WQCS00372_Response to NOV-2020-DV-0195_20200717

July 17, 2020

Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section Raleigh Regional Office
Division of Water Resources, NCDEQ

Subject: NOTICE OF VIOLATION
Collection System Permit No. WQCS00372
Briar Chapel Collection System
Chatham County

Dear Mr. Vinson:

Old North State Water Company (“ONSWC”) appreciates the opportunity to respond to the
Notice of Violation issued on May 19, 2020 by the Division of Environmental Quality
regarding the self-reported SSOs on March 12th, April 8th, and April 16th. It is our hope that
this additional information is sufficient, and that the Division will decide not to pursue
further action.

REQUESTED RESPONSE:
1. Please provide a more detailed location description for the two incidents that
referenced the location, Briar Chapel Sub (#202001166, #202001213).
The locations in these two instances were along the same section of force main line that has
previously broken between Lift Station A and the WWTP. In particular, the location can be
further described as the +/- 1000 LF of force main near the backyards of 75 Hill Creek and
300 Serenity Hill Circle
2. Please provide a written response of the remedial actions, if not already
implemented, that should be taken to correct the above referenced non-compliance.
Significant analysis over the past eighteen (18) months has been performed to try to identity the
source for the breaks in this force main line. In addition to field review of the pipe break(s) to
determine if the pipe was installed incorrectly or defective from the manufactures, data loggers
were installed to gain better insight into transient pressure wave concerns that were believed to
be a cause. Accordingly, pump adjustments (i.e., start-up and shut-down) were made to address
water hammer concerns as a result of these previous breaks over the past year.

The breaks at the start of 2020 led Old North to believe that pipe fatigue in this section of the line
was the likely the cause of the breaks. Therefore, Old North initiated a pipe replacement project.
After County, State, and Federal approvals were obtained for erosion control and stream impacts,
the construction to replace the pipe began in early June. The pipe installation and connection to
the active force main was completed by the end of June. Final erosion control removal and dress-
up remains to be done and will occur once stabilization of the site occurs most likely by the end of
July.
Please contact us if additional information is needed. While the violation was unfortunate,
we feel that a civil penalty would not be prudent as we have acted in a responsible manner
to address these issues. We hope that the Division recognizes the significant amount of
resources that are devoted to this system. Therefore, we request that the Division consider
these efforts when deciding on further enforcement. We are committed to full compliance
with all the permits of the Briar Chapel Permit Number WQCS00372.
Sincerely,

Old North State Water Company, LLC

Cc: Dave Strum
Rebecca Manning
Charles Donnell
Lee Bowman
William Lamm