NC0060526_NOV-2023-LV-0694 Response_20231110

COMMERCIAL REALTORS'
November 10, 2023
Mrs. Vanessa Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Subject: Notice of Violation and Assessment of Civil Penalty
Tracking Number: NOV-2023-LV-0694
Permit No. NCO060526
Pope Industrial Park WWTP
Wake County
Mrs. Manuel,
Thank you for allowing the Pope Industrial Park the opportunity to respond to this Notice of Violation
issued October 9, 2023; received on November 01, 2023, for the BOD Daily Maximum exceedance and
Monthly average exceedance which occurred during the August 2023 monitoring period.
The BOD daily exceedance reported on August 16, 2023, with a value of 18.6 mg/L, was a result of what
we believe to be suppressed dissolved oxygen in the aeration basin due to a peak effluent water
temperature resulting in less efficient removal of the BOD. This is illustrated below in the chart showing
the highest recorded temperature for the sampling month was on the day the sample was collected. On
August 22, 2023, we were notified of the elevated BOD value and the operator increased the amount of
air to the system in an attempt to increase the dissolved oxygen concentrations in the plant. The
remainder of the samples collected for the month were compliant, however, the monthly average
resulted to 5.84 mg/I, equivalent to a 16.8 % exceedance of the limit established on the permit.
As can see on the following chart, the value that caused both violations in this period does not reflect
the normal performance of the facility, and the remaining samples pulled from the system were
compliant. It is evident through the trendline below that the treatment facility operates below the 5
mg/L line routinely.
P. O. BOX 97215
RALEIGH, NORTH CAROLINA 27624
919-846-3500

Pope Industrial BOD performance
During a recent inspection of the facility, some systems of the plant were identified to be in need of
repair. Currently, we are waiting for quotes and financial approval to move forward with these identified
items.
As described above, the values that caused the violations of this facility are not representative of the
actual performance of the system. It is our request that the Division take into consideration the actions
taken by the permittee when deciding whether further enforcement actions are warranted.
Sincerely,
a&4
Albert E Finley,
Pope Industrial Park II Ltd Partnership
CC:
Andrew White, Envirolink, Inc.
William Lamm, Pope Industrial WWTP ORC