WQCS00240_Remission Request_20181130

AQUAS.
November 30, 2018 RECEIVED/DEN
DEC 042018cesR/DWR
Ms. Morella Sanchez King,Acting Regional Supervisor Water Resour
Water Quality Regional Operations Section Permitting section
Wilmington Regional Office
Division of Water Resources,NCDEQ
127 Cardinal Drive Extension
Wilmington,NC 28405
Re: The Cape,New Hanover County,Permit No.WQCS00240
Case No. PC-2018-0029
Notice of Violation and Assessment of Civil Penalty
New Hanover County
e
Remission Request
Dear Ms.King:
Aqua North Carolina, Inc. (Aqua) formally requests remission for the following violations and penalty
assessments for The Cape Collection System Inspection on June 8,2018.
Aqua's Findings and Request for Remission:
Pump Station: Bala PS#5 control panel still not replaced or reinforced after nearly 2 years.
Found not secure as well
During the inspection on June 8,2018,Aqua personnel discussed with Mr. Dean Hunkele(Inspector)
that Aqua had determined to take the approach to schedule improvements for all the lift stations within
the Cape Collection System.The first phase of this project was completed in 2017/2018,and the
second phase included the upgrade of the control panels.The project was spread out over a multi-year
window due to funding allocations and extensiveness of the project. The project required considerable
coordination between various entities to include,the New Hanover County Building and Codes
Department and Duke Power.Due to delays from those entities the project was behind schedule;
however,Aqua personnel did inform Mr. Hunkele that the quick connect, disconnect,and panel board
were scheduled to be upgraded.Those components were installed by July 2018. Aqua continues to
coordinate activities with Duke Power to complete the project.
In the Assessment Factor worksheet,the penalty was assessed for the duration and gravity of the
violation and amount of money saved by non-compliance.Aqua disagrees with the assessment that it
had not taken measures to correct the issue and had and continues to spend money to perform
operation and maintenance upgrades throughout The Cape Collection System. This information and
evidence of such actions was discussed and provided during the inspection. Aqua requests remission
of the$350.00 penalty based on evidence provided during the inspection that demonstrates that it had
202 MacKenan Court, Cary, NC 27511 • AquaAmerica.com

Page Two
Ms. Morella Sanchez King
November 30,2018
in fact taken measures to correct the known deficiency and had spent significant capital dollars to
complete improvements not only at the Bala LS,but throughout the collection system.
Pump Station:
Bella Point PS not secure&not posted 5 months after certification
Bella Point Lift Station was certified in late January 2018. Although certified on that date,the system
had not been receiving flow as homes were not yet built and activated on the system. Immediately
after the inspection Aqua placed temporary signs and ordered permanent signs which were installed
immediately upon receipt from the manufacturer.Aqua requests remission of the $350.00 penalty as
the assessment factors were based on long-standing deficiencies,and this was not a long-standing
deficiency, did not contribute to any environmental impact,and they took immediate action to address
the concern noted by Mr. Hunkele.
Pump Station:
River Oaks Section 8 PS not secure&not posted 2 years after certification
River Oaks Lift Station was certified in late January 2016. Although certified on that date,the system had
not been receiving flow throughout the duration since certification.Homes were built and contributed to
the flow to that lift station over a period of time since certification. Also,the inspection dated August 19,
2015 noted that signage was present at all lift stations and no deficiencies were noted. Immediately after
the inspection Aqua placed temporary signs and ordered permanent signs which were installed
immediately upon receipt from the manufacturer.Aqua requests remission of the $1300.00 penalty as the
assessment factors were based on long-standing deficiencies,and this was not a long-standing deficiency,
did not contribute to any environmental impact, and they took immediate action to address the concern
noted by Mr. Hunkele
Pump Station:
Roundtree Ridge PS not secure&not posted 2 months after certification
Roundtree Ridge was certified in April 2018. Although certified on that date,the system had not been
system. Immediatelyafter the inspection
receivingflow as homes were not yet built and activated on the p
Aqua placed temporary signs and ordered permanent signs which were installed immediately upon receipt
from the manufacturer. Aqua requests remission of the$350.00 penalty as the assessment factors were
based on long-standing deficiencies, and this was not a long-standing deficiency,did not contribute to any
environmental impact, and Aqua took immediate action to address the concern noted by Mr. Hunkele
Records:
System map still incomplete after 13 years; 3 years past 10-year allowance window
During the inspection on June 8, follow-up correspondence on August 9,2018,Aqua provided
evidence to Mr. Hunkele that indicated that the Cape Collection System Map met the requirements
specified in the rule(size, approx. age, flow direction,pipe,material, approximate taps into lines,
pump station locations,names, capacities,etc.).A paper copy of the map was provided, in addition
to a demonstration of electronic mapping that is available to all operators. Per guidance documents
provided by the Department,the intent of the rule is to enable operators to have quick access to
view information regarding the collection system. It specifically states that the map does not have
to be computerized;however,it should be a goal. Aqua has had and made a computerized map

