NC0065480_NOV/NOI-2022-LV-0386_20220705

AQUA.
July 5, 2022
Ms. Morella Sanchez -King
Regional Supervisor
DWR / NCDEQ
Water Quality Regional Operations Section
Wilmington Regional Office
127 Cardinal Drive Extension
Wilmington, NC 28405
Re: Notice of Violation and Intent to Assess Civil Penalty
Permit No. NCO065480
Beau Rivage Plantation WWTP
New Hanover County
Dear Ms. Sanchez -King:
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 violations that occurred in April 2022.
Aqua's Response
Aqua is concerned about the long-term viability of the WAS system at Beau Rivage
W WTP. Other utilities using similar systems are having failures, including Moyock
NC. It was recently noted that the WAS media in some of the basins has gradually
become darker over the past few years and is failing to fully slough fixed film
growth. One recommendation was to power wash the media in situ. After multiple
days of continuous power washing, it was determined this wasn't an effective way
to return media to its proper operating condition. AQUA quickly ordered 14 cubic
meters of additional media from the vendor that built the original plant and it was
installed in the basins the week of June 27th. It is hoped that this additional media
provides sufficient surface area to provide the necessary aerobic fixed film to reduce
the risk of non-compliance, and that the overloaded media starves, sloughs, and
returns to normal operation.
The plant continues to have problems treating effluent with consistent low BODs. A
couple changes have been made to the plant after recent visits with expert
treatment personnel. The blowers have been increased to increase the DO, the
caustic fed into the plant has been increased to adjust the incoming pH and
251 Merchant Circle Building 24-I, Hampstead, NC, 28443 • 910.270.1412 • AquaAmericacom

AQUA_
alkalinity (offsetting the acid formation from the septic media) and lastly the MLSS
in the plant has been reduced. In addition, Aqua is having continuous on-line
oxygen analyzers connected to SCADA telemetry to reduce the risk of low dissolved
oxygen situations. AQUA fully expects these changes to improve system operation
and is concurrently exploring the conversion of the facility to a membrane
bioreactor facility.
If you have any questions or comments, please contact me at [phone].
Sincerely,
JoLI A. 5VW—
Area Manager
cc: Joe Pearce
Amanda Berger
Shannon Becker
251 MerchantCircle Building 24-1, Hampstead, NC, 28443 • 910.270.1412 • AquaAmerica.com