NC0063321_LV20170174_20170621

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GHMR(MKGNYAL 10k*LdrY
Certified Mail # 7016 1370 0001 6571 5256
Return Receipt Requested
Dan Harbaugh
Tuckaseigee Water & Sewer Authority
1246 W Main St
Sylva, NC 28779
ROY COOPER
gom%or
MICHAEL S. PI GAN
Seta ary
S. JAY ZIta MEMAN
Mlectvr
June 21, 2017 CCENFONC®E-000
0 21 WT
Water Q Se tion
permitting
SUBJECT Notice of Violation and Assessment of Civil Penalty
for Violations of North Carolina General Statute (G S ) 143-215 1(a)(6)
and NPDES WW Permit No NCO063321
Tuckaseigee Water & Sewer Authority
TWSA Plant #3/ Cashiers
Case No LV-2017-0174
Jackson County
Dear Permittee
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of $866 62 ($750 00 civil penalty +
$116 62 enforcement costs) against Tuckaseigee Water & Sewer Authority
This assessment is based upon the following facts a review has been conducted of the Discharge Monitoring Report
(DMR) submitted by Tuckaseigee Water & Sewer Authority for the month of October 2016 This review has shown the
subject facility to be in violation of the discharge limitations and/or monitoring requirements found in NPDES WW Permit
No NCO063321 The violations, which occurred in October 2016, are summarized in Attachment A to this letter
Based upon the above facts, I conclude as a matter of law that Tuckaseigee Water & Sewer Authority violated the terms,
conditions or requirements of NPDES WW Permit No NCO063321 and G S 143-215 l(a)(6) in the manner and extent
shown in Attachment A In accordance with the maximums established by G S 143-215 6A(a)(2), a civil penalty may be
assessed against any person who violates the terms, conditions or requirements of a permit required by G S 143-215 1(a)
Based upon the above findings of fact and conclusions of law, and in accordance with authority provided by the Secretary
of the Department of Environmental Quality and the Director of the Division of Water Resources, I, G Landon Davidson;
P G, Regional Supervisor, Asheville Regional Office hereby make the following civil penalty assessment against
Tuckaseigee Water & Sewer Authority.
State of North Carolina I Environmental Quality I Water Resources
2090 U S 70 Highway, Swannanoa, NC 28778
828-296-4500

S11
$500 00 1 of the 1 violations of 143-215.1(a)(6) and Permit No NC0063321, by discharging wastewater into
the waters of the State in violation of the Permit Monthly Average for BOD - Conc.
$0.00 0 of the 1 violations of 143-215.l(a)(6) and Permit No.NC0063321, by discharging waste water into
the waters of the State in violation of the Permit Monthly Average for TSS - Conc
$250 00 1 of the 1 violations of 143-215.1(a)(6) and Permit No NC0063321, by discharging waste water into
the waters of the State in violation of the Permit Weekly Average for BOD - Conc.
$0.00 0 of the 1 violations of 143--215.1(a)(6) and Permit No NC0063321, by discharging waste water into
the waters of the State in violation of the Permit Weekly Average for TSS - Conc
$750.00 TOTAL CIVIL PENALTY
116.62 Enforcement Costs
$866.62 TOTAL AMOUNT DUE
Pursuant to G S 143-215.6A(c), in determining the amount of the penalty I have taken into account the Findings of Fact and
Conclusions of Law and the factors set forth at G S 143B-282.1(b), which are
(1) The degree and extent of harm to the natural resources of the State, to the public health, or to private property
resulting from the violation;
(2) The duration and gravity of the violation,
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance,
(6) Whether the violation was committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs over which the Environmental
Management Commission has regulatory authority; and
(8) The cost to the State of the enforcement procedures.
Within thirty (30) days of receipt of this notice, you must do one of the following-
(1) Submit payment of the penalty, OR
(2) Submit a written request for remission, OR
(3) Submit a written request for an administrative hearing
Option 1: Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environmental Quality (do not include waiver
form) Payment of the penalty will not foreclose further enforcement action for any continuing or new violation(s).
Please submit payment to the attention of
Wastewater Branch
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617

