NC0021881_NOV-2019-LV-0221 Response_20190408

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Municipalities
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Subject: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
NOV Tracking No. NOV-2019-LV-0221
NPDES Permit No. NBC O021881
Lake Waccamaw WWTP
Columbus County
Please accept this letter as acknowledgement of and reply to your Notice of Violation & Intent to
Issue Civil Penalty labeled NOV-2019-LAP-0221.
As you know, we have been having problems with our Clarifier since 12/17/18. Both the
upper and the lower bearing in the shaft operating the Clarifier sweeps had to be replaced and parts
had to be found to rebuild the gear box. Our Clarifier was originally installed in 1972 and parts were
very hard to find. The Clarifier was down for about ten weeks,
When the Clarifier went out of service, we immediately diverted the flow from the Aeration
Basin around the Clarifier to the first Polishing Pond, The Clarifier was then drained and inspected
by Charles R. Underwood, Inc,, the problem was identified and a search for parts began.
While the search for parts continued, effluent from the Aeration Basin continued to be
diverted to the first Polishing Pond, Sludge was accumulating in the Pond and, in an effort to avoid
#!UiLjti raw sewage into the Swampwe-c=n acted McGill Costin- and them bepan
sludge out of the Polishing Pond and taking it to a composting facility for processing. This
continued until the Clarifier was back online and as much sludge as possible was removed from the
Polishing Pond.

Once the Clarifier was online, seeding the Aeration Basin began. Over the next three weeks,
between 40,000 and 50,000 gallons of wastewater was brought in from the Whiteville WWTP. This
wastewater contained sludge with healthy bacteria needed in the Activated Sludge process. The
reseeding was slow but seems to have been successful. The results from the last set of samples sent
to the lab indicate that we are back in compliance with our permit limits.
There is no doubt that being out of compliance in so many parameters for such a long period
of time is a very serious matter. However, equipment does fail and limits are exceeded. In this
case, everything that could be done to prevent a spill of virtually raw sewage and to keep permit
violations to a minimum was done. Cost must also be taken into consideration, Parts & Labor to
repair the Clarifier — approximately $10,000, Cost to remove sludge and clean out the Polishing
Pond — approximately $50,000 and that is not including the number of hours put in by Town Staff in
an effort to control the problem.
Please take the above into consideration when assessing the need for a Civil Penalty, If you
have any questions, please feel free to call me.
Sincerely,
r (
Gordon Hargrove
Manager, Town of Lake Waccamaw