Page Two
Ms. Morella Sanchez King
November 30,2018
(GIS)available since 2015,in addition to electronic as-built drawings and paper system map. As
maps are living documents,these require continuous updating as the system is built-out and
rehabilitation is performed. In addition to the above,Aqua provides tablets to all operators that
allow them to view the map and as-builts electronically and are accessible in the field,in addition
to paper maps. Aqua provided this information and subsequently requested additional detail
regarding what system components were missing from the map after the Notice of Violation was
delivered. In follow upcorrespondence(enclosed), our request was not answered.Furthermore,
Mr.
p
Hunkele complemented Aqua's recent efforts towards improving the map upon a follow-up
meeting with Aqua personnel. Mr. Hunkele referenced three years past the 10-year window;
however,the GIS map and electronic as-builts have been available since the last inspection in 2015.
Based on the information provided during and after the inspection,Aqua requests remission of the
$500 penalty based on the assessment factors noted.The map was and is complete based on the
latest drawings;therefore duration, gravity, and amount of money saved should not be assessed.
Aqua has dedicated monies towards a comprehensive GIS program and team to ensure continued
compliance.
Pump Station:
Westview PS not secure&not posted plus no audible alarm installed 6 months after
certification
Westview Lift Station was certified in December 2017. Although certified on that date,the system had
did not begin to receive flow until mid-2018. Immediately after the inspection Aqua placed temporary
signs and ordered permanent signs which were installed immediately upon receipt from the manufacturer.
Furthermore, an Omni Beacon,which exceeds regulatory requirements in 15A NCAC 02T.0305 (h)(1)(F)
that require"high water audio and visual alarm"was installed and operational on the date of inspection.
Mr. Hunkele referenced during the inspection and follow-up meeting on November 9,2018 that it must be
loud enough to alert neighbors and his assessment was that it was not loud enough.Per the regulation
above,the requirement is that an alarm must be installed,it does not reference a specific decibel rating. If
a standard is to be assessed,it must be referenced by statute or administrative code. Aqua requests
remission of the$200.00 penalty as the assessment factors were based on long-standing deficiencies,and
this was not a long-standing deficiency, did not contribute to any environmental impact, and Aqua took
immediate action to address the signage as noted by Mr. Hunkele
If you have any questions or comments,please do not hesitate to contact Joel Mingus at(910)270-1412.
Sincerely,
Josep• R. Pearce
Director of Operations
Aqua North Carolina,Inc.
cc: Joel Mingus
Amanda Owens
Shannon Becker

