WQ0000088_NOV-2023-LV-0610_20231025

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October 18, 2023
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: Notice of Violation & Intent to Assess Civil Penalty
Governors Club W WTP, Chatham County
Permit No. W00000088
NOV-2023-LV-0610
Dear Ms. Manuel:
Aqua North Carolina, Inc. (Aqua) offers the following response to the above -referenced Notice of Violation and Intent
to Assess Civil Penalty, which was issued for Chloride, pH, and TDS from the March 2023 Ground Water Monitoring
Report.
Aqua's Response:
The Aqua engineering team, in concert with our external engineering and hydrogeological consultants, are actively
investigating and will determine if this is an error in sampling or if a corrective action plan per the permit condition is
necessary. If a corrective action plan is necessary, it is expected to be produced within the next 90 days.
14. Reclaimed water irrigation fields permitted prior to September I, 2006 have compliance and review
boundaries established at the property boundary. Any cxcccdaacc of groundwater standards at or
beyond the compliance boundary shall require corrective aclion. Division -approved relocation of the
compliance boundary shall be noted in Attachment B. Multiple contiguous properties under common
ownership and permitted for use as a disposal system shall be treated as a single property with regard
to determination of a compliance boundary. I15A NCAC 02L .0106, 02T .0105(h), 02H
.0219(kX I XC)(iXllp, G.S. 143-215.1(i), G.S. 143-215.1(k)I
15. The Permium shall apply for a permit modification to establish a new compliance boundary prior to
any sale or transfer of property affecting a compliance boundary (i.e.. parcel subdivision). 115A NCAC
02L .0107(c))
W 00000088 Version 4.1 Shell Version 200201 Page 4 of 13
As this is a groundwater violation and per the permit condition, the assessment of a civil penalty does not appear
appropriate. Additionally, please recognize that the irrigation sites for the golf course primarily use fresh water and
not the reclaimed water generated at the treatment plant. As such, the golf course co -applies fertilizers and pesticides,
and the golf operation may be the source of pollutants of concern. Aqua does not control these applications and as for
any potential contamination event, it is important that the source be properly identified. If you believe differently, we
request a meeting with your office. If you have any questions or comments, please do not hesitate to contact me at
[phone].
Sincerely,

Robert Krueger
Area Manager
cc: Joseph Pearce PE
Lauren Raup-Plummer PE
Shannon Becker