WQ0030088_NOV2020LV0447_20200720

Old North State Water Co.
An
4)IntegraWaEa
Company
July 8, 2020
Morell Sanchez King, Acting Regional Supervisor
Water Quality Regional Operations Section
Wilmington Regional Office
Division of Water Resources, NCDEQ
127 Cardinal Drive Extension
Wilmington, NC 28405
Subject: NOTICE OF VIOLATION & ASSESSMENT OF CIVIL PENALTY
CASE No.: NOV-2020-LV-0447
WWTP Permit No. WQ0030088
Majestic Oaks WWTP
Pender County
Dear Ms. Sanchez King:
Old North State Water Company (ONSWC) appreciates the opportunity to respond to
the Notice of Violation issued on June 1, 2020 by the Division of Environmental Quality.
Please find enclosed our response regarding the permit exceedances for Total
Suspended Solids, Total Nitrogen, Total Phosphorous and Total Ammonia Nitrogen for
the month of March 2020.
An unexpected change of ORC at the Majestic Oaks Wastewater Treatment Plant
required ONSWC to place a new certified operator at the plant. The new operator was
not fully aware of the sampling details for the plant. As a result, he took grab samples
at an inappropriate location (upstream of the filters). This was directly responsible for
the permit violations; not the operation of the plant itself. The new ORC is now
subsequently trained in the correct sampling procedure for Majestic Oaks.
Since the violations occurred as a direct result of a personnel/training issue and not
because of the plant operation, we request the division take no further action. ONSWC
quickly identified the souce of the problem and took remedial action.

We believe this letter shows the investment and commitment that the Utility continues
to make, and we hope that the Division recognizes these efforts. Please feel free to
contact me at 252-235-4900 with questions or additional details.
Sincerely,
Old North State Water Company, LLC
Cc: Lee Bowman
Tracy Miller
Dave Strum
John Pruitt
Old North Water Company, LLC

DocuSign Envelope ID: D57E5B72-1043-4CD5-9722-1B6862536647
ROY COOPER
cov2,rw
MICHAEL 5. REGAN
Secreary
S. DANIEL SMITH
Dlreetur
Certified Mail # 7018 2290 0001 8295 9861
Return Receipt Requested
NORTH CAROLINA
ErIvIranmentat Quaffty
June 1, 2020
Michael J Myers
Old North State Water Company LLC
4700 Homewood Ct
Suite 108
Raleigh, NC 27609
SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL
PENALTY
Tracking Number: NOV-2020-LV-0447
Permit No. WQ0030088
Majestic Oaks WWTP
Pender County
Dear Permittee:
A review of the March 2020 Non -Discharge Monitoring Report
(NDMR) for the subject facility revealed the
violation(s) indicated below:
Limit Exceedance Violation(s):
Sample
Limit
Reported
Location Parameter Date
Value
Value
Type of Violation
001 Nitrogen, Ammonia Total (as 3/31/2020
6
6.3
Daily Maximum Exceeded
N) (00610)
001 Nitrogen, Total (as N) (00600) 3/31/2020
7
8.95
Monthly Average Exceeded
001 Phosphorus, Total (as P) 3/31/2020
3
4.07
Monthly Average Exceeded
(00665)
001 Solids, Total Suspended 3/31/2020
5
5.8
Monthly Average Exceeded
(00530)
002 Nitrogen, Ammonia Total (as 3/31/2020
1.5
6.6
Monthly Average Exceeded
N) (00610)
-x NorthCafoLnaDepartmentoffnvironmeata3Qua;ity I DiuisionofWater Resouroes
Wilmington R ionaIOffice I =CArd'InslDFivefxtension I WiHmington, North Caroma23405
�'T °y 1310-796-7215

DocuSign Envelope ID: D57E5B72-1043-4CD5-9722-1B6862536647
Limit Exceedance Violation(s):
Sample
Location Parameter
Limit Reported
Date Value Value Type of Violation
003 Nitrogen, Ammonia Total (as 3/31/2020 1.5 2.5 Monthly Average Exceeded
N) (00610)
A Notice of Violation/Intent to Issue Civil Penalty is being issued for the noted violation of North Carolina General
Statute (G.S.) 143-215.1 and the facility's Non -discharge Permit. Pursuant to G.S. 143-215.6A, a civil penalty of
not more than twenty-five thousand dollars ($25,000.00) may be assessed against any person who violates or
fails to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S.
143-215.1.
If you wish to provide additional information regarding the noted violation, request technical assistance, or
discuss overall compliance please respond in writing within ten (10) business days after receipt of this Notice. A
review of your response will be considered along with any information provided on the submitted Monitoring
Report(s). You will then be notified of any civil penalties that may be assessed regarding the violations. If no
response is received in this Office within the 10-day period, a civil penalty assessment may be
prepared.
Remedial actions should have already been taken to correct this problem and prevent further occurrences in the
future. The Division of Water Resources may pursue enforcement action for this and any additional violations of
State law. If the violations are of a continuing nature, not related to operation and/or maintenance problems,
and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by
Consent.
If you have any questions concerning this matter or to apply for an SOC, please contact Helen Perez of the
Wilmington Regional Office at 910-796-7215.
Sincerely,
DoTcuSigTned
l 0' IM\IIIV V7F141E73B6F3456...
for
Morelia Sanchez -King, Regional Supervisor
Water Quality Regional Operations Section
Wilmington Regional Office
Division of Water Resources, NCDEQ
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