NC0061719_NOV-2013-PC-0079_20130314

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NCDENR — DIVISION OF WATER QUALITY
ATTN: PAUL RAWLS
225 GREEN S 1 BEET, SUITE 714
FAYETTEVI1 .IE NC 28301-5043 DCA1R-FRCS
MAR 2 1 2013
OWC
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North Carolina Department of Environment and -Natural Resources
Division of Water Quality
Pat McCrory Charles Wakild, P. E. John E. Skvarla, III
Governor Director Secretary
March.14, 2013
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7009 0820 0000 2474.1.749
Thomas J. Roberts, President
Aqua North Carolina, Inc.
202 Mackenan Court
Cary, .North .Carolina 27511
SUBJECT: NOTICE OF VIOLATION and Compliance Evaluation Inspection
NOV No. NOV-2013-PC-0079
Aqua North Carolina, Inc., Woodlake Country Club WWTF
NPDES Permit No. NC0061719
Moore County
Dear Mr. Roberts:
This NOTICE OF VIOLATON and enclosed Compliance Evaluation Inspection report are based
on the findings of an. unannounced Compliance Evaluation Inspection conducted by Mr. Paul
Rawls, Environmental Program Consultant, of my staff, March 5 and 6, 2013. The inspection
conducted at the Woodlake Country Club Wastewater Treatment Facility (WWTF) revealed that
AQUA, North Carolina (AQUA) has failed to meet the conditions set forth in NPDES Permit
NC0061719 (Permit). Specifically AQUA is in violation of Section C. Operation and
Maintenance of Pollution Controls, 2. Proper Operation and Maintenance . Section C., 2. of the
Permit that states:
Proper Operation and Maintenance
The Permittee shall at all times provide the operation and maintenance resources necessary to operate the
existing facilities at optimum efficiency. The Permittee shall at all times properly operate and maintain all
facilities and systems of treatment and control (and related appurtenances) which are installed or used by
the Permittee to . achieve compliance with the conditions of this permit. Proper operation and
maintenance also includes adequate laboratory controls and appropriate quality assurance procedures.
• 225 Green Street — Suite 714 — Fayetteville, North Carolina 28301-5095
Phone: 910A33-3300 1 FAX: [phone] \ Customer Service 1-877-623-6748
Internet: www.ncwaterquality.orq
One
NorthCarolina
Nature,.
. An Equal Opportunity 1 Affirmative Action Employer

Mr. Roberts
March 14, 2013
Page 2 of 6
This provision requires the Permittee to install and operate backup or aukiliary facilities only when
necessary to achieve compliance with the conditions of the permit [40 CFR 122.41 (e)].
Note: Properly and officially designated operators are fully responsible for all proper operation and
maintenance of the facility, and all documentation required thereof, whether acting as contract operator
(subcontractor) or a member of the Permittee's staff.
During the inspection your staff was asked to check the Chlorine Contact Chamber (Chamber)
to determine the sludge/solids accumulation, if any, that may have been present in the chamber.
It was determined by your staff that there was solids in excess of three (3) feet in depth at
several points in the chamber (it should be noted that the water depth in this unit is a reported
six (6) feet in depth). Also please note that this office as well as your staff feels that solids depth
more than one (1) foot is excessive. _
As you may know solids management has been a topic of discussion with your staff in the past.
Based on the above and in Tight of the history of sludge/solids management at this facility we
feel that this violation notice is more than warranted.
It is suggested in the strongest possible way that the chamber should be checked at
least twice per week and after each weather event that significantly elevates flow (due to
Infiltration/Inflow).
It is suggested that the check consist of solids level determinations at least at two (2)
locations in each side of the chamber. This information should be recorded (written) into
AQUA's onsite records and should be made available upon request to DWQ staff.
Further, it is strongly suggested that when the sludge/solids depth reaches one foot in
depth or more the unit be cleaned immediately, but in no case more than twenty-four
hours of the depth determination.
You are asked to provide to this office on or before April 15, 2013 your written plan of
action to address overall solids management at Woodlake WWTF.
Further, beginning the 15th day of the month following receipt of this notice you are asked to
provide a written monthly report containing, at a minimum, the following information:
• Date and time the solids determination was made,
• Depth of the solids at each point measured,
• When the chamber is. cleaned, (if only one side of the chamber is cleaned please
designate the side that is cleaned,
• Status and description of any work performed to correct the sludge/solids problem,
• Any other information that AQUA feels is appropriate to demonstrate that AQUA is
addressing issues with the operation and maintenance of the facility.
In addition to the above the following are other observations and comments relating to the
subject inspection:
-The facility grounds were noted to be clean and neat in appearance at the time of the
inspection.

