NC0066516_NOV-2024-MV-0037 Response to Notice_20240320

Michael Wagner
Public Utilities Director
[e-mail]
Public Utilities

Town of Fuquay-Varina 134 N. Main Street, Fuquay-Varina, NC 27526 [phone] fuquay-varina.org

March 20, 2024

Vanessa Manuel
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
1628 Mail Service Center, Raleigh, NC 27699-1628

RE: NOTICE OF VIOLATION NOV-2024-MV-0037
Terrible Creek WWTP
NPDES No. NC0066516
Town of Fuquay-Varina
Wake County

Dear Ms. Manuel,

The Town of Fuquay-Varina appreciates the opportunity to respond to the Notice of
Violation dated March 12, 2024, for a conductivity monitoring violation that occurred during
the January 2024 monitoring period. It is our intent that this response will provide sufficient
additional information regarding the incident and justification that the Town should not be
assessed a civil penalty.

Cause of non-compliance:
On January 26, 2024, the treatment plant staff failed to collect an effluent conductivity
sample. Recently, new operators have been hired to prepare for 24/7 operation when the plant
is expanded in the years 2026-2027. As a result of the expansion, areas of responsibility have
been divided up into zones to assist with training the new employees. The ORC has
investigated the reason why a sample was not collected, and it was attributed to a
miscommunication of responsibilities for that day.

Remedial Action Taken:
To prevent this from happening in the future, the standard operating procedure for
zone responsibilities was provided in written format to each operator to clearly specify the
responsibilities within each zone. We have included the written process as an attachment to
this letter.

As demonstrated, ORC was responsive and took immediate action to prevent future
violations. We believe this letter justifies our commitment to permit compliance and we hope
that the Division recognizes these efforts. Therefore, we respectfully request that the Division
not take any further enforcement action against the Town.

Sincerely,

Michael Wagner
Public Utilities Director

Cc: file
Adam Stephenson, ORC
Zone 1 Influent sampler/Influent Pump Station/Coarse
Barscreen/Pre-treatment Facility/Motor Control
Center/Chemical Building/Generator
Influent sampler – check for operatfon, check cabinet temperature, pull process control sample
and have to lab by 07:30, clean influent sampler container weekly.
IPS – check influent flow meter.
Coarse Barscreen - clean up trash around dumpster, clean scraper blade, clean chute under
conveyor, make sure the barscreen is running (15 min tfmer).
Pre-Treatment Facility building- make sure dumpster room is clear of debris and cobwebs, clean
floor, walls and under dumpster.
Grit pump room - clean underneath dumpsters, clean trash and debris around PTF building
check heaters and ventflatfon systems.
Top of Pre-treatment Facility - check for clogs, vibratfons, leaks, check fine screens, grit
classifiers and compactor for operatfon, clean and hose any debris or floatfng solids in cyclones,
clean grit chute weekly.
Generator - floor is clean, no leaks, no visual or audible alarms, turn off lights.
Chemical feed building – make sure alum pump is on and feeding, floors clean and swept no
cobwebs, check for leaks, drain chemical catch basin daily, test eyewashes in and around
building weekly.
Do a chemical catch monthly.
Motor Control Center 1- check for fault lights, sweep, and clean floors, check generator
exerciser on schedule and voltage.
Check the outiall weekly.
Zone 2 BNRs/Clarifiers/Blowers/Digester/RAS Building
Blowers - check oil levels daily, check for air leaks or oil leaks, check HMI screens for
maintenance issues or messages.
BNR - Check mixers for operatfon, check DO probe readings and clean probes weekly, bleed air
system weekly, check alum feed, 30 min settleometer daily, remove debris on top of plant and
hose down any debris inside plant, check air diffuser pattern, take MLSS reading daily.
Clarifiers - check blankets, hose down weirs and center ring daily, check for operatfon of scum
trough arms, check weir brushes for operatfon and clean debris off brushes.
RAS - check flow meter for return, clean building, sweep remove dust debris, spider webs.
Digester- check level indicator, check air diffuser pattern.
Zone 3 MCC2/UVs/Disc filters/Press/Truck loading /Electrical
manhole pump
Have effluent sample to the lab by 7:30 AM daily.
Disc filters - check operatfon, clean backwash filter weekly, pull covers weekly and visually inspect, hose
down as needed, listen for vibratfons or unusual noises.
UVs - check eff flow meter, check non potable flow meter, note any alarms on UV screen, check that UV
bulbs operatfng match.
MCC2 - check a/c units for operatfon, panels for faults, keep room free of debris, dust spider webs, etc
Check sump pump in electrical manhole for operatfon.
Press – keep the press room swept and hosed, hose presses daily, check heaters and fans for operatfon,
optfmize for 17% solids when pressing, Bring sludge sample to lab for % solids test.
Truck loading – keep area free from debris including solids.
Check Fire Alarm panel in admin building weekly.
Clean effluent sampler container weekly
Lab
Calibrate DO and pH meter by 7:30 AM daily,
Monday, Wednesday, Friday conduct all influent and effluent process control testfng for Terrible
Creek and Brighton Forest,
Set up daily state sample kits for Terrible Creek and Brighton Forest
Clean lab and future lab, take stock of lab supplies.
Calibrate MLSS meter weekly.
Run % solids testfng.
Update process control sheets daily.
Pull daily compliance samples at TC and verify BF compliance samples have been pulled daily.

***Please keep all areas clean and free from trash, dirt, cobwebs, dust, solids, etc.