WQ0002829_NOV-2019-LV-0215-0218 & 0350 0389 0350 0506 0591 AND 0104 Response_20190926

Enviro-Tech
William G. Freed, Inc.
PO Box 69
Harbinger, NC 27941-0069
Robert Tankard
Environmental Resources, Water Quality
Washington Regional Office
943 Washington Square Mall
Washington, NC 27889
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Teleph4dQfi 77
Fax (25�'%,
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September 26, 2019
The following is in response to Notices Of Violation NOV-2019-LV- 215,216,217,218,350,389.,506, 591
as well as assessment for NOV-2019-LV-104. This response is prepared by the operator on behalf of the
ownership of KDHWWTP, LLC with their consent and knowledge.
Background, the permitee requested a permit modification after recognizing a trend of elevated Nitrate
levels in some of the monitoring wells. After some wrangling, a permit was issued in July of 2017. It
wasn't a seamless permit but we were tired of the battle just to correct any problem that we had identified.
The new permit contains a few issues; 1) Phosphorus limit was added to the permit for no apparent reason
2) the flow reporting and tracking didn't make any sense 3) the permit did not have any language about
phasing in or taking effect once improvements were made, however at that point we were tired of the
battle, we accepted the permit issued and I figured one day we would have to straighten it out and so here
we are.
The attached spreadsheet I believe summarizes all of the violations that I am aware of to date. There are
11 NOVs listed with 36 specific data points of concern within those 11 NOVs.
Of the 36 data points of concern, 16 are the result of the new permit being enforced prior to any plant
modifications necessary and listed in the permit being accomplished.
Of the 36 data points of concern, 1 is a clerical reporting error on the part of the operator. Mistake no
doubt, but certainly nothing that meets the criteria listed for concideration to assess civil penalties.
Of the 36 data points of concern, 3 are for reporting flow. They were a result of flow reporting changes
that make no sense. We are now aware of how to manage the reporting so it doesn't throw any red flags,
but it still doesn't make sense and again none of the criteria needed to justify civil penalties were met.
Of the 36 data points of concern, 4 are clerical errors on the part of the person writing the NOV. Ref. Jan
30, 2019 below.
Of the 36 data points of concern, 2 are for the same event. The interpretation of the reporting system
would allow someone to see one sample as two violations but it's the same sample reported in two
different places, the sampling event only happened once. Ref. April, May 2019.
Of the 36 data points of concern, 1 is for the Monitoring well exceedance. The purpose of the plant
modifications is to reduce the nitrate going into the ground.

The following is a listing of NOVs and a brief explanation of each:
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NO V-2019-L V-215, Issued March 26, 2019 for the DMR for the month of July 2018. d'
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Violation Date Sample Location Contaminent limit Daily exceedence Monthly Average Exceedence NOV Number
July 312018 2 Total Nitrogen 7 20.91 NOV-2019-LV-215
July 312018 2 Phosphorus 3 5.72 NOV-2019-LV-215
July 242018 3 TSS 10 14.9 NOV-2019-LV-215
July 312018 3 TSS 5 7.2 NOV-2019-LV-215
July 312018 3 Flow Missing NOV-2019-LV-215
Total Nitrogen and Total Phosphorus reduction are beyond the capability of the plant during this reporting
period.
Concerning the TSS violation. The underdrain of the Tertiary filters failed and had to be rebuilt, the
Tertiary filters were bypassed the third week of July to facilitate repairs. The cost of repairs was in excess
of $10,000. The following months to date, the filters have performed well and there have been no repeat
violations.
Concerning the Flow Violation. The NOV states Flow IN Conduit missing PPI 02. The operator and I as
his oversite missed this discrepancy, a replacement report is being prepared and will be submitted within
10 days.
NOV-2019-LV-216Issued March, 26 2019 for the month ofAuzust 2018.
Violation Date Sample Location Contaminent limit Daily exceedence Monthly Average Exceedence NOV Number
August 312018 2 Total Nitrogen 7 14.12 NOV-2019-LV-216
August 312018 2 Phosphorus 3 5.34 NOV-2019-LV-216
August 312018 5 Flow 215,456 240,000 NOV-2016_LV-216
Total Nitrogen and Total Phosphorus reduction are beyond the capability of the plant during this reporting
period.
The reported 240,000 gallons is the estimated irrigation water applied to the irrigation areas as reported
by the ground's keepers, this estimated quantity is well in excess of the actual water sent to PPI-005.
There has been substantial confusion over the years as to how irrigation water is to be reported. It would
be helpful if a detailed written directive were developed by the permit writers explaining how the data
needs to be collected and submitted so it meets the intent of the permit. Understanding that as I write this
response a full 14 months later, we have a better understanding of what is expected although the detailed
written directive would be helpful.
NOV-2019-LV-217 issued March 26, 2019 for the month of September 2018
Violation Date Sample Location Contaminent limit Daily exceedence Monthly Average Exceedence NOV Number
September302018 2 Total Nitrogen 7 31 NOV-2019-LV-217
September302018 2 Phosphorus 3 13.62 NOV-2019-LV-217
September302018 5 Flow 215,456 240,000 NOV-2019-LV-217
Total Nitrogen and Total Phosphorus reduction are beyond the capability of the plant during this reporting
period.