r Option 2: Submit a written request for remission or mitigation including a detailed justification for such
r
request:
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. Because a remission request forecloses the option of an administrative hearing,
such a request must be accompanied by a waiver of your right to an administrative hearing and a stipulation and
agreement that no factual or legal issues are in dispute. Please prepare a detailed statement that establishes why you
believe the civil penalty should be remitted, and submit it to the Division of Water Resources at the address listed below.
In determining whether a remission request will be approved, the following factors shall be considered:
(1) whether one or more of the civil penalty assessment factors in NCGS 143B-282. I (b) was wrongfully
applied to the detriment of the petitioner;
(2) whether the violator promptly abated continuing environmental damage resulting from the violation,
(3) whether the violation was inadvertent or a result of an accident;
(4) whether the violator had been assessed civil penalties for any previous violations, or
(5) whether payment of the civil penalty will prevent payment for the remaining necessary remedial actions
Please note that all evidence presented in support of your request for remission must be submitted in writing The
Director of the Division of Water Resources will review your evidence and inform you of his decision in the matter of
your remission request. The response will provide details regarding the case status, directions for payment, and
provision for further appeal of the penalty to the Environmental Management Commission's Committee on Civil Penalty
Remissions (Committee). Please be advised that the Committee cannot consider information that was not part of the
original remission request considered by the Director. Therefore, it is very important that you prepare a complete and
thorough statement in support of your request for remission.
In order to request remission, you must complete and submit the enclosed "Request for Remission of Civil Penalties
Waiver of Right to an Administrative Hearing, and Stipulation of Facts" form within thi 30Lys of receipt of this
notice. The Division of Water Resources also requests that you complete and submit the enclosed "Justification for
Remission Request."
Both forms should be submitted to the following address:
Wastewater Branch
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617

Option 3: File a petition for an administrative hearing with the Office of Administrative Hearings: Y
If you wish to contest any statement in the attached assessment document you must file a petition for an administrative
hearing. You may obtain the petition form from the Office of Administrative Hearings. You must file the petition with
the Office of Administrative Hearings within thirty (3 0) days of receipt of this notice A petition is considered filed
when it is received in the Office of Administrative Hearings during normal office hours. The Office of Administrative
Hearings accepts filings Monday through Friday between the hours of 8 00 a.m. and 5.00 p.m, except for official state
holidays The petition may be filed by facsimile (fax) or electronic mail by an attached file (with restrictions) - provided
the signed original, one (1) copy and a filing fie (if a filing fee is required by NCGS § 15013-23.2) is received in the
Office of Administrative Hearings within seven (7) business days following the faxed or electronic transmission. You
should contact the Office of Administrative Hearings with all questions rejzarding the filing fee and/or the details of the
filing process.
The mailing address and telephone and fax numbers for the Office of Administrative Hearings are as follows -
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, NC 27699-6714
Tel- [phone]
Fax- (915-) 733-3478
One (1) copy of the petition must also be served on DEQ as follows:
Mr. William F. Lane, General Counsel
Department of Environmental Quality
1601 Mail Service Center
Raleigh, North Carolina 27699-1601
Please indicate the case number (as found on page one of this letter) on the petition.
Failure to exercise one of the options above within thirty (3 0) days of receipt of this letter, as evidenced by an internal
date/tune received stamp (not a postmark), will result in this matter being referred to the Attorney General's Office for
collection of the penalty through a civil action. Please be advised that additional penalties may be assessed for violations
that occur after the review period of this assessment.
If you have any questions, please contact Janet Cantwell with the Division of Water Resources staff of the Asheville
Regional Office at [phone] or via email at janet [e-mail].
Sincerely,
G. Landon Davidson, P G, Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS
Co. WQS Asheville Regional Office - Enforcement File
NPDES Compliance/Enforcement Unit - Enforcement File
G 6VRdVQUacksonlWasteuvater bluniupaflCashiers FVWIP u_ +2 [kLb 2017-017A rlf

