NC0020354_Response to NOV-2024-LM_0009_Chatham Park Water Recovery Center_20240213

February 13, 2024
North Carolina Department of Environmental Quality
Division of Water Resources
Attn: Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
3800 Barrett Drive
Raleigh, NC 27609
RE: Notice of Violation & Intent to Assess Civil Penalty
Tracking Number: NOV-2024-LM-0009
Permit No. NC0020354
Chatham Park Recovery Center
Chatham County
Dear Ms. Manuel:
This letter is in response to the NCDEQ-DWR letter of February 6, 2024 regarding the violations
that were identified through the review of discharge monitoring reports (DMRs) for the December
2023 monitoring period.
The letter identified three exceedances for this period and were identified as Daily Maximum
Exceeded for Nitrogen, Ammonia Total on December 18, 2023, Daily Maximum Exceeded for
BOD, 5-Day (20 Deg C) on December 29, 2023 and for Monthly Average Exceeded for Nitrogen,
Nitrate Total (as N).
This exceedance can be attributed to the low flow and the inability to perform efficient treatment at
the low flows experienced by the facility. The average flow for this period was 39,000 gallons per
day which is less than 10 percent of permitted flow, which leads to treatment inefficiencies.
Effluent sampling results for the exceedance for December 18 of Ammonia, previous day was
result of < 0.1 mg/L and the day following 0.8 mg/L, with no operational changes or modifications
to plant operations. For the BOD Daily Max exceedance on December 29 the day previous was 9.8
mg/L with the following day 2.0 mg/L, with no operational changes or modifications to plant
operations. With an increase in flow, the plant will be able to more efficiently provide adequate
and efficient treatment.

The monitoring violations we take exception with as Five (5) Fecal Coliform samples were taken
December 4-December 8, 2023 and Five (5) Fecal Coliform samples were taken December 11-
December 15, therefore no monitoring frequency violation occurred. The monitoring violation for
Total Nitrogen calls for a weekly frequency and one was taken during week of December 4-
December 8, 2023, one was taken December 11-December 15, 2023, one was taken week December
17-December 20, 2023, and one was taken week of December 27-December 29, 2023.
Thank you again for continuing to work with the Chatham Park Water Recovery Center. We look
forward to working with NCDEQ-DWR in a very positive and proactive manner as we continue to
improve the facility's environmental stewardship. If upon receipt and review of this information
you have any questions or would like to discuss this matter at greater length, please do not hesitate
to contact me at your earliest convenience at [phone] or Tim Smith at [phone].
Sincerely,
McKim & Creed
James W. Holland, PE
Process Group Leader
cc: Tim Smith
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