The reported 240,000 gallons is the estimated irrigation water applied to the irrigation areas as reported
by the ground's keepers, this estimated quantity is well in excess of the actual water sent to PPI-005.
There has been substantial confusion over the years as to how irrigation water is to be reported. It would
be helpful if a detailed written directive were developed by the permit writers explaining how the data �©
needs to be collected and submitted so it meets the intent of the permit. Understanding that as I is 2�
response a full 14 months later, we have a better understanding of what is expected although the ds
written directive would be helpful. o�°:o` O 2
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NO V-2019-L V-218 Issued March 26, 2019 for the month of October 2018
61
Violation Date Sample Location Contaminent limit Dailyexceedence Monthly Average NOV Number
October312018 2 Total Nitrogen 7 12.85 NOV-2019OLV-218
October312018 5 Flow 215,456 240000 NOV-2019OLV-218
Total Nitrogen reduction is beyond the capability of the plant during this reporting period.
The reported 240,000 gallons is the estimated irrigation water applied to the irrigation areas as reported
by the ground's keepers, this estimated quantity is well in excess of the actual water sent to PPI-005.
There has been substantial confusion over the years as to how irrigation water is to be reported. It would
be helpful if a detailed written directive were developed by the permit writers explaining how the data
needs to be collected and submitted so it meets the intent of the permit. Understanding that as I write this
response a full 14 months later, we have a better understanding of what is expected although the detailed
written directive would be helpful.
NO V-2019-L V-220 Issued March 26, 2019 for the month of November 2018
November 30 2018 2 Total Nitrogen
November 30 2018 2 Phosphorus
9.6 NOV-2019-LV-220
4.4 NOV-2019-LV-220
Total Nitrogen and Total Phosphorus reduction are beyond the capability of the plant during this reporting
period.
NO V-2019-L V-222 Issued March 26, 2019 for the month of December 2018
December 30 2018 2 Total Nitrogen
December 302018 2 Phosphorus
13.5 NOV-2019-LV-222
3.58 NOV-2019-LV-222
Total Nitrogen and Total Phosphorus reduction are beyond the capability of the plant during this reporting
period.
NO V-2019-L V-218 Issued March 26. 2019 for the month of December 2018
January 30 2019
Field
Missing
NOD-2019-PC-0073
January 302019
Field 1 B
Missing
NOD-2019-PC-0073
January 302019
Field 3
Missing
NOD-2019-PC-0073
January 302019
Field 1A
Missing
NOD-2019-PC-0073
January312019
Total Nitrogen 7
9.5NOV-2019-LV-350
Total Nitrogen reduction is beyond the capability of the plant during this reporting period.
I have reviewed the report as sent and the referenced "missing" data was in fact reported unless maybe
one page of that stapled 10 page report got misplaced, a copy is attached to this report.

