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Home My WebLink AboutNC0037508_LV20170044_20170216Pu6Cic 'Works Water PoCCution ControCPCant 1094 Addor Road Aberdeen, NC 28315 February 8, 2017 Wastewater Branch Division of Water Resources 1617 Mail Service Center Raleigh, NC 27699-1617 `o�Nn Av rooAe �'"'xMOATN �n County of Moore RE: Moore County WPCP Permit NCO037508 Case No. LV -2017-0044 To Whom It May Concern, (910) 281-3146- Phone (910) 281-2047- Fax RECEIVEDINCDENWR FEB 16 2017 Water Quality Permitting Section Regarding the Notice of Violation and Assessment of Civil Penalty for May 2016, Moore County would like to request remission on the grounds that we promptly began investigating the issues when we knew we had a problem, we had no previous violations of this kind, and the cause was accidental and unavoidable through our proper operation of the WPCP by the operators and staff. We researched several reasons for the weekly and monthly BOD violations including wastewater that may have caused pass through, over -wasting, grease entering the plant, BOD meter/analyst problems, and effluent sampler issues. The log books maintained by the operators were reviewed and found nothing unusual. While most exceedances were on Mondays, this was not always the case. On the days with high effluent BOD results, we looked at all other plant data, including all results from our in house compliance testing and process control, and results from the commercial lab we send samples to. There were no other exceedances on any other parameters. Influent BOD data was within normal ranges for our plant. Our wastewater `bugs' looked healthy under the microscope and showed no signs of stress or die off. We concluded that we did not receive anything via the collections system that could have caused pass through. The attached spreadsheet includes influent and effluent BOD data for May. We reviewed septic hauler load information and found nothing unusual with the septage we received. We did not see significant changes in the grease or scum layers on our three primary clarifiers. When we waste the activated sludge (WAS) from our aeration basins we calculate the gallons wasted based on the mixed liquor (MLSS) numbers which are calculated daily. We run our WPCP on summer/winter target ranges (First Stage: summer 1800mg/L, winter 2400mg/L; Second Stage: summer 1900mg/L, winter 2300mg/L).The MLSS samples are collected by operators from designated locations and run in house by our certified lab staff. On weekends and holidays the operators have the ability to run MLSS in the mini lab. Volatile suspended solids (MLVSS) are run weekly for process control reasons. Based on all data collected for May, over- Pu6Cic `Works t-'%" of AMID, (910) 281-3146- Phone Water PoCCution ControCPCant 1 (glo) 281-204.7- Fax 1094 .Addor Road 1784 .Aberdeen, NC 28315 1 n County of Moore wasting was determined not be the issue. As the attached spreadsheet shows, our MLSS numbers and wasting fluctuated throughout the summer while we continued to have BOD issues. The BOD meter and lab analysts were investigated. The BOD meter we currently have in the lab is an Orion Star A213. We have three probes for the meter which we alternate through the year. As we were having the BOD problems, we switched the probes (see attached drift log). This did not correct the problems. The standard operating procedure (SOP) was reviewed with all analysts to verify that the SOP was being followed during the reading of the BODS. One analyst runs the BODS on a daily basis, unless she is out. Several different people read the BODS as they come out of the incubator during the week and on Saturdays. The quality