WQ0038597_NOV-2019-PC-0498_20190705

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Dlwwr
NORTH CAROLINA
Environmental Quality
July 5, 2019
CERTIFIED MAIL # 7016 3560 0000 4428 5195
RETURN RECEIPT REQUESTED
Kendra D. Parrish, PE -Director of Engineering
Town of Holly Springs
Post Office Box 8
Holly Springs, NC 27540
Subject: NOTICE OF VIOLATION
NOV-2019-PC-0498
Trinity Creek Phase I
Reclaimed Water Distribution Line
Permit WQ0038597
Reclaimed Water Generation System
Permit WQ0032289
Wake County
Ms. Parrish,
On June 21, 2019 staff from the Division of Water Resources (DWR) Water Quality Regional
Operations received an email notification from Mr. Brendan Reeser with the Town of Holly
Springs regarding a reclaimed water cross -connection in the Trinity Creek Subdivision. This cross -
connection was discovered after the homeowner informed the Town of Holly Springs that water
service to the interior of the home had been lost after the reclaimed water had been turned off to
the neighborhood during maintenance activities. Mr. Reeser made a site visit to a home at 216
Scarlet Tanager Circle (Phase 1 B) where the cross -connection had taken place and spoke with the
leading developer of the neighborhood. The Town of Holly Springs was issued Permit #
WQ0032289 for the generation of reclaimed water and Permit # WQ0038597 for reclaimed water
distribution at Trinity Creek Phase I (which includes 216 Scarlet Tanager Circle) on January 19,
2017 and January 17, 2017, respectiN-ely. DWR records indicate that the final Engineer's
certification for permit # WQ0038597 was received on December 5, 2017.
Since the cross -connection has been discovered, the residents of the home have been residing in a
hotel. According to Mr. Reeser, samples taken from the reclaimed water connection and the
potable water connection support the observation of a cross -connection in the water lines.
North Carolina Department of Environmental QualityDivlslvn of Water Resources
,�/� Raleigh Regional Office 3800 Barrett Drive Raleigh. North Carolina 27609

Kendra Parrish, P.E.
Town of Holly Springs
NOV-2019-PC-0498
July 5, 2019 x
Page 2 of 7
On June 26, 2019 Rick Bolich and Rick Trone of the Division of Water Resources Raleigh
Regional Office conducted a site visit at the affected home. During this inspection, representatives
from Dan Ryan Homes, Fielding Homes, and the Town of Holly Springs were present. The
following observations were noted during the site inspection:
• Staff observed the reclaimed water and potable water in -ground connections and meters
(see photographs below)
• The potable water meter was observed to be installed in the box that should house the
reclaimed water meter (see photograph 1). The reclaimed water meter had been removed
from the ground (see photograph 2)
• Temporary lines had been installed in a "U" shaped connection to facilitate flushing and
disinfection of the potable water lines to the affected home (see photograph 3)
• A spot-check of nearby homes revealed no other obvious issues and all meters appeared to
be installed in their correct boxes and locations, and the visible water lines, valves, and
meter boxes were correctly marked or labelled. (see photograph 4)
As a result of the site inspection, violations of permit WQ0032289 and WQ0038597 described
below, were noted:
Permit # W00032289 - II. Performance Standards
Condition 8, which states that, "No direct cross -connections shall be allowed between reclaimed
water and potable water systems, unless such connection has been approved by the Department
pursuant to 15A NCAC 18C .0406. [reference 15A NCAC 02U .0403
Permit # W00038597 - II. Performance Standards
Condition 5, which states that, "No direct cross -connections shall be allowed between reclaimed
water and potable water systems, unless such connection has been approved by the Department
pursuant to 15A NCAC 18C .0406. [reference 15A NCAC 02U .0403 (f)].
A direct cross -connection between reclaimed water and potable water was observed at 216 Scarlet
Tanager Circle in Holly Springs, NC. You are requested to respond to this Notice with the
following information:
1) Please explain how the cross -connection at 216 Scarlet Tanager Circle occurred.
2) Please provide this office with confirmation that no other similar cross -connections
have occurred associated with this permit and how this determination was achieved.
3) Indicate in your response any measures that the Town is undertaking to prevent other
cross -connections between reclaimed and potable water from occurring associated

Kendra Parrish, P.E.
Town of HoIIy Springs
NOV-2019-PC-0498
July 5, 2019
Page 3 of 7
with this and related reclaimed water distribution permits held by the Town of Holly
Springs.
Permit condition violations have been documented for this permit. Please respond in writing
to this office within 30 days upon your receipt of this Notice of Violation regarding your
plans or measures to be taken to address the indicated violations. Please include in your
response all corrective actions already taken and a schedule for completion of any corrective
actions not addressed.
Failure to comply with conditions in a permit may result in a recommendation of enforcement
action, to the Director of the Division of Water Resources who may issue a civil penalty assessment
of not more that twenty-five thousand ($25,000) dollars against any "person" who violates or fails
to act in accordance with the terms, conditions, or requirements of a permit under authority of G.S.
143-215.6A.
Please submit required materials to:
Rick Trone
Division of Water Resources
3800 Barrett Drive
1628 Mail Service Center
Raleigh, NC 27699
Should you have any questions regarding these matters, please contact Rick Trone or myself at
[e-mail] or [phone].
Sincerely,
4��Bolich, L.G., Assistant Regional Supervisor
Raleigh Regional Office, Water Quality Regional
Operations Section, Division of Water Resources

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Kendra Parrish, P.E.
Town of Holly Springs
NOV-2019-PC-0498
July 5, 2019
Page 6 of 7

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