NO V-2019-L V-389 Issued June 7. 2019 for the month ofFebruary 2019
February 282019 2 Total Nitrogen 7 8.9 NOV-2019-LV-389
Total Nitrogen reduction is beyond the capability of the plant during this reporting period. )
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NO V-2019-L V-506 Issued July 24, 2019 for the month of March 2019 _� o o c�
March 312019 2 Total Nitrogen 7 9.15 NOV-201k@/&6
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Total Nitrogen reduction is beyond the capability of the plant during this reporting period.` `� 9
NOV-2019-LV-59O Issued August 9. 2019 for the month ofAP 12019
April 302019
2 Ammonia
4
6.6 NOV-2019-LV-590
April 302019
2 Total Nitrogen
7
19.2 NOV-2019-LV-590
April 302019
2 Phosphorus
3
3.42 NOV-2019-LV-590
April 23 2019
3 Ammonia
6 13.2
NOV-2019-LV-590
April 302019
3 Ammonia
4
6.6 NOV-2019-LV-590
April 302019 CW-C
Nitrate
10 16.1
NOV-2019-LV-590
Total Nitrogen and Total Phosphorus reduction are beyond the capability of the plant during this reporting
period.
Concerning the Ammonia violations. There was one high Ammonia sample on the 23' as noted, this one
sample at 13.2 ppm was high enough to exceed the daily high and monthly average. The same sample that
caused the daily high and monthly average exceedance was double counted as a violation for PPI2 and
PP13. This is either incorrect or the way violations are accounted for needs to be reviewed and corrected.
It is not reasonable to be fined for multiple discharge points. The high Ammonia sample is the result of
high flow over the Easter Weekend, while other parameters adjusted well it is really not possible to
increase flow rapidly without some Ammonia bleed through. Had we known the exceedance was coming
or if the exceedance happened earlier in the month, we could have pulled more samples and averaged out
the monthly number. It wouldn't have changed anything other than making a better number.
The nitrate in Monitoring well is noted, permitted modifications to the plant will be implemented within
the next 6 months which will remove the source of Nitrates.
NOV-2019-LV-59O Issued August 9th 2019 for the month ofMav 2019
Violation Date
Sample Location Contaminent limit
Daily exceedence Monthly Average Exceedence NOV Number
May 312019
2 Ammonia
4
7.46 NOV-2019-LV-591
May 312019
2 Total Nitrogen
7
15.64 NOV-2019-LV-591
May 8 2019
3 Ammonia
6
11.4 NOV-2019-LV-591
May 16 2019
2 Ammonia
6
8.7 NOV-2019-LV-591
May 22 2019
3 Ammonia
6
13.9 NOV-2019-LV-591
Mayl 302019
3 Ammonia
4
7.46 NOV-2019-LV-591
Total Nitrogen and Total Phosphorus reduction are beyond the capability of the plant during this reporting
period.
On May 7ch one of the aeration diffusers blew out which allowed most of the air to be dumped through the
one ruptured diffuser. When the blowers cycled the mixed liquor would fill the aeration grid and
progressively fouled several diffusers, the entire 300,000 gallons of aeration tank contents had to be
removed by decanting, pushing through the online component or wasting. Once the aeration tank was
empty, repairs were accomplished and the aeration tank was put back on line. Starting a plant in mid -May
at a beach resort after losing half the mixed liquor does require some recovery time. We did look at
buying bugs to add and speed up recovery however, considering shipping time and even accelerated grow

in time, buying bugs would not have changed the outcome dramatically. The monthly Ammonia average
of 7.46 for PPI 002 and 7.46 for PPI 003 are the same sample, this is a double jeopardy thing.
Although the plant will be capable of reducing Phosphorus, I believe the Phosphorus limit was w
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inadvertently stuck in there because it's what permit writers are used to seeing. The Phosphorus Will rf)
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should be removed from the permit and the Phosphorus violations should be waived without qu&41F -°
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The ownership of KDHWWTP, LLC has entered into a contract with Enviro-Tech Unlimted Con%t&*n
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Services to construct improvements as outlined in the permit necessary to convert the process to a ge o
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Bardenpho process. The first stage of the project is to convert one half of the plant in time for seagw�t
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flows in 2020. Our plan is to have all improvements of the first half complete by April 2020 allowUig
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operations staff time to get the process lined out before seasonal flows.
We are currently working through submittals and ordering equipment, some of the components have
excessively long lead times. Work will begin on site in October. The initial work will be to tune up the
South aeration system to make sure when the process is moved to that tank operations will not have any
problems while improvements are being made in the North tanks.
Major components are expected to arrive in March 2020 and will be installed immediately upon arrival.
The cost of this first stage of improvements is expected to be in the range of $500,000.
The operations staff and the ownership of KDHWWTP, LLC remain committed to providing an excellent
service to the community while protecting the environment, it is however a bit frustrating to have to spend
hours upon hours responding to enforcement actions because other people in the process have no grasp of
reality; the people who are supposed to be our partners in protecting the environment.
The individuals involved in the permit writing process in Raleigh were so incompetent and arrogant that
communication devolved to operations withdrawing from the process and just accepting and doing the
best we could with whatever was handed down. Now as always the local people that actually make the
whole process create a positive result have to get together clean it up and make it work.
I look forward to your response.
Regards,
Bill Freed