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MICHAEL S.REGAIN' <'OJB
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LINDA CULPEPPER
Interim Director
Certified Mail#7017 0190 0000 9534 3199
Return Receipt Requested
October 29,2018
Shannon V Becker
Aqua North Carolina Inc
202 Mackenan Ct
Cary,NC 27511
SUBJECT: Notice of Violation and Assessment of Civil Penalty
for Violations of 15A NCAC 02T.0403
and Collection System Permit No. WQCS00240
Aqua North Carolina Inc •
The Cape Collection System 1
Case No.PC-2018-0029
New Hanover County
Dear Permittee: •
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of$3,487.75($3,350.00 civil penalty
+$137.75 enforcement costs)against Aqua North Carolina Inc.
This assessment is based upon the following facts: an inspection of the The Cape Collection System was conducted on June
8,2018. This inspection was conducted to verify that the facility is operating in compliance with the conditions and
limitations specified in Collection System Permit No.WQCS00240. This inspection has shown the subject facility to be in
violation of the conditions and limitations found in Collection System Permit No. WQCS00240. The violations found during
the inspection are summarized in Attachment A to this letter.
Based upon the above facts,I conclude as a matter of law that Aqua North Carolina Inc violated the terms,conditions or
requirements of Collection System Permit No. WQCS00240 and 15A NCAC 02T.0403 in the manner and extent shown in
Attachment A. In accordance with the maximums established by G.S. 143-215.6A(a)(2), a civil penalty may be assessed
against any person who violates the terms,conditions or requirements of a permit required by G.S. 143-215.1(a).
DEC
North Carolina Department of Environmental Quality I Division of Water Resources
127 Cardinal Drive Extension,Wilmington,North Carolina 28405
910-796-7215

Based upon the above findings of fact and conclusions of law,and in accordance with authority provided by the Secretary
of the Department of Environmental Quality and the Director of the Division of Water Resources,I,Morella Sanchez-King,
Acting Regional Supervisor, Wilmington Regional Office hereby make the following civil penalty assessment against Aqua
North Carolina Inc:
$3,350.00 For 6 of the 6 violations of the conditions and limitations specified in Permit No. WQCS00240 .
$3,350.00 ;;TOTAL CIVIL PENALTY
5137.75 ' Enforcement Costs
$3,487.75 TOTAL AMOUNT DUE
Pursuant to G.S. 143-215.6A(c),in determining the amount of the penalty I have taken into account the Findings of Fact and
Conclusions of Law and the factors set forth at G.S. 143B-282.1(b),which are:
(1) The degree and extent of harm to the natural resources of the State,to the public health,or to private property
resulting from the violation;
(2) The duration and gravity of the violation;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violation was committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs over which the Environmental
Management Commission has regulatory authority; and
(8) The cost to the State of the enforcement procedures.
Within thirty(30)days of receipt of this notice,you must do one of the following: •
(1) Submit payment of the penalty, OR
(2) Submit a written request for remission, OR
(3) Submit a written request for an administrative hearing
Option 1: Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environmental Quality(do not include waiver
form). Payment of the penalty will not foreclose further enforcement action for any continuing or new violation(s).
Please submit payment to the attention of:
Wastewater Branch
Division of Water Resources
1617 Mail Service Center
Raleigh,North Carolina 27699-1617

