HomeMy WebLinkAboutNC0063762_Response to Notice_20240306Baker, Caroline D
From: Dusty Metreyeon <dmetwater@aol.com>
Sent: Wednesday, March 6, 2024 9:36 AM
To: Scheller, Roberto
Subject: [External] Fw: Carolina Village to regarding proposed fine$$??
Attachments: Carolina Village WWTP SOP -February 2024.docx
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Roberto,
Thank you for calling me back Monday, while I was at doctor and taking the time for my call yesterday
during your inspection of another facility. Both times we did not get to talk about everything we
needed to regarding Carolina Village and what my Clients at Horizon Land Company can expect.
My understanding as of now is:
You are NOT waiting for response to any NOV,s or follow up from Carolina village as of right now.
NOV-2024-LV-0075 was addressed in a letter I wrote while responding to NOV-2023-LV-0869 , prior
to NOV-2024-LV-0075 being issued.
You later asked me to "copy and paste" the same verbiage and that doing so in a follow up email to
you would suffice and negate any further need to follow up on NOV-2024-LV-0075 at this time (all can
be seen in body oft this email)
From our phone call yesterday, I took you to mean a [small] fine is coming but did not recall how
much, but when you got back to your office you would let me know the amount. Please let me know
as soon as you can.
You plan to schedule an on -site inspection at end of this month (March) or First of next month(April).
Also, I would like to know;
What is the protocol regarding the review of non-compliance, what triggers it, who performs the
review and who sets the fines?
Do all persons, review groups get to read our response letters to non-compliance? ....Review
operator comments on the EDMR's?
Respectfully,
Dusty Metreyeon
Metwater, Inc.
704-506-4255
----- Forwarded Message -----
From: Dusty Metreyeon <dmetwater@aol.com>
To: Scheller, Roberto <roberto.scheller@deq.nc.gov>
Cc: Emmett Conneely <econneely@horizon lm.com>; Dustin Luckinbill <dluckinbill@horizon lm.com>; Jayna Russo
<jrusso@horizon landco.com>; Travis Bivens <tbivens@horizonlandco.com>; Zulema Gatica <zgatica@horizon lm.com>;
dcmmetwater@gmail.com <dcmmetwater@gmail. com>
Sent: Monday, February 5, 2024 at 10:54:40 AM EST
Subject: Re: Carolina Village NOV's.... NOV-2024-LV-0075, NPDES# NCO063762 (10 day response)
Roberto,
As we discussed on the phone last week, I referenced November 2023 BOD exceedances in a letter
of response to related to NOV-2023-LV-0869 on 12-17-23. This email is intended to address the
violation NOV-2024-LV-0075 with the same explanation.
As you know, foaming issues are nothing new to the Carolina Village Wastewater Plant. Up until
recently a small upset could be corrected with sludge wasting, chlorine sprayers and some lime. This
is not the case anymore. I have never seen the foam and scum come on so fast and stay for so long.
As we discussed, foam has the potential to contribute to poor settling and treatment leading to an
array of non-compliance issues as we are seeing here. And unfortunately the first 2 weeks of
November 2023 as BOD's were > 53 mg/l and > 49 mg/l. However, the 3rd week of November shown
improvements with BOD at 17mg/l, TSS at 7.8 mg/l, NH3N at 8.1 mg/l and a fecal of 10
colonies/100ml.
We have been and continue to collect additional data and analytical results from our influent, EQ
basin, aeration basin and effluent. We have found influent constituents to be at the high end of what
should be 100% domestic, including CBOD's in the 300mg/l range and source water (City) pH in the
low to mid 7.0 S.U.
We have also identified through mixed liquor microscopy that our microorganism predominance
consist of manly filamentous bacteria with only a small population of desired organisms. We have
been injecting chlorine into the RAS and are beginning to see a decline in filamentous bacteria and
groupings of ciliates.