Mr. Roberts
March 14, 2013
Page 3 of 6
-Several Discharge Monitoring Reports (DMRs) were spot checked for accuracy. The
following items were noted and. should be addressed.
1. DMR, November 2012
Residual Chlorine values were reported as "0". Please be advised the values •
reported below PQL should be provided on DMRs as < the PQL value. In order to assist
your staff concerning this matter our office contacted Mr. Jeff Adams with the DWQ
Laboratory Certification Branch. Mr. Adams has provided several informational items
pertaining to Free and Total Chlorine. The packet of information is attached entitled
"Free/Total Chlorine Information".
Also please be advised that AQUA staff can receive automatic email pertaining to
notices of changes of policies, regulations and resources pertaining to
Wastewater/Groundwater Laboratory Certification that could have an impact on
your day to day operations. If desired AQUA or any of the AQUA staff can send a
blank email to the following address to get on the list.
DENR.DWQ.Lab. Cert-ioin(c�Iists.ncmail.net
2. DMR, November 2012
Under the Total Nitrogen column there was 30 instances where "0" was reported and one
date 11/19/2012 where the Total Nitrogen value was reported as 6.93.
Based on comments provided it appears that the zeros were inadvertently placed in the
column on days when there was not sample tested.
AQUA is asked to review all DMR's provided for the last three years and provide amended
reports for each month that Residual Chlorine was not reported corrected and each month
that Total Nitrogen was not reported correctly. You are asked to provide the corrected
reports on or before April 15, 2013.
- Records were very neat and well organized.
- It was noted that influent, bar screen and the metal box supporting the screen is significantly
corroded. Furtheris was noted that the bar screen was constructed with bar spacing that is
allowing a considerable about of debris to enter the facility. As numerous debris was observed
in theaeration basin and digester it is suggested that the unit be modified/rehabilitated or
replaced. Please include your plan to address this item in your written response to be received
on or before April "15, 2013...
-The wastewater treatment facility (WWTF) is NOT currently equipped with grit removal.
By failing to remove grit the facility can be systematically filled with grit/sand/debris.
Settled material can and will occupy treatment area within the plant that can cause
compliance problems. This is the second inspection that this item has been noted. .
It is"recommended that Aqua consider the installation of a grit removal unit
as soon as possible.
-Reportedly the Woodlake collection system has a significant amount of
Infiltration/Inflow (1/1). Please note that I/1 can cause higher than normal flow in the
collection and treatment systems. Unusually high flows can cause compliance and

Mr. Roberts
March 14, 2013
Page 4 of 6
operational problems. Further, I/I can cause needlessly high power costs, premature
replacement of pumps and motors as well as playing a leading role in some sanitary
sewer overflows (SSOs). It is recommended that Aqua, if not already doing so,
investigate sources of I/I. Typical I/1 investigations include visual observations at
manholes during dry and wet weather periods/events, flow measurement at various
points in the system, smoke testing, CCTV and the use of pump run meters just to
name a few.
-Wastewater from water treatment plant (WTP) filter backwash continues to be taken to this
WWTF. It is further understood that pumped and hauled backwash from WTP Ion -Exchange
units is placed in the "Old" part of the WWTF not the "EQ" holding tank referenced in your
permit. After the waste is stored in the old part of the WWTF it is then pumped into the
functioning portion of the WWTF. Soda Ash and Caustic are reportedly used to adjust the pH of
the pumped and hauled waste.
As a general precautionary statement Aqua is encouraged to slowly introduce the waste into
the WWTF and to closely monitor the facility to gauge the effect the WTP waste is having.
Please note that dissolved constituents in the WTP wastewater can contribute to or cause
effluent toxicity violations and can potentially cause WWTF process inhibition.
As in the past AQUA is asked to keep records to include but not necessarily limited to
the amount of the waste delivered to the WWTF, any chemical analysis performed on the
waste and how much of this waste is transferred to the active part of the WWTF on a
daily basis. These records may be requested during future inspections and should be furnish
upon request.
- It was noted that the two (2) Aeromod Units in the portion of the WWTF designated at the
"Old" section has been taken out of the WWTF for rehabilitation. It is understood that the Old
portion of the WWTF will be cleaned and placed back into service in the near future (exact date
was not requested or given). AQUA is commended for continued work to bring the WWTF back
to full functionality.
- Also it was noted that the "return" line(s) in the Aeromod Units in the larger portion of the
facility that were rehabilitated during,2012 is experiencing operational problems. It is believed
that the difficultly in operating the Aeromod units, excessive I/1 and or other issues are the
cause of the sludge/solids discharge into the chlorine contact chamber. It is requested that
AQUA provide a plan of action to correct this operational problem on or before April 15,
2013. The plan should contain a complete engineering evaluation of the entire WWTF
outlining what action is any is planned. The plan should contain a time line for the
completion of each corrective action as well as a date that the entire project will be
complete.
-The facility bar screen was again viewed as inadequate: This primary treatment is viewed as
inadequate as there was an unacceptable amount of debris in the WWTF. Based on comments
from AQUA staff, it is understood that AQUA is in the process of replacing the bar screen.
Please provide to this office the complete plan to replace the unit to include completion
date by April 15, 2013.
-Aqua has previously been asked to develop and submit a comprehensive Operation and
Maintenance Plan (Plan) for the facility. During the subject inspection the current plan was
reviewed with Mr. Daniels. Based on that review and observations made during the onsite

