NC0027626_NOV-2023-LV-0633_20231013

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NC/ Department of
Adult Correction
v PROTECTION • INNOVATION
REHABILITATION
Roy Cooper, Governor
10 October 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-0633
Roanoke River C.I. — WWTP
Halifax County
Dear Ms. Manuel:
Af CoLD 2:( � 2 �
Todd Ishee, Secretary
The Department of Adult Correction (DAC) has received the aforementioned NOV on 02 October
2023, and we are submitting herewith, the desired response.
We exceeded fecal coliform daily limit by a small number. Although our monthly fecal limit was well
below the allowed maximum limit. The DAC conducted a comprehensive investigation into the
occurrence and obtained all relevant field notes and logs related to the incident.
You may recall that in our last communication, I had mentioned that there may be a possibility of
fecal exceedance. During the time when exceedance occurred, the DAC was in the process of
significantly major upgrade and maintenance of the wetlands. We invested close to $96,000 to
establish new varieties of specialized plants in our constructed wetlands. To maintain a safe water
level for the new plants, we had to turnoff half of the facility's wetland cells (16 out of 32). Asa
result, we were only achieving 50%treatment efficiency.
MAILING ADDRESS:
4216 Mail Service Center
Raleigh, NC 276994216
OFFICE LOCATION:
2020 Yonkers Road
Raleigh, NC 27604
­0 :..
An Equal Opportunity Employer
FROM THE OFFICE OF:
Nainesh Patel
Environmental Engrg. Manager
Central Engineering
Telephone: [phone]
https://dac.ne.gov

NOV-2023-LV-0633
NCDAC - Roanoke River C.I.
Page 2 of 2
10 October 2023
Our suspended solids and turbidity in the wetland cells were significantly higher. There were
significant human movement and other wildlife migration within the wetland cells. There was
ongoing pumping (to sustain extremely low water levels) and transferring of plant within the
wetland cells. The combination of limited treatment capacity and disturbance in the settled
wetland environment had caused this one time daily elevated level in the fecal coliform count. Ever
since then, we continue to remain in full compliance. A note about this change was also included in
our a-DMR report.
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 maximum daily limit by 200 MPN, we still met the
monthly fecal limit for the subject month.
(2) Soon after major the new planting related activities were completed, the situation was
promptly remedied.
(3) 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.
(4) 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 has requested to eliminate fecal coliform monitoring at the subject facility. Also, due to
the complex wastewater treatment and disinfection system at this facility, the DAC is asking the
DEQto allow sampling for the fecal coliform and the toxicity on different cycle.
The DAC is still steadfastly committed to upholding strict compliance.
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��
Nainesh (Nash) Patel, PE, PEM
Civil/ Environmental Engineering Manager
NCDPS - Central Engineering
Cc: NP/BM/JO/Central File
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