WQ0030088_Response to NOV2019LV0531_20190822

August 20, 2019
Morella Sanchez -King, Regional Supervisor
Water Quality Regional Operations Section
Wilmington Regional Office
Division of Water Resources, NCDEQ
Old North State Water Co.
An
Water Company
AUG 2 2 2019
Subject: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Tracking No.: NOV-2019-LV-0531
WWTP Permit No. WQ0030088
Majestic Oaks WWTP
Pender County
Dear Ms Sanchez -King:
Old North State Water Company appreciates the opportunity to respond to the Notice of
Violation issued on July 30, 2019 by the Division of Environmental Quality. The Notice of
Violation was issued related to data submitted by ONSWC to the Division for May 2019. The
specific violations were for an exceedance of Total Phosphorous (as P) (00665).
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 Majestic Oaks
Sample Plan
We have confirmed that we did exceed the Monthly Average for Total Phosphorous for the
month of May 2019 with our laboratory to ensure earlier notification of results and to raise
visibility beyond just the operator in responsible charge.

Additional finding was as listed:
1. The chemical feed pump that feeds the ferric chloride for phosphorous removal had issues
with air locking. The operator would have to keep priming the pump and increasing the
pump rate until the air locking stopped.
2. The ferric chloride is fed into the influential splitter box. When it was being added while
flow from the Equalization (EQ) Basins was not pumping, the ferric chloride caused the grease
in the splitter box to cause a mat. The operator would have to remove the grease mat which
was absorbing and holding some of the ferric chloride inside the grease causing it to be
removed from the treatment process before it made its way into the treatment process.
ONSWC feels that all proper procedures have been taken to ensure this doesn't have in the
future.
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. 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,
Michael J. Myers
Old North State Water Company
Cc:
David Strum, Envirolink
Rebecca Manning, Envirolink
Don Feller, Envirolink