NC0045471_NOD-2018-PC-0311 Response_20181120

November 14, 2018
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
Subject: NOTICE OF DEFICIENCY
Mr. Basinger,
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V,OORMILLE REGIONAL OFFICE
Tracking number: NOD-2018-PC-0311
Permit No. NCO045471
Barium Springs Home for Children W WTP
Iredell County
Thank you for allowing the Barium Springs Home for Children W WTP an opportunity to
respond to the Notice of Deficiency issued 5 November 2018 by the Division of Water
Resources. This letter is our response to the failure to provide proper operations and
maintenance, failure to properly collect effluent pH and dissolved oxygen samples, and failure to
designate an Operator in Responsible Charge within 120 days.
The failure to provide proper operations and maintenance was noted due to a caustic soda drip
into the contact chamber for pH adjustment. Because the Imhoff tank was not dosing, the caustic
soda caused the pH to be excessively high on the day of the inspection. This was immediately
corrected by pumping the contents of the contact chamber back onto the sand filter. This action
resulted in a pH that was well within the permitted 6-9 SU range. In order for a long-term
solution to be reached for this issue, the staff at Barium Springs is working with Envirolink
operators to implement a chemical feed pump that will pump caustic soda into the contact
chamber for pH adjustment only when the Imhoff tank doses so that chemical is only added
when it is needed.

The failure to properly collect effluent pH and dissolved oxygen was a result of the operator
taking a sample before dechlorination rather than at the actual plant effluent, after all chemical
treatment occurred. This matter was discovered through the course of the inspection and has
been corrected from that point going forward because the operator }mows the correct location for
the pulling of effluent samples.
The failure to designate an Operator in Responsible Charge within 120 days of vacating occurred
when the proper form was filled out but not submitted to DEQ following the previous O.R.C.
terminating her employment with Envirolink. Shortly after she left her position for other
employment opportunities, the Envirolink Area Manager vacated his position as well. With both
of these employees gone, the operator that was to be designated was under the assumption that
he was indeed the Operator in Responsible Charge for this facility. Mr. Bell brought to our
attention in the inspection that the former O.R.C. had not relinquished her position there. To
right this wrong, an O.R.C. designation form has been filled out and will be submitted to DEQ,
pending the signature from the owner.
We believe that the Barium Springs Home for Children wastewater treatment plant is being run
in an ethical and responsible manner, and the staff members operating it are doing so in a manner
according to rules and regulations set forth by governing authorities. The deficiencies at hand
described above resulted from inadvertent mistakes, and corrective action is being taken in order
to prevent them from recurring. As a result, it is our request that the Division of Water Resources
take into consideration our honesty in this matter as well as the steps taken to ensure that future
infractions do not occur when determining enforcement action on this Notice of Deficiency.
Sincerely,
Barium Springs Home for Children W WTP

CC: Mike Myers, Envirolink
Heather Adams, Envirolink
Chris Bitterman, Envirolink