOV letter dated September 4, 2014 SEP 17 2014 As stated in the letter provided with the DMR for the Richlands WWTp in June 2014, the violation was due to higher than design limits of influent BOD and NH3 along with low DO levels. In an effort to correct the DO levels staff added additional disc's to the rotors. The oxidation ditch has shown improvement since these actions were taken. We also contacted NCRWA's Wastewater Technical Assistance Program for input on our activities. Mr. Lancaster did visit the facility and stated that we were working in the right direction to correct the problems. If you should have any other further question I can be reached at (910) 937 -7509 or twebb i4onwaoa i-om Respectfully, Tim Webb Utilities and Planning Superintendent ONWASA 228 Georgetown Rd Jacksonville NC 28540 Tel 910- 937 -7509 Enclosure 27R n- cc: Billy Farmer; Executive Director ONWASA e —•� "" "c"I - r. v. [sox 1415 • Jacksonville, NC 28540 • Tel 910.455.0722 • Fax 910 747 n70 2 ........ 4 00 KDENR North Carolina Department of Environment and Natural Resources Pat McCrory John E. Skvarla, III Governor Secretary September 4, 2014 CERTIFIED MAIL # 7013 2630 0002 0760 8148 RETURN RECEIPT REQUESTED Billy Joe Farmer Onslow Water and Sewer Authority PO Box 1415 Jacksonville, NC 28540 -1415 Subject: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY Tracking No. NOV- 2014 -LV -0411 Permit No. NCO023230 Richlands WWTP Onslow County Dear Mr Farmer: A review of Onslow Water and Sewer Authority's Discharge Monitoring Report(s) forthe Richlands WWTP submitted for the month(s) of June 2014 showed the violations indicated below. THE FOLLOWING ARE PARAMETER LIMIT VIOLATIONS: Parameter Date Limit Value Reported Value Limit Type Nitrogen, Ammonia 6/14/2014 6.000 mg /I 14.970 mg /I Weekly Average Exceeded BOD, 5 -Day 6/21/2014 7.500 mg /I 33.900 mg /I Weekly Average Exceeded BOD, 5 -Day 6/28/2014 7.500 mg /I 35.700 mg /1 Weekly Average Exceeded BOD, 5 -Day 6/30/2014 5.000 mg /I 19.480 mg /I Monthly Average Exceeded Nitrogen, Ammonia 6/30/2014 2.000 mg /I 8.460 mg /I Monthly Average Exceeded A Notice of Violation /Intent to Issue Civil Penalty is being issued for the noted violation of North Carolina General Statute (G.S.) 143 -215.1 and the facility's NPDES Permit. Pursuant to G.S. 143- 215.6A, a civil penalty of not more than twenty -five thousand dollars ($25,000.00) may be assessed 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. If you wish to provide additional information regarding the noted violation, request technical assistance, or discuss overall compliance please respond in writing within ten (10) business days after receipt of this Notice. A review of your response will be considered along with any information provided on the submitted Discharge Monitoring Report(s). You will then be notified of any civil penalties that may be assessed regarding the violations. If no response is received in this Office within the 10 -day period, a civil penalty assessment may be prepared. 127 Cardinal Drive Extension, Wilmington, North Carolina 28405 Phone: 910 - 796 -7215\ Internet: www.ncdenr.gov An Equal Opportunity \ Affirmative Action Employer — Made in part by recycled paper N OV- 2014 -LV -0411 September 4, 2014 Page 2 of 2 Remedial actions should have already been taken to correct this problem and prevent further occurrences in the future. The Division of Water Resources may pursue enforcement action for this and any additional violations of State law. If the violations are of a continuing nature, not related to operation and /or maintenance problems, and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by Consent. Reminder: Pursuant to Permit Condition 6 in Section E, the Permittee is required to verbally notify the Regional Office as soon as possible, not to exceed 24 hours, from first knowledge of any non - compliance at the facility including limit violations, bypasses of, or failure of a treatment unit. A written report may be required within 5 days if directed by Division staff. Prior notice should be given for anticipated or potential problems due to planned maintenance activities, taking units off -line, etc. In addition, you may wish to consider registering to use the Division's new a -DMR process for completion and submittal of monthly monitoring reports, for more information please visit our website at: http: / /Portal.ncdenr.org /web /wq /admin /bog /ipu /edmr If you should have any questions, please do not hesitate to contact Dean Hunkele with the Water Quality Section at (910) 796 -7215 or via email at Dean. Hunkele@ncdenr.gov. Sincerely, c Jame regson, Regional Supervisor Water Quality Regional Operations Section Wilmington Regional Office Division of Water Resources, NCDENR Cc: DWQ/Wilmington Regional Office - Green File Central Files, Water Quality Section ro (Domestic Mail Only; r—1 , , our C] • information OFFICIAL J] r`- Postage $ O Certified Fee fU Poahnark C3 Retum Receipt Fee Here E3 (Endorsement Required) O Restricted Delivery Fee C3 ( Endors)ment Required) i r .0 Total Postage & Fees $ �/ rU M ra Er�e;elitli �__ i P 1,� � /�------ - - - - -- r. No.; -- �% ` Nor PO Box --- - -C/ , ----- ,Y PS Form 3800, August r. See Rever �c for Instructions • Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. • Print your name and address on the reverse s6 that we can return the card to you. • Attach this card to the back of the mailpiece, or on the front if space permits. 