NCG590002_NOV-2023-LV-0181_20230330

March 27, 2023
Mr. Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Subject: Notice of Violation
Tracking Number: NOV-2023 -LV-0 181
Permit No. NCG590002
Bailey Well #2 WTP
Nash County
Mr. Vinson,
Thank you for allowing the opportunity to respond to this Notice of Violation issued March 14, 2023, and received on
March 20, 2023, for the Total Suspended Solids violations and the Turbidity Daily maximum exceedance that occurred
during the January 2023 monitoring period.
We want to mention that the system was attended and correctly managed for the period corresponding to January 2023, and
regarding to the Violations enlisted in the corresponding document, at the beginning we determined that the cause of the
high readings were result of an incorrect sampling procedure during the Back wash, so even when the facility have
performed in compliance for several months prior these period, the personnel were trained again and supervised to ensure
the correct sample pulling, however after an exhaustive study of the perfonnance of the system, it seems that the facility
has been affected by an external factor that has increased the value of the TSS during the first half of the month.
On January 3, the TSS sample pulled resulted in 158 mg/L resulting in the Daily maximum exceedance and contribute to
the Monthly average exceedance. Is necessary to mention that the second sample pulled on January 19, 2023 was compliant
and with a value of 19.5 mg/L.
Regarding the Turbidity Daily Maximum exceedance violation, it is considered to be result of the external factor that is
disturbing the normal development of the system, this issue is being included as part of the investigation that will help
identify the root of the anomaly in the system.
• We have contacted the Lab and requested the notification of this kind of incidents as soon the sample has been
analyzed in order to pull the sample as soon as possible to monitor and determine if the issues has to be with the
performance of the facility, or if it was an incorrect value.
• An investigation is being performed to determine the possible cause of the increase on the first half of the month.
We appreciate the effort that your office applies to keep track of all the incidents and reports for this system. The Town of
Bailey WWTF has taken these issues into account to prevent future non-compliance events. It is always our goal to remain
in compliance with regulations set forth by the Division of Water Resources. It is our request that our cooperation and action
in these matters be taken into account by the Division when proceeding with enforcement.
Sincerely,
Daniel Sears,
Compliance Manager
CC:
Thomas Richards, Mayor, Town of Bailey.
Joel Killion, Town Administrator/Town Clerk, Town of Bailey
Vanessa E. Manuel, Assistant Regional Supervisor
Tracy Miller, Regional Manager, Envirolink, Inc.
William Lamm, Town of Bailey WWTF ORC