WQ0005134_Correspondence_20220829 (2)

Wake County Wildlife Club
PO Box 99048
Raleigh, NC 27624-9048
Monday August 29, 2022
North Carolina Department of Environmental Quality
Division of Water Resources
Raleigh Regional Office
3800 Barrett Drive
Raleigh, NC 27609
Dear Ms. Manuel,
Wake County
Wildlife Club
I spoke with Molly Nicholson in your office once we finally received these Notices of Violations
(NOV's) and have also emailed with her on more than one occasion. Please rest assured that we
take these notices seriously and have been working with our contractor (G.C. Environmental,
Inc.) and our board of directors to understand the issues and come up with a plan for
remediation going forward.
G.C. Environmental assures us that since receipt of the WCWC wastewater system permit in
May of 2020, they have operated the system to include pH and chlorine measurements during
and in conjunction with spraying activities. Apparently G.C. Environmental must determine if
spray conditions are acceptable (per permit and state guidance) during weekly on -site visits
where freeboard, soil wetness, recent rain fall, and weather conditions are evaluated prior to
initiating a spray event. Unfavorable weather conditions at the site during the same site visits
preclude state certified laboratory analyses with sensitive lab equipment to obtain pH and
chlorine parameter results. Unfavorable weather conditions or a very recent rainfall event
triggers a delay in either conducting a spray event and or collecting test parameters for one or
more days which would require an additional visit. Another point of concern from G.C.
Environmental is the level of infiltration that the system may experience due to heavy rain
events and the impact that may have on the system to maintain a consistent chlorine residual.
These operational constraints can substantially increase the operating costs for these type of
systems in respect to weekly monitoring for pH and residual chlorine. G.C. Environmental
advises that we request the Division of Water Resources considers the aforementioned items
and issue a modification to the subject permit to only require pH and chlorine residual
measurements in conjunction with spray activities.
G.C. Environmental, Inc's understanding of the permit required them to visit the facility on a
weekly basis, and to conduct measurements for pH and chlorine residual of the wastewater
during a spray event under favorable weather conditions. We are being advised by G.C.
Environmental that we request clarity from the Division of Water Resources on how to
appropriately document these conditions on the Non -Discharge Monitoring Report and will
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request this weekly monitoring be contingent on the irrigation system being operated for next
permit renewal in 2026. At Molly Nicholson's recommendation, we have already reached out to
Nathaniel Thornburg at NCDENR, but haven't received a response as of this letter.
We are a 501-C4 volunteer organization dedicated to wildlife conservation and education. In
over 30+ years we have stressed the importance of taking care of our natural resources with
the over 9,000 students we've been fortunate to interact with. Again, we take these notices
seriously and will do everything we can to rectify the situation as soon as possible.
Sincerely,
N.
Mr. G.W. Atkinson, President
Wake County Wildlife Club
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