WQ0005910_Enforcement (Letter)_20181127

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Water Resources
Environmental Quality
November 27, 2018
CERTIFIED MAIL (7017 3380 0001 0998 9674)
RETURN RECEIPT REQUESTED
Keith Silverman, President
Ashland, LLC.
1005 Route 202/206
Bridgewater, NJ 08807
Subject: Notice of Violation NOV-2018-LV-0839
Groundwater Quality
Ashland, LLC
Permit No. WQ0005910
Bertie County
Dear Mr. Silverman:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Interim Director
Permit No. WQ0005910 was issued by the Division on April 4, 2014 for the continued operation
of the wastewater treatment and disposal system serving the above referenced facility. A review
of the permit and Groundwater Monitoring Reports showed that total ammonia in Monitoring
Well MW-8 and nitrate nitrogen in MW-4 were above the groundwater standard.
The Division of Water Resources has reason to believe that Ashland, LLC is responsible for
activities resulting in noncompliance with North Carolina law. Ashland, LLC is producing
wastewater effluent with concentrations above the Groundwater Quality Standards for nitrate
nitrogen and total ammonia (IOmg/L and 1.5 mg/L, respectively). The self -reported sample
reports for the above referenced wells have elevated concentrations of nitrate nitrogen or total
ammonia. This letter is to formally notify you of violations of 15A NCAC 2L (Groundwater
Quality Standards) and to advise you of what you are required to do to correct these violations in
accordance with 15A NCAC 2L .0106 (d).
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State of North Carolina I Environmental Quality
943 Washington Square Mall I Washington, North Carolina 27889
252-946-6481

Page 2
Keith Silverman
December 13, 2018
According to 15A NCAC 2L .0106 (d) (1) the permittee shall demonstrate through predictive
calculations or modeling, that natural site conditions, facility design and operational controls will
prevent a violation of standards at the compliance boundary. Alternately, the person may submit
a plan for alteration of existing site conditions, facility design or operational controls that will
prevent a violation at the compliance boundary, and implement that plan upon its approval by the
Secretary.
If contaminants are detected at or beyond the compliance boundary, the permittee shall respond
in accordance with the requirements of 15A NCAC 2L .0106 (f). The permittee shall assess the
cause, significance and extent of the violation of standards and submit the results of the
investigation, and a plan and propose a schedule for corrective action to the Division. The
permittee shall implement the plan as approved.
Also, according to 15A NCAC 2L .0106 (f) an initial response is required to be conducted prior
to or concurrent with the assessment required in 15A NCAC 2L .0106 (d). The permittee shall
abate, contain, or control the migration of contaminants. The permittee shall remove, treat or
control the primary pollution source. The site assessment shall be in accordance with 15A NCAC
2L .0106 (g) and the corrective action shall be in accordance with 15A NCAC 2L .0106 (h).
We request that you respond to this notice within fifteen working days from its receipt. In your
response, please confirm that Carolina Water Service Inc of North Carolina intent to comply
with the above requirements.
We appreciate your attention and prompt response in this matter. If you have questions, please
do not hesitate to call Robert Tankard at [phone].
Sincerely,
ROW T""
Robert Tankard
Assistant Regional Supervisor
Water Quality Operations Section
Washington Regional Office
cc: Central Office - Water Quality Permitting
Bertie County Health Department
WaRO
Enclosure: 15A NCAC 02L .0106