NC0038784_Response to Notice_20221228

December 28, 2022

Vanessa E. Manuel,
Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office,
Division of Water Resources, NCDEQ
3800 Barrett Drive
Raleigh, NC 27609

Re: Compliance Inspection Report
Neuse River Village WWTP
Permit No. NC0038784
Wake County

Dear Ms. Manuel:

Aqua North Carolina, Inc. (Aqua) offers the following response to the above-referenced Compliance
Inspection Report, during evaluation on November 30, 2022, for item 8 and 12.

The overflow weirs appeared to be level and algae free. The operator used a sludge judge to measure the
sludge depth. Clarifier #1 showed the sludge depth to be approximately 9 feet deep with basin
approximately 9 feet deep. It is recommended that the sludge depth not exceed ¼ the sidewall depth of the
clarifier. Measures should be taken to reduce the amount of sludge in clarifier #1.

Mr. Casey stated for the fecal coliform sampling, he grabs the sample at the V notch weir below the plant
which is right after chlorination. The wastewater then enters the settling basin where it receives
dichlorination and is then discharged into the Neuse River. Grab samples must be representative of the
discharge. All effluent samples should be taken after all treatment, including dichlorination. Please respond
in writing the protocol for the collection of the fecal coliform grab sample which will ensure a representative
sample is collected.

Aqua’s Response:

8. Significant effort has been made for operational staff to convert to MLSS control versus sludge depth in
their clarifiers. Aqua has found that the sludge depth in the clarifier as a control point will often result in
over wasting and will result with a young sludge which results in even poorer settling. Aqua would like to
discuss more in detail at NCDEQ’s leisure and also request that this comment be amended in the CEI.

12. The current grab sample location was approved onsite by the previous inspector from Wake County
who was acting under an improper MOA between NCDEQ and Wake County.
The post treatment pond is consistently battling natural influences such as algae growth and temperature
changes that have caused elevated TSS results in the past. Aqua would like a clear decision on the location
for we were only sampling at this location due to the request of the last inspector.

If you have any questions or comments, please do not hesitate to contact me at [phone].

Sincerely,

Robert Krueger

Robert Krueger
Area Manager

cc: Joseph Pearce
Amanda Owens
Shannon Becker