JUSTIFICATION FOR REMISSION REQUEST
Case Number: LV-2017-0174
County: Jackson
Assessed Party: Tuckaseigee Water & Sewer Authority/ TWSA #3, Cashiers
Permit No.: NC0063321 Amount Assessed: $866.62
Please use this form when requesting remission of this civil 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.0 G.S § 143B-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 143B-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 (i e , 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);
(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
COUNTY OF JACKSON
IN THE MATTER OF ASSESSMENT
OF CIVIL PENALTIES AGAINST
Tuckaseigee Water & Sewer Authority
TWSA Plant #31 Cashiers
PERMIT NO. N00063321
DEPARTMENT OF ENVIRONMENTAL QUALITY
WAIVER OF RIGHT TO AN
ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
CASE NO. LV-2017-0174
Having been assessed civil penalties totaling $866.62 for violation(s) as set forth in the assessment document of the Division
of Water Resources dated June 21, 2017, the undersigned, desirmg 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 day of , 20
SIGNATURE
ADDRESS
TELEPHONE

ATTACHMENT A
Tuckaseigee Water & Sewer Authority
CASE NUMBER: LV-2017-0174
PERMIT: NCO063321
REGION:
Asheville
FACILITY: TWSA Plant #3/ Cashiers
COUNTY:
Jackson
LIMIT VIOLATION(S)
SAMPLE LOCATION: Outfall 001 - Effluent
Violation Report
Unit of
Limit
Calculated % Over
Violation
Penalty
Date MonthNr Parameter
Frequency
Measure
Value
Value Limit
Type
Amount
10/29/2016 10-2016 BOD, 5-Day (20 Deg
Weekly
mg/I
2250
3330 479
Weekly
$250 00
C) - Concentration
Average
Exceeded
10/31/2016 10-2016 BOD, 5-Day (20 Deg
Weekly
mg/I
15
1990 324
Monthly
$500 00
C) - Concentration
Average
Exceeded
10/29/2016 10-2016 Solids, Total Weekly mg/I 45 5350 189 Weekly $0 00
Suspended- Average
Concentration Exceeded
10/31/2016 10-2016 Solids, Total Weekly mg/I 30 31 10 36 Monthly $0 00
Suspended- Average
Concentration Exceeded

DIVISION OF WATER RESOURCES - CIVIL, PENALTY ASSESSMENT (File)
Violator: Tuckaseizee Water & Sewer Authority
Facility Name: TWSA Plant #3/ Cashiers
Permit Number: NCO063321
County: Jackson
Case Number: LV-2017-0174
ASSESSMENT FACTORS
1) The degree and extent of harm to the natural resources of the State, to the public health, or to private property
resulting from the violation;
All effluent violations may be detrimental to the receiving stream but may not be immediately quantified.
2) The duration and gravity of the violation;
One Monthly Average BOD exceeded the permit limit by 32.37%.
One Weekly Average exceeded the permit limit by 47.88%.
One Monthly Average TSS exceeded the permit limit by 3.55%
One Weekly Average TSS exceeded the permit limit by 18.88%.
3) The effect on ground or surface water quantity or quality or on air quality;
All effluent violations may be detrimental to the receiving stream but may not be immediately quantified.
4) The cost of rectifying the damage;
The cost is unknown.
5) The amount of money saved by noncompliance;
The amount of money saved is unknown.
The amount of money saved would include the cost of excess solids removal and additional aeration. It
would also include more operating and maintenance time on site and the cost of additional chemical
treatment.
The amount of money saved would include the cost of collection of the additional samples and the cost of
analyzing them at a certified lab.
6) Whether the violation was committed willfully or intentionally;
It does not appear to be either.
7) The prior record of the violator in complying or failing to comply with programs over which the Environmental
Management Commission has regulatory authority; and
There have been no civil penalty enforcements in the twelve months prior to this violation.
8) The cost to the State of the enforcement procedures.
$116 62
Date
G. Landon Davidson, P.G., Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ

