NC0003816_NOD-2019-LV-0128 AND 0129 Response_20190918

UNITED STATES MARINE CORPS
MARINE CORPS AIR STATION
POSTAL SERVICE CENTER 8003
CHERRY POINT, NORTH CAROLINA 28533-0003
IN REPLY REFER TO:
5090/07101
LN
Sep 18, 2019
Mr. Robert Tankard
North Carolina Department of
Environment Quality
Division of Water Resources
943 Washington Square Mall
Washington, NC 27889 a1�A
9i c O
Dear Mr. Tankard: o,J�a
Marine Corps Air Station (MCAS) Cherry Point (Permit NC0003816)
submits the following in response to the NOTICE OF DEFICIENCY (NOD)
letters with tracking numbers NOD-2019-LV-0128 and NOD-2019-LV-0129
dated September 10, 2019.
G�
The NODS were issued for exceeding daily maximum limits
established in the permit for various parameters over multiple days
from June 30, 2019 to July 24, 2019.
MCAS Cherry Point has been in open communication with your
office to try and determine a root cause of the elevated enterococci
and exceedances. On July 19, 2019, Mr. Robbie Bullock of your office
conducted a Technical Assistance Visit at our request to help find
the cause of the periodic violations. At that time, we were operating
our UV system at 100 percent and dosing chlorine for added
disinfection to keep the enterococci below exceedance levels. Our
Operator in Responsible Charge (ORC) was also chlorinating the
effluent line and the reclaim water storage tank in an effort to
remove any regrowth that was occurring.
During this time, it was determined that a faulty valve from the
reclaimed water storage tank was malfunctioning and allowing water
from the tank to reenter the post aeration basin. This was
introducing enterococci that was present in the storage tank to the
basin where the final effluent sampling is collected. The faulty
valve has been replaced and a project to clean the storage tank has
been programmed. While the replacement of the faulty valve reduced
the enterococci levels to non-exceedances, our treatment plant is
still experiencing higher than normal enterococci readings.
As a result of the high enterococci readings, we were adding
chlorine for supplemental disinfection. Unfortunately, this led to
several exceedances of total residual chlorine (TRC) in our effluent.
We have stopped dosing chlorine as our system does not have the

ability to dechlorinate based on the flow pacing. We are working to
modify or upgrade our system to allow for this adjustment so that our
backup disinfection system is better suited to maintain permit
parameters.
MCAS Cherry Point is currently experiencing a reduction in the
number of personnel and processes that have decreased the influent
flow to the wastewater treatment plant. This reduction is related to
the inbound F-35 squadrons which require demobilization of staff and
equipment and new infrastructure to be built. This reduction of flow
could be a contributing factor to the recurring enterococci issues as
the waste stream is less diluted than in previous years. The
engineering design firm that designed the ultraviolet (UV)
disinfection system (as well as the recent upgrades to the treatment
plant) is currently evaluating the system.
These efforts have clearly yielded some improvements through
adjustment of the UV system operating parameters. Our highest daily
enterococci reading has been 133 per 100 milliliter (mL). This is
below the permitted effluent daily maximum of 276 per 100 mL. The
average enterococci has been 20 per 100 mL which is below the
permitted effluent monthly average of 35 per 100 mL.
Upon the receipt of the engineering design firm's evaluation, we
will openly communicate with your office the results as well as any
recommendations for further actions. If you wish to discuss this
matter further, please contact Mr. Timothy Lawrence, PE of the
Environmental Affairs Department at [phone] at your earliest
convenience.
Sincerely,
C. E. SCHULZ
Deputy Facilities Director
By direction of the
Commanding Officer
2

