WQ0033770_NOV2020LV0731_20201012

016)IntegraWaWs
3212 6th Avenue South
Suite 200
Birmingham. AL 35222
Telephone [phone]
www. i nteg rawate r. coin
October 12, 2020
Ms. Morelia Sanchez -King, Regional Supervisor
Water Quality Regional Operations Section
Wilmington Regional Office
Division of Water Resources, NCDEQ
Re: Notice of Violation & Intent to Assess Civil Penalty
Tracking Number NOV-2020-LV-731
Permit No. WQ0033770
Carolina Plantation WWTP
Onslow County
Dear Ms. Sanchez -King:
I am in receipt of the above referenced NOV dated October 5, 2020 and wanted to make you aware of
some modifications we are either planning or have made at the facility. The discharge line had a 90
degree elbow on the discharge line, just after the effluent box inside the plant. The elbow was not
allowing a smooth flow of water through the meter because of the vacuum created in the pipe. A "T"
was installed on the discharge line and allows the water to flow smoothly and evenly from the
discharge. Here are the before and after pictures:
before after
It is our theory that the intermittent flows and backups caused by the vacuum caused the flow meter to
read artificially high flows. The data since the installation of the "T" seems to confirm the theory. Here
are the flows since the installation of the "T":

Flows
9/25-164300 Gallons
9/26-172,200
9/27-184,300
9/28-172,100
9/29-164,900
10/1-153,500
After Tee was installed
10/2-138,000
10/3-139,000
10/4-155,700
10/5-156,500
10/6—142,600
10/7—138,750
10/8—142,900
10/9—146,700
10/10—155,300
10/11 — 162,500
10/12 147,000
In addition to the above -mentioned improvements, we have engaged a professional engineer to
evaluate the feasibility of rerating the plant. We are watching the new flow data, and the engineer is
working to determine if rerating the plant is feasible or if additional improvements will be required to
address both the flows, and the permit exceedances.
Last, Old North State has terminated its relationship with Envirolink, Inc. for contract operations the last
week of September. We were receiving poor service and very little information related to performance,
compliance, and maintenance. We believe you will see improved communications, operations and
maintenance from Old North State moving forward. We would ask for some limited leeway to study the
flows and determine if the installation of the "T" will allow compliance or rerating of the WWTP, or if
further improvements will be required. Please reconsider the enforcement of the civil penalty, as we
are working diligently to solve the issues.
Thank you for any consideration and please reach out with questions or concerns at the address above,
email at imcdonald(@integrawater.com or give me a call directly at 205.326.3355.
Sincerely,,
John L. McDonald
Manager