Option 2: Submit a written request for remission or mitigation including a detailed justification for such
request:
Please be aware that a request for remission is limited to consideration of the five factors listed below as they may
relate to the reasonableness of the amount of the civil penalty assessed. Requesting remission is not the proper
procedure for contesting whether the violation(s)occurred or the accuracy of any of the factual statements contained in
the civil penalty assessment document. Because a remission request forecloses the option of an administrative hearing,
such a request must be accompanied by a waiver of your right to an administrative hearing and a stipulation and
agreement that no factual or legal issues are in dispute. Please prepare a detailed statement that establishes why you
believe the civil penalty should be remitted,and submit it to the Division of Water Resources at-the address listed below.
In determining whether a remission request will be approved,the following factors shall be considered:
(1) whether one or more of the civil penalty assessment factors in NCGS 143B-282.1(b)was wrongfully
applied to the detriment of the petitioner;
(2) whether the violator promptly abated continuing environmental damage resulting from the violation;
(3) whether the violation was inadvertent or a result of an accident;
(4) whether the violator had been assessed civil penalties for any previous violations;or
(5) whether payment of the civil penalty will prevent payment for the remaining necessary remedial actions.
Please note that all evidence presented in support of your request for remission must be submitted in writing. The
Director of the Division of Water Resources will review your evidence and inform you of his decision in the matter of
your remission request. The response will provide details regarding the case status,directions for payment,and
provision for further appeal of the penalty to the Environmental Management Commission's Committee on Civil Penalty
Remissions(Committee). Please be advised that the Committee cannot consider information that was not part of the
original remission request considered by the Director. Therefore,it is very important that you prepare a complete and
thorough statement in support of your request for remission.
In order to request remission.you must complete and submit the enclosed"Request for Remission of Civil Penalties,
Waiver of Right to an Administrative Hearing,and Stipulation of Facts"form within thirty(30)days of receipt of this
notice. The Division of Water Resources also requests that you complete and submit the enclosed"Justification for
Remission Request."
Both forms should be submitted to the following address:
Wastewater Branch
Division of Water Resources
1617 Mail Service Center
Raleigh,North Carolina 27699-1617

Option 3: File a petition for an administrative hearing with the Office of Administrative Hearings:
If you wish to contest any statement in the attached assessment document you must file a petition for an administrative
hearing. You may obtain the petition form from the Office of Administrative Hearings. You must file the petition with
the Office of Administrative Hearings within thirty(30)days of receipt of this notice. A petition is considered filed
when it is received in the Office of Administrative Hearings during normal office hours. The Office of Administrative
Hearings accepts filings Monday through Friday between the hours of 8:00 a.m. and 5:00 p.m.,except for official state
holidays. The petition may be filed by facsimile(fax)or electronic mail by an attached file(with restrictions) -provided
the signed original, one(1)copy and a filing fee(if a filing fee is required by NCGS §150B-23.2)is received in the
Office of Administrative Hearings within seven(7)business days following the faxed or electronic transmission. You
should contact the Office of Administrative Hearings with all questions regarding the filing fee and/or the details of the
filing process.
1 The mailing address and telephone and fax numbers for the Office of Administrative Hearings are as follows:
6714 Mail Service Center
Raleigh,NC 27699 6714
Tel: [phone]
Fax: [phone]
One(1)copy of the petition must also be served on DEQ as follows:
Mr. William F.Lane,_General Counsel ---
Department of Environmental Quality
1601 Mail Service Center
Raleigh,North Carolina 27699-1601
Please indicate the case number(as found on page one of this letter)on the petition.
Failure to exercise one of the options above within thirty(30)days of receipt of this letter, as evidenced by an internal
date/time received stamp(not a postmark),will result in this matter being referred to the Attorney General's Office for
collection of the penalty through a civil action. Please be advised that additional penalties may be assessed for violations
that occur after the review period of this assessment.
If you have any questions,please contact Dean Hunkele with the Division of Water Resources staff of the Wilmington
Regional Office at(910)796-7215 or via email at [e-mail].
Sincerely,
DocuSlgned by:
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Morella Sanchez-King,Acting Regional Supervisor
Water Quality Regional Operations Section
Wilmington Regional Office
Division of Water Resources,NCDEQ
ATTACHMENTS
Cc: WQS Wilmington Regional Office-Enforcement File
Upload to Laserfiche

