WQCS00380_CEI conducted 51021_20210701

July 1st, 2021

Mr. Scott Vinson, Regional Supervisor
Water Quality Regional Operations
Raleigh Regional Office
1628 Mail Service Center
Raleigh, NC 27699-1628

Re: Compliance Evaluation Inspection and NOV Rescission Request
Hawthorne Wastewater Collection System
Permit No. WQCS00380
Wake County

Dear Mr. Vinson:

Aqua North Carolina, Inc. (Aqua) offers the following response to the above-referenced Compliance
Evaluation Inspection which required a response to three deficiencies, item 3) Fats, Oil and Grease (FOG)
program, item 4) Capital Improvement Plan (CIP) and 5) Annual Reporting.

Aqua’s Response:

Item 3: Aqua mails the Fats, Oil, and Grease pamphlets bi-annually. Customers receive this
communication in March and September. Attached is a copy of the letter that is sent to Aqua customers
for your records. All Aqua field staff have been provided an additional copy of the letter as well.

Item 4: Aqua updates its company-wide 5-year Capital Improvement Plan (CIP) every fiscal year. This
plan includes funds for collection system upgrades, expansions, and replacements. The plan also
includes regional bucket allocations that include all of Aqua’s collection systems and wastewater
treatment facilities. Aqua’s CIP more than meets the environmental regulatory requirement, and please
recognize that our financial operations are regulated by the North Carolina Utilities Commission. The
requirement for CIP review is more appropriate for municipal governments without financial regulatory
overview by the North Carolina Utilities Commission. Per Joe Pearce, PE, Aqua’s extensive capital
improvement program includes more detail than any municipal program he has witnessed. If you wish
to discuss this in further detail, please contact Joe Pearce directly at [e-mail].

Item 5: Annual reports are only required on plants that discharge 200,000 GPD or more. Hawthorne’s
average discharge for 2020 was well under the 200,000 GPD. See attached statute.

Item 9: Boxelder and Galway pump station replacement signage has been ordered and will be installed
immediately upon arrival.

2

With consideration that the Notice of Violation had errors and that the issues noted were not substantive,
please rescind or correct the Notice of Violation. I have reiterated to staff that they respond promptly to
inquiries from your office, and I have been assured that delayed response will not happen again. I
appreciate your attention to this matter. If you have any questions or comments, please do not hesitate to
contact me at [phone].

Sincerely,

Robert Krueger

Robert Krueger
Area Manager

cc: Joseph Pearce, PE
Amanda Berger