NC0001899_NOV-2022-LV-0574 Response_20220919

Eco TIP West LLC
PO Drawer 9
Sanford, NC 27331
September 19, 2022
Vanessa E. Manuel
Assistant Regional Supervisor
Water Quality Regional Operations Section Raleigh Regional Office
Division of Water Resources, NCDEQ
SUBJECT: RESPONSE TO NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY
Tracking Number: NOV-2022-LV-0574
Permit No. NC0001899
Moncure Holdings West WWTP Chatham County
Dear Ms. Manuel,
This is in response to the Notice of Violation & Intent to Assess Civil Penalty for Eco-Tip West,
LLC dated August 22, 2022. It was noted that the following permit limit exceedances occurred in
the month of June 2022.
Limit Exreedance Violation('s}:
Sample Limit Reported
Location Parameter Date Value Value Type of Violation
001 Effluent Nitrogen, Ammonia Total (as 6/8/2022 2 2.3 Daily Maximum Exceeded
N) - Concentration (C0610)
001 Effluent Nitrogen, Ammonia Total (as 6/30/2022 1 2.05 Monthly Average Exceeded
N) - Concentration (C0610)
The limit exceedances are due to the evaporation of the Wastewater Treatment ponds during this
time period concentrating the naturally occurring ammonia caused by the wildlife in the ponds.
This facility has long since been shut down and the WWTP is due to be decommissioned
between late 2022 and early 2023. No biological treatment exists in the plant and there are no
process and very minimal sanitary inputs to the plant. We saw similar occurrences with BOD
during July 2022, when we were discharging only to meet the Quarterly requirements for
sampling and Toxicity. Toxicity tests performed in July 2022 were passing and showed no ill
effects on the test subjects. No discharge from the plant has occurred since July 26, 2022. As
more rain flow fills the system the BOD and Ammonia constituents will be diluted. Process

Control testing will be done before the next release to ensure compliance with the NPDES
Permit.
Sincerely,
Kirk J. Bradley
Manager, Eco TIP West LLC
CC: Cheng Zhang, NC DEQ, Division of Water Resources, Raleigh Regional Office
Amanda Grenier, Greener EHS Solutions, LLC
WQS, Raleigh Regional Office — Enforcement File