JliSTIFICATION FOR REMISSION REQUEST
Case Number: PC-2018-0029 County: New Hanover
Assessed Party: Aqua North Carolina Inc
Permit No.: WQCS00240 Amount Assessed: 53,487.75
Please use this form when requesting remission of this civil penalty. You must also complete the "Request For Remission,
Waiver of Right to an Administrative Hearing, and Stipulation of Facts"form to request remission of this civil penalty.
You should attach any documents that you believe support your request and are necessary for the Director to consider in
evaluating your request for remission. Please be aware that a request for remission is limited to consideration of the five
factors listed below as they may relate to the reasonableness of the amount of the civil penalty assessed. Requesting
remission is not the proper procedure for contesting whether the violation(s) occurred or the accuracy of any of the factual
statements contained in the civil penalty assessment document. Pursuant to N.C.G.S. § 143B-282.1(c),remission of a civil
penalty may be granted only when one or more of the following five factors apply. Please check each factor that you
believe applies to your case and provide a detailed explanation,including copies of supporting documents,as to why the
factor applies(attach additional pages as needed).
X
(a) one or more of the civil penalty assessment factors in N.C.G.S. 143B-282.1(b)were wrongfully applied to the
detriment of the petitioner (the assessment factors are listed in the civil penalty assessment document);
• X (b) the violator promptly abated continuing environmental damage resulting from the violation(i.e., explain the
steps that you took to correct the violation and prevent future occurrences);
(c) the violation was inadvertent or a result of an accident(i.e., explain why the violation was unavoidable or
something you could not prevent or prepare for);
X (d) the violator had not been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary remedial actions (i.e., explain
how payment of the civil penalty will prevent you from performing the activities necessary to achieve
compliance).
EXPLANATION:
Aqua disputes the penalty assessment based upon the factors utilized to assess the penalty. Per the enclosed documentation,
the assessment factors utilized to assess the penalties were based on duration and gravity of the violation and amount of money
saved by non-compliance. Aqua has invested significant capital dollars towards rehabilitation of the Cape Collection System and
operational money towards improved record keeping.Aqua also took immediate remedial actions to address sign and security
deficiencies, Aqua provided supporting evidence and documentation that disputes the deficiencies noted for the system map,
audible alarm, and Bala LS during and after the inspection on June 8, 2018.
Enclosed are supporting documents and formal remission request. Attachments include:
1. Written formal remission request.
2. Communication between DEQ and Aqua personnel.
3. Division of Water Resources-Civil Penalty Assessment

•
•
STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
COUNTY OF NEW HANOVER
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
Aqua North Carolina Inc )
The Cape Collection System )
)
PERMIT NO. WQCS00240 ) CASE NO. PC-2018-0029
Having been assessed civil penalties totaling 53,487.75 for violation(s)as set forth in the assessment document of the
Division of Water Resources dated October 29,2018,the undersigned,desiring to seek remission of the civil penalty, does
hereby waive the right to an administrative hearing in the above-stated matter and does stipulate that the facts are as
alleged in the assessment document. The undersigned further understands that all evidence presented in support of
remission of this civil penalty must be submitted to the Director of the Division of Water Resources within thirty(30) days
of receipt of the notice of assessment. No new evidence in support of a remission request will be allowed after(30) days
from the receipt of the notice of assessment.
This the 30th day of November ,20 18
SIGNATURE
ADDRESS
202 MacKenan Court
Cary, NC 27511
TELEPHONE •
• 919-653-6965

ATTACHMENT A
Aqua North Carolina Inc
CASE NUMBER: PC-2018-0029
PERMIT NO: WQCS00240 REGION: Wilmington
FACILITY: The Cape Collection System COUNTY: New Hanover
VIOLATION VIOLATION PENALTY
DATE AREA TYPE VIOLATION DESCRIPTION AMOUNT
6/8/2018 Pump Station Violation detected during Bala PS#5 control panel still not $350.00
inspection replaced or reinforced after nearly 2
years. Found not secure as well
6/8/2018 Pump Station Violation detected during Bella Point PS not secure&not posted $350.00
inspection 5 months after certification
6/8/2018 Pump Station Violation detected during River Oaks Section 8 PS not secure& $1,300.00
inspection not posted 2 years after certification
6/8/2018 Pump Station Violation detected during Roundtree Ridge PS not secure&not $200.00
inspection posted 2 months after certification
6/8/2018 Records Violation detected during System map still incomplete after 13 $500.00
inspection years 3 years past 10-year window
6/8/2018 Pump Station Violation detected during Westview PS not secure&not posted $650.00
inspection plus no audible alarm installed 6
months after certification

