NC0021253_Respone to Notice_NOV-2024-LV-0473 & NOV-2024-LV-0474_20240613

PUBLIC SERVICES DEPARTMENT
Rick Day, Public Utilities Director
104 OUTER BANKS DRIVE
PO BOX 368
HAVELOCK, NC 28532
252-444-6409
RECEIVED/NCDENR/DWR
June 5, 2024
Robert Tankard
943 Washington Square Mall
Washington, NC 27889
North Carolina Department of Environmental Quality
Division of Water Resources
Water Quality Regional Operations Section
Subject: Response to
Notice of Violation/ Notice of Intent for to Issue Civil Penaity
Case No. NOV2024-LV-0473 and NOV2024-LV-0474
BOD Effluent average exceedance
City of Havelock Wastewater Treatment Plant Permit No: NCO021253
Craven County
Dear Mr. Tankard:
JUN 13 2024
Water Quality
Regional Operations Section
Washington Regional Office
Please allow this correspondence to serve as the City of Havelock's response to the Notice of Violation issued for the
Limit Exceedance for BOD Values for testing in March and April 6 of 2024.
On January 10, 2024 the plants methanol pump and related VFD control panel malfunctioned and was out of service
until February 22, 2024 due to equipment procurement issues and onsite electrical routing complications. As a result
of the lack of methanol feeding, the mixture caused a three -fold increase in nitrates. Therefore, to decrease the nitrate
load, we increased methanol dosing from late February through Mid -march which created the spike in BOD numbers
as seen on the reports for March and the first week of April. Because of the initial equipment malfunction and long
lead repair/replacement time for the pump, we had to make our best efforts during March to mitigate nitrate loading
and then balance out BOD numbers to a normal level. Since April to today, we are back on track with compliant values
for both nitrates and BOD.
Please feel free to call with any further questions and I appreciate your understanding regarding this matter. We ask
that you consider imposing no, or at least a minimal, civil penalty in this case as the causes were not a result of
negligence on the part of the City but rather a result of unfortunate mechanical failure with added challenges in material
procurement. The City is performing as diligently as possible within our control to maintain and replace equipment
and balance mixtures in order to remain compliant with State requirements and most importantly safeguard the
surrounding environment.
Sincerely,
Rick Day,
Public Utilities Director
City of Havelock, Public Services
[phone]