NPDES PERMIT NO.: NCO063321 PERNUT VERSION: 4 0
FACILITY NAME: TWSA Plant #3 �'-/-"CLASS: WW-2
OWNER NAME: Tuckaseigee Water & Sewer Authority ORC: Ben L Henson
GRADE: WW-4. ORC HAS CHANGED: No
eDMR PERIOD. 10-2016 (October 2016) VERSION 10
PERNIIT STATUS: Active
l ee,&
COUNTY: Jackson
ORC CERT NUMBER: 16864
STATUS: Processed
SAMPLING LOCATION: EFFLUENT DISCHARGE NO.: 001 NO ➢ ISCHARGE*: NO
h
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4
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a
9
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a
50050
00010
00400
50060
C0310
C0610
C0530
11616
10300
Continuous
5Xweek
Weekly
2Xwee
Weekly
Weekly
Weekly
Weekly
Weekly
Continuous
Grab
Grab
Grab
Composite
Composite
Composite
Grab
Grab
FLOW
TEMP-C
PH
CHLORINE
HOD -Cone
NH3-N-Cone
TSS-Cone
FCOLIHR
DO
2400 clock
Hrs
2400 clock
Hrs
YINN
mgd
deg c
su
u94
m
mg/1
cfi✓100ml
I119/1
1
1112
1
B
0 048
2
N
0 056
3
1100
4
Y
0 057
185
<20
4
1041
24
10930
4
Y
0046
189
62
<20
114
<05
138
<4
86
5
1000
4
Y
0 054
193
6
1000
4
Y
0 057
191
%
1000
4
Y
008
196
8
1100
1
B
009
9
N
007
10
1100
4
Y
007
189
< 20
11
1044
24
0930
4
Y
0054
183
69
<20
61
<05
85
<4
87
12
1000
4
Y
0 051
181
13
1000
4
Y
0 057
178
14
1000
4
Y
0 063
179
is
1345
2
B
0 072
16
N
0 061
17
1100
4
B
0 062
178
< 20
1s
1120
24
1000
4
B
0 072
181
65
<20
94
21
185
1350
85
19
1100
4
Y
0 066
185
20
1105
24
1000
4
Y
0 052
186
51
88
<4
21
1
1110 13
B
0 066
184
22
1031
1
B
0 061
23
N
0 055
24
1100
4
B
0 056
169
<20
25
1130
24
1100
4
B
0 047
164
66
<20
47
4 5
62
34900
9
26
1100
1000
4
B
0 053
165
270
27
1100
24
1030
6
B
0 059
16 4
34 1
26
66
210
28
1110
24
1015
6
B
0 055
167
266
50
75
29 11200
24 11015
14
B
10057
18 1
5 4
36
;1L63
30
1100
1
B
0 061
31
1424
24
1100
4
Y
0 055
184
13 6 115
16
Monthly AverageL—t
02
i5
2.2
30
200
Monthly Average
0060097
18 054545
0
19 855556
1783333
31066667
61519955
87
Daffy Ma:imnm
009
196
69
0
47
45
66
34900
9
Daily Mavmum
0 046 1164
162
0
51
0 18.5
10
85
****No Reporting Reason ENFRUSE=No Flow,,-Reuse/Recycle, ENVWTHR=No Visitation -Adverse Weather, NOFLOW=No Flow, HOLIDAY =NoVisitation -Holiday
<`� dv:�7