Berger, Amanda A
From: Owens, Amanda
Sent: Thursday,August 09, 2018 5:38 PM
To: 'Hunkele, Dean'
Cc: Mingus, Joel A.
Subject: RE: [External] The Cape GIS Map
Categories: DEQ
Hi Dean,
Thanks for the quick response. Appreciate it!
Speaking from my years of experience, I have never found a map,or utility that will publicly state,the GIS is perfect.The
issue regardless of how great or bad your as-builts are,you fighting old records, repair, change, and time when going
back years to develop electronic maps. In my former life I testified in front of the DOD that 95%complete is about as
good as it actually ever gets because of time and change. I stand true to that statement. I am sure with drones and
submarines and whatever else comes our way technologically that could change, but for now I hold to it. So to answer
your question, based on what I have observed we are close to the goal. I am not able to find much based on the items
below that needs updating. If you saw something, please let me know.
As I mentioned I have only been at Aqua for about 8 months now, but I have met our GIS manager and his team is
dedicated to providing NC quality information.So as it becomes available to us (and the GIS team), its updated within a
couple of days. I can't state what happened in the past, but you are right we are committed to improvement and
working aggressively towards it.Joel and his team are testament to that.
The other systems are also in GIS.All available as-builts were sent over a few years ago (including the Cape)and
incorporated into the map. I haven't looked at those as closely as the Cape, but I will and get back with you.
Once again, appreciate your help. I view Aqua and DEQ as a partnership. If there is something that needs to be
addressed, please let Joel and I know.
Thank you,
v.,
AQUA.
�, f'tCtt 6tp�4
Amanda Owens-Berger
Manager,Environmental Compliance
Aqua North Carolina
202 MacKenan Court,Cary NC 27511
0: 919-653-6965 M: 910-773-0406
000
1

From: Hunkele, Dean [mailto:[e-mail]]
Sent:Thursday,August 09, 2018 4:50 PM
To: Owens,Amanda <[e-mail]>
Cc: Mingus,Joel A. <[e-mail]>
Subject: RE: [External]The Cape GIS Map
Amanda,
I don't believe we will assess for the map since progress is being made and he showed me how much more has already
been added since June, but still isn't quite complete from what I gathered/observed. Still doesn't explain why it took so
long, but we know you are taking things more serious now.
By the way,taps are no longer required and should have been dropped from the permit requirements. Thus reason
marked as N/A in the report and it will not even appear on the revamped inspection report when it launches. They are
great if you can have it but they are tough as you indicated, best if just mandated to developer/contractor as left, right,
or center of lot.
So how are the status of mapping systems at other locations like Cannonsgate,Avendale, Castle Bay, Sterling Farms,
etc? Last I saw with Don Williams for the Avendale system was a bunch of record drawing pdfs when we were trying to
figure out it was all connected as neither Kirklyn nor he knew.
Dean Hunkele
Environmental Specialist II
Water Quality Regional Operations Section
Division of Water Resources
Department of Environmental Quality
910.796.7215 Reception Desk
910.796.7380 Direct
910.350.2004 Fax
Dean.HunkelePncdenr.gov
Wilmington Regional Office
127 Cardinal Drive Ext
Wilmington,NC 28405
http://deq.nc.gov/contact/regional-offices/wilmington
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third
parties
The goal of the Fast Track sewer permit program is to issue a permit in no more than 30 business days from receipt of a complete application and if
no additional information has to be requested upon full review. Please use the Department's Permit Application Tracker to determine the official
application receipt date to allow you to estimate a date for issuance and find the reviewer's name. Once issued,the record stays on the site for 30
days.
For previously issued sewer permit info or to check on sewer certification receipt status,please use the Division's Sewer Extension Permit
Tracker. Using the Issue Date on top of the Engineer Certification Form is best way to ensure getting what you want especially for multi-version
permits;using today's date only gives info on the latest permit version. Confirmation using this method will replace letters and emails;it is
recommended that confirmation be printed and/or saved.
Links to both trackers can be found on the sewer permitting site here: https://deq.nc.gov/about/divisions/water-resources/water-resources-
permits/peres/collection-systems-permits
Subscribe to Collection System Updates listserve to receive automatic alerts for changes to applications,policies,regulations,etc.
2