Mr. Roberts
March 14, 2013
Page 5 of 6
inspection it is understood that the plan will be reviewed and if deemed appropriate by AQUA
will be modified:
In the past AQUA was asked to consider the following in developing the plan, we again suggest
that the following is at least considered when revising the plan.
• -A description of each unit
• -How each unit,'by design, operates
• -Provide a description of how each unit has been modified, if modified, from original
design and installation
9 -Establish target levels for parameters such as MLSS, Settleablity, Sludge Age, D.O.
'level and what to do when target levels are not met
m -What process control tests will be performed at the facility and on what schedule
® -How process control testing will be used in the operation of the facility to meet or
surpass effluent limitations outlined in the NPDES permit
• -Schedule for testing standby power unit
• -Schedule for servicing standby power unit
• -How screenings from the bar screen will be managed and disposed of
o -Target mixed liquor suspended solids level
e -Schedule for assessing solids build up in the aeration basin
e -Process and schedule for cleaning the solids out of the aeration basin
O -How to inspect the Aeromod Units
o -When should the Aeromod Units be backwashed
• -When and how the'Aeromod Units will be cleaned (When Aeromod Units are
mentioned the clarifier components should be included)
• -At what point the Aeromod Units will be taken offline and cleaned and/or repaired
• -Process by which solids/sludge will be wasted and disposed of
• -Process by which the dual path chlorination system will be operated and cleaned
© -Method and frequency effluent chlorine will be monitored
e -When flow monitoring device will be calibrated
e -How the receiving stream will be visually monitored
o -Description of record keeping processes
© -How the ORC and Backup ORC communicate needs to the permittee
(management) in writing to maintain compliance
- How Aqua assesses on an ongoing basis the performance of the WWTF
- Effluent composite sampler was inspected. Temperature was noted to be 6 degrees C.
The unit appeared to be clean. Effluent sample tubing was observed to be clean.
- Blower building was clean. The filter on one blower unit was spot checked. The filters
were noted to be clean. All blower covers appeared to present and secure.
-While not discussed during the inspection Special care should be taken when
sampling fecal coliform, even slight contamination can lead to high test results and can
cause violations.

Mr. Roberts
March 14, 2013
Page 6 of 6
The cooperation and participation by Mr. Don Williams, Area Manager, Mr. Allen Daniels,
Regional Supervisor, Mr. Erich Ulrich, Operator and Mr. Tony Baldwin, Operator In Responsible
Charge is greatly appreciated.
Again you are asked to provide the information requested on or before April 15, 2013
and to address the violation noted in a manner to ensure that future violations do not
reoccur.
Also, please refer to the enclosed inspection report for additional observations and comments. If
you or your staff have questions related to this report or would like further technical assistance
please do not hesitate to contact Mr. Paul Rawls or myself [phone].
Sincerely,
420t,1,441eD iifimvez
Belinda S. Henson
Regional Supervisor
Surface Water Protection Section
Fayetteville Regional Office
BSH/PER/pr
Enclosures: Free/Total Chlorine Information, Compliance Evaluation Report
cc: Allen Daniels, AQUA NC
Michael Melton, AQUA NC
Don Williams, AQUA NC
Tony Baldwin, ORC. , AQUA NC
%FRO_ SWPS(Mark__Brantley
DWQ Central Files

