WQCS00372_NOV-2019-PC-0645 Response_20191108

November 8, 2019
Division of Water Resources, NCDEQ
Wastewater Branch
1628 Mail Service Center
Raleigh, NC 27699-1628
Old North State Water Co.
An
0S)tPIegraviates
Company
NC Dept of Environmental Quality
NOV 15 2019
Raleigh Regional Office
Subject: Subject: Notice of Violation- Notice of Intent to Enforce
NOV-2019-PC-0645
Briar Chapel Subdivision Collection System
Permit Number WQCS00372
Dear Mr. Bolich:
Old North State Water Company appreciates the opportunity to respond to the Notice of
Violation -Notice of Intent to Enforce issued on September 24, 2019 by the Division of
Environmental Quality. Please find enclosed our response to this Notice of Violation. This
response will provide additional information and it is our hope that this additional
information is sufficient, and that the Division will decide not to pursue further action.
REQUESTED RESPONSE:
1. Please provide a list of any spills that were below the reportable thresholds that
were not self -reported.
On September 15, 2019 we experienced a 250-gallon spillage that was non reportable. This
occurred at the manhole in the street on Great Ridge Parkway and the manhole behind the
station.
2. SeveraI of the more recent spills appeared to be caused by pipe failures in the area
around Hill Creek Boulevard. Please provide details and possible reasons for the
cause of the pipe breaks.
As background, ONSWC acquired this station and line in 2014 fro►n Briar Chapel Utilities. We
identified issues related to air release valves and completed the upgrade to this line in 2018. In
2018 we had one break, which occurred during the period we were completing the work to address
the items identified in 2017.
Earlier this year, the line began experiencing additional issues. In response to this issue, we
installed data loggers that indicated the break was the result of fatigue failure related to pressure

waves associated with the pump start up In response to this issue, we installed soft starts on the
pumps. However, we continued to experience issues.
Therefore, we conducted extensive pressure monitoring and modeling of the force main line near
Great Ridge Parkway. The modeling theorized that water column separation caused negative
pressure which PVC pipe cannot withstand. As a result, soft shutdowns were installed on the
pumps and the force main line near Great Ridge Parkway had air relief valves installed the last
week of September. Now that the installation is complete, we have performed field observations of
the areas that were previously presenting evidence of these pressure waves.
3. Please explain what has already been done to address these spills.
See explanation and follow-up regarding resolution to pressure wave issue in answer from
Item #2 for technical solutions. In response to each spill, we have cleaned up the spills and
stabilized the affected areas.
4. Please provide a corrective action plan on what will be done in the future to
prevent SSOs.
We feel that the Iastest improvements have resolved the issues with the forcemain but
the area does continue to experience periodic power failures. The concern is that pump
station was constructed without auto resets on the pumps, so we have initiated monitoring of
the power feed from Duke Energy and authorized installation of auto reset starters on the
pumps.
In addition, toe have initiated or are planning the following:
1) We have begun a more frequent visitation and inspection schedule that includes not only
the ORC but additional maintenance personnel both at the pump station and along the
forcemain.
2) began a project to convert the existing telemetry system to full-time SCADA monitoring.
We expect to have this project completed by the end of the year.
3) We are also assessing potential electrical issues in the Lift Station: control panel.
3. Please explain how often the Operator in Responsible Charge (ORC) visits this
site and inspects the pump station and force mains, and what is done on these
inspections.
The ORC visits the Briar Chapel System and inspects the pump stations daily. During these
SSO and force main break incidents, the ORC would inspect the pump station(s) more
frequently; Lift Station A was inspected daily. The areas that presented pressure wave issues
were walked more frequently than required by the permit. After the air release valves were
installed, we did snore frequent visual inspections and have not noticed any concerns.

In addition to the ORC visitations, other on -site maintenance personnel are conducting daily
inspections of the line.
6. Please provide testing documentation for the force mains installed at the Briar
Chapel subdivision.
We are not purposefully being non -responsive, but we are not sure what testing
documentation is being requested. We will follow up with you to determine exactly what
information you are requesting.
ONSWC strives to effectively manage, maintain and operate the wastewater collection
system at all times to prevent discharge to Iand or surface waters, and to prevent any
contravention of groundwater standards or surface water standards. In the event that the
wastewater collection system fails to perform satisfactorily, including the creation of
nuisance conditions ONSWC takes immediate action.
Please contact us if additional information is needed. While the violation was unfortunate,
we feel that a civil penalty would not be prudent as we have acted in a responsible manner
to address these issues. We hope that the Division recognizes the significant amount of
resources that are devoted to this system. Therefore, we request that the Division consider
these efforts when deciding on further enforcement. We are committed to full compliance
with all the permits of the Briar Chapel Permit Number WQCS00372.
Sincerely,
Michael Myers
President
Old North State Water Company, LLC
Cc: Dave Strum
William Lamm
Rebecca Manning

