WQ0031506_Response NOV-2023-MV-0115_20230717

Orange Water and Sewer Authority
OWASA is Carrboro-Chapel Hill's not -for -profit public service agency
delivering high quality water, wastewater, and reclaimed water services.
July 13, 2023
Vanessa E. Manuel
Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
1628 Mail Service Center
Raleigh, NC 27699-1628
NC Dept of Enviromnental Quality
Re: Notice of Violation & Intent to Assess Civil Penalty
Tracking Number: NOV-2023-MV-0115
OWASA Mason Farm WWTP Non -discharge Permit No. WQ0031506
Dear Ms. Manuel:
'JUL 17 2023
Raleigh Regional Office
The Orange Water and Sewer Authority (OWASA) is in receipt of the subject Notice of Violation
(NOV) dated June 26, 2023 (received July 3, 2023), concerning a monitoring frequency violation for
Turbidity (00076), Carbonaceous BOD (cBOD) (80082), Fecal Coliform (31616), Ammonia Nitrogen
(00610) and Total Suspended Solids (TSS) (00530) (see Attachment 1).
We performed the required turbidity, cBOD, fecal coliform, ammonia nitrogen and TSS sampling
from February 1, 2023 through February 12, 2023. On February 13, 2023, the reclaimed water
(RCW) system was shut down and no flow was discharged from the Mason Farm Wastewater
Treatment Plant to any RCW user for the remainder of February while a contractor replaced
multiple RCW distribution system pipe couplings as part of a Capital Improvements Program
project. The RCW system resumed operation on March 7, 2023.
In the February 2023 NDMR, we noted the incorrect RCW system shutdown date of February 19,
2023 instead of the correct date of February 13, 2023. Therefore, it appeared as though the
February 2023 NDMR report was missing sample data from February 13tn through February 19tn
Per guidance received from you and a voicemail from Dorothy Robson on July 10, 2023, we revised
and resubmitted our February 2023 NDMR (see Attachment 2) on July 11, 2023. In the revised
report, we stated in each testing parameter column 'No Flow' from February 13' through
February 28'. We also revised the statement on the certification page to make note of the correct
date we stopped sending flow out from the reclaimed water system.
To prevent this clerical error from happening again, we have changed our reporting process to
include 'No Flow' in the individual parameter cells for each day the RCW system is shut down in
the future.
0 400 Jones Ferry Road, Carrboro, NC 27510 0 919-968-4421 0 [e-mail] 0 @OWASA_NC 0 www.owasa.org

Response to Notice of Violation (NOV-2023-MV-0115)
Non -discharge Permit No. WQ0031506
July 13, 2023
Page 2
Thank you for your guidance and support working through this process. We respectfully request
NOV-2023-MV-0115 be rescinded in consideration of the information we have provided including
(1) we did not have monitoring frequency violations, rather we had a clerical error and typed the
incorrect date the reclaimed water system was shut down for maintenance on the NDMR; (2) we
submitted the revised NDMR indicating no flow on the dates the system was shut -down as soon as
we were notified of the issue and received guidance on how to correct it; and (3) we have taken
corrective action to prevent reoccurrence on future NDMRs.
If you have any questions or need any additional information, please do not hesitate to contact me
or Wil Lawson, Wastewater Treatment and Biosolids Recycling Manager at [e-mail]
or [phone].
Sincerely,
I
Todd Taylorl.E.
Executive Director
Attachments:
1. NOV-2023-MV-0115
2. Revised February 2023 NDMR
CC: Mary Darr, PE, General Manager of Operations
Wilmer Lawson, Wastewater Treatment and Biosolids Recycling Manager
Travis Rich, Operations Supervisor
Ronnie Weed, Laboratory Supervisor

