WQ0011655_NOD-2011-PC-0015 0016 0012 AND 0013 Response_20210128

Carolina Environmental Group
Benjamin H. Davis, President
1520 Leggett Rd.
Washington, NC 27889
NC Department of Environmental Quality
Division of Water Resources
Attention: Mr. Robert Tankard
Washington Regional Office
943 Washington Square Mall
Washington, NC 27889
January 28, 2021
Dear Sir or Madam,
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I am writing this letter in response to two "Notices of Deficiency" dated 1/13/21
(NOD-2021-PC-0015 and NOD-2021-PC-0016) and two "Notices of Violation" dated
1/13/2021 (NOV-2021-PC-0012 and NOV-2021-PC-0013). The four notices
pertain to the absence of sending in on -site effluent monitoring data (i.e. Total
Residual Chlorine) in the Non -Discharge Monitoring Reports for the months of
August 2020, September 2020, October 2020, and November 2020. It is the opinion
of the current ORC that the fourth NOV, specifically NOV-2021-PC-0013 for the
month of November 2020, did not violate the permit WQ0011655 because the spray
irrigation field was not irrigated for the entirety of November 2020 and therefore,
did not require the submission of the Total Residual Chlorine parameter on the
November 2020 NDMR report.
The previous ORC for Camp Boddie , Mr. Nelson Medford, left abruptly in mid -
September 2020, leaving no ORC to operate the facility. Shortly after, East Carolina
Council/BSA, Inc. CEO Mr. Doug Brown, approached Carolina Environmental Group
to inquire about operating the facility at Camp Boddie. During contract negotiations,
Mr. Davis sent in the Non -Discharge Monitoring Reports and the Non -Discharge
Application Reports for August 2020 and September 2020. On October 13, 2020,
Benjamin Davis of Carolina Environmental Group became the new ORC for Camp
Boddie, and subsequently, Mr. Davis began operating the facility and sent in the
appropriate monitoring reports for October 2020 and November 2020.
The purpose of a "Notice of Deficiency" letter is to notify the facility that something,
needs to be corrected so that it doesn't rise to the level of a violation in future
months. Because the ORC received the Notices of Deficiency and Violation for the
months of August, September, October, and November 2020 on the same day on
January 19, 2021, it is the opinion of the current ORC that appropriate time was not
given by NCDEQ to amend the deficiency in a timely manner. The appropriate
sample data (i.e. Total Residual Chlorine) was taken on -site during each irrigation
event, and amended monitoring reports that reflect this data have been resubmitted

for each of the months in question. The violations are not due to a lack of
maintenance but to an inadvertent clerical error of not sending in one data
parameter line item. The ORC is now aware of the data parameter deficiencies and
will be sending in correct monitoring reports in the future.
With regards to the Notice of Violation for November 2020 (i.e. NOV-2021-PC-
0013), it is the opinion of the current ORC that a violation did not occur because the
spray irrigation field was not irrigated for the entirety of November 2020.
According to "Attachment A -Limitations and Monitoring Requirements" for Permit
Number WQ0011655, Total Residual Chlorine Samples are to be taken "Per Event."
"Per Event" is defined under Footnote "Number 2" as follows: "Per Event sampling
shall be conducted per irrigation event, but shall not exceed Weekly." Treated
effluent was irrigated on the spray irrigation fields on the following days: August 18,
2020; September 3 and 21, 2020; and October 13 and 24, 2020. Total Residual
Chlorine Samples were taken by previous ORC Nelson Medford during each of the
irrigation events in August 2020 and September 2020. In addition, current ORC
Benjamin Davis took Total Residual Chlorine samples on each of the irrigation event
dates in October 2020. Effluent was not irrigated during the month of November
2020 (or December 2020), so therefore, no Total Residual Chlorine samples were
taken on -site during these months. The ORC takes pH samples during each on -site
monitoring visit out of habit; however, similar to Total Residual Chlorine samples, it
is also not necessary to report pH measurements on the NDMR reports, unless an
irrigation event occurs, according to the permit. As previously stated, amended
NDMR reports have been resubmitted reflecting the on -site lab data taken only on
dates that the spray field was irrigated with treated effluent. Please note that the
resubmitted November 2020 NDMR does not include Total Residual Chlorine nor
pH data, because the spray irrigation field was not irrigated.
I look forward to working with NCDEQ in protecting the water resources of North
Carolina as we operate and maintain the wastewater treatment facilities at Camp
Boddie. If you require additional information or would like to discuss this matter
further, please feel free to contact me at [phone] or via email at
badavis68Pgmail.com.
Sincerely,
/Ttikt/t--‘1,
Benjamin H. Davis
President, Carolina Environmental Group