NC0023736_NOV-2018-PC-0193 Response_20180613

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Public Utilities Lower Creek Wastewater Treatment
PO BOX 958 Elisa Triplett,Superintendent
Lenoir, NC 28645 [e-mail]
[phone]
June 13, 2018
Deborah Gore, PERCS Unit Supervisor
Division of Water Resources
Department of Environmental Quality RECEIVEDIDENWDWR
1617 Mail Service Center JUN 18 2018
Raleigh, NC 27699-1617
Water Resources
Permitting Section
Subject: NOTICE OF VIOLATION TRACKING 3 NOV-2018-PC-0193, Permit NC0023736 Failure to inspect SIU's
Dear Ms. Gore:
This letter is in response to the Notice of Violation letter dated June 12, 2018. Please allow this letter to
function as a response to address the issue.
The City of Lenoir Pretreatment program has been cited for not meeting the minimum requirements,
specifically the City failed to conduct the annual inspections for the three SIU's in the program.
As I have discussed before, I am very new to the position of wastewater plant Superintendent which includes
being responsible for the all of the various State required programs for wastewater treatment facilities. For
the last year and a half I have been trying to learn all the details of the pretreatment program which requires
lots of organization and remembering all the requirements.
As the plant Superintendent along with trying to learn and implement all the required elements for the
Pretreatment program, I also have the responsibility of maintaining and learning and implementing the
requirements of the State and EPA Residuals program, Head-works analysis, PAR, eDMR's, Lower Creek and
Gunpowder Creek plant permit renewals, daily plant operations, manage the lab, and I am also training a lab
technician/lab supervisor. So as you can see there are many aspects that I am still learning the requirements
of.
The 5 year SIU permit renewals were due in December 2017, with much help from you, Linda Wiggs, and
Vivien Zhong, I spent many days and hours working on getting the required documents from the industries

and getting the permits written. The permits were finally signed on June 12, 2018 which was 6 months past
the expiration date or the previous permits.
There was a pretreatment compliance schedule conducted on July 31, 2017 at which time it was discussed the
need to inspect the SIU's. A follow-up technical assistance visit was also made on September 22, 2017 at
which time you came to help get the pretreatment files in order, and it was mentioned again about
inspections. With all being stated here in this letter,the inspections requirement for the SIU's was simply
missed.
To address and remedy the situation I would like to say that we are scheduling those inspections this week,
and should be able to conduct them in the next two to three weeks, definitely before the due date of July 24th,
2018 which you have graciously extended to the City of Lenoir. We have also implemented using a reminder
for annual inspections on our work calendars.
Thank you for all the help and advice that was given to me during this difficult transition and learning phase.
Elisa Triplett, Superintendent