ROY COOPER
MICHAEL S REGA'S
LINDA CUUT-Pf FR
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NUR' H CAROLIN A
Environmental Quality
September 24, 2019
CERTIFIED MAIL 7017 0190 0000 9562 7374
RETURNED RECEIPT RE UESTED
Mr. Michael J. Myers, Managing Partner
OId North State Water Company, LLC
4700 Homewood Court Suite 109
Raleigh, NC 27609
Dear Mr. Myers -
p�ME0IN
SEP 2 6 2019
By
Subject: Notice of Violation - Notice of Intent to Enforce
NOV-2019-PC-0645
Briar Chapel Subdivision Collection System
Permit Number WQCS00372
This Notice of Violation - Notice of Intent to Enforce is in regards to the numerous Sanitary Sewer
Overflows (SSOs) that have occurred from Briar Chapel Subdivision's Wastewater Collection System,
The system is owned/operated by Old North State Water Company, LLC, and operates under permit
WQCS00372. According to the most recently issued Coilection System Permit that became effective on
August 1, 20I8, the system includes approximately 9.13 miles of gravity sewer and approximately 7.31
miles of force main.
Below is a Iist of SSOs in Briar Chapel that have been self -reported by Old North State Water Company,
LLC. since July 2017:
- -D_ Q�.
North Carolina Department of Environr, entai QLalrty I Divis'on of Water Resource,
1628 Ma I Service Center, Ra ergr, NC 27699-1628
919 791420a

Mr. Michael J. Myers, Old North State Water Co., LLC
NOV-2019- PC-0645
September 24, 2019
Page 2 of 4
Self-
Self --
Incident
Incident
Source of
Estimated
Estimated
Number
Start Date
Overflow
Incident Location
Volume
Volume
Cause
(Gallons)
to Waters
(gallons)
20I 701165
7/t 2/2017
Sanitary
Sewer
75 Hillcreek Blvd
5000
5000
Other/Pipe
Failure
201701784
12/24/2017
Pump
1690 Great Ridge
500
500
Pipe Failure
Station
Parkway
Sanitary
Forcemain Behind 380
201801334
8/15/2018
Sewer
and 390 Beacon Ridge
1000
300
Other
Rd from Lift Station D
PS Failure/
201803141
10/12/2018
Pump
Turtle Point Bend Lift
200
200
Severe
Station
Station
Natural
Conditions
Sanitary
FM behind home on
201803499
l 1/14/2018
Sewer
440 Old piedmont Cr
2000
1000
Other
from LS D
201900237
1/27/2019
Sanitary
1690 Great Ridge
I00
100
PS Failure
Sewer
Parkway
201900781
4/18/2019
Pump
I LS B 1058 Great
1000
200
Grease
Station
Ridge Park -way
201901001
6/5/2019
Sanitary
480 Beacon Ridge
1000
500
I Other
Sewer
BIvd
201901062
6/11/2019
Sanitary
Santa
MH Lift station Great
2 000
Q00
Pipe Failure
Sewer
Ridge Parkway
201901249
7/16/2019
Sanitary
I Lift station behind 75
4000
4000
Pipe Failure
Sewer
Hill Creek Blvd
201901312
7/31/2019
Sanitary
52 Hill Creek Blvd,
500
500
Other
Sewer
Chapel Hill, NC
201901350
8/12/20I9
Sanitary
75 Hill Creek Blvd,
200
200
pipe Failure
Sewer
Chapel Hill NC
Sanitary
300 N Serenity Hill
01901423
9/1/2019
Sewer
Cir, Chapel Hill, NC
1500
0
Pipe Failure
27516
201901481
9/7/20I9
Sanitary
Sewer
75 Hill Creek Blvd
4000
4000
Pipe Failure
The frequency of SSOs from this collection system relative to the size of the system, as well as the numerous
spills that have occurred on the same force main, is a violation of Condition 1.2 of Briar Chapel's
Wastewater Collection System Permit:

Mr. Michael 1, Myers, Old Worth State Water Co., LLC
NO V-2019-PC-0645
September 24, 2019
Page 3 of 4
Condition 1.2 (Performance Standards) of the Wastewater Collection System Permit (WQCS00372) states:
"The tivastewater collection system shall be effectively managed, maintained and operated at all
times to prevent discharge to land or surface waters, and to prevent any contravention of
groundwater standards or surface water standards. In the event that the wastewater collection
system fails to perform satisfactorily, including the creation of nuisance conditions, the Pennittee
shall take immediate actions as per the Response Action Plan (Condition 11(9)), as well as any
actions that may be required by the Division of Water Resources (Division), such as the
construction of additional or replacement sewer lines and/or equipment [15A NCAC 02t 0108 (b)] "
Please answer the following questions:
I. Please provide a list of any spills that were below the reportable thresholds that were not self -
reported.
2. Several of the more recent spills appeared to be caused by pipe failures in the area around
Hill Creek Boulevard. Please provide details and possible reasons for the cause of the pipe
breaks.
3. Please explain what has already been done to address these spills.
4. Please provide a corrective action plan on what will be done in the future to prevent SSOs-
5. Please explain how often the Operator in Responsible Charge (ORC) visits this site and
inspects the pump station and forcemains, and what is done on these inspections.
6. Please provide testing documentation for the forcemains installed at the Briar Chapel
subdivision.
You are required to take any necessary action to correct the above violations and to provide a written
response to this Notice within thirty (30) days of receipt. Please include in your response all corrective
actions already taken and a schedule for comp!etion of any corrective actions not addressed.
As a result of the violations in this Notice our o tee is considet7n t a rcconunc:tidation far the assLssmLvu
o a civil enalty. Ifyou wish to present an explanation for the violations cited, or ifyou believe there are
otherfactors which should be considered, please send such information to me in writing within thirty (30)
days following receipt of this letter. Your response will be reviewed and taken into consideration prior to
the assessment of any civil penalty.

Mr. Michael J. Myers, Old North State Water Co., LLC
NO V-2019-PC-0645
September 24, 2019
Page 4 of 4
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.
SLncc re] ,
R olich, L G., Assistant Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resourccs, NCDEQ
cc: Chatham County Environmental Health