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HomeMy WebLinkAboutNC0026441_NOV-2023-MV-0203_20240201Tobin of *ffer c tp Public works and Utilities January 18, 2024 Attn: Vanessa E. Manuel, Assistant Regional Supervisor 1617 Mail Service Center Raleigh, NC 27699-1617 NCLte;'":,i _11 Subject: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY Tracking Number: NO V-2023-MV-0203 NPDES Permit # NCO026441 Town of Siler City Chatham County Dear Vanessa E. Manuel, RECEIVED JAN 3 0 2024 NC DEQ/DWR Central Office FEB - 1 2W4 This letter is in response to the NOV & Intent for Civil Penalty issues on December 14, 2023, for the sampling frequency of LCD Downstream, LCU Upstream, RRD Downstream, and RRU Upstream for August 2023: It is believed that these violations occurred due to a misunderstanding regarding the proper protocol regarding these samples. I have attached an email chain that reflects the conversations between Cheng Zhang and myself. On August 10`h I received an email regarding missing information on the DMR and the sampling frequencies of the rivers. I responded on August 14`h stating that I had updated the missing information and went on to discuss the river sample confusion I was having. Where I also informed Cheng Zhang that due to my confusion the July and August samples were done in the same manner as June. Therefore, would be in violation as well. The next email I received from Cheng Zhang was on October 18`h asking about sampling frequency in August for the rivers. I responded to that email on October 19'h the river samples were conducted the same as in June and that on August 10that I informed him of that. Cheng Zhang then responded to both my August 141h and October 19'h emails on October 201h his understanding of how the sampling was expected to be performed. By then I bad already gained a better understanding of these samples, and we were compliant in our river sampling for September. On December 12'h Cheng Zhang reached out again regarding the sampling frequencies for July and August. I responded on December 15`h that we had already been in communication regarding these sampling frequency concerns. I believe that this was a misunderstanding due to our first time having to sample them at this frequency and we now understand what is needed. I do not foresee we will have this violation in the future. Brittany York W WTP Superintendent PO Box 769. 311 N Second Avenue Siler City, NC 27344-0769 Brittany York byork@silercity.org Phone:919-742-2939 www.silercity.org re advance a %i am,,,worh for our success cirrou ii balanced governance, dynamic partnerships, and an engaged cnrnr mmn y- Sincerely 'A, C� Brittany York WWTP Superintendent Town of Siler City Cc: Hank Raper — Town Manager, Chris McCorquodale — Utility Director Brittany York W WTP Superintendent PO Box 769 e 311 N Second Avenue Slier City, NC 27344.0769 Brittany York byork@silercity.org Phone: 919-742-2939 www.silercity.org 7L arlamre np anjework/or oar cuccas rluauylt balnn[eJ iorenmun, , di I'm tnersh iF�s, and an enygyed cononmiitY. /�/%, j`i l.A"_ r hl.! :; 'i3C'O�.Ji i_=.y mi i • ':i !;C- '>_': =?'/ (� (i'-.'Q r`8:"(:co From: Brittany York <byork@silercitv.org> Sent: Monday, August 14, 2023 4:57 PM To: Zhang, Cheng <cheng.zhang@deq.nc.gov> Cc: Bobbie Hill <bhill@silercity.org> Subject: [External] RE: June DMR CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message button located on your Outlook menu bar on the Home tab. Good afternoon, June 19`h was an observed holiday so Effluent conductivity was not collected on that day. Would you like us to update the DMR with an H in the field? As for the river sample for week 1 of June, those samples were not collected because of the short week and transition from May to June. I think we were thinking of it wrong. Can you please explain how that is typically done during times when there is not a whole week at the beginning of the month or the end? July and August will reflect the same way. Does these samples need to have a day in between? For example with only 2 days in a week do we collect samples on both days or only one because the other samples earlier in the week were collected as well? Should we just think about it in 3 samples per week (specific days like Mon, Wed, Frid) regardless of where it falls in the month? I think there was just a little confusion there on our end. Can you just specify how you need to see it being done and we will ensure moving forward it's done correctly? Thank you for your help RECEIVED Brittany York WW Superintendent JAN 3 0 2024 Town of Slier City 919-742-4581 Office ` G DEQ/DWR 919-742-5499 Fax 0,mtraj Office bvork@silercity.org From: Zhang, Cheng <cheng.zhang@deq.nc.gov> Sent: Thursday, August 10, 2023 3:56 PM To: Brittany York <byorkPsilercitv.org> Subject: June DMR Eo ridw!cr. i This email originated from outside of the Town of Slier City, NC Missing parameters: Effluent conductivity on June 19`h; Upstream and downstream for the week of June 3rd: conductivity, nitrate/nitrite, ammonia, TKN, DO, pH, total phosphorous, and temperature, three times per week, reported only once for the week. Please revise the DMR if you have the data, thanks. Cheng Zhang Environmental Specialist II Raleigh Regional Operations Section Division of Water Resources 919 791 4259 office 919 817 3856 cell 919 788 7159 fax chenq.zhang a.deo.nc.eov Please note that my email has chanoed 