control, glassware, distilled water, reagents, and other supplies were determined not to be the problem as the high results were not consistent. At times we had both high and low results in the same batch (May 30 and 31). We found no issues with the lab or lab staff. The effluent sample is collected from the bottom of the cascade via tubing that is approximately 25 feet long. The tubing is held in place by two pieces of PVC pipe attached to the concrete structure, one horizontal piece that is directly before the sampler, one vertical piece that pulls from the effluent channel (picture attached). At some point over the summer, the PVC pipe came detached from the wall. This occurred at around the same time we began having BOD non- compliance issues. We secured the pipe back to the wall on May 18 by having a maintenance mechanic climb down while on a harness at low flow to reattach the PVC pipe (picture attached). While this placed the tubing back into the effluent channel, we were not certain that it was in the same position- a non -turbulent zone with adequate flow. Our practice was to pause the effluent composite sampler program on the weekends beginning Friday morning after the operators collected the sample and ending Sunday morning when they restarted the sampler. In August, after exhausting our investigation as to where the problem was coming from, we began letting the program run all weekend, therefore flushing the strainer and tubing continuously. We concluded that a combination of the pipe coming detached from the wall and the effluent sampler and sampler hose sitting idle all weekend were contributing to our BOD exceedances. After correcting these problems, we continued to improve our compliance during June and July. In June, we had a monthly average exceedance and in July we had one weekly exceedance. Since August 2016, Moore County has remained compliant on all parameters. We also passed the toxicity test in June 2016 while we were still non-compliant for BOD, as well as all toxicity tests since then. Our costs to abate the compliance issue include: PVC Pipe $100.00 Sampler Tubing $150.00 Public 'Warks `ppHSf OF! pp9F "Water PoCCution ControCPCant b 06 1094 Addor Road ® 1784 M Aberdeen, NC 28315n T < a �FpFkpfliHO� County of Voore BOD caps for meter $55.00 Time for repairing the pipe/changing tubing Approximately 4 man hours at $19.00 average $76.00 Time to investigate, compile data Approximately 20 man hours at $21.00 average $420.00 Total cost $801.00 (910) 2813146- Phone (910) 281-2047- Fax If you have any questions or require more information concerning this correspondence, please contact me at your convenience. Sincerely, Janna Scherer Nall, Superintendent Moore County Water Pollution Control Plant RECEIVEDINC®EC M, Cc: Randy Gould, PE, Public Works Director, County of Moore FEB IS 2017 Mark Brantley, Fayetteville Regional Office Water Quality Permitting Section ,i,5 Lo nr-,Ol 00 L,D ri lD N Ln M N O ri N 00 O co +� O O N N N c co N M d' k.0 Ln r, Ln N lz;r L0 +, 0 at lD v 01 n 00 V) o w Ol 01 M 0 lD �% N -� LD co lD L9 -:t 00 lD LD t\ NC _ 00 w C a U N \ Ln N Ln M 00 00 M N N O lD -�f O 00 O CL c0 3 O N - .L a N ri N M ri ri N M N. -I ri LL 2 E on ,-� U G n t? o LL N N N N N N N N N O HM ri ri N N N w N N c -I c -I N N N M It u m E N 4-1 cu 'Q w Z C N E bbD 0 U n L n n r o 4l v Lo 3 41 \ M M N r -I N lD n -4 ch > c m Q to N -1 00 00 00 w N tw C a� a n L rr, N N C Q 0 mmmmm mCo 4J 41 C ft5 i0 C6 f6 f6 (0 LD LO c c U C N ,i,5 N nr-,Ol 00 L,D ri lD N Ln M N O ri N 00 O co 11D O O N N N 00 N N M d' k.0 Ln r, Ln N lz;r L0 +, 0 at lD O 01 Ln 00 M o w Ol 01 M 0 lD �% N -� LD co lD L9 -:t 00 lD LD t\ NC t 00 w 40 LL N \ Ln N Ln M 00 00 M N N O lD -�f 00 O L J fY'f N N ri N ri N M ri ri N M N. -I ri LL 2 E u G N N N N N N N N N N N N O HM ri ri N N N w N N c -I c -I N N N M It u m E N w � N nr-,Ol 00 L,D ri lD N Ln M N O ri N 00 O co 11D O O N WlD M 00 N N M d' k.0 Ln r, Ln N lz;r L0 +, 0 at lD O 01 Ln 00 M fMA w C 01 M 0 lD �% N -� LD O lD L9 -:t 00 lD LD N NC t 00 w 40 LL N \ Ln N Ln M 00 00 M N N O lD -�f 00 m L J fY'f N N ri N ri N M ri ri N M N. -I ri LL 2 E N G N N N N N N N N N N N N O HM ri ri N N N LL N N c -I c -I N N N M It u m E N = M 'O y� 0 0 0 0 0 0 00 0 0 0 0 0 0 3 bA rMi N a� N 41 110 nr-,Ol 00 L,D ri lD N Ln M N O ri N 00 O co 11D O O N WlD M 00 N N M d' k.0 Ln r, Ln N lz;r L0 +, 0 at lD O 01 Ln 00 M fMA w C 01 M 0 lD �% N -� LD O lD L9 -:t 00 lD LD N 00 t 00 w N LL N \ Ln N Ln M 00 O M N N O lD -�f N m L J fY'f N N ri N ri N M ri ri N M N. -I ri LL 2 E N N N N N N N N N N N N N N O HM ri ri N N N lD N N c -I c -I N N N M It u m E w N A n bA 110 nr-,Ol 00 L,D ri lD N Ln M N O ri N 00 O co LO O O N WlD M 00 N N M d' k.0 Ln r, Ln N lz;r N +, 0 at lD O 01 Ln 00 M fMA w C 01 M 0 lD �., 0 E N W ci W W ri M ^ OlM N n 't ri N LL N m f6 NNoo;t (0 (6 lV f6 C-413)0,N�HN O l0 t9 (6 l6 N (4 L fY'f � d' ri O O Q1 00 M LL l0 \ M d ci d O M 4 00 ri O O d O ri Y N J 00 L,D -�t N d' 00 N -;t 00 N O 00 O lD N J 'd' 00 n M c -i N 00 m d' k.0 M O O N 111 N 00 DO lD m Q1 m N O m 00 00 m 01 m lD 00 ++01 y1 L C E N N N N N M N N NN N N N ri N LL N lV f6 (0 (0 (6 lV f6 f6 O l0 t9 (6 l6 N (4 O fY'f � d' ri O O Q1 00 M 4) l0 \ M d ci d O M 4 00 ri O O d O ri 1p HM ri ri N N N lD N N c -I c -I N N N M It m E W A n 41 \ M M N r -I N lD n -4 ch N m Q to N -1 00 00 00 w N C m rr, N N mmmmm 4J 41 C ft5 i0 C6 f6 f6 (0 LD LO c c c C C 2 G G G G C O ci N M d In l0 I� 00 N Ni r Ln N O 41 Ln LL 4D C 4) ca OI OIOIOIdt co pIr- riI(n r, NI�IOI a^-il NI -I NId'IMINIchINIMIMIMIMIMILn CY) N N N N N N N N N N N N N N N 1 ri ` , N M d '* 00 n Ln Ln M Ln m d' `1 O M d' 01 In M M N 07 N00 Ln 0) 10 M ri W ri M O O C7 n n Ln ri N p O M N I� M 1p O1 O 01 ri l0 Ln' I� O O lD 1p 1p M 't 4 m 00 00 d' 00 d' lD d' d' d' O N N N O O 00 LD O 'd' d' tD M q O 00 N N Ln 01 q 00 t LD N 00 DO lD G lD Ln ED Ln O N Ln .ED lD 1-% r -i O N N N N N N N N M N N N N N N M f6 N lV f6 (0 (0 (6 lV f6 f6 O l0 t9 (6 l6 N (4 O fY'f � d' ri O O Q1 00 M Lf l0 1- c O 01 O c -I N M 4 Ln Lb r� 00 Ol O ri 1p HM ri ri N N N lD N N c -I c -I N N N M It 00 d' -1 N M N lD 11)1001-11 r, Ln LD lD Ln O N N ci O h m O1 N N ri ri N 1 N I I N I N I N N ri N 1 N f6 LD lV f6 (0 (0 (6 lV f6 f6 O l0 t9 (6 l6 f0 (4 Lf l0 1- c O 01 O c -I N M 4 Ln Lb r� 00 Ol O ri r -I ri ri ri ri N N N N N N N N N N M M D"'Issolved Oxygen Probe Calibration/Drift Check Log SM 4500 O G- 2001 Table 4500-0:I Difference in check and actual value must be < 0.20 mg/l, if not, you must recalibrate the meter and re- rwwl all comnica hnfhrlcann Arran+ahlc rlri# rhorlrc RpviczpH 111 d/1 A Initial Drift !Calibrationj Check Probe Used A nalyst initials: rown SM 4500 O G- 2001 Table 4500-0:I Difference in check and actual value must be < 0.20 mg/l, if not, you must recalibrate the meter and re- rwwl all comnica hnfhrlcann Arran+ahlc rlri# rhorlrc RpviczpH 111 d/1 A I U. Dissolved Oxygen Probe Calibration/Drift Check Log .;p1V1 It.lVV V l7- LVV 1 Table 4500-0:1 Difference in check and actual value must be < 0.20 mg/l, if not, you must recalibrate the meter and re• roar! all carrinicc hatu .-AAM art-an+ahip rlrifF rhankc VI Ili VIRavi¢a�i 1l1dl1 IVMM Mll VMI/11.I1VY NVt��VVI l MVW�./l{ANIV IVVIIV. Initial Drift -�Calibrationj Check Probe Used 1,2,3 Analyst Initials ME WIEME NOME ME EME�: 'EMINSEME - MNIARE INE ME IMIEE�E �'M1WWMMN1W= W1E1NMMN--- MEESE 010" AVE� �-4- ME .;p1V1 It.lVV V l7- LVV 1 Table 4500-0:1 Difference in check and actual value must be < 0.20 mg/l, if not, you must recalibrate the meter and re• roar! all carrinicc hatu .