WQ0030088_RESP to NOV-2019-0143_20190327

Old North State Water Co.
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Company
March 20, 2019
Morella Sanchez-King, Regional Supervisor
Water Quality Regional Operations Section
Wilmington Regional Office
Division of Water Resources, NCDEQ
Subject: NOTICE OF VIOLATION &INTENT TO ISSUE CIVIL PENALTY
Tracking No.: NOV-2019-LV-0143
WWTP Permit No. WQ0030088
Majestic Oaks WWTP
Pender County
Dear Ms Sanchez-King:
Old North State Water Company appreciates the opportunity to respond to the Notice of
Violation issued on March 4, 2019 by the Division of Environmental Quality. The Notice of
Violation was issued related to data submitted by ONSWC to the Division for December 2018.
The specific violations were for Daily Maximum and Monthly Average Ammonia, Monthly
Average Total Nitrogen and a missed nitrogen samples for PPI002 and PPI003.
In response to the notice of violation, ONSWC has taken the following action related to the
violation.
1. Reviewed all the analytical data for the month of December to validate the limit
violations.
2. Audited the laboratory and operations information to validate the missed samples.
3. Discussed action plans with the operator in responsible charge to ensure compliance
with the required sample plans.
4. Ensured that the operator in responsible charge had a written copy of the Majestic Oaks
Sample Plan

Regretfully, we have determined that the missed sample, ammonia and total nitrogen results
reported on the December 2018 Discharge Monitoring Report are accurate. Our audit of the
operations has resulted in the following findings:
Total Nitrogen and Ammonia
The total nitrogen results for December were as follows:
12/7/2018—NH3-N=0.3 mg/1 and TN= 1.0 mg/l
12/18/2018—NH3-N=9.7 mg/1 and TN=13.7 mg/l
As noted in these results, the plant was performing well in early December but the second
sample on the 181h was elevated. The elevated ammonia result are due to a lack of bacteria
known as nitrifiers, while the elevated total nitrogen is related to the plant not achieving
denitrification. Since December, the operator has been working to optimize the oxygen and
carbon feed systems in order to restore the nitrifiers and denitrifying bacteria. Nitrification
appears to have been restored in January while denitrification has just recently been restored.
Since learning of these issues, we have worked closely to ensure that the operator is educated
on the importance of maintaining a proactive approach consistent with our expectations.
The operator continues to closely monitor the system to ensure that the proper biology is
present to achieve both nitrification and denitrification. At this time, we have received and
reviewed our latest data for February, and it does appear that the plant is achieving both
nitrification and denitrification in compliance with the permit.
In addition, we have worked with our laboratory to ensure earlier notification of results and to
raise visibility beyond just the operator in responsible charge.
PPI002 and PPI003 Missing Results
The lack of Total Nitrogen for the PPI002 and PPI003 sampling cycle in the month December
was due to human error. When completing the Chain of Custody, the operator missed the
total nitrogen samples. By the time the mistake was discovered, the sample was no longer
available at the lab to test outside of the hold time. Our audit concluded that this could have
been avoided had the laboratory been provided a copy of the sample plan and permit. This
error was the result of the transition in laboratories. Thus, we have ensured the laboratory has
copies of the permit and have implemented protocols to ensure that the laboratory checks
samples on the Chain of Custody against the permit requirements.
While we concur that these do constitute a violation, we hope that our response shows our
commitment to providing support to the operator to ensure that future compliance issues
receive visibility thorough out the organization and as a check to ensure compliance. As you

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are aware, since taking over this facility ONSWC has made considerable investment into this
plant and continues to make investments into this facility as requested by the operator. We
feel that a civil penalty would not be prudent as we have acted in a responsible manner to
address these issues and bring the facility into compliance. Therefore, we request that the
Division considers these efforts when deciding on further enforcement.
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Old North Water Company strives for excellence and has always welcomed open
communication with NC DWR Staff to ensure compliance with any permit and we continue to
be concerned about the issuance of NOV's that could have been avoided through open
communication. If Old North State Water Company can be of any further assistance or
additional information is needed,please contact me at 252-235-4900.
Sincerely,
Ar
Michael J. Myers
Old North State Water Company
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Cc:
David Strum,Envirolink
Rebecca Manning, Envirolink
Don Feller, Envirolink