WQ0036766_Response to NOV2019LM0049_20190819

Old North State Water Co.
An
05)7-ir Nater
Company
August 19, 2019
Morella Sanchez -King, Regional Supervisor
Water Quality Regional Operations Section
Wilmington Regional Office
Division of Water Resources, NCDEQ
Subject: NOTICE OF VIOLATION
Tracking No.: NOV-2019-LM-0049
W WTP 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 1, 2019 by the Division of Environmental Quality. The Notice of
Violation was issued related to data submitted by ONSWC to the Division for December 2018.
The specific violations were for an exceedance of Total Suspended Solids and missing BOD,
Fecal Coliform, Total Ammonia Nitrogen, Total Nitrate Nitrogen and Total Suspended Solids
for the month of December 2018.
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 December 2018 Discharge Monitoring Report were inaccurate. Our audit of the
operations has resulted in the following findings of an additional lab report not originally sent.
The results of the lab finding are as follows:
Additional lab results are as follows:
12/18/2018 BOD 3.0

12/18/2018
Fecal <1.0
12/18/2018
Ammonia 0.3
12/18/2018
Nitrate 2.58
12/18/2018
Total Nitrogen 2.99
12/18/2018
Total Phosphorous 0.94
12/18/2018
TSS 4.0
12/18/2018
TKN 0.41
12/18/2018
Nitrite <0.02
12/18/2018
Nitrite/Nitrate 2.58
In addition, we have confirmed that we did exceed the Monthly Average for Total Suspended
Solids for the month of December 2018 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 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. The NDMR for December 2018 has
been amended and attached to this letter. 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,,,G17� /" `d
Michael J. Myers
Old North State Water Company
Cc: David Strum, Envirolink
Rebecca Manning, Envirolink
Stanley Buck, Envirolink

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