1628 Mail Service Center Raleigh, NBC 27699-1628 ';G Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized state official. Brittany York From: Zhang, Cheng <cheng.zhang@deq.nc.gov> Sent: Wednesday, October 18, 2023 8:42 AM To: Brittany York Cc: Bobbie Hill Subject: July and August DMR issues 6e This email originated from outside of the Town of Siler City, NC Brittany, BIMS shows missing upstream/downstream monitoring for the week of August 51, only two sampling events were reported, permit requires three times; also missing was total effluent flow for the month of August. Has upstream/downstream sampling being down in the last couple of day in July? Please double check. Thanks. Cheng Zhang Environmental Specialist II Raleigh Regional Operations Section Division of Water Resources 919 791 4259 office 919 817 3856 cell 919 788 7159 fax cheng.zhangna deg.nc.gov Please note that my email has changed 1628 Mail Service Center Raleigh, NC 27699-1628 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Email correspondence to and from this address may be sueact to the North Carolina Public Records law and may be disclosed to third parties by an authorized state official. Brittany York From: Brittany York Sent: Thursday, October 19, 2023 12:13 PM To: Zhang, Cheng Cc: Bobbie Hill Subject: RE: July and August DMR issues Good morning, I have updated the August DMR to reflect the Total Flow. That was an oversight on my behalf. There was no upstream/downstream monitoring performed on July 31" and the first week of August upstream/ downstream was only performed twice. However, the last week of August they were performed on 8/28, 8/30, and 9/1. There was some confusion on our part about how these samples needed to be collected and if a day needed to be between samples. On 8/14/2023, 1 responded to an email you had sent regarding June's upstream/downstream sampling that there was some confusion regarding these samples and also informed you that July and August would reflect the same as June. In further research, I gained a better understanding of how these samples need to be conducted and September's DMR will reflect that. Any guidance would be appreciated to ensure we are doing our part to comply with our permit requirements. I apologize for any inconvenience. We are working hard to keep everything straight and navigate the changes the last year has brought. Thank you for your patience. Thank you! Brittany York WW Superintendent Town of Siler City 919-742-4581 Office 919-742-5499 Fax byork@silercity.org From: Zhang, Cheng <cheng.zhang@deq.nc.gov> Sent: Wednesday, October 18, 2023 8:42 AM To: Brittany York <byork@silercity.org> Cc: Bobbie Hill <bhill@silercity.org> Subject: July and August DMR issues This email originated from outside of the Town of Siler City, NC Brittany, BIMS shows missing upstream/downstream monitoring for the week of August 5, only two sampling events were reported, permit requires three times; also missing was total effluent flow for the month of August. Has upstream/downstream sampling being down in the last couple of day in July? Please double check. Thanks. Cheng Zhang Environmental Specialist II Raleigh Regional Operations Section Division of Water Resources 919 791 4259 office 919 817 3856 cell 919 788 7159 fax cheng.zhangCo deg.nc.eov Please note that my email has changed 1628 Mail Service Center Raleigh, NC 27699-1628 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disctosed to third parties by an authorized state official §rsttanj Ycyk From: Zhang, Cheng <cheng.zhang@deq.nc.gov> Sent: Friday, October 20, 2023 9:56 AM To: Brittany York Cc: Bobbie Hill Subject: RE: [External] RE: June DMR .. ... This email originated from outside of the Town of Siler City, NC Please revise June DMR by marking June 19`h as holiday for effluent conductivity. For instream monitoring, the frequency is three times per week between June and September, my understanding is samples can be collected on consecutive days (does not have to be Mon., Wed., and Fri.), the week ended on June 3rd falls in June, there should have been three samplings. Let me know if you have questions, thanks. Cheng Zhang Environmental Specialist II Raleigh Regional Operations Section Division of Water Resources 919 791 4259 office 919 817 3856 cell 919 788 7159 fax chenq.zhanq(@deq.nc.gov Please note that my email has changed 1628 Mail Service Center Raleigh, NC 27699-1628 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Brittany York <byork@silercity.org> Sent: Monday, August 14, 2023 4:57 PM To: Zhang, Cheng <cheng.zhang@deq.nc.gov> Cc: Bobbie Hill <bhill@silercity.org> Subject: [External] RE: June DMR CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message button located on your Outlook menu bar on the Home tab. Good afternoon, June 1911 was an observed holiday so Effluent conductivity was not collected on that day. Would you like us to update the DMR with an H in the field? As for the river sample for week 1 of June, those samples were not collected because of the short week and transition from May to June. I think we were thinking of it wrong. Can you please explain how that is typically done during times when there is not a whole week at the beginning of the month or the end? July and August will reflect the same way. Does these samples need to have a day in between? For example with only 2 days in a week do we collect samples on