REVIEW NOTES FOR CORRESPONDENCE RECEIVED FROM AQUA NORTH
CAROLINA ADDRESSING ITEMS NOTED IN THE DWQ ISSUED NOV (NOV-2013-PC-
0079)
TO: BELINDA HEN
FROM: PAUL RAW
DATE: APRIL 29, 2013
The response is generally acceptable but the following should be considered.
1.Noted is the smaller side of the WWTP is going to be brought back online on or about June
2013. AQUA should provide target levels of MLSS/sludge age and other target operational
thresholds so that any operator will know how to operate the facility.
2. The new bar screen should help especially if it acts as some sort of grit removal. Also please
not that the lack of grit removal should not be an issue if the facility is cleaned periodically
(every 2 to 3 years) as well as the pump stations.
3 Filter backwash the noted monitoring should be ok.
4. DMR Amendments.
AQUAs response is unacceptable.
They should be able to correct DMR by using their records and the current ORC can QUALIFY
the revised DMRs if he/she feels compelled to do so.
5 I/1. AQUA indicates that they will continue I/1 work but does not mention work on the flow
meter. The onsite flow meter should have a chart that depicts flow throughout the day.
AQUA should provide what the unit by unit max. flow (each and total) is and when should there
be expected drag out of solids.
I will call Allen Daniels and talk with him one last time
COPY TO THE COMPLIANCE FILE.

RECEIVED
AOUA. APR 15 2013
April 11, 2013
Aqua North Carolina, Inc.
202 MacKenan Court
DENR -FAYETTEVILLE REGIONAL OFr illy, NC 27511
Ms. Belinda S. Henson
Regional Supervisor
Surface Water Protection Section
Fayetteville Regional Office
225 Green Street, Suite 714
Fayetteville, NC 28301-5095
Re: Notice of Violation and Compliance Evaluation Inspection
NOV-2013-PC-0079, NPDES Permit No. NC0061719
Woodlake Country Club WWTF, Moore County
Dear Ms. Henson:
Thomas J. Roberts
President and Chief Operating Officer
T: 919.653.5770
F: 919.460.1788
[e-mail]
www.aquanorthcarolina.com
Aqua North ,Carolina; :Inc.. (Aqua) offers the; following. response .to. the. Notice of:.Violation ,and
Compliance Evaluation ,Inspection dated March 14, 2013,.NOV-2013-PC-0079.
Solids Management Plan of Action
Aqua has developed a specific Standard Operating Procedure (SOP), which is enclosed, to assist
in the overall improvement of managing solids at the Woodlake Wastewater Treatment Facility (WWTF).
This SOP will allow a clear and concise operating guide for the Operator in Responsible Charge (ORC)
and back-up ORC. The SOP that has been developed considered all of the recommendations that were
provided by your office. Aqua_has_also-developed-a-Sludge-Report that_will_be_submitted to your off c-
each month going forward. --%r
The smaller of f the two aeration basins (original,side) of the WWTF is currently being cleaned and
renovated; tliis. work should be com pleted_b_y_June2013. Once completed, Aqua will gain the redundancy
Land -flexibility needed to be able to take either one of the aeration basins out of service for periodic
cleaning. Our plans are to operate both sides of the WWTF as a dual train to assist in managing flow
surges and to help spread out the settling area of solids in the Aero-Mod units.
Aqua has also reached out to Aero-Mod and have met on -site to evaluate the treatment process.
We await their recommendations on how to better operate the WWTF and will evaluate the
recommendations and, if necessary, revise the SOP.
Additional Items
. Bar Screen and Box: Aqua is in the process of re-evaluating bids for the complete renovation of
a, new bar Screen:and-,box.:. The design will. assist Aqua in removing•.more solids and grit before
entering, the aeration .basins:: We are optimistic.thii ldiprovement will-beTinstalled-and-operational-----1
byt- July 2013:
2. Grit Removal: Aqua has no plans to install a conventional true grit removal system. owever
,-"thei'e-ilforildte-more-grit-removal-once-the-new-barsacenThrid-box is installed. ;
An Aqua America Company

