WQ0035784_NOV-2023-LM-0069 Response_20230928

DocuSign Envelope ID: 017614C4-8A41-4D94-8397-EC46A8EAA3C2
September 28, 2023
Mr. Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ-WRSO
Dear Mr. Snider,
Thank you for allowing the Cottages of Boone the opportunity to respond to the Notice of Violation dated September 15,
2023, regarding the following exceedance and monitoring violations that occurred at the Cottages of Boone WWTP
during the June 2023 monitoring period.
Subject: Notice of Violation & Intent to Assess Civil Penalty
Tracking Number: NOV-2023-LM-0069
Permit No. WQ0035784
The Cottages of Boone WWTP
Watauga County
On June 23, 2023, the plant experienced (1) TSS daily maximum exceedance, (1) Ammonia Nitrogen daily maximum
exceedance, and subsequent monthly average exceedance violations for each parameter. In May 2023, the treatment plant
membranes were disassembled, de -fouled, de -plugged, and then reinstalled. Following this procedure, continued
membrane cleaning was required as the plant returned to normalcy. As a result of this process, further de -plugging and
deep cleaning in June created intermittent turbid water conditions that resulted in elevated effluent TSS levels at the time
of sampling. Six new membranes were ordered and replaced as of early August. Regarding the Ammonia Nitrogen
exceedance, 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. In addition, operations staff are going to
begin wasting more to support the plant's de -nitrification processes.
During the June 2023 compliance period, weekend 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. The samples collected on
6/23/2023 demonstrate that TKN, Ammonia Nitrogen, and Nitrate/Nitrite samples were collected, however, an individual
Nitrate sample was inadvertently omitted. Previously, we responded to this issue by providing additional compliance
training and updated sample schedules to existing operations staff to prevent the potential recurrence of this error. During
a period of continued staff turnover over the summer months, a transitional error occurred that resulted in some lapses in
training that caused operations staff to sample combined 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. As an additional measure, we have incorporated these sample schedules into our work order system
so that they can be provided automatically to operations staff. As of September 2023, an individual Nitrate sample has
been collected in addition to the other routine parameters sampled, and we are ensuring to maintain compliance with this
requirement going forward. We are hopeful 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.
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. 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.

DocuSign Envelope ID: 017614C4-8A41-4D94-8397-EC46A8EAA3C2
Sincerely,
50�
Wallace Loft LLC d.b.a. The Cottages of Boone
CC
Todd Robinson, Envirolink, Inc.
Donald Feller, Envirolink, Inc.