DowSign Envelope ID: CBFCC7B1-0B55-4952-8666-4DC54842B902
M l 0 llJ � HJUL — , 2023
Attachment 1
Certified Mail # 7020 3160 0000 2219 4911 NC Dept
Return Receipt RequestedofEitviromnental Quality
June 26, 2023
Todd Taylor JUL 1 .f 2023
Orange Water and Sewer Authority igh Regional
400 Jones Ferry Rd Office
Carrboro, NC 27510-2001
SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CML PENALTY
Tracking Number: NOV-2023-MV-0115
Permit No. WQ0031506
Mason Farm WWTP
Orange County
DearPermittee:
A review of the February 2023 Non -Discharge Monitoring Report (NDMR) for the subject facility revealed the
violation(s) indicated below:
Monitoring Wolationfs):
Sample
Monitoring
Location
Parameter Date
Frequency
Type of Violation
001
Turbidity, HCH Turbidimiter (00076) 2/13/2023
Continuous
Frequency Violation
001
Turbidity, HCH Turbidimiter (00076) 2/14/2023
Continuous
Frequency Violation
001
Turbidity, HCH Turbidimiter (00076) 2/15/2023
Continuous
Frequency Violation
001
Turbidity, HCH Turbidimiter (00076) 2/16/2023
Continuous
Frequency Violation
001
BOD, Carbonaceous 05 Day, 20 C 2/18/2023
2 X week
Frequency Violation
(80082)
001
Coliform, Fecal MF, MFC Broth, 2/18/2023
2 X week
Frequency Violation
44.5 C (31616)
001
Nitrogen, Ammonia Total (as N) 2/18/2023
2 X week
Frequency Violation
(00610)
001
Solids, Total Suspended (00530) 2/18/2023
2 X week
Frequency Violation
001
Turbidity, HCH Turbidimiter (00076) 2/18/2023
Continuous
Frequency Violation
GRE�'

DocuSign Envelope ID: CBFCC7B1-OB55-4952-86664DC54842B902
A Notice of Violation/Intent to Issue Civil Penalty is being issued for the noted violation of North Carolina General
Statute (G.S.) 143-215.1 and the facility's Non -discharge Permit. Pursuant to G.S. 143-215.6A, a civil penalty of
not more than twenty-five thousand dollars ($25,000.00) may be assessed against any person who violates or
fails to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S.
143-215.1.
If you wish to provide additional information regarding the noted violation, request technical assistance, or
discuss overall compliance please respond in writing within ten 10 business days after receipt of this Notice.
review of your response will be considered along with any information provided on the submitted Monitoring
Report(s). You will then be notified of any civil penalties that may be assessed regarding the violations. If no
response is received in this Office within the 10-day period, a civil penalty assessment may be
prepared.
Remedial actions should have already been taken to correct this problem and prevent further occurrences in the
future. The Division of Water Resources may pursue enforcement action for this and any additional violations of
State law. If the violations are of a continuing nature, not related to operation and/or maintenance problems,
and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by
Consent.
Reminder: Pursuant to Permit Condition 6 in Section E, the Permittee is required to verbally notify the Regional
Office as soon as possible, not to exceed 24 hours, from first knowledge of any non-compliance at
the facility including limit violations, bypasses of, or failure of a treatment unit. A written report may
be required within 5 days if directed by Division staff. Prior notice should be given for anticipated or
potential problems due to planned maintenance activities, taking units off-line, etc.
If you have any questions concerning this matter or to apply for an SOC, please contact Dorothy Robson of
the Raleigh Regional Office at 919-791-4200.
Sincerely,
C.. 0000spom nr:
Vav"t,SSa f. 1(4alwd
929t6E6A99214F_
Vanessa E Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Cc: WQS Raleigh Regional Office - Enforcement File
NON -DISCHARGE Laserfche