From: Owens,Amanda [mailto:[e-mail]]
Sent:Thursday, August 9, 2018 4:21 PM
To: Hunkele, Dean <[e-mail]>
Cc: Mingus,Joel A.<[e-mail]>
Subject: [External] The Cape GIS Map
CAUTION.External email.Do not click links or open attachments unless verified.Send all suspicious email as an attachment to
Hi Dean,
Joel forwarded me the collection system NOV, and I have a question regarding the collection system map.Our GIS map
contains all requirements (flow direction,size, approximate age, lift station names, etc). We are adding taps, but that is
slow process for sewer as its more difficult due to as-builts; however,we are working on it. I am not able to print it with
all that information because the labels will overwrite each other; however,the GIS is accessible by all operators and
management electronically(tablets, computer, and phone). Per the information from the DEQ website(see below)this
map met these requirements.
Please note,that as we add to the system it does take a period of time to upload the as-builts to the GIS system;
however,that is the case for all utilities. I have managed complex GIS projects for years and I am not aware of any utility
that can capture that data immediately.
Below is the basis for the data that is being updated. If there is something that we are missing, please let me know. I will
forward that information immediately to our GIS team.
Does My Comprehensive Map Need To Be Computerized?
The comprehensive map does not need to be computerized. Although, it would be a goal to plan for in the
future due to the capabilities and benefits of computerized mapping. The intent of the comprehensive map is
not that it fits all on one sheet, but that the collection system and all information associated with it (size,
approx. age, flow direction, pipe material,approximate taps into line segments,pump station locations,
names, capacities, etc.) is available in one central location. This will enable not only the current collection
system personnel to quickly view information about the system to make decisions about line cleaning, ROW
maintenance, rehabilitation needs, capacity issues, connection points for new flows, etc., but that someone in
the future can come in and quickly become familiar with the system.The Division is not wanting to see a stack
of unorganized as-built plans collecting dust in the corner or scattered between several locations as proper
collection system O&M depends on knowledge of the entire system as a whole.
Thank you Dean.Appreciate your help.
AOUAJb
Amanda Owens-Berger
Manager,Environmental Compliance
Aqua North Carolina
202 MacKenan Court,Cary NC 27511
0: 919-653-6965 M:910-773-0406
0 0 0
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A 0 U ,
August 27,2018
Ms.Morella Sanchez King,Acting Regional Supervisor
Water Quality Regional Operations Section
Wilmington Regional Office
Division of Water Resources,NCDEQ
127 Cardinal Drive Extension
Wilmington,NC 28405
Re: The Cape,New Hanover County,Permit No. WQCS00240
Tracking Number:NOV-2018-PC-0313
Notice of Violation and Intent to Assess Civil Penalty
Dear Ms.King:
Aqua North Carolina, Inc.(Aqua)offers the following response to the above-referenced Notice of
Violation and Intent to Assess Civil Penalty issued after the inspection of The Cape collection system on
June 8, 2018:
Pump Station:Bala PS#5 control panel still not replaced or reinforced after nearly 2 years.
Found not secure as well
As discussed with Dean Hunkele during the inspection,Aqua has taken the approach to address
the Cape lift station upgrades for the system as a whole.First,in 2017-2018 Aqua scheduled
improvements on all Beau Rivage and Cape lift stations that did not satisfy the back-up power
requirements first. Bala PS#5 was one of these 20 lift stations.This project was extensive given that it
required coordination with mutilple parties; including the New Hanover County building and codes
department, Duke Power,and easement research.These items were installed in July 2018. These items
completed the panel board,quick connect and disconnect phase of the project.The next phase of the
project includes moving meter/meter sockets over to the new panel boards so that controls can be
moved or replaced on the new panel board. The final phase of the system improvements will include
replacement of the lift station controls,to which Bala is prioritized to receive this upgrade.Aqua will
move the controls at this lift station over as soon as feasible,following the Duke meter transfer and
inspections. Pictures are attached of the work performed in 2017 and includes the existing panel board
reinforced with lag bolt and rail replacement.
Pump Station:
Bella Point PS not secure&not posted 5 months after certification
This pump station is now posted and locked. AQUA posted a temporary sign and has installed a new
permanent sign as of August 22,2018.Pictures attached.