Page Two
Ms. Belinda S. Henson
April 11, 2013
3. Filter Backwash: Aqua currently documents not only theamount of backwash, but also records
the date o` f when it is hauled to the WWTF. In adonr ditio tan he quarterly onitoring of
rc:cOaict vm the effluent,, Agua ras-beguirmonitormg and recording conductivity levels at the4
WWTF-as-noted-in the,.updated-SOP -`Phis will allow Aqua to selyf-assess the rate of transfer and
he effectiveness o the overall treatment of the backwash. We plan to continue to offload the
backwash brine into one of the two digesters but are planning to install a holding tank by the end
of 2014 or earlier to better manage this process.
MR Amendments _Aqua- is unable to amen -the D1' R's—for the astthree years because the,;
two most recent ORC-'s-for-the W-WTF-ate-no-longer employed b Aqua. It is our concern thL
information ould not b. complete without `the-ORC'"s=srgnatures Going -forward the cfianges
requested`have-been= noted_andwtll be reflected 'in fiiture D1VIR s
5. Influent &Infiltrat n (I&I): PA —qua ' is inr the - process of inspecting undeveloped areas in
oodlake that have sewer clean outs in order to make any necessary repairs needed to minimize
I&I. We have ordered manhole rain guards to place in designated areas that we are most
vulnerable to rain water run-off entering into the collection system. Also, the lift stations are
being visually inspected for any I&I issues and pump run times are monitored to determine
possible I&I influences. If any are found, Aqua will make necessary repairs to eliminate the
source of the I&I.
6. In an effort to achieve continuous improvement of the operation of this facility, Aqua regularly
consults with both internal and external resources. Aqua will continue to explore prudent and cost
effective improvements to both the physical structures and the processes.
If you have any questions or comments, please do not hesitate to contact Don Williams at [phone]
or Jack Lihvarcik at (9.19) 653-6964.
Since
ly,
Thomas J. Rcr6erts
President and COO.
TJR/rl
cc: Don Williams
Allen Daniels
Michael Melton
Jack' Lihvarcik
Erich Ulrich, Operator

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woocoake WWTP Operational Duties 4 .,, 1
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''.. " .
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As Needed
' .:, .'i :
Rake and clean barscreen & properly remove dried solids into dumpster
x
Brush, skim, and clean clarifiers
x
Calibrate test equipment (As required per manufactures recommendations )
x
Monitor chemical levels and report/repair any leaks or malfunction in equipment
x
Clean/Maintain interior of all buildings at the plant
x
Clean grounds
x
Insure chlorine contact chambers are free of debri and floating solids
x
Coordinate sludge hauling
x
Decant digester
x
Maintain oil, belts, and filters on blowers
x
Check flow meter and record
x
Replace flow meter paper and ink'
x
Insure proper operation of sludge returns & skimmers
x
Test stationary generator and record run time meter
x
Test mobile generator and record run time meter
x
Check effluent outfall & receiving waters
x
Monitor and record blower motor amperage
x
Monitor and record rainfall
x
Order parts and chemicals
x
Monitor for any plumbing or mechanical repairs
x
Prepare monthly DMR's
x
Insure proper operations & maintenance of all diffusers
• x
Wash down plant (walls, walkways, & diffuser valves) .
x
Waste to digester
x
Test and record aeration levels
pH
x
Temp.
x
Dissolved Oxygen
x
30 Min Settle ability jar test
x
Conductivity (Timed w/ Backwash Hauling)
x
*Sludge Depth (Designated Areas)
x
MLSS
x
Test and record chlorine contact chamber levels , ..
pH
3x
Temp.
3x
Dissolved Oxygen
3x
Conductivity (Timed w/ Backwash Hauling)
x
Pre and Post Chlorine residual
3x
*Sludge Depth(Designated Areas daily and after a major rain event =+/> 3 inches on the
following day)
x
Pump chlorine contact chamber sludge to digester when level is =/> 12 inches within 24
hours.
x
*Slude Depth checked in designated areas. The areas are marked with a green marker and should be collected an arms length from the wall.
ORC Name Print/Sign/Date:
Back-up ORC Name Print/Sign/Date:
4/9/2013