NC0031836_Response to Notice_20230925

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CNORTH CAROLINA
September 25, 2023
NCDEQ
Andrew Pitner, Regional Supervisor
Mooresville Regional Office
610 East Center Avenue, Suite 301
Mooresville, NC 28115
Subject: Response to Notice of Violation
Tracking Number: NOV-2023-LV-0620
Permit No. NCO031836
Fourth Creek WWTP
Dear Mr. Pitner,
Upon reviewing the data for the month of July 2023 and discussing the overall operations of the Fourth
Creek WWTP with the Supervisor, we believe that the daily max on copper was an outlier result. The
daily max exceedance for copper has led to the monthly average exceedance as well. There was no
indication of any negligence or derelict of duty regarding any of the operations staff that would have
allowed this to happen.
There was no indicator that would have brought the daily max exceedance to our attention during this
time frame. The months leading up to July and the months subsequent show no indication of high total
copper concentrations than normal entering the Fourth Creek WWTP or the ability to treat what is
coming into the Fourth Creek WWTP.
The Pre -Treatment staff are following up on the potential of any slug flows that may have occurred
during this time that might account for the effluent violation of Total Copper. We are also going to start
sampling more frequently for Total Copper as the need arises so that we may track it better and to avoid
future NOV's for Total Copper.
The City is committed to effective operation to maximize nutrient reduction of the Third Creek WWTP.
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Water Resources Operations Manager
PO Box 1111 • Statesville, NC 28687 • ci.statesville.nc.us