NC0025453_NOV-2024-MV-0058_20240507

Manuel, Vanessa
From: David White <[e-mail]>
Sent: Tuesday, May 7, 2024 10:12 AM
To: Hall, Michael
Cc: Manuel, Vanessa
Subject: [External] Town of Clayton Response to NOV February 17th 2024
Attachments: RE_ [External] Town of Clayton NPDES Non -Compliance for Conductivity for February
2024.eml; NOV NPDES Febraury 17th 2024 Response.docx
Follow Up Flag: Follow up ^,i r (� ( �(J�_2o7 (-I-fV-0058
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Good Morning Michael,
I'm reaching out to you regarding the NOV the Town received for the Frequency Violation on Conductivity
the week of February 17th, 2024. The NOV was issued on April 26th, 2024, and was received by the Town
of May 6th, 2024. I've attached the Town's Response to this NOV and the email sent to notify the DEQ of
Non -Compliance for that month. Please contact me at 919-594-0417 or email me at
[e-mail] for any questions or concerns. Thank you in advance.
Respectfully,
David White
Water Reclamation Superintendent
Town of Clayton, INC
PO BOX 879
919-594-0417
[e-mail]

May 7, 2024
Michael Hall
Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
3800 Barrett Dr.
Raleigh NC, 27609
Re: Notice of Violation, Tracking Number: NOV-2024-MV-0058, Permit # NC0025453, Sam's Branch WRF
(SWF), Johnston County
Mr. Hall:
The Town of Clayton offers the following information regarding the NOV for the Frequency Violation on
Conductivity during the week of February 17, 2024. The NOV is dated April 26, 2024 and was received by
the Town on May 6, 2024. During the week of February 17th, our Lab Supervisor and several new hires
were out sick during the week making the plant short staffed. During the 15th and 16th, one of our new
hire operators was in the lab filling in Field Test Parameters for Daily Compliance and during that time it
was miscommunicated about running Conductivity on an Effluent Grab. Upon the Lab Supervisor's
return on Monday the 19th, it was found the two samples were missed and the DEQ was notified that
same day for our Non -Compliance for the month of February. An email was sent to Vanessa Manuel that
Monday afternoon to explain the issue. Donald Smith from the DEQ was later called for guidance and we
ran conductivity on our effluent composite for the 16' and 17th and the results were added in the
comments section of the eDMR. The results were left out of the Compliance Reporting Results due to
the samples being composite and not a grab. While I understand as ORC there are no excuses for
missing samples, the Town has already taken action to prevent this from happening again. Through
SOPS, Daily Compliance Lab Check Sheets, proper training and communication, and future
implementation of our KLIR Dashboard Software, employees and operators have a clear understanding
of what samples and parameters are to be tested during the week to ensure Compliance.
Please contact me at (919)-594-0417 or email me at dwhitePtownofclaytonnc.ora for any questions or
concerns.
Sincerely,
David White
Water Reclamation Superintendent
Town of Clayton, NC
PO Box 879
919-594-0417
[e-mail]

Manuel, Vanessa
From: Manuel, Vanessa <[e-mail]>
Sent: Tuesday, February 20, 2024 10:25 AM
To: David White
Cc: James Blalock; Joshua Baird; Smith, Donald
Subject: RE: [External] Town of Clayton NPDES Non -Compliance for Conductivity for February
2024
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Hi David,
Thanks for notifying our office. When we evaluate the Town's self -monitoring data for February, we will send the
appropriate enforcement notice letter. At that time and if requested, you should provide a written explanation for the
missed sampling and let us know the actions you are taking and have taken to ensure the issue has been resolved. If you
have any questions, please feel free to reach out to Donald Smith of my staff.
Respectfully,
Vanessa E. Manuel
Assistant Regional Supervisor
Division of Water Resources — Raleigh Regional Office
Department of Environmental Quality
919 791-4232 Office; 919 817-1256 Mobile
va nessa. manuel(a.dec.nc.00v
Physical: 3800 Barrett Drive, Raleigh, NC 27609
Mailing: 1628 Mail Service Center, Raleigh, NC 27699-1628
Note: DEQ is updating its email addresses to @deq.nc.gov in phases from May 1" to June 91h.
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From: David White <[e-mail]>
Sent: Monday, February 19, 2024 2:13 PM
To: Manuel, Vanessa <[e-mail]>

Cc: James Blalock <[e-mail]>; Joshua Baird <[e-mail]>
Subject: [External] Town of Clayton NPDES Non -Compliance for Conductivity for February 2024
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Good afternoon Vanessa,
I'm reaching out to you regarding our NPDES compliance for this month of February 2024. This morning,
we were made aware that on Thursday the 15`h and Friday the 16th no number was recorded for
Conductivity, Parameter Code 00094, which is a Daily Grab sample of our Effluent Monday through
Friday. Our Lab Supervisor was not available those two days in which case one of our operators was in
the lab testing daily field compliance and the Conductivity was not taken. While I understand this is no
excuse on the matter, the Town has already begun our response to this matter so that it is not repeated
again. I just wanted to let you and the State know within the 24-hour window of finding this issue. Please
contact me with any questions or concerns on this matter. Thank you in advance.
Respectfully,
David White
Water Reclamation Superintendent
Town of Clayton, NC
PO Box 879
919-594-0417
d-white@townofclaytonnc org
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.