NC0065480_NOV-2019-LV-0305 Response_20190520

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Ms. Morella Sanchez King, Acting Regional Supervisor
Water Quality Regional Operations Section
Wilmington Regional Office
Division of Water Resources, NCDEQ
127 Cardinal Drive Extension
Re: Beau Rivage, New Hanover County, Permit No. NCO065480
Tracking Number: NOV-2019-LV-0305
Notice of Violation and Intent to Assess Civil Penalty
Aqua North Carolina, Inc. (Aqua) offers the following response to the above -
referenced Notice of Violation and Intent to Assess Civil Penalty; this was for
enterococci daily maximum exceedance violations that occurred March 12 and 26,
2019:
The only change that was made at this plant was the chlorine feed was turned off,
partially due to an email from the local Wilmington Branch stating that feeding
chlorine "would probably require an A-to-C from the NPDES Group" on February 51h,
The chlorine feed was discussed internally amongst the regional staff and the feed
was turned off based on the email. AQUA personnel discussed the situation while
on -site with NCDEQ during the March 91h site visit and later sent an email directly to
the NPDES Permitting. ' rou% to confirm that chlorine can be fed in combination with
the UV system, as long as the parameters are reported. The NPDES Supervisor
confirmed, and the chlorine feed was re -activated. The Operator in Responsible
Charge (ORC) of Beau Rivage is of the opinion that turning off the chlorine feed
directly contributed to the enterococci exceedances. He had replaced bank 1 of the
Trojan UV bulbs and sleeves the week of February 251h. At that time, they had been
in service for approximately 1 year.
If you have any questions or comments, please do not hesitate to contact me at
[phone].

4
Joel k'Mingus
Area Manager
Aqua North Carolina, Inc.
cc: Joe Pearce
Amanda Oweis
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