1, Article Addressed to: Ile f /X /. A. St� nature D. 19 delivery adds different from item 1? ❑ Yes If YES, enter delivery address below: ❑ No Service Type ertified Mail ❑ Express Mail ❑ Aegistered ❑ Return Receipt for Merchandise ❑ Insured Mail ❑ C.O.D. 4. Restricted Delivery? (Extra Fee) ❑ Yes 2. Article Number (Transfer from service label) 7 013 2630 0 0 0 2 0760 814 8 PS Form 3811. February 2004 Domestic Return Receipt 102595 -02 -M -1540 NPDES PERMIT NO. NC 0023230 FACILITY NAME RICHLANDS WWTP CERTIFIED LABORATORY(1) ONWASA LAB (list additional laboratories on the backside /page 2 OPERATOR IN RESPONSIBLE CHARGE (ORC) PERSON(S) COLLECTING SAMPLES Staff EFFLUENT _ DISCHARGE NO. I MONTH JUNE YEAR 2014 CLASS II COUNTY ONSLOW CERTIFICATION NO. 539 of this form) Mark Young GRADE 3 CERTIFICATION NO. 985317 ORC PHONE 1- 910 - 937 -7572 CHECK BOX IF ORC HAS CHANGED Lam, NO FLOW I DISCHARGE F"JkE" ' BY THIS rILES ACCURATE AND COWLETE TO THE BEST OF MY KNOWLEUrbE. A I fir t 1 ►t`I�UI - - = Mn Q 1:11 •1 `� 1 1: __- _ - -__ -- MRS MOUSIME "M MOULIZE 11- __- - -_ - -- ® f I I • 1 _�- 1 �N_ • I � • • __ MEMINK "06 ® 1.1 I 1 / 1 00��000 ©QQ� Facility Status: (Please-check one of the following) All monitoring data and sampling frequencies meet permit requirements. (including weekly averages, if applicable) Compliant All monitoring data and sampling frequencies do NOT meet permit requirements. Non - Compliant The permittee shall report to the Director or appropriate Regional Office any non - compliance that potentially threatens public health or the environment. Any information shall be provided orally within 24 hours from the time the permittee became aware of the circumstances. A written submission shall also be provided within 5 days of the time the permittee becomes aware of the circumstances. If the facility is non - compliant, please attach a list of corrective actions being taken and a time -table for improvements to be made as required by Part II.E.6 of the NPDES permit. "I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations." Tim Webb (Utilities and Planning Supervisor) Permittee (Please print or type) Signatur of Permittee*** Date 228 Georgetown Rd. Jacksonville, N.C. 28540 910 -455 -0722 7/3112012 Permittee Address Phone Number Permit Exp. Date Certified Laboratory (2) Certified Laboratory (3) Certified Laboratory (4) Certified Laboratory (5) ENVIROCHEM ADDITIONAL CERTIFIED LABORATORIES PARAMETER CODES Cerification No. Cerification No. Cerification No. Cerification No. 94 Parameter Code assistance may obtained by calling the NPDES Unit Group at (919) 733 - 5083 or by visiting the Surface Water Protection Section's web site ath2o.enr.state.nc.us /wqs and linking to the unit's information pages. * No Flow /Discharge From Site: Check this box if no discharge occurs and, as a result, there are no data to be entered for all of the parameters on the DMR for the entire period. ** ORC On Site? ORC must visit facility and document visitation of facility as required per 15A NCAC 8G.0204. * *' Signature of Permittee: If signed by other than the permittee, then the delegation of signatory authority must be on file with the state per 15A NCAC 2B.0506(b)(2)(D). Page 2 NPDES Permit No. NC 0023230 Facility Name RICHLANDS WWTP Discharge No INFLUENT lull Enter Parameter Code Above, Name and Units Bel- DWQ Form MR -3 (Revised 712000) 01 County Stream Location Month June Year 2014 ONSLOW Mill Swamp NCSR 1003 Bridge Enter Parameter Code Above, Name and Units Bel- F MF ember GovernmenHnlh Ridge acksonville on i Topsail Beach nslow Coiauv Richhuids Skmrsboro ONWAS A Onslow Water & Sewer Authority TO: NCDWR, Surface Water Protection Section FROM: Mark C. Young, ORC — Richlands Wastewater Treatment Plant DATE: July 29, 2014 RE: Non - Compliance Statement for exceeding BOD & NH3 limits To Whom It May Concern, Wastewater Plants Division Tim Webb Utiti[ies & Planning Supervisor twebbCnionwasarow The Richlands Plant was non - compliant this month due to exceeding its permitted limits for BOD and NH3. The plant experienced the increase of BOD and NH3 from the seasonal temperature change and hirer than design BOD and NH3 levels in the influent flow. Despite exceeding these limits the plant BOD percent removal for the month was 96.5 %. Average influent NH3 levels were 25% higher than design parameters. 910.937.7506+ Tel In an effort to correct the low DO in the oxidation ditch, staff made adjustments to the ditch level and ultimately installed additional rotor disc's to provide more aeration. Further, additional sampling was performed to closely monitor the levels and the NCRWA was contacted for assistance. In recent weeks the plant staff and the Lab have been working on a more efficient solids program that will give real time data to operators so plant adjustment can be more gradual rather than abrupt. The new program closely monitors all areas of process control to include more microscopic evaluation, solid concentration observation in the oxidation ditch, RAS, and WAS by the use of the centrifuge, and comparable sampling between the lab and plants. The program has provided additional training to the staff as well as new techniques for more efficient operations of the facilities. If you have any questions, please give me a call, 910- 455 -0722 ext. 7572 Sincerely, 14( Mark C. Young ORC — Richlands Wastewater Treatment Plant 728 Georgetown Road • P.O. Box 1415 • Jacksonville, NC 28540 • Tel 910.455.0722 - Fax 910.455.2587 - www.onwasa.com