NPDES PERMIT NO.: NCO063321 PERMIT VERSION: 4 0
FACILITY NAME: TWSA Plant #3 CLASS: 'WW-2
OWNER NAME: Tuckaselgee Water & Sewer Authority ORC: Ben L Henson
GRADE: WW4 ORC HAS CHANGED: No
eDMR PERIOD: 10-2016 (October 2016) VERSION. 10
PERMIT STATUS: Active
COUNTY: Jackson
ORC CERT NUMBER: 16864
STATUS- Processed
SAMPLING LOCATION: EFFLUENT DISCHARGE NO.: 001 NO DISCHARGE*: NO (Continue)
g
f
u
E
�
E
=
a
C0600
C0665
81010
81011
Semi-annually
Semi-annually
Composite
Composite
Composite
Composite
TOTALN-Cone
TOTAL P-Cone
BODS-%R
TSS-%R
2400 clack
Hs
2400 clock
Mrs
Y/B/N
mg/1
mg/l
percent
percent
1
1112
1
B
2
N
3
1100
4
Y
4
1041
24
0930
4
Y
5
1000
4
Y
6
1000
4
Y
1
1000
4
Y
8
1100
1
B
9
N
10
1100
4
Y
11
1044
24
0930
4
Y
12
1000
4
Y
13
1000
4
Y
14
1000
4
Y
15
1345
2
B
16
N
17
1100
4
B
18
1120
24
1000
4
B
19
1100
4
Y
20
1105 124
1000 14
Y
21
1110
3
B
22
1031
1
B
23
N
24
1100
4
B
25 11130
24
1100
4
B
26
1100
1000 14
B
27
1100
24
1030
6
B
28
1110
24
1015
6
B
29
1200
24
1015
4
B
30
1100
1
B
31
1424 124
11100
14
Y
956
88 6
Monthly Avenge Luo&
Monthly Avenge
'
95 6
88 6
Daily Maiimum
.956
886
DadyMmlmum
1956
1886
**** No Reporting Reason ENFRUSE = No Flow-Reuse/Recycle, ENVWTHR=No Visitation— Adverse Weather, NOFLOW=No Flow, HOLIDAY =NoVisitation —Holiday

W
FACILITY NAME: TWSA Plant #3 CLASS: W -2 COUNTY: Jackson
OWNER NAME: Tuckaseigee Water & Sewer Authority ORC: Ben L Henson ORC CERT NUMBER:
GRADE: WW-4 ORC HAS CHANGED: No
eDMR PERIOD. 10-2016 (October 2016) VERSION: 10 STATUS. Processed
COMPLIANCE STATUS: Non -Compliant CONTACT PHONE #: [phone] SUBMISSION DATE: 11
ORC/Certifier Signature. Stan Bryson E-Mail:sbrysontwsa@frontier com Phone #,82
By this signature, I certify that this report is accurate and complete to the best of my knowledge
NPDES PERMIT NO.: NC0063321 PERMIT VERSION: 4 0 PERMIT STATUS: Actry
16864
/29/2016
11/29/2016
85869318 Date
The permittee shall report to the Director or the appropriate Regional Office any noncompliance that potentially threatens public health or the environment
Any information shall be provided orally within 24 hours from the time the permittee became aware of the circumstances A written submission shall also be
provided within 5 days of the time the permittee becomes aware of the circumstances
If the facility is noncompliant, please attach a list of corrective actions being taken and a time -table for improvements to be made as required by part II E 6 of
the NPDES permit
11/29/2016
Permittee/Submitter Signature.*** Stan Bryson E-Mail sbrysontwsa@frontier com Phone #.[phone] Date
Permittee Address 852 Cashiers Lk Rd Casluers NC 28717 Permit Expiration Date: 08/31/2017
I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed
to assure that qualified personnel properly gather and evaluate the information submitted Based on my inquiry of the person or persons who managed the
system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true,
accurate, and complete I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for
knowing violations
LAB NAME: TWSA Lab
CERTIFIED LAB #: 160
PERSON(s) COLLECTING SAMPLES: Operators/Staff
CERTIFIED LABORATORIES
PARAMETER CODES
Parameter Code assistance may be obtained by calling the NPDES Unit [phone] or by visiting http //portal ncdenr org/web/wq/swp/ps/npdes/forms
FOOTNOTES
Use only units of measurement designated in the reporting facility's NPDES permit for reporting data
* No Flow/Discharge From Site. Check this box if no discharge occurs and, as a result, there are no data to be entered for all of the parameters on the DMR
for entire monitoring period
** ORC on Site9. ORC must visit facility and document visitation of facility as required per 15A NCAC 8G .0204
*** Signature of Permittee If signed by other than the permittee, then delegation of the signatory authority must be on file with the state per 15A NCAC 2B
0506(b)(2)(D)

