NC0024236_NOV-2023-LV-0267_20230419

Kinston
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Buildings & Grounds, Business Office, Electric, Engineering, Environmental Services, 2009
Fleet Maintenance, Meter Reading, Stormwater, Streets, Wastewater, and Water
Kinston, the right place ... Kinston Public Services, the right choice.
April 19, 2023
NC DWQ-Washington Regional Office
Attn: Robert Bullock
943 Washington Square Mall
Washington, NC 27889
Re: Notice of Violation & Intent to Assess Civil Penalty Response from the City of Kinston
Tracking Number: NOV-2023-LV-0267
Dear Mr.Bullock:
The City has received a Notice of Violation and Intent to Assess Civil Penalty from the Division of
Water Resources, NCDEQ dated April 13, 2023. Based on that NOV, the City requests that the
Division consider this response letter in regards to the violation that occurred on February 18`h and 28th.
On February 12, 2023, the City of Kinston had to bypass part of its treatment process (the
denitrification filters).
Flows had been increasing prior to the bypass and they finally began to effect plant operations. All
basins remained in service. With flows around 10 MGD, we began to experience heavy pin flocking
from our clarifiers and at 12:00 pm, we had to start bypassing the filters. As you are aware, the filters
are the last stage of treatment prior to UV disinfection and final discharge to the Neuse River.
The State (Mr. Bullock) was notified within 10 mins of the bypass.
Average influent flows fluctuated between 10-11 MGD over the event with rainfall total of just over
inch (total rain fall here at the plant for the month has been 2.725 inches).
Total gallons wasted from the clarifiers from February 10- February 16, 2023 is 384,398.
All filters were put back on line at 12:42 pm, Thursday, February 16, 2023.
Daily composite effluent TSS results for the event are as follows:
• February 13, 2023: 1420 mg/L
• February 14, 2023:
1070 mg/L
• February 15, 2023:
5.8 mg/L
• February 16, 2023:
139 mg/L
• February 17, 2023:
3 mg/L
• February 18, 2023:
< 2.5 mg/L
Johnnie Mosley Regional Water Reclamation Facility
2101 Becton Farm Rd Kinston, North Carolina 28501 Phone [phone] Fax [phone]

Both the February 12-18, 2023 weekly average limit value and monthly valve was exceeded.
As previously reported, there were some operational issues prior to the bypass that if addressed
properly may have prevented the bypass. The shift operator prior to the bypass failed to open the peak
flow basin bypass to take the high flows off the system which would have reduced flows to the
clarifiers and allowed the sludge blanket to settle. The operator also failed to monitor the filters
properly and the filter beds clogged. The filters where within an inch of overflowing into the pipe
gallery below. The operator admitted to "being negligent in completing his operator checks on the
1211." He mentions that he was having some issues with his back and left knee and being out in the cold
rain in the night air made it worse (He did not report that at that time). He didn't want to climb up the
steps to the Headworks in the rain to open the peak flow bypass valve.
He also admitted to being negligent in his monitoring of the sand filters which in turn filled up and
blinded them out,. He saw they were full prior to the change of shift but still did not want to bypass
them.
The operator was reprimanded and given five working days off without pay. He is currently being
retrained in proper operational procedures and will be given an oral exam from his supervisor upon
completion.
Solids within the basin remain constant with where we should be at this time of year. The last few
months however our ability to properly waste and remove solids from the plant have been hampered
with mechanical and operational issues. One of the belt filter presses was down for weeks with a sludge
pump rebuild. The City's cake biosolids remover company reduced their solids pick-ups and we
reached capacity on the sludge pads. Wasting was also reduced due to both of those prior mentioned
issues.
If I can be of any further assistance, please call me at 252-939-3375 or email at
Kenneth. [e-mail].
Sly,
�r -
Kenneth R. Stevens, Jr.
Johnnie Mosley RWRF Superintendent
C:
Steve Miller -Director of Public Services
File
Johnnie Mosley Regional Water Reclamation Facility
2101 Becton Farm Rd Kinston, North Carolina 28501 Phone [phone] Fax [phone]