WQ0002648_Notice of Violation_20240404

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
April 4, 2024
CERTIFIED MAIL No. 7022 2410 0003 1826 9852
RETURN RECEIPT REQUESTED
Michael T. Walker — Secretary
Seagrove — Ulah Metropolitan Water District
P.O. Box 370
Seagrove, North Carolina 27341
SUBJECT: Notice of Violation (NOV-2024-LV-0251)
Seagrove — Ulah Metropolitan Water District WWTP
Permit No. WQ0002648
Randolph County
Dear Mr. Walker:
A review of the July and November 2023 groundwater monitoring reports has been
completed by this office of the Division of Water Resources. This review reflected non-
compliance with Permit No. WQ0002648 and 15 NCAC 02L Groundwater Quality
Standards. The following violations are noted:
Well
Date
Parameter
Concentration
2L Standards
MW3
07/31/2023
Nitrogen, Nitrate Total (as N)
11.2 mg/L
10 mg/L
MW3
11/30/2023
Nitrogen, Nitrate Total (as N)
12.9 mg/L
10 mg/L
A review of additional sample events shows that the nitrate concentration in MW2 and
MW3, both downgradient wells, has been trending upward for since at least November
2018. Monitoring Well 3 is located on the compliance boundary of the facility. Based on
the findings and per 15A NCAC 02L .0106(e), you are required to complete a
Comprehensive Site Assessment (CSA), and a corrective action plan may be needed.
Per 15A NCAC 02L .0106(e)
"For any person conducting or controlling an activity which is conducted under the
authority of a permit issued by the Department pursuant to G.S. 143-215.1, Article
9 of G.S. 130A, or article 11 of G.S. 130A that results in an increase in
concentration of a substance in excess of the standards at or beyond a compliance
boundary or within the compliance zone as specified by Rule .0107(p) of this
Section, the person shall take the following steps:
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105
NoanicaaouNn
oep.m.m or em�nmen� Qualm
336.776.9800

(1) Within 24 hours of discovery of the initial violation, notify the Department of
the activity that has resulted in the increase, the contaminants that are in
exceedance, and the contaminant concentration levels.
(2) Respond in accordance with Paragraph (f) of this Rule.
(3) Implement a monitoring program in accordance with Rule .0110 of this
Section.
(4) Submit a site assessment report to the Director in accordance with Rule
.0111 of this Section.
(5) Submit a notification in accordance with the requirements of Rule .0114(a)
of this Section.
(6) If required, submit a corrective action plan to the Director in accordance with
Rule .0111 of this Section or pursue risk -based remediation per Paragraph
(i) of this Rule. The corrective action plan may include alteration of existing
site conditions, facility design, or operational controls that will prevent a
violation at the compliance boundary. If a corrective action plan is submitted
for active remediation or natural attenuation, then:
(A) Submit a notification in accordance with the requirements of Rule
.0114(b) of this Section.
(B) Implement the corrective action plan upon its approval by the
Secretary.
(C) Submit a notification in accordance with the requirements of Rule
.0114(c) of this Section.
As indicated in 15A NCAC 02L .0106(f)(2), response actions are required, which should
include, but are not limited to, control and/or removal of the contaminant source to the
treatment facility and irrigation fields, additional monitoring well sample events, and
surface water sampling.
The CSA must assess the cause, significance, and extent of the violation of standards,
and you are required to submit the results of the investigation prior to submitting a
Corrective Action Plan. Per 15A NCAC 02L .0111(b), the CSA should include the
following items:
1. a description of the site including current and historical operations at the facility
and all current and historical waste streams;
2. the source and cause of contamination;
3. any imminent hazards to public health and any actions taken to mitigate them;
4. a description of the initial response actions taken in accordance with Rule .0106(f)
of this Section;
5. all potential receptors and expected exposure pathways;
6. the horizontal and vertical extent of soil and groundwater contamination and all
significant factors affecting contaminant transport;
7. background threshold values for affected media;
8. geological and hydrogeological features influencing the movement, chemical, and
physical character of the contaminants;
NORTH CAROLINAD��` ��I
0_u Mo Emimnmen 9uei�
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Winston-Salem, North Carolina 27105
336.776.9800

9. the nature and extent of any surface water or sediment contamination resulting
from interactions with contaminated soil or groundwater;
10. a description of the sampling procedures followed, and methods of chemical
analyses used;
11. all technical data utilized in support of any interpretations, conclusions,
determinations, or evaluations made; and
12. the results of predictive calculations or modeling, including a copy of the
calculations or model runs and all supporting technical data.
All reports and plans shall be prepared under the charge of a professional engineer,
licensed soil scientist, or licensed geologist.
You are required to provide a report summarizing an initial response to this Notice of
Violation within forty-five (45) days of its receipt. The initial response could include any
actions taken, such as resampling of the monitoring wells, increased wastewater
treatment efficiency, or decreased irrigation. Once this response is received by our office,
a schedule for the CSA will be established. If you have any questions, please contact
Caitlin Caudle at the letterhead address and phone number, or by email at
caitlin.caudle�deg.nc.gov.
Sincerely,
DocuSigned by:
OD2D3CE3F161456...
Jennifer F. Graznak, Assistant Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
Enc: Attachment A: Historic Nitrate Levels (mg/L)
Site Map
Cc: Randolph County Environmental Health
Larry Chilton, ORC (electronic copy)
Scott Cole, Board Member (electronic copy)
NORTH CAROLINAD E Q
oeo+ro�.m m F,mro���w n�si�
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Winston-Salem, North Carolina 27105
336.776.9800

Attachment A: Historic Nitrate Levels (mg/L)
Samling
Event
MW1
(Background)
MW2
(Downgradient)
MW3
(Downgradient)
2L
Standard
%
Over
11 /2023
1.32
8.46
12.9
10.0
29%
7/2023
0.652
7.01
11.2
10.0
12%
3/2023
0.066
6.25
8.12
10.0
0%
11/2022
0.104
4.41
7.85
10.0
0%
7/2022
0.187
6.16
8.09
10.0
0%
3/2022
0.13
2.74
5.37
10.0
0%
11/2021
0.302
7.47
8.88
10.0
0%
7/2021
0.08
5.44
6.76
10.0
0%
3/2021
0.14
1.51
1.62
10.0
0%
11/2020
0.112
6.43
8.90
10.0
0%
7/2020
0.086
4.99
5.70
10.0
0%
3/2020
<0.05
6.16
8.72
10.0
0%
11/2019
<0.05
3.24
5.04
10.0
0%
7/2019
<0.05
3.24
5.04
10.0
0%
3/2019
0.39
8.26
9.06
10.0
0%
11/2018
0.36
8.74
9.06
10.0
0%

Seagrove -Utah
WQ0002648
-
--arS a ./.T y � •�
�I � 9 � j •. w• 1�
iT fi
• 2 mil gal Lagoon
WWTF
588,000 gal Lagoon
' Bear Creek E.
N -
Lane #1
Lane #2 < f
e #3 4a ane ale ,•
LanQe 116
Lane #4{jgj,
<a 4
� 40 acre ne&S
y Lane#15 Spray Field +F
a
Lane #16
'�.rkr—�Q .�e MW-2
'y va
N t
J 4J
C
1
r
Approx. Scale: 1 inch,= 200 feet l ,