NC0060526_Response to Notice_20230112

COMMERCIAL REALTORS"
January 12, 2023
Ms. Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Subject: Notice of Violation and Assessment of Civil Penalty
Tracking Number: NOV-2022-LM-0083
Permit No. NCO060526
Pope Industrial Park
Wake County
Mr. Manuel,
Thank you for allowing the Pope Industrial Park the opportunity to respond to this Notice of Violation
issued November 23, 2022; received on January 05, 2023, for the Monitoring Violation, and the Limit
Exceedance Violation during the September 2022 monitoring period. Our first response corresponds to
the Monitoring Violation.
The violation was as follows:
Monitoring Violation(s):
Sample
Parameter
Location
001 Effluent
001 Effluent
001 Effluent
BOD, 5-Day (20 Deg. C) — Concentration
Date
9-3-2022
Coliform, Fecal MF, MFC Broth, 44.5 C 9_3-2022
_ (31616)
Nitrogen, Ammonia Total (as N) -
Concentration
001 Effluent Solids, Total Suspended —Concentration
(C0530)
9-3-2022
9-3-2022
Monitoring
Weekly
Weekly
Weekly
Weekly
Type of Violation
Frequency Violation
Frequency Violation
Frequency Violation
Frequency Violation
The sampling for BOD, TSS, Ammonia, and Fecal Coliform is performed by the ORC on Tuesdays or
Wednesday, and the September period start on Thursday, so the information for the first week should
have appeared on the August period. Examining the reports it was noticed that the August period did not
showed the results for the last week, and it was because the results were not received, we want to
mention that on the bench sheets the ORC wrote down that the sampling was taken the Wednesday
P. O. BOX 97215
RALEIGH, NORTH CAROLINA 27624
919-846-3500

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August 31, 2022, we requested the Lab the report, and it has been received showing a BOD value of 3.3
mg/L, TSS = <2.6 mg/L, Nitrogen Ammonia = 0.7 mg/L, and Fecal Coliform = <1 CFU/ 100 ml, all of these
are compliant values for the Daily Maximum Limit established on the Permit.
With this new information, the August report has been Revised, Validated and Submitted, in order to
amend the Issue. This update, attend the frequency violation that was described above. We have attached
the Lab result and as evidence.
Limit Exceedance Violations
Sample
Parameter
Date
Limit
Reported
Type of Violation
Location
Value
Value
001 Effluent
BOD, 5-Day (20 Deg. C) —
9/13/2022
7.5
19.4
Daily Maximum
Concentration (C0310)
Exceeded
001 Effluent
Coliform, Fecal MF, MFC Broth,
9/27/2022
400
405
Daily Maximum
44.5 C (31616)
Exceeded
001 Effluent
BOD, 5-Day (20 Deg. C) —
9/30/2022
5
7.4
Monthly Average
Concentration (C0310)
Exceeded
The personnel at the facility have detected that during the weekends the recorded flow shows an
increased volume, and it is considered as the possible cause of the irregular and elevated fluctuations on
the system. So, the reported value of 19.4 mg/L, when the personnel were notified on Monday September
26, regarding this high result, the sample for September 20th was already taken, and evidently the BOD
got back to its normal parameter, however this high value already caused the Monthly Average
Exceedance, no matter all the previous and subsequent registered values were compliant.
Regarding the Fecal Coliform exceedance reported on August 27, when notified the personnel took a new
sample on September 30 to verify if the system was not in compliance, and it resulted on a value of <1
CFU/100 ml, so we consider that the elevated value could result from an incorrect sample handling,
because the Residual Chlorine values reported twice a week are obtained after the dichlorination process,
and these have been maintained constant.
Before receiving this Notice of Violation, the personnel at the facility started an investigation that has
continued through several months to determine if the system shows possible sites of entry, so all the
Manholes have been monitored weekly and there have not been identified vulnerabilities, right now the
aspects that can prevent the increase of the flow on the weekends.
Some of the corrective actions done to the system are:
The replacement of 14 leaking flappers in toilets throughout the entire industrial park, done on
December 01, 2022.
The implementation of a digital chart recorder on the meter to help determine what is causing
the increase in the flow and the BOD.
It is our request that the Division take into consideration the inaccuracies in the Notice of Violation and
the immediate corrective actions taken by the permittee when deciding whether further enforcement
actions are warranted.
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Sincerely,
A".A - C'. .
Albert E Finley,
Pope Industrial Park II Ltd Partnership
CC:
Tracy Miller, Envirolink, Inc.
William Lamm, Envirolink, Inc
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