WQ0023693_NOV-2022-LV-0781,0782_20221110

BRUNSWICK COUNTY PUBLIC UTILITIES
OPERATIONS CENTER
250 GRFY WATER ROAD NE
SUPPLY, NORTH CAROLINA 28462
MAILING ADDRESS
POST OFFICE Box 249
BOLIVIA, NORTH CAROLINA, 28422
November 10, 2022
Mrs. Morella Sanchez -King
Regional Supervisor
NCDEQ, WIRO
127 Cardinal Drive Extension
Wilmington, NC 28405
RE: Brunswick County -West Brunswick Regional, WQ0023693, Notice of Violation
Tracking No. Nov-2022-LV-0781 & 0782
Dear Mrs. King:
TELEPHONE
[phone]
FAX
[phone]
We are in receipt of your letter dated October 25, 2022, indicating a Notice of Violation for the
exceedance of Solids, Total Suspended (both daily and monthly limits) for the months of January
and February 2022. Please see our response below:
During the months of January and February 2022, the West Brunswick Regional WWTP (WBR)
experienced issues with high suspended and total solids throughout the process. The average
MLSS concentration over the two months was 8400 me due to the inability to land apply
biosolids. There had been an ongoing issue with the contracted biosolids hauler (Bio green
Services Inc.) which in turn limited the facilities ability to waste biosolids. The issues ranged from
lack of personnel, equipment breakdown and inability to access fields. In addition to the high TSS.
the inability to waste also impacted the functionality of the auto thermal thermophilic aerobic
digestion process. What would typically be a 24-28 hour process to meet 503 regulations (Class
A) biosolids in a reactor, turned into several weeks of not producing Class A and eventually
hauling several reactors as Class B biosolids. This lack of hauling essentially led to high solids
retention times (SRT) which further exacerbated the "back up" of solids within the facility.
Due to ongoing issues with the biosolids hauler, Brunswick County chose not to renew the contract
and took the opportunity to advertise, bid and award our biosolids hauling contract, effective July
1, 2022, to EMA Resources Inc. (EMA). EMA has effectively managed the biosolids since
beginning the contract. MLSS, SRT and TSS have been effectively managed in the process. This
change in biosolids hauling contractor has come at a cost as the overall combined biosolids hauling
has increased over 50% with the initiation of the new contract. Brunswick County requests
consideration be given to the enormous cost increase incurred in the determination of the Issuance
of a Civil Penalty.

If you have any questions, please feel free to contact me at [phone] or e-mail at
[e-mail].
Sincerely,
Donald B. Dixon
Deputy Director -Wastewater Operations