NC0089583_NOV-2019-LV-0632 Response_20190913

NC Dept of Environmental Quality
SEP 19 2of9
Raleigh Regional Office
Division of Parks and Recreation
NC Department of Natural and Cultural Resources
Governor Roy Cooper
September 13, 2019
Rick Bolich, L. G., Assistant Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
1628 Mail Service Center
Raleigh, NC 27699-1628
Subject: Response to Notice of Violation Letter Dated August 28, 2019
Tracking Number: NOV-2019-LV-0632
Permit Number: NCO089583
Hibernia Recreation Area
Vance County
Secretary Susi H. Hamilton
The Hibernia Recreation Area sand filter system at Kerr Lake State Recreation Area is an existing sand filter
system that was modified in 2016 when an existing shower house was demolished and replaced with a new
shower house. The Division of Parks and Recreation took ownership of the new shower house and modified
sand filter system in December 2016. It is in a campground that is closed from November - March. The first
EDMR was submitted for December 2016. It, along with the EDMRs for January 2017, February 2017,
March 2017 and April 2017 were submitted as "no flow".
The campground and shower houselseptic system opened for the season on March 27, 2017. Because there
was so little water use, our ORC could not get a flow to sample except on weekends when there were no labs
open that could receive a sample from us. Eventually, our Facility Maintenance Supervisor II, Chris Curl,
spoke with Danny Smith about this. Mr. Smith told Chris Curl, that we could turn the system pump off for a
few days and let the water level build in the pump tank. We could then turn on the pump and collect a
sample through the discharge outlet. For the May 31, 2017 sample collection, which was the first sample
collected from the permitted system. We turned the pump off on Sunday, May 29, left the alarm on in case
the level got too high and then let the level build until Wednesday, May 31, when we collected the
sample. When the sample results came back high for fecal coliform, Ammonia Nitrogen total and total
suspended solids, Kerr Lake SRA staff contacted the designer, Robert Graham, and Division of Parks and
Recreation design and development staff. Kerr Lake State Recreation Area staff met with Robert Graham on
site. It was recommended that we throttle the pumps back to increase the contact time with the chlorination
tablets and increase the de -chlorination to solve the problems with the fecal coliform. It was also noted that
the discharge pipe, which was existing from the previous system had been underwater because of a recent
flooding event at the lake and that may have caused the suspended solids issue.
On June 15, 2017, Kerr Lake State Recreation Area staff took a second sample from the system. That time,
everything was within acceptable parameters except for fecal coliform, which was 900 col/100ml. Park staff
contacted Robert Graham and the Division of Parks and Recreation Area construction staff again to have a
Dwayne Patterson, Director
NC Division of Parks and Recreation NORTH CAROLIMA STATE PARKS
1615 MSC - Raleigh, NC 27699 1615 Na&Aa* AnzAW
919,707.9300 / ncparks.gov

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Division of Parks and Recreation
NC Department of Natural and Cultural Resources
Governor Roy Cooper
Secretary Susi H. Hamilton
second meeting on site to determine further adjustments to the system to correct the issue. After that
meeting, Kerr Lake State Recreation Area staff inserted a PVC baffle into the outlet side of the chlorine
tablet box, increasing the contact time with the chlorination tablets. It was also determined that the discharge
pipe from the previous system was compromised allowing foreign matter into the pipe. Kerr Lake State
Recreation Area Staff re -plumbed the discharge with new pipe to eliminate that issue.
After that, Kerr Lake State Recreation Area Staff collected samples from the system on June 29, 2017, July
12, 2017, July 27, 2017, August 10, 2017 and August 31, 2017. All the samples taken through August 31,
2017 were within parameters set by the permit. No samples were collected after August 31, 2017 until June
5, 2018 due to low usage and the area being closed over the winter. The June 51 samples came back with
high TSS result of 42mg/l, but results fell within permit daily limit of 45mg/l. Fecal Coliform result was I
MPN/100ml, which was well within permit limits. On June 28,2018 staff took samples and results came back
with high Fecal Coliform 1600 MPN/100ml and high TSS 109 mg/l. Kerr Lake SRA lab Research Analytical
ran the TSS twice and found it high and noticed sand in sample. Once Kerr Lake was notified about sample
results, Maintenance Supervisor Chris Curl contacted Mitch Hayes on July 11,2018 with NCDEQ and
discussed issues with recent high sample results. During the discussion, Chris informed Mitch about sand
showing up in plumbing piping and both discussed possibility of sand media breaking down entering
plumbing system. Later that same day Chris Curl found one possibility that sandy soil was entering system
by tablet pill cylinders. Curl found sand on the sides of pill cylinders and inside pill boxes. Curl cleaned
cylinders off and flushed sand out through discharge pipe. On July 12, 2018 staff sampled system and results
were received on July 18, 2018. Results showed TSS 6.2 mg/1 and Fecal Coliform 7 MPN/100m1. With
recent findings and sample results, Curl felt Kerr Lake was on the correct path to working out issues with
system. Kerr Lake SRA has also met with the designer and made grading repairs around the system to
address issues with sand entering around tablet cylinders.
During the spring of 2019, Kerr Lake staff met with Jane Bernard, Emily DelDuco, Emily Phillips and
Sydney Carpenter about the possibility of a permit change. During meeting, we discussed different issues we
had encountered since we began operating the system in 2017. We discussed some of the modifications we
had made to help the system. We were advised to not make any more changes to system until we heard back
from of them. On June 4, 2019, Kerr Lake staff sampled the system and the Ammonia Nitrogen was 32.8
mg/l, which is just under the daily max of 35mg/1. On June 18, 2019, Kerr Lake staff took a second sample
for the month of June and the Ammonia Nitrogen was 35.2mg/1 which is just over the daily max. Kerr Lake's
monthly average was 34 mg/l which exceeds monthly limits. Kerr Lake ORC contacted Jane Bernard and
updated her with the sample results and findings of infiltration during rain events. ORC John Abbott found
major infiltration entering pump tank during afternoon storms. Infiltration appears to be coming from drain
field.
On July 2, 2019, Kerr Lake staff sampled the system and the Ammonia Nitrogen was 37 mg/l which exceeds
the daily limit of 35 mg/l. Then on July 30, 2019 staff took a second sample for the month and the Ammonia
Nitrogen was 16.6 mg/I. The monthly average of 26.8 mg/l exceeds the limits of 21 mg/l. Kerr Lake has had
Dwayne Patterson, Director
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NC Division of Parks and Recreation NORTH Ala&&CAROLd STAT,.l,��p� d
1615 MSC • Raleigh, NC 27699-1615 N� „�`�
919.707.9300 / ncparks.gov

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Division of Parks and Recreation
NC Department of Natural and Cultural Resources
Governor Roy Cooper
Secretary Sus! H. Hamilton
the septic tank pumped during the month of August. Chris Curl contacted Jason Robinson on 9/6/2019 and
discussed issues with system.
Curl, Abbott and I met with Robert Graham, the system designer, on September 11, 2019 to discuss system
issues. When Graham was provided information about the infiltration of the water that John Abbott
witnessed, Graham felt that it was likely surface water was infiltrating through the sand filter. Graham is
working on a proposal for a subsurface system for consideration.
Please contact me if you have any additional questions or concerns.
Sincerely,
Bryce Fleming ark Superintendent IV
Kerr Lake State Recreation Area.
Dwayne Patterson, Director
NC Division of Parks and Recreation
1615 M5C - Raleigh, NC 27699-1615
919-707.9300 / ncparks.gov
NORTH CAROLIHA STATE PARKS
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