NC0060526_NOV-2023-LV-0458 Response to notice_20230718

COMMERCIAL REALTORS'
July 18, 2023
Mr. Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Subject: Notice of Violation & Intent to Assess Civil Penalty
Tracking Number: NOV-2023-LV-0458
Permit No. NCO060526
Pope Industrial Park WWTP
Wake County
Mr. Vinson,
Thank you for allowing the Pope Industrial Park the opportunity to respond to this Notice of Violation
issued July 3, 2023; received on July 11, 2023, for the Nitrogen Ammonia Monthly average exceedance
and the Total Residual Chlorine Daily maximum exceedance, occurred during the May 2023 monitoring
period.
The Ammonia monthly average exceedance was caused by the increase in the temperature, this started
on the first week of the May monitoring period. since the ammonia levels are not a visible parameter, it
depends on the notification from the analysis of the samples pulled, the first result corresponding to the
05/03 was notified until 05/10, so when the Operator received the results for the 4.5mg/L the second
sample with a value of 7.Omg/L was already pulled. These two values were compliant to the Daily
Maximum limits, and as corrective action and to reduce the Ammonia levels the operator increased the
amount of air in the system. The correct management of the facility induced the system to reduce the
Ammonia concentration levels, however, the first two values affected the monthly average.
The Chlorine exceedance reported originated as response to the lab results obtained for fecal coliform.
As shown on the Table 1, the system was operating within the limits established for Chlorine, but even
in the presence of 34 ug/L of Chlorine on 05/03, the lab reported the presence of 50 colonies of Fecal
coliform on the sample, forthat reason the ORC increased the amount of Chlorine to reduce the colonies
in the system. This immediate response resulted in a exceedance for the chlorine on 05/09, but even
with the increased concentration, the lab reported the presence of coliforms in the sample, for that
reason the Operator maintained an increased concentration on the system.
R O. BOX 97215
RALEIGH, NORTH CAROLINA 27624
919-846-3500

Table 1. Record of Fecal Coliform and TCR reported for May 2023 monitoring period.
Sample pulled date
04/24
04/25
05/01
05/03
05/08
05/09
05/15
05/16
05/22
05/23
Chlorine (ug/L)
10
34
19
34
24
53
20
54
8
24
F.Coliform (#/100ml)
<1
50
40
<1
<1
When the result corresponding to the 05/16/2023 for Fecal coliform was received and it indicated the
absence of coliform colonies, the Chlorine concentration was brought back to the normal
concentrations.
As has been described, the facility has been attended and monitored constantly to ensure the correct
performance, however the delay between the sample pulling and the report is a factor that contributed
significatively on the performance for this May 2023 monitoring period. We recognize that the monthly
exceedance occurred, however these were attended immediately, and the system is operating in
compliance. It is our request that the Division take into consideration the actions taken by the permittee
when deciding whether further enforcement actions are warranted.
Sincerely,
44�.� li,
Albert E Finley,
Pope Industrial Park II Ltd Partnership
CC:
Andrew White, Envirolink, Inc.
William Lamm, Envirolink, Inc