Working with a consultant, we tried adding hydrated lime to reach the prescribed pH of 8 to 8.5 S.U.
in the aeration basin. We went through a pallet of lime (45, 501b. bags) in couple weeks with little
success. Then we switched to a 25% caustic drip into the EQ and although we are still tweaking the
drip per minute setting, we are starting to see a consistent pH of 7.5 S.U. and above.
We extend to you, an invitation to this facility at a time convenient for you, so that you can see the
progress we have and continue to make. These letters give you the details but seeing the efforts and
changes first hand really shows or commitment to regaining compliance.
We are currently on a path to:
1. Evaluating blower efficiency, amp draws, size of pulleys, calculating SCFM as it relates to oxygen
horsepower needed
pil
2. Adding 25% caustic to increase and maintain pH of 8.5 +/- 0.2 S.U.
3. Evaluating condition of air headers and changing filters to wire mesh to increase air flow
4. Increase dissolved oxygen in aeration basin from its current 1.5 mg/I to the desire 3.5 mg/I — 5.0
mg/I
5. Replacing all 8 diffusers in aeration basin
6. Evaluating need to have aeration basin emptied and any settleables removed off site
7. Continuing with the 12.5% Hypochlorite to RAS injection to control proliferation of filamentous
bacteria.
8. Leaving one blower on 24 hrs. a day. Never turning off nor cycling blower run times.
9. We have also spoken to the manufacturer of NEWCO chlorine tablets (Sanitizer) to obtain a clear
understanding of dosing requirements per gallons of water treated as the size of the tablets fluctuate
and routinely only partially dissolve preventing the next tablet from dropping.
In closing, we respectfully ask that your office consider the remedial actions taken thus far and our
plan of action provided herein while in consideration of a civil penalty and chose not to move forward
with any further enforcement.
Should you need additional information or follow up please contact me directly by calling 704-506-
4255 or emailing me at dmetwater(c)aol.com.
Also thank you for the extension to reply.
See attached Standard Operating Procedure for Carolina Village MHP WWTP.
Sincerely,
Dusty Metreyeon
ORC, Carolina Village WWTP
Metwater, Inc.
11[$00]LTJ • • 4117MIT=-
Monroe, NC 28110
3
On Thursday, January 25, 2024 at 09:52:23 AM EST, Dusty Metreyeon <dmetwater@aol.com> wrote:
Roberto, When we talked about this yesterday, I felt I had already responded to high BOD's in
November 2023.
Actually what I had done was, include an advanced explanation of the November BOD's within the
body of a letter dated 12-15-23, while responding to a separate NOV-2023-LV-0869 (Ammonia). I
have included a copy of this letter herein please see attached.
My intent at that time was to give prior notice to your office pursuant to Permit Condition 6 (e).... first
knowledge of any non-compliance... including limit violations... of results prior to my submitting of the
November 2023 EDMR or the issuing of violation like the one here for same BOD for NOV-2024-LV-
0075.
I want to ensure you, my clients, Horizon Land Management, and I are on the same page. We
routinely discuss operational strategies, budgets, compliance and pending issues. As you can see
from my 12-15-23 response we are doing big this like ....replacing diffusers, adding telemetry and
providing easier and safer access to treatment components i.e.: tablet feeders.
We respectfully ask that your office consider the remedial actions taken thus far and our plan of
action provided herein while in consideration of a civil penalty and chose not to move forward with
any further enforcement.
Should you need additional follow up regarding the BOD violation letter NOV-2024-LV-0075 please
call. I will also reach out to you today.
Thank you.
Respectfully,
Dusty Metreyeon, ORC
Metwater Inc.
704-506-4255
On Wednesday, January 24, 2024 at 04:27:34 PM EST, Scheller, Roberto <roberto.scheller@deq.nc.gov> wrote:
Dusty,
Attached is the violation for November 2023. As noted in our phone call on 1/24/2024 if you need additional time to
respond please email me.
I'll send you a copy of October 2023 when it is signed.
Thank you.
Roberto L. Scheller
Environmental Consultant
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
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