WQ0036766_Response to NOV2019LV0550_20191122

August 19, 2019
Morella Sanchez -King, Regional Supervisor
Water Quality Regional Operations Section
Wilmington Regional Office
Division of Water Resources, NCDEQ
Old North State Water Co.
An
-' Company
RECEIVED/RCUERR/M
AUG 2 2 ;:1,119
water QuJ 111 Renional
Operaf ions Section
01mington RegAnal Office
Subject: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Tracking No.: NOV-2019-LV-0550
WWTP Permit No. WQ006766
Cedar Point WWTP
Carteret County
Dear Ms Sanchez -King:
Old North State Water Company appreciates the opportunity to respond to the Notice of
Violation issued on July 31, 2019 by the Division of Environmental Quality. The Notice of
Violation was issued related to data submitted by ONSWC to the Division for May 2019. The
specific violations were for an exceeciance of Total Suspended Solids and missing TKN.
In response to the notice of violation, ONSWC has taken the following action related to the
violation.
1. Reviewed all the analytical data for the month of May to validate the limit violations.
2. Audited the laboratory and operations information to validate the missed samples.
3. Discussed action plans with the operator in responsible charge to ensure compliance
with the required sample plans.
4. Ensured that the operator in responsible charge had a written copy of the Cedar Point
Sample Plan
Respectfully, we have determined that the required 2x monthly sample, TKN results reported
on the May 2019 Discharge Monitoring Report are accurate. Our audit of the operations has
resulted in the following findings:

TKN twice monthly
The TKN results for May were as follows:
5/7/2019 - TKN = 1.45 mg/1
3/23/2019 - TKN = 0.67 mg/1
In addition, we have confirmed that we did exceed the Monthly Average for Total Suspended
Solids for the month of May 2019 with our laboratory to ensure earlier notification of results
and to raise visibility beyond just the operator in responsible charge.
While we concur that the TSS exceedance does constitute a violation, we hope that our
response shows our commitment to providing support to the operator to ensure that future
compliance issues receive visibility thorough out the organization and as a check to ensure
compliance. We have been proactive in purchasing a spare chemical pump in order to reduce
Total Suspended Solids in the future.
We feel that a civil penalty would not be prudent as we have acted in a responsible manner to
address these issues and bring the facility into compliance. Therefore, we request that the
Division considers these efforts when deciding on further enforcement.
Old North Water Company strives for excellence and has always welcomed open
communication with NC DWR Staff to ensure compliance with any permit and we continue to
be concerned about the issuance of NOV's that could have been avoided through open
communication. If Old North State Water Company can be of any further assistance or
additional information is needed, please contact me at 252-235-4900.
Sincerely,
Michael J. Myers
Old North State Water Company
Cc:
David Strum, Envirolink
Rebecca Manning, Envirolink
Stanley Buck, Envirolink

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