WQ0035784_NOV-2023-LM-0068 / NOD-2023-LM-0005 Response_20230918

DocuSign Envelope ID: 5D89990C-01OA-478B-B84F-C65C3ACD123D
September 18, 2023
Mr. Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ-WRSO9
Dear Mr. Snider,
Thank you for the opportunity to respond to the deficiencies noted in the September 5, 2023 Notice of Violation (Tracking
Number NOV-2023-LM-0068) and Notice of Deficiency (Tracking Number NOD-2023-LM-0005) arising from your
review of the May 2023 monitoring reports for the Cottages of Boone wastewater treatment plant located in Watauga
County. We have reviewed the deficiencies outlined in these notices and wanted to bring to your attention the following
actions and corrective actions.
Within the past year, the plant has seen a number of changes including decreased flow volumes stemming from the 2022
water conservancy project, seasonality of physical occupancy with many students leaving for the summer each May, as
well as recent repair/upgrade works done in the spring and summer of 2023. Within the last 3 months, operations staff and
the owner have executed a series of upgrades at the facility; including the installation of six new membranes, and
scheduled improvements to the blowers, pumps, probes, and other miscellaneous equipment that are essential to the
operation of the plant.
In recent months, operations staff have worked with the treatment plant manufacturer (Dynatec), as well as seasoned
operators who have previous experience with the plant; where they were provided with more in depth training of how the
treatment plant works, how the computer for the plant functions, and how to operate the equipment in the plant. As a
result of the plant upgrades and supplementary training mentioned above, we have seen large improvements in the plant
infrastructure, operational efficacy, and effluent quality at the WWTP.
Subject: Notice of Violation & Intent to Assess Civil Penalty
Tracking Number: NOV-2023-LM-0068
Permit No. WQ0035784
The Cottages of Boone WWTP
Watauga County
On May 19, 2023, the plant received an Ammonia Nitrogen result of 16.69 mg/l, exceeding the daily maximum limit of 6
mg/l and resulting in a subsequent monthly average limit violation. During this period, the plant was experiencing some
instrumentation problems with the DO probes, specifically the automatic DO adjustment feature that opens and closes the
air valve automatically to control aeration. This resulted in lower -than -normal DOs in the aeration tank, which resulted in
increased Ammonia Nitrogen levels. To remediate this issue, operators began conducting increased manipulation of the
DO adjustment features as an interim measure until new probes could be installed. Those new probes were installed
during the last week of August 2023.
Regarding the following matters related to sampling at the facility:
• Frequency violations for Turbidity
• Frequency violations for Flow
• Nitrate reporting violation
• Fecal coliform daily maximum exceedance, subsequent monthly average exceedance
• TSS Daily maximum exceedance, subsequent monthly average exceedance
During the May 2023 compliance period, turbidity and flow measurements were observed but not recorded, resulting in an
inability to properly complete the monitoring reports. As a result of this event, operators are now required to record
measurements in Envirolink's CMMS system in addition to the field bench sheets. In addition, all personnel have gone
through additional compliance training, and are required to obtain refresher training annually.

DocuSign Envelope ID: 5D89990C-01OA-478B-B84F-C65C3ACD123D
The samples collected on 5/19/2023 demonstrate that TKN, Ammonia Nitrogen, and Nitrate/Nitrite samples were
collected, however an individual Nitrate sample was not. Previously, we responded to this issue by providing additional
compliance training and updated sample schedules to existing operations staff in order to prevent potential recurrence of
this error. Due to a transitional error during a period of staff turnover, some lapses in training resulted in operators
sampling for Nitrate/Nitrite rather than just Nitrate. In response to this concern, we have repeated the process of providing
additional compliance training and sample schedules to our new operations personnel, and as an additional measure, have
incorporated these sample schedules into our work order system so that they can be provided automatically to operations
staff. We believe that the implementation of a comprehensive work order system will be effective in improving adherence
to sampling schedules, streamlining O&M procedures, and promoting thorough data recording.
Subject: Notice of Deficiency
Tracking Number: NOD-2023-LM-0005
Permit No. WQ0035784
The Cottages of Boone WWTP
Watauga County
Regarding the fecal coliform and TSS exceedances reported for 5/19/2023: At the beginning of the month, all membranes
were disassembled, de -fouled, de -plugged, and then reinstalled. As a result of that process, residual turbidity issues
persisted, temporarily creating turbid water conditions that elevated TSS levels and reduced the potential for adequate UV
disinfection until the membranes developed a healthy biomass.
We believe that the Cottages of Boone and its wastewater treatment plant operational staff have responded to these issues
to the best of our ability and in good faith. It is always our goal to remain in compliance with the regulations set forth by
the Division of Water Resources, and we believe that our most recent steps will achieve consistent compliance with our
permit requirements. It is our request that our cooperation and action in these matters be taken into account by the
Division.
Please reach out to Madelyn Mills at [e-mail], or Donald Feller at [e-mail] with any
further questions or comments.
Sincerely,
Wallace Loft LLC d.b.a. The Cottages of Boone
CC
Todd Robinson, Envirolink, Inc.
Donald Feller, Envirolink, Inc.