FORM: NDMR 03-12
NON -DISCHARGE MONITORING REPORT (NDMR)
Attachment
Page 1 of .1
Permit No.: WQ0031506
Facility Name: Mason Farm WWTP
County: Orange
Month: FEBRUARY
Year: 2023
PPI: 001
Flow Measuring Point: ❑ Influent Q+ Effluent No (low generated
Parameter Monitoring Point: El influent 2 Effluent Groundwater Lowering ❑ Surface Water
Parameter Code
WQ01
80082
31616
00076
C0610
C0530
A
u
tY
p
c
p
U t0
rd0
uo
0
O
e m
'e "'
V
u c
U
`
f'3
E
E
Q
g.o
0 an
w
24•hr
him
gallons
mg/L
71.1/100 ml
NTU
mg/L
mg/L
1
700
9
<2
1.1
<0.10
<2.5
2
630
10.5
<2
<1
2.0
<0.10
3
700
8
.O
<2
1A
<2.5
4
700
13.5
ad.�
0.7
5
700
13
'C
�+
0.4
6
0.4
<0.10
<2.5
7
700
8.5
N
<2
<1
0.4
<0.10
8
700
13.5
<2
0.4
<0.10
<2.5
9
630
12.5
.d„
<2
<1
0.4
<0.10
10
700
10.5
M
<2
0.8
<2.5
11
*O
0.7
12
E
0.6
13
700
9.5
'tp
No Flow
No Flow
No Flow
No Flow
No Flow
14
700
9.5
Ct
No Flow
No Flow
No Flow
No Flow
No Flow
15
700
9.5
No Flow
No Flow
No Flow
No Flow
No Flow
16
700
8
r_
O
No Flow
No Flow
No Flow
No Flow
No Flow
17
700
9
�
No Flow
No Flow
No Flow
No Flow
No Flaw
18
1900
7.5
No Flow
No Flow
No Flow
No Flow
No Flow
19
O
No Flow
No Flow
No Flow
No Flow
No Flow
20
700
7.5
No Flow
No Flow
No Flow
No Flow
No Flow
211
700
1 9
No Flow
No Flow
No Flow
No Flow
No Flow
22
700
10
"
No Flow
No Flow
No Flow
No Flow
No Flow
23
1900
13.5
t
No Flow
No Flow
No Flow
No Flow
No Flow
24
1900
13
a+
No Flow
No Flow
No Flow
No Flow
No Flow
25
1900
13
C
No Flow
No Flow
No Flow
No Flow
No Flow
26
1900
15
W
No Flow
No Flow
No Flow
No Flow
No Flow
27
700
8
No Flow
No Flow
No Flow
No Flow
No Flow
28
700
10
No Flow
No Flow
No Flow
No Flow
No Flow
1
Average:
0.00
1.00
0.33
0.00
0.00
Daily Maximum:
2,316,000
2.00
1.00
2.00
0,10
2.50
Daily Minimum:
2.00
1.00
0.40
0.10
2.50
Sampling Type:
Recorder
Composite
Grab
Composite
Composite
Composite
Monthly Avg. Limit:
10
14
4
5
Daily Limit:
15
1 25
10
5
10
Sample Frequency:
Continuous
2 z Week
2 a Week
continuous
2 v Week
2 z Week

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iei

FORM: NDMR 03-12 NON -DISCHARGE MONITORING REPORT (NDMR) Page 3 of 3
Sampling Persons) Certified Laboratories
Name: Ronne Weed Name: OWASA
Name: Travis Rich Name: PACE Analytical, LLC
Does all monitoring data and sampling frequencies meet the requirements in Attachment A of your permit? O complern ❑ Nan.cpmpllent
If the facility is non -compliant, please explain in the space below the reason(s) the facility was not in compliance. Provide in your explanation the date(s) of the non-compliance and describe the corrective action(s) taken.
Attach additional sheets if necessary.
This revision changes the shutdown/no flow period previously listed on the originally submittal. The no flow period for the rcw system was from Feburary the
13th, 2023 to March 7th, 2023.
Operator in Responsible Charge (ORC) Certification
Permittee Certification
ORC: Travis Rich
Permittee: Orange Water and Sewer Authority
Certification No.: 999730
signing Official: Wilmer Anthony Lawson
Grade: IV Phone Number: 919-537-4354
signing official's Title: Wastewater Treatment & Biosolids Recycling Manager
Has the ORC changed since the previous NDMR? ❑ yes 0 No
Phone Number: 919-537-4351 Permit Expiration: 11/30/2027
Ki 07/10/2023
Signature Date
Signature Date
By this signature, I candy that this report Is eccurets and complete to the bast of my knowledge.
I rangy, under penally of law, that this document and all attachments were prepared under my direction or supervision In accordance with a
system designed to assure that all qualified personnel properly gathered and evaluated the Information submitted. Based on my inquiry of
the person or persons who manage the system, or those persons directly responsible for gathering the information, the information
submitted is, to the beat of my knowledge and babe( Ime, accumle, and complete. I am aware that there are significant penalties for
submitting false informeton, including the possibility of fins and imprisonment for knowing violations.
Mail Original and Two Copies to:
Division of Water Quality
Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617