both days or only one because the other samples earlier in the week were collected as well? Should we just think about it in 3 samples per week (specific days like Mon, Wed, Frid) regardless of where it falls in the month? I think there was just a little confusion there on our end. Can you just specify how you need to see it being done and we will ensure moving forward it's done correctly? Thank you for your help Brittany York WW Superintendent Town of Siler City 919-742-4581 Office 919-742-5499 Fax bvork@silercity.org From: Zhang, Cheng <cheng.zhang@deq.nc.gov> Sent: Thursday, August 10, 2023 3:56 PM To: Brittany York <byork@silercity.org> Subject: June DM This email originated from outside of the Town of Siler City, NC Missing parameters: Effluent conductivity on June 191^; Upstream and downstream for the week of June 3rd: conductivity, nitrate/nitrite, ammonia, TKN, DO, pH, total phosphorous, and temperature, three times per week, reported only once for the week. Please revise the DMR if you have the data, thanks. Cheng Zhang Environmental Specialist II Raleigh Regional Operations Section Division of Water Resources 919 791 4259 office 919 817 3856 cell 919 788 7159 fax chenq.zhanq(@.deq.nc.gov Please note that my email has changed 1628 Mail Service Center Raleigh, NC 27699-1628 Brittany York From: Brittany York Sent: Monday, October 23, 2023 1:20 PM To: Zhang, Cheng Cc: Bobbie Hill Subject: RE: [External] RE: June DMR I have updated the June DMR. Thank you for the information. Thank you! Brittany York WW Superintendent Town of Siler City 919-742-4581 Office 919-742-5499 Fax byork@silercity.org From: Zhang, Cheng <cheng.zhang@deq.nc.gov> Sent: Friday, October 20, 2023 9:56 AM To: Brittany York <byork@silercity.org> Cc: Bobbie Hill <bhill@silercity.org> Subject: RE: [External] RE: June DMR -......._ This email originated from outside of the Town of Siler City, NC Please revise June DMR by marking June 191h as holiday for effluent conductivity. For instream monitoring, the frequency is three times per week between June and September, my understanding is samples can be collected on consecutive days (does not have to be Mon., Wed., and Fri.), the week ended on June 31 falls in June, there should have been three samplings. Let me know if you have questions, thanks. Cheng Zhang Environmental Specialist II Raleigh Regional Operations Section Division of Water Resources 919 7914259 office 919 817 3856 cell 919 788 7159 fax cheng.zhang(a),deg.nc.eov Please note that my email has changed 1628 Mail Service Center Raleigh, NC 27699-1628 Email correspondence to and from this address is subject to the Brittany York From: Brittany York Sent: Friday, December 15, 2023 10:41 AM To: Zhang, Cheng Cc: Bobbie Hill Subject: RE: August DMR upstream/downstream sampling Good morning, I have had a chance to review the information and email chain regarding the upstream/downstream sampling. On 8/14/2023, 1 responded to an email you had sent regarding June's upstream/downstream sampling that there was some confusion regarding these samples and also informed you that July and August would reflect the same as June. In further research, I gained a better understanding of how these samples need to be conducted and September's DMR will reflect that. Also, on 10/19/2023 1 responded to an email regarding the August 51' upstream/downstream sampling. I stated in my email response the following statement regarding the July and August sampling, There was no upstream/downstream monitoring performed on July 3111• and the first week of August upstream/ downstream was only performed twice. However, the last week of August they were performed on 8/28, 8/30, and 9/1. There was some confusion on our part about how these samples needed to be collected and if a day needed to be between samples. I think we are on track to perform these tests correctly in the future. Should you have any questions please let me know. Thank you! Brittany York WW Superintendent Town of Siler City 919-742-4581 Office 919-742-5499 Fax byork@silercity.org From: Zhang, Cheng <cheng.zhang@deq.nc.gov> Sent: Wednesday, December 13, 2023 3:16 PM To: Brittany York <byork@silercity.org> Cc: Bobbie Hill <bhill@silercity.org> Subject: RE: August DMR upstream/downstream sampling Be Advised: This email originated from outside of the Town of Siler City, NC I will have to send out a NOV if the issue is not resolved, please respond, thanks. Cheng Zhang Environmental Specialist II Raleigh Regional Operations Section Division of Water Resources 919 7914259 office 919 817 3856 cell 919 788 7159 fax chenq.zhang(. deq.nc.eov Please note that my email has changed 1628 Mail Service Center Raleigh, NC 27699-1628 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Zhang, Cheng Sent: Tuesday, December 12, 2023 1:46 PM To: Brittany York <bvork@silercity.ora> Cc: Bobbie Hill <bhill@silercitv.ora> Subject: August DMR upstream/downstream sampling Brittany and Bobbie, Was upstream/downstream sampling conducted on July 31, 2023? BIMS shows only two sampling for the week of August 5t'. Thanks. Cheng Zhang Environmental Specialist II Raleigh Regional Operations Section Division of Water Resources 919 791 4259 office 919 817 3856 cell 919 788 7159 fax cheng.zhangCo deg.nc.gov Please note that my email has changed 1628 Mail Service Center Raleigh, NC 27699-1628 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties.