WQ0000088_NOV-2023-LV-0610_20231018

Manuel, Vanessa
From: Goodson, Miranda D <[e-mail]>
Sent: Wednesday, October 18, 2023 9:24 AM
To: Manuel, Vanessa
Cc: Becker, Shannon V; Pearce, Joseph R; Raup-Plummer, Lauren A.; Krueger, Robert D;
Lambeth, Robyn E
Subject: [External] Governors Club WWTP NOV-2023-LV-0610
Attachments: Governors Club WWTP NOV-2023-LV-0610.pdf
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Good Morning Ms. Vanessa,
Attached is Aqua's response to the Governors Club WWTP NOV-2023-LV-0610, the original will be mailed to
you. Please advise if you have any questions or require further information.
Thanks in Advance,
.7vliranda
A U X
Miranda Goodson
Administrative Assistant I
Aqua North Carolina, Inc.
202 Mackenan Court, Cary NC 27511
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A UA_
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.
Aaua'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.
IJ. Reclaimed w.rto ul,e,juon lidds Imnnumd I to S,pm nba I, 21JU6 bare comphancc nurl re%iru
boundaries established at the propem Iwundan'. Am e\cccd;mec of _rounda'atcr stmd:ads at or
he%ond the compliance houndar, +ball require rorleoke anion. 1)o Polna-appmted tnloealion ollhe
compliance txmndap shall he noted ,I Attachment R. Nlultlple ;onneuous proFxntcs under common
ownership and Ixnnitied Rrr u.c as a dt.posal system Shill he treated :, ,since prop.. nnth reeard
nt demnnl:IATOn of a compliance boondarv. Iti.A V 4( u'1_ ltlun. u71 alo+dn. Ie.H
0.'.10f1,n 14(Ni HIll" G S I43-'IgIIi1OS 14?-'1ij(kII
15. Ill, pcnnalcc shall apply hot a pcuwt I...4ticunon T, r,mbl ,h .; ncs, compliance lotmdary peon to
nq ;i1c or innstirot propMe attesting a comphance boundaty li e. p wol subdi, kion). I ISA\C'AC
OIL ul!I- 0I
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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
2