NC0057703_NOV-2021-LV-0733 Response_20211101

AO U A RECENED/NGDENROWR
NOV 012021
October 27, 2021 Water Dually R-9ro
O"llaos section
WWnVV nReybnnl Office
Mr. Tom Tharrington, Assistant Regional Supervisor
Water Quality Regional Operations Section
Wilmington Regional Office
Division of Water Resources, NCDEQ
127 Cardinal Drive Extension
Wilmington, NC 28405
Re: The Cape WWTP, New Hanover County
Permit No. NCO057703
Tracking Number: NOV-2021-LV-0733
Notice of Violation and Intent to Assess Civil Penalty
Dear Mr. Tharrington:
Aqua North Carolina, Inc. (Aqua) offers the following response to the above -
referenced Notice of Violation and Intent to Assess Civil Penalty which was issued
for flow monthly average exceedance and monthly geometric mean exceedance for
enterococci in August 2021.
AQUA started the construction expansion of the Cape WWTF prior to exceeding the
90% flow requirement of 15A NCAC 02T .0118. AQUA received the Authorization to
Construct in March of 2020 and this expansion project was started in June of 2020,
t If,
and originally scheduled for startup in Q1 of 2021; however, issues related to the
ongoing pandemic created delays in both personnel schedules and equipment
supply. The startup will occur in the next two weeks and will expand plant
treatment capacity to 400,000 GPD. Below is a chart of the design, permitting, and
construction sequence for the expansion and please note the facility met the
requirements of 15A NCAC 02T .0118, without exception.
I b0%b8U% exceeded lin Design? 1 90*690%exceeded I In Construction?
2019 207,000.00 208000 No Yes 234000 No No
2020 231,000.00 208000 Yes 234000 No iYes
2021 ytd 245,000.00 208000 234000
Pagel of 3
251 Merchant Circle Building 24-I, Hampstead, NC, 28443 • 910.270.1412 • AquaAmerica.com

AQUA.
As flow itself is not a pollutant of concern and as Aqua has diligently worked to
complete the expansion during a time of exceptional pandemic conditions, please
take in consideration prior to any additional actions.
With respect to the slight (5.8% exceedance) of the monthly enterococci limit, the
wastewater treatment plant was under construction and the operator has diligently
worked to operate and maintain the facility during near constant disruption. Please
note the expansion will have tertiary filtration, UV disinfection with the ability to
also feed sodium hypochlorite and dechlor.
Page 2 of 3
251 Merchant Circle Building 24-I, Hampstead, NC, 28443 • 910.270.1412 • AquaAmerica.com

AQUA
If you have any questions or comments, please do not hesitate to contact me at
[phone].
Sincerely,
&elingus
Area Manager
Aqua North Carolina, Inc.
cc: Joe Pearce
Amanda Berger
Shannon Becker
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251 Merchant Circle Building 24-I, Hampstead, NC, 28443 • 910.270,1412 • AquaAmerica.com