NC0027626_NOV-2023-LV-0501_20230803 (3)

NCDepartment of
Adult Correction
PROTECTION • INNOVATION
REHABILITATION
Roy Cooper, Governor
02 August 2, 2023
Vanesa E. Manuel
Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
3800 Barrett Dr., Raleigh, NC 27609
IN RE: NOV-2023-LV-0501
Roanoke River C.I. — WWTP
Halifax County
Dear Ms. Manuel:
Todd Ishee, Secretary
The Department of Adult Correction (DAC) has received the aforementioned NOV on 28 July 2023,
and we are submitting herewith, the desired response.
The DAC conducted a comprehensive investigation into the occurrence and obtained all relevant
field notes and logs related to the incident. As the DEQ is aware, we employ a Chlor./Dechlor.
system for disinfection. The chlorination pump failed suddenly and unexpectedly. This mechanical
issue prevented the proper amount of chlorine from being discharged in time for disinfection,
resulting in a minor increase in the fecal count (daily limit).
The instructions stated that the diaphragm should be replaced. Despite our efforts, it continued to
malfunction. As a result, we had to replace the entire pump. We completed this repair,
immediately upon learning about the mechanical flaw. Please be aware that we examine and
maintain the entire system on a daily basis. Nonetheless, certain mechanical failures (such as this
one) are unexpected and difficult to predict.
MAILING ADDRESS:
4216 Mail Service Center
Raleigh, NC 276994216
OFFICE LOCATION:
2020 Yonkers Road
Raleigh, NC 27604 An Equal Opportunity Employer
FROM THE OFFICE OF:
Nainesh Patel
Environmental Engrg. Manager
Central Engineering
Telephone: [phone]
https://dac.nc.gov

NOV-2023-LV-0501
NCDAC — Roanoke River C.I.
Page 2 of 2
02 August 2023
Due to the following reasons, the DAC respectfully requests that the DEQ not impose any civil
penalties for this incident:
(1) Even though the WWTF exceeded daily limit by 200 MPN, we still met the monthly fecal
limit for the subject month.
(2) As soon as the issue was identified, the situation was promptly remedied.
(3) The mechanical failure of the chlorination pump that stopped working while ostensibly
exhibiting no symptoms of deterioration was beyond the DAC's control.
(4) The DAC has been able to maintain full compliance and there haven't been any violations
for the wastewater treatment at this facility in a very long time.
(5) The available funds could be used to make more significant and beneficial enhancements
to operation and maintenance rather than paying a civil penalty (if one were to be levied).
The DAC is still steadfastly committed to upholding strict compliance.
We are informing the DEQ that we finished a project to replenish specialty wetland plant growth in
wetland cells between the second week of June 2023 and July 2023. We have 32 cells in
constructed wetlands. The DAC has spent over $96,000 to upgrade the wetland systems utilized for
wastewater treatment at the relevant site. During a recent project, we had to shut down half of the
wetland cells at a time and pump wastewater in a certain pattern in order to maintain the
extremely low wastewater level required for the specialty wetland plants. This water pumping and
transferring had increased turbidity and suspended particulates, which may have affected the fecal
count for this period.
Should you have any questions or need additional information, please do not hesitate to contact me
at [phone] or via e-mail at [e-mail].
Respectfully,
1 J ,,A ,.t , P-�
Nainesh (Nash) Patel, PE, PEM
Civil/ Environmental Engineering Manager
NCDPS - Central Engineering
Cc: NP/BM/JO/Central File
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