WQ0022870_NOV-2019-PC-0633_20190917

ROY COOPER
Governor
MICHAEL S.REGAN
Secretary
UNDA CULPEPPER NORTH CAROLINA
Director Environmental Quality
September 17, 2019
CERTIFIED MAIL#7012 1640 0001 9605 7003
RETURN RECEIPT REQUESTED
Shannon V. Becker
AQUA—North Carolina, Inc.
202 MacKenan Court
Cary,North Carolina 27511
Subject: Notice of Violation
NOV-2019-PC-0633
Permit No.WQ0022870
AQUA—North Carolina, Inc., Chapel Ridge Subdivision
Non-Conjunctive Wastewater Treatment and Reclaimed Water Utilization
System
Chatham County
Dear Mr. Becker,
Staff of the NC Division of Water Resources (DWR), Water Quality Regional Operations Section
inspected the subject wastewater residuals dewatering facility on August 20 and 27, 2019. I wish
to thank Brian Peters and Eric Riggins for their help during the inspection. The purpose of the
visit was to conduct a compliance inspection of the wastewater treatment and non-conjunctive
reclaimed water utilization facility in response to complaints from residents that the reclaimed
water carries an offensive odor.
On the day of the inspections, the wastewater treatment facility was found to be in good working
order. The plant receives 50 to 100 K gallons per day(gpd) and is permitted to receive 500 K gpd.
Not all of the EQ basins, clarifiers, sludge basins are in use. The effluent is clear and odorless.
The facility was vandalized recently, and operator logbooks were stolen and the turbidimeter, flow
meter and several electric valves were destroyed. Repairs to the vandalized meters were nearly
complete. The digester is emptied monthly. The 5 day holding pond is nearly empty and there
was adequate freeboard in the reclaimed water holding pond.
The irrigation system was in good working order. Variable frequency drive (VFD) pumps keep
the system pressurized to 135 psi. The spray system is operated between 9 pm and Sam and is
controlled by a computer program. Spray heads operate for 10 or 20 minutes each. Several spray
heads were manually operated during the inspection and found to be in working order.
North Carolloa Department ofEnvironmintal Quality [ Division of Water Resources
Raleigh Regional Office 13800 Barrelt Drive I Raleigh.North Carolina 27609

Mr. Shannon Becker
NOV-2019-PC-0633
September 17,2019
Page 2 of 3
The following items specify permit conditions and limitations that were in violation during the
time of the inspection. Please also refer to the attached inspection report.
Permit Condition Violation 1 - I. PERFORMANCE STANDARDS:
Condition 1 which states, "The subject reclaimed water facilities shall be effectively maintained
and operated at all times so there is no discharge to surface waters, nor any contravention of
groundwater or surface water standards. In the event the facilities fail to perform satisfactorily,
including the creation of nuisance conditions due to improper operation and maintenance, or
failure of the utilization areas to adequately assimilate the reclaimed water, the Permittee shall take
immediate corrective actions including Division required actions, such as the construction of
additional or replacement reclaimed water generation and utilization facilities. [G.S. 143-215.1,
143-213.3(a)] ."
1) On the day of the inspection, DWR staff noted that the reclaimed water carried
a strong and offensive odor. According to residents and AQUA staff, this
problem has been ongoing since 2018.
Permit Condition Violation 2- IV. MONITORING AND REPORTING
REQUIREMENTS:
Condition 10, which states, three copies of all operation and utilization records (as specified in
Conditions IV.S. and IV.6. shall be submitted on Form NDAR-I for every non -conjunctive
utilization site listed in Attachment B. (Note: conjunctive use sites do not require NDAR-1
submission). Reporting forms shall be submitted on or before the last day of the following month.
If no reclaimed water utilization activities occurred during the month, monitoring reports are still
required documenting the absence of the activity. All information shall be submitted to the
following address: Division of Water Resources, Information Processing Unit, 1617 Mail Service
Center, Raleigh,North Carolina, 27699-1617. [15A NCAC 02T .0105(1)]."
1) In January, 2019, irrigation records were not submitted for the PHSA irrigation
fields.
2) In February 2019, irrigation records were not submitted for the PHSA fields,
OS-5, or OS 6B.
3) In March 2019 irrigation records were not submitted for the PHSA fields, OS-5,
or OS 6B.
4) In May 2019, irrigation records were not submitted for the PHSA fields, PLSA
fields or OS fields.
5) In 2018, there were similar violations for failure to submit irrigation records for
blocks of fields and individual fields.
6) In May 2019, records were not submitted for residual chlorine or total nitrogen.

Mr. Shannon Becker
NOV-2019-PC-0633
September 17,2019
Page 3 of 3
7) In June 2019,records were not submitted for residual chlorine or for pH.
This office requires that the violations, as described above, be promptly resolved, and that you
submit a written response to this Notice within 30 days of receipt. In your response letter, please
address the following:
I) For permit condition violation 1,please provide a description of and a schedule for system
maintenance and improvements necessary to mitigate the offensive odors created by the
reclaimed water storage and distribution system.
2) For permit condition violation 2, please submit the required records listed above and take
necessary steps to ensure the required records arc submitted to the DWR in accordance
with the permit.
Please note that assessment of civil penalties may have already been recommended for violations
described within this Notice of Violation Failure to comply with the State's rules,in the manner
and time specified,may result in the assessment of additional civil penalties and/or the use of other
enforcement mechanisms available to the State.
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
Should you have any questions regarding these matters, please contact Ray Milosh or me at(919)
791-4200.
Sincerely,
c Bo�, Assistant Regional Supervisor
Raleigh Regional Office, Water Quality Regional
Operations Section, Division of Water Resources
cc: Anne Lowry, Chatham County Environmental Health Director