NC0086291_LV-2023-0035, LV-2023-0036_20230203

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N�RTH'CARO - A
ovddi3PORAl'ED j722
John Hennessy
Supervisor
Wastewater Branch
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
February 03, 2022
Re: Notice of Violation and Assessment of Civil Penalty
For Violations of North Carolina General Statute (G.S.) 143-215.1 (a)(6)
And NPDES WW Permit No. NCO086291
And NPDES WW Permit No. NC0007552
Town of Edenton
Beaver Hill WTP
Case No. LV-2023-0035
Case No. LV-2023-0036
Case No. LV-2023-0034
Case No. LV-2023-0033
Dear Mr. Hennessy,
Please accept this letter and the included attachment(s) as a written request for remission for Case No. LV-
2023-0033, Case No. LV-2023-0034, Case No. LV-2023-0035, and Case No. LV-2023-0036. The Town of
Edenton first received notice in August of 2022 regarding the exceeded limit for Chlorides from the Beaver Hill
WTP (NC0086291) & Freemason (NC0007552). Since this time the WTP ORC (Roy Alons) & Town Manager
(Corey Gooden) have worked towards developing a corrective action plan for the effluent chloride exceedance
but have exhausted all internal options. We have also reached out for guidance from the Washington regional
office BUT do not see a logical option to meet the 230 mg/l limit within our water system.
Printed on Recycled Paper
P.O. BOX 300, Edenton N.C. 27932 - [phone]
[phone] - FAX

Since the 1st notice in August of 2022, the Town of Edenton sampled all water sources (on 11/09/2022) within
the water system ranging from each of the four (4) raw water well sites, both water treatment plants, and the
open water discharge points. These results are included in Attachment 1— Environment I Chloride sample
results, for a total of three (3) pages. Of the Town's four (4) well sites, two (2) were over the 230 mg/1 limit and
the remaining two (2) wells were at 60-72% of the limit. For the WTP site, one was over the limit and one was
70% of the limit. Lastly, when looking at the discharge points upstream and downstream, the open water bodies
are more that 550 to 750% of the limit. Often times the limit appears to be the lowest number in the group,
which creates quite a challenge for us.
The Town of Edenton was recently awarded funding for two (2) additional well sites and an interconnect
between the two (2) raw water tanks at each plant location. The goal of the project is to improve the raw water
quality of the Town's well site and to use any raw well at either plant. We have also applied for a third well site
in the most recent fall round of DWI funding and we are optimistic this funding will also be successful. The
implementation of both projects would greatly increase the water chemistry and quality of our aging system.
We know that until that time, we will likely and often not meet the limit.
In the Interim, The Town of Edenton would like to request that we (1) be considered for a reduced or removed
penalty and, (2) be considered for a permit variance for this often -unreachable limit.
Sincer y,
Ian Gooden
own Manager
Cc: Julie Grzyb, Deputy Director of DEQ Division of Water Resources
Robert Tankard, Assistant Supervisor, Division of Water Resources, DEQ
Sarah Toppen - Environmental Specialist II, Division of Water Resources, DEQ
Robbie Bullock - Environmental Specialist II WWTP Consultant, Division of Water Resources, DEQ
David Meyers, Edenton PW Director
Roy Alons, Edenton WTP Supervisor

114 OAKMONT DRIVE
GREENVILLE, N.C. 27858
TOWN OF EDENTON
MR. ANTHONY JORDAN
PUBLIC WORKS DEPARTMENT
P.O. BOX 300
EDENTON, NC 27932
PARAMETERS
Chloride, mg/l
Wastewater XVt lu
PHONE [phone]
FAX [phone]
ID#: 58 Z
DATE COLLECTED: 11/09/22
DATE REPORTED : 11/16/22
REVIEWED BY:
Sample Sample Sample Sample Sample Analysis Method
#1 #2 #3 #4 #5 Date Analyst Code
291 406 139 167 1730 11/14/22 JDJ 4500CLB-11

Emmfl(W 1, hgopudA
114 OAKMONT DRIVE
GREENVILLE, N.C. 27858
TOWN OF EDENTON
MR. ANTHONY JORDAN
PUBLIC WORKS DEPARTMENT
P.O. BOX 300
EDENTON, NC 27932
pARAMETERS
Chloride, mg/1
Sample Sample
#6 #7
1270 327
Ll
PHONE [phone]
FAX t252) 756-0633
ID#: 58 Z
DATE COLLECTED: 11/09/22
DATE REPORTED : 11/16/22
REVIEWED BY:
Sample Analysis Method
#8 Date Analyst Code
163 11/14/22 JDJ 4500CLB-11

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