Page Two
Ms. Morella Sanchez King
August 27,2018
Pump Station:
River Oaks Section 8 PS not secure&not posted 2 years after certification
This pump station is now posted and locked. AQUA posted a temporary sign,and has installed a new
permanent sign as of 8-22-18. Pictures attached.
Pump Station:
Roundtree Ridge PS not secure&not posted 2 months after certification
This pump station is now posted and locked.AQUA posted a temporary sign, and has installed a new
permanent sign as of August 22,2018. Pictures attached.
Records:
System map still incomplete after 13 years; 3 years past 10 year allowance window
AQUA reviewed our current GIS maps with Dean Hunkele during the inspection. The GIS map
meets the conditions of the rule by providing a spatial reference and database of force mains,
gravity mains(to include size and pipe material where known),customer services,and pump
stations,to include names and capacities.The intent of the rule is so that a new employee can
quickly familiarize themselves with the system.The GIS map is accessible to all employees, both
office and remotely in the field.The GIS project commenced over three years ago included
extensive scanning of available maps and drawings,the development of a corporate GIS team and
staffed to support NC,cataloging drawings and allowing remote access via the On Base software.
A reference GIS map is attached.
Pump Station:
Westview PS not secure& not posted plus no audible alarm installed 6 months after
certification
Westview Pump station is also known as Lookout Point.This pump station is now posted and locked.
AQUA posted a temporary sign,and has installed a new permanent sign as of August 22,2018.This site
has an Omni Beacon which has a visible alarm,audible alarm and cellular telemetry. The Omni Beacon
meets and exceeds the regulatory standard.The secondary audible alarm mentioned by Mr. Hunkele can
be installed per the request.
If you have any questions or comments,please do not hesitate to contact Joel Mingus at(910)270-1412.
Sincerely,
4.1"\..
Joe ingus
Area Manager
Aqua North Carolina, Inc.
cc: Joseph Pearce
Amanda Owens
Shannon Becker

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New BALA Panel board,quick connect and disconnects, ready for new controts(PH2)after
Duke moves meter.
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on panel, part of this process.
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GIS Map and zoomed in Exhibits. Per the discussion with Dean Hunkele on site and
demonstration on AQUA GIS Computer. The GIS continues to be updated as additional
information is provided.Currently, it proivdes pipe sizes, locations, materials,and direction.
When printed,the map does not show all of the information at large scale, but when utilizing
the GIS viewer you can zoom in and see pipe sizes, purple dots are sewer customers, blue
dots are water customers,etc. Below are screen shots of the GIS viewer that is available in
both desktop and mobile(tablet, phone)functions.Also attached is copy of the Cape system
on GIS provided to Dean Hunkele.
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thereore,we are including a copy of this gis map. Most of our collection systems updates are
in progress on AQUA GIS. Similar to the Cape CS, pipe size and material is available inside
the GIS system and the operator has access to this in the field.
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A QU A Legend
!�• nc_ponder_parcels_poly_2018_02_26
Manhole
I Pump Station
WWTP
Sewer Main
all other values>
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Type
Forcemain
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e.� Low pressure
—as_Casing
ss_LateralLines
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Avendale Collection System