WQCS00166_Response to Notice: NOV-2024-PC-0459_20240805

r ■ HARNETT
-� REGIONAL
rWATER www.harnettwater.org
PO Box 1119
700 McKinney Parkway
Mark Brantley August 5,2024 Lillington, NC 27546
Regional Supervisor
Fayetteville Regional Office ph: 910-893-7575
225 Green St. fax: [phone]
Suite 714
Fayetteville,NC 28301
Subject: Notice of Violation&Intent to Enforce NOV-2024-PC-0459
Mr. Brantley,
Please consider this Harnett Regional Water's official response to the above referenced, Notice of Violation,dated
July 26,2024.This NOV lists 3 violations associated with the Collection's System Inspection conducted on July 25,
2024. Below you will find our understanding of the violation and corrective actions to be taken to return to
compliance with our permit.(WQCS00166)
1.) ORC reports not meeting the annual inspection of the entire system.ORC reported only visiting an
estimated 75%of the system.
- While the ORC may have only seen the 75%reported personally,the other 25%was visited by our
Back-up ORC and collection's personnel which are designated by the Permittee to conduct these
inspections.The ORC(Randolph Clegg)misunderstood the question because 100 percent of the
system was visited during the past year.
2.) The 10%cleaning requirement of 116,160 feet has not been met for the previous 2 years and not on
target for this year.
- Shortfalls in this area are a direct result of staffing issues.Since the pandemic we have struggled to
keep a full crew in our Collection's Department.This situation has been exacerbated by numerous
retirements within this division.Both due to longevity and medically necessary reasons.We are
finally fully staffed in this division as of early 2024 and have began planning to make sure we meet
the ten percent rule moving forward.
3.) Failure to submit a performance annual report for the Collection System.
- As we discussed last week,we have always done PAR's for both Wastewater Treatment Plant's and
were unaware that this was also required for Collections Permits.Beginning this year,HRW will
produce one single PAR that includes all Wastewater related permits and programs.This report shall
be posted on all our bulletin boards and copies will be made available upon request.In addition,a
copy of this report will be sent to the Fayetteville Regional Office for your files.
Please do not hesitate to contact me if you have any questions.
Respectfully,,
Kenneth W. Fail
Wastewater Superintendent
Harnett Regional Water
910-814-6470