NPDES PERMIT NO.: NC0063321 PERMIT VERSION: 4 0 PERMIT STATUS: Active
FACILITY NAME: TWSA Plant #3 CLASS: W W-2 COUNTY: Jackson
OWNER NAME: Tuckaseigee Water & Sewer Authority ORC: Ben L Henson ORC CERT NUMBER: 16864
GRADE: WW-4 ORC HAS CHANGED: No
eDMR PERIOD- 10-2016 (October 2016) 'VERSION 10 STATUS: Processed
Report Comments:
Colder temperatures caused coagulation of greases and oils in the Influent to the facility This led to carryover of fine solids over the effluent weir These solids adversely
impacted Effluent water quality and resulted in violations of some permitted parameters The addition of lure and polymers has resulted in compliant Effluent analysis but did not
result in compliance with permitted levels for some weekly and monthly parameters

Cam)
TUCKASEIGEE WATER & SEWER AUTHORITY
SERVING JACKSON COUNTY
1246 West Main Street
Sylva, NC 28779
Phone: [phone] ® Fax- (828) 63
April 28th, 2017
NCDEQ/ARO
Div. of Water Resources
Attn: G. Landon Davidson
2090 US 70 Hwy
Swannanoa, NC 28778
Subject: Response to NOV-2017-LV-0262
Permit # NCO063321
TWSA Plant #3 (Cashiers WWTP)
Jackson County
Dear Mr. Davidson
bmRECEIVED
sion of Water Resources
MAY -- 8 2017
Water Ouality Regional Operations
Asheville Regional Office
The Tuckaseigee Water and Sewer Authority has reviewed at length the circumstances
surrounding the NPDES permit violations that occurred during the month of October 2016.
Based on historical records and the operator's field observations, the evidence indicates that as
the water and air temperatures cool in the fall and to a lesser extent again as it starts to warm in
the spring, the TWSA Plant #3 experiences recurring upsets to the biological process and
changes to the content of the influent. These upsets are in my opinion, related to the amount of
grease that is emulsified into the influent to the WWTP. Due to the relatively small residential
customer base and the high number of seasonal restaurants and businesses tributary to the
system, the facility has always experienced a high organic loading.
This emulsified grease is difficult to treat with the conventional activated sludge process
utilized at this facility. The grease does not completely break down in the treatment process
and the residual solids are extremely small and fine in nature. This results in an effluent that is
relatively clear but the fine solids clog filters and the emulsified grease creates an oxygen
demand that results in permit violations.
To address this problem we've identified the following avenues to be pursued; identification
and elimination of source, public education on FOG program and increased vigilance on
Grease Trap / Interceptor maintenance, optimization of current plant processes to meet permit
requirements when grease loading occurs and identification of engineered options to address
the problem if necessary.

WWI? and Collection System operators have attempted to identify and eliminate the source in
the system when the problem was identified in the fall 2016 without success. Plant operators
made process changes such as more frequent cleaning of filters and beginning to add lime to
the process on a daily basis to help with biological activity. This has helped to increase the
bacteria's ability to breakdown the grease emulsified in the influent. Other process changes
have included the addition of polymers during times of upsets which has also proven to
improve the settleability of these solids in the treatment process, resulting in a clearer effluent
and permit compliance.
Going forward, the TWSA collection system staff has committed to a more aggressive
maintenance schedule of the collection system lines before these problems occur. This
heightened schedule will be undertaken in addition to an informational notice to customers in
their monthly billing along with the FOG protocols already in place. Plant Operators will be
more vigilant in their plant operations as we approach these seasonal timeframes, looking for
signs of any changes to the influent stream and beginning to make changes to chemical
additions and filter maintenance frequency as appropriate. TWSA Staff is also requesting
funds for FY 2017-18 to obtain the professional services of a consultant familiar with the
treatment of wastewater from this unique blend of commercial/residential users to identify
other options.
We are confident that these measures address those things that are in our control and if we
continue to implement them as planned they should mitigate the impact of this seasonal
change to the influent stream and prevent a reoccurrence of permit violations. We do request
consideration of our responses to this problem as you review this matter and determine any
further actions to be taken by your agency under this Notice of Violation.
Please contact me with any questions or comments.
Sincer ly,
Stan Bryson
Wastewater Plant Operations Superintendent
Tuckaseigee Water and Sewer Authority
xc: Mr. Ben Henson, ORC, TWSA Plant #3
Mr Dan Harbaugh, Executive Director, TWSA