-AAM art-an+ahip rlrifF rhankc VI Ili VIRavi¢a�i 1l1dl1 IVMM Mll VMI/11.I1VY NVt��VVI l MVW�./l{ANIV IVVIIV. 4 .4 4 # Cti 10j, i JUSTIFICATION FOR REMISSION REQUEST Case Number: LV -2017-0044 County: Moore Assessed Party: Moore County Permit No.: NC0037508 Amount Assessed: $2,142.81 . Please use this form when requesting remission of this Evil penalty. You must also complete .the "Request For Remission, Waiver of Right to an Administrative Hearing, and Stipulation of Facts" form to request remission of this civil penalty. You should attach any documents that you believe support your request and are necessary. for the Director to consider in evaluating your request for remission. Please be aware that a request for remission is limited to consideration of the five factors listed below as they may relate to the reasonableness of the amount of the civil penalty assessed. Requesting remission is not the proper procedure for contesting whether the violation(s) occurred or the accuracy of any of the factual statements contained in the civil penalty assessment document. Pursuant to N.C.G.S. § 14313-282.1(c), remission of a civil penalty may be granted only when one or more of the following five factors apply. Please check each factor that you believe applies to your case and provide a detailed explanation, including copies of supporting documents, as to why the factor applies (attach additional pages as needed). (a) one or more of the civil penalty assessment factors in N.C.G.S. 14313-282.1(b) were wrongfully applied to the detriment of the petitioner (the assessment factors are listed in the civil penalty assessment document); (b) the violator promptly abated continuing environmental damage resulting from the violation (Le., explain the steps that you took to correct the violation and prevent future occurrences); (c) the violation was inadvertent or a result of an accident (i.e., explain why the violation was unavoidable or something you could not prevent or prepare for); X(d) the violator had not been assessed civil penalties for any previous violations; (e) payment of the civil penalty will prevent payment for the remaining necessary remedial actions (i.e., explain how payment of the civil penalty will prevent you from performing the activities necessary to achieve compliance). EXPLANATION: STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY COUNTY OF MOORE IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN OF CIVIL, PENALTIES AGAINST } ADMINISTRATIVE HEARING AND STIPULATION OF FACTS Moore County ) - Moore County WPCF ) PERMIT NO. NCO037508 ) CASE NO. LV -2017-0044 Having been assessed civil penalties totaling $2,142.81 for violation(s) as set forth in the assessment document of the Division of Water Resources dated January 30, 2017, the undersigned, desiring to seek remission of the civil penalty, does hereby waive the right to an administrative hearing in the above -stated matter and does stipulate that the facts are as alleged in the assessment document. The undersigned further understands that all evidence presented in support of remission of this civil penalty must be submitted to the Director of the Division of Water Resources within thirty (30) days of receipt of the notice of assessment. No new evidence in support of a remission request will be allowed after (30) days from the receipt of the notice of assessment. This the —1 day of CA0'CU 0-4- ti , 20 —1 ADDRESS VALA Add oy, Road &e -Yd :eA, NIC 206315 TELEPHONE CW)- plg1- 3 ILA k4