NC0058416_NOV-2023-LV-0129_Resp Rvcd_20230324

FS -GWA S A
WW0&4
cl;
NC Dept of Environmental Quality
South Granville Water and Sewer Authority
March 21, 2023
Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
1628 Mail Service Center
Raleigh, NC 27699-1628
Re: Notice of Violation & Intent to Assess Civil Penalty
NOV-2023-LV-0129
South Granville Water and Sewer Authority (SGWASA)
Pen -nit No. NCO058416
Granville County
Ms. Manuel:
MAR 2 4 2023
Raleigh Regional Office
I am writing to you in response to NOV-2023-LV-0 129 related to the January 2023 Discharge
Monitoring Report (DMR) that revealed a frequency monitoring violation of copper at the
effluent monitoring location. SGWASA received the NOV-2023-LV-0129 notification letter
from NCDEQ on March 14, 2023. A written response to your office is required within 10
business days following receipt of the notification. This response dated March 21, 2023 complies
with that requirement. Following is an overview and response by SGWASA to this incident.
Incident Summary: In accordance with our operating pen -nit, the South Granville Water and
Sewer Authority water treatment staff routinely collects and analyzes effluent samples from our
water treatment plant. Samples collected on January 17, 2023 and January 31, 2023 showed
copper levels higher than the permitted Maximum Contaminant Level (MCL). On February 8,
2023 SGWASA staff collected samples from the two holding tanks located at the water treatment
plant, which are a source of effluent. Following the analysis of these samples, lab test results
show that copper levels did not exceed the MCL. SGWASA water treatment staff continues to
perform increased testing cycles of the effluent to monitor copper levels.
Corrective Actions: Following the events in January, 2023, SGWASA developed and started a
plan for corrective actions related to the copper exceedance. To date, SGWASA staff confirmed
with Hazen & Sawyer, our engineering design consultant for the 2022 water treatment upgrade
project that no copper lines were installed during the upgrade project completed in 2020. This
leads us to believe that copper may be prevalent in the existing effluent discharge line. As such,
we plan to shut down the water treatment plant in the next few weeks and televise the existing
discharge line to determine if any portion is made of copper. If none is found, then we will
expand our search to determine where the copper is located.
In addition to the research mentioned above, SGWASA speculates that the sludge in the existing
holding tanks could be a source of copper contamination. A vender is scheduled to be on site
during the next few weeks to remove and dispose of all sludge in the primary holding tank (total
cost is approximately $46,000).

I look forward to discussing this information finther with you. Please contact me at your
convenience.
Sincerely,
Scott N. Schroyer, Executive Director
South Granville Water and Sewer Authority (SGWASA)
415 Central Avenue, Suite B.
Butner, NC 27509
919-575-3367 Ext. 312
[e-mail]
Cc: Mark Hamlett, PE, Engineering Director; Jonathan Yancey, Water Treatment Plant Superintendent

SwSGSIormwater Services Group, LLC
March 22, 2023
Jane Bernard
Raleigh RO — Surface Water Protection
NC Division of Environmental Quality
1628 MSC
Raleigh NC 27699-1628
RE: Gillespie Property, 3815 Bright -wood Ln., Durham NC
NPDES General Permit NCG550751
113OF67-roTIM,
*4,p
Rai
Raleigh, North Carolina
Phone: [phone]
Fax: [phone]
In response to Permit requirements, we have collected a discharge sample from the sand filter and have analyzed it for the parameters
indicated in the General Permit. The results are as follows:
Table 1 — Effluent Analysis Results
Outfall
Date
Flow,
Gals/ Day
(est)
BOD5,
mg/L
TSS,
mgfL
pH,
Std. Units
Ammonia,
mg/L
Total
Nitrogen,
mg1L
Total
Phosphorus,
mg/L
Total
Residual
Chlorine,
raff!
Fecal
coliform,
CFU/ 100
mL
Limits
1000
45.0
45.0
6.0-9.0
Monitor & Report
0.017'
400
Sand Filter
05/11/20
15
< 2.0
153
6.84
Not applicable
> 50.01
1990
Sand Filter
08/10121
< I
Insignificant Flow Today — not able to collect a sample
1 Sand Filter
1 08/22/22
200
1 29.4
172
5.84
16.5
22.5
3 * 8
> 5.01
2.0
Sand Filter
03/07/23
lo()2
94.1
46.0
6.94
<0.10
16.8
1.2
> 10.01
< 1.0
' Receiving stream chlorine levels are not to exceed 17 VgL. Sample is taken at end of effluent pipe. Nearest stream is +/- 1400 ft downgradient.
2 Two adufts live in the residence as of March 2023. Flow is based on 50 gpd/ person.
3 Residence is on City of Durham water system which is chlorinated. Chlorine tablets are inserted into chlorinator device downstream of sand filter in accordance
with permit.

NC Dept of Environmental Quality
NCDEQ
March 22, 2023
Page 2
Theoretical Flow Rate estimate is based on two adults living at
the residence using an industry average of 50 gpd/ adult. Actual
flow rate at this property is much less as typical daily water usage
creates a flow consisting of about two or three milliliters per
minute. There was no flow when this consultant arrived on site.
To collect a sample, the system was surcharged by running cold
water through the septic system for 30 minutes.
The sand filter effluent pipe discharges into a wooded buffer (see
Figure 1). There is no defined channel from a point about 30 ft
from the end of the pipe into the wooded buffer. The nearest
stream, Unnamed Tributary to Chunky Pipe Creek, is more than
1400 ft from the end of pipe. In the opinion of this consultant,
there is no point source discharge from this septic/ sand filter
system into waters of the State.
The original laboratory report and chain -of -custody form is
maintained at the residence.
The next effluent sample will be collected and analyzed in 2 d or
P Quarter 2024. In the meantime, if you have any questions, do
not hesitate to call me.
Sincerely,
STO)W"TER SHIVICES GRoup, LLC
Senior Project Manager
cc: S.Gillespie, Owner
File
MAR 2 7 2023
Raleigh Regional Office
SaWaIN
Figure I — View looking downgradient from Pipe outlet
Dry channel was dug recently to allow for flow out of pipe.
There is no channel beyond the dug portion; effluent infiltrates into ground
within 15 ft from end of pipe.