WQ0035784_Staff Report_20211208

December 1, 2021
Ms. Caitlin Caudle
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ-WRSO
Subject: Notice of Deficiency (NOD-2021-PC-0506)
The Cottages of Boone — Wastewater Irrigation System
Permit No. WQ0035784
Watauga County
Ms. Caudle,
Thank you for allowing The Cottages of Boone the opportunity to respond to the concerns brought forward in this NOD
following the inspection conducted October 12, 2021.
1. At the time of inspection, a Spill Plan was not available for review. Per Permit Condition III.1 a spill response plan is
a component of the Operations and Maintenance Plan. Please locate or develop a Spill Response Plan and keep a copy
posted within the wastewater treatment plant and apartment clubhouse, ensure that all staff or contractors are
aware of the location of the Spill Response Plan, and ensure that all staff that work with the collection system and
the wastewater treatment plant are aware of spill response procedures. Please send Ms. Caudle evidence of the
Spill Response Plan being posted in the requested locations within thirty (30) days of receipt of this letter.
- A Spill Response Plan was drafted between Mr. Feller and representatives of the Cottages of Boone. Mrs.
Caudle reviewed the draft of the spill response plan, which was revised to reflect her comments. The Plan has
been posted at the Plant and the Clubhouse and pictures will be provided to Ms. Caudle the Week of Nov. 29
— Dec. 3. 2021.
A. The 14-day wet weather storage tank had a few small leaks around the second band of metal plates from the bottom of
the storage tank. Leaks in the storage tanks were referenced in correspondence from the previous compliance evaluation
inspection and follow up inspection. Repairs were made after the previous inspections, and additional repairs were made
shortly after DWR staff concluded the subject inspection. Please continue to monitor the storage tanks and make
timely repairs as needed.
- The 14-day wet weather storage tank leaks noted were addressed and sealed the same day as the inspection.
As this structure is made of metal panels secured together with screws, there is the risk that these issues will
persist. With changing weather and pressures on the tank, we will continue to monitor for additional seepage.
B. Anoxic Tank A (located inside the treatment building) reportedly has two small holes around the drain valve. Mr.
Feller stated that he has contacted the manufacturer of the tank and is in the process of determining the most effective and
efficient repair. Please repair this tank in a timely manner and notify Ms. Caudle of any developments associated
with this repair.
- The Pre-Annox tank has two small holes at the bottom of the tank under the drain valve. This large plastic tank
is located inside the treatment plant building. Repairing or replacing the tank is complicated by the structure of the
building itself. The tank was not leaking at the time of the inspection nor at present. Options discussed include
replacing the existing valve and flange with an even bigger flange to accommodate the holes, or having the tank
plastic welded to seal the holes from both sides. We are seeking qualified and competent contractors who may be
able to perform either of these repairs, as replacing the tank would be a last resort due to the location of the tank
inside the building.

C. Trees were visible growing on the mats covering treated effluent in the 5 day upset tank. While on site, Ms. Caudle
observed that the trees and other vegetation pulled the cable attached to the freeboard marker, changing the observed
freeboard. Based on this observation, it is likely that the trees and other vegetation can alter the observed freeboard
to present a false reading. Please consider taking measures to remove the trees and vegetation or take measures to
ensure that the freeboard in the 5-day upset storage tank is accurately represented at all times. Further action may
be required by the Division if the freeboard marker is consistently impacted by the vegetation.
We are currently seeking a tree removal company to carry out vegetation removal from outside the tankage,
but have not found a company willing to complete the work as of yet. We are investigating ways to remove
the mats entirely, but again this will take specialized crews and equipment to complete.
D. Mr. Feller stated that the rain sensor is not operational, and the current operations are to turn the system off when staff
are not on site and there is rain in the weather forecast. Mr. Feller stated that he is in the process of acquiring a rain sensor
for the system. Please repair the rain sensor in a timely manner and notify Ms. Caudle when the rain sensor is
repaired.
- A new moisture sensor was ordered on 11-29-21, and will be installed upon arrival.
We appreciate the Division's willingness to work with us while we continue to work hard to resolve the above
deficiencies and meet the facility's permit conditions as specified by NC-DEQ. It is our request that our attention in these
matters be taken into account by the Division when proceeding with enforcement.
Sincerely,
Sean Dwyer
Wallace Loft, LLC — The Cottages of Boone
CC:
Don Feller, Envirolink