ROY COOPER
cavfn,ar
MICHAEL S. REGAN
SerrMary
LINDA CULPEPPER
Drrfelor
NORTH CAROLINA
Environmental Quality
September 10, 2019
George W Radford, Affairs Environmental Officer
US MCAS Cherry Point
Psc Box 8006
Cherry Point, NC 28533-0006
SUBJECT: NOTICE OF DEFICIENCY
Tracking Number: NOD-2019-LV-0128
Permit No. NC0003816
Cherry Point WWTP
Craven County
Dear Mr. Radford:
A review of the June 2019 Discharge Monitoring Report (DMR) for the subject facility revealed the deficiency(s)
indicated below:
Limit Exceedance Deficiency(s):
Sample Limit Reported
Location Parameter Date Value Value Type of Deficiency
001 Effluent Enterococci (61211) 6/30/2019 35 43.75 Monthly Geometric Mean Exceeded
Please be aware that non-compliance with your permit could result in enforcement action by the Division of
Water Resources for these and any additional violations of State law. The Washington Regional Office
encourages you to take all necessary actions to bring your facility into compliance.
If you should need any assistance or would like to discuss this non-compliance situation, please contact Robbie
Bullock of the Washington Regional Office at 252-946-6481.
Cc: Laserfiche
Sincerely,
Ra" Tas.lw►.l
Robert Tankard, Assistant Regional Supervisor
Water Quality Regional Operations Section
Washington Regional Office
Division of Water Resources, NCDEQ
North Grona Dapartmant of Envaaa�aantas ¢vaty i Devaian of Water Raaouroaa
WaWnjloaRttana;M* i 943Wasbsrtloa8quw*MiMs i Waahmgtw, Norr-Gro;ra 27888

ROY COOPER
Co"Mor
MICHAEL S. REGAN
Serwarp
LINDA CULPEPPER
D$Wtor
NORTH CAROLINA
Environmental Qualtry
September 10, 2019
George W Radford, Affairs Environmental Officer
US MCAS Cherry Point
Psc Box 8006
Cherry Point, NC 28533-0006
SUBJECT: NOTICE OF DEFICIENCY
Tracking Number: NOD-2019-LV-0129
Permit No. NC0003816
Cherry Point WWTP
Craven County
Dear Mr. Radford:
A review of the July 2019 Discharge Monitoring Report (DMR) for the
subject facility
revealed the deficiency(s)
indicated below:
Limit Exceedance Deficiency(s):
Sample
Limit
Reported
Location Parameter
Date
Value
Value
Type of Deficiency
001 Effluent Chlorine, Total Residual
7/3/2019
28
50
Daily Maximum Exceeded
(50060)
001 Effluent Chlorine, Total Residual
7/8/2019
28
66
Daily Maximum Exceeded
(50060)
001 Effluent Enterococci (61211)
7/11/2019
276
344
Daily Maximum Exceeded
001 Effluent Chlorine, Total Residual
7/17/2019
28
188
Daily Maximum Exceeded
(50060)
001 Effluent Chlorine, Total Residual
7/24/2019
28
65
Daily Maximum Exceeded
(50060)
,:<D North I Matson of Water Reswrees
.--'—W—Q-3' Washvnjwa Regatta; Office 1943 Wasb,rgton Squat* Mass I Wash r�gwn, North Caro ina 27989
-- 252-946-6"1

i
Please be aware that non-compliance with your permit could result in enforcement action by the Division of
Water Resources for these and any additional violations of State law. The Washington Regional Office
encourages you to take all necessary actions to bring your facility into compliance.
If you should need any assistance or would like to discuss this non-compliance situation, please contact Robbie
Bullock of the Washington Regional Office at 252-946-6481.
Sincerely,
Robert Tankard, Assistant Regional Supervisor
Water Quality Regional Operations Section
Washington Regional Office
Division of Water Resources, NCDEQ
Cc: Laser -fiche
�D Norm Caw;na Depsttnent of Eneionnent*iQm"y I D+ isoo of Water Resources
Wash:ajtoa Regan#' Moe I fM43 Washmtlon Square Mena I Wash mpon, flarth Cawwna 27889
252b48$l81