WQ0035784_NOV-2023-LM-0085 Response_20231103

DocuSign Envelope ID: AC8D9379-E1BA-4F7F-A6DD-76C9985AOFC2
November 3, 2023
Mr. Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ-WRSO
Subject: Notice of Violation & Intent to Assess Civil Penalty
Tracking Number: NOV-2023-LM-0085
Permit No. WQ0035784
The Cottages of Boone WWTP
Watauga County
Dear Mr. Snider,
We appreciate the chance to address the deficiencies highlighted in the October 24, 2023 Notice of Violation (Tracking
Number NOV-2023-LM-0068) following the examination of the April 2023 and July 2023 monitoring reports for the
Cottages of Boone wastewater treatment plant. After carefully reviewing the issues outlined in these notices, we have
implemented corrective actions (as detailed below). Your review and consideration are greatly appreciated.
July 2023
• BOD and TSS Daily Maximum and Monthly Average exceedances:
o BOD
The BOD Daily Maximum and Monthly Average exceedances for July 18, 2023, were a result of a blower
malfunction from an overheat issue resulting in a lower -than -normal Dissolved Oxygen level below the
recommended 2.0 — 4.0 mg/1 in the plant's aeration tanks. The lower Dissolved Oxygen level resulted in less
efficient biological activity without achieving efficient BOD removal rates. The blower was repaired, and the
dissolved oxygen levels returned to the normal levels of between 2.0 — 4.0 mg/l in the plant's aeration tanks by
July 19, 2023.
o TSS
The TSS Daily Maximum and Monthly Average exceedances were related to aggressive membrane cleaning in
which the membranes had to be removed from service and de -plugged of solids in the membrane influent passage.
After the thorough cleaning which removes all of the sludge material from the membrane, there is a period in
which the membranes "self -heal" and rebuild a biomass on the membranes which aids in filtration. During this
"self -heal" process, it is common for some pass-thru of solids through the membranes which can result in higher -
than -average TSS and turbidity values. The sample results and exceedances for July 18, 2023, were elevated as a
result of this cleaning process and pass-thru from the membranes.
Frequency Violations for Flow:
An amended NDMR was submitted on 10/24/2023 to rectify missing flow data from the original report. The flow
data was compliant with daily maximum and monthly average limits.
Frequency Violation for Nitrate:
The samples collected on 7/17/2023 demonstrate that TKN, and Nitrate/Nitrite samples were collected, however
an individual Nitrate sample was not. To prevent future recurrences, operators have received additional
compliance training, and updated sample schedules have been distributed to all operations staff. The staff will
adhere to these schedules moving forward. As of current, the facility is compliant in meeting Nitrate monitoring
requirements.
April 2023
0 Frequency Violations for Turbidity and Flow:

DocuSign Envelope ID: AC8D9379-E1BA-4F7F-A6DD-76C9985AOFC2
During this period, turbidity and flow measurements were observed but not recorded, resulting in incomplete
monitoring reports. To prevent such occurrences, operators are now required to document measurements in both
Envirolink's Computerized Maintenance Management System (CMMS) and the field bench sheets. Moreover, all
staff members have undergone additional compliance training, are receiving additional training and support on a
once weekly basis, and are mandated to undergo refresher training annually.
An updated NDMR was generated on 10/30/2023 to incorporate the previously omitted flow data. Presently, the
facility is compliant in meeting turbidity and flow monitoring requirements.
• (1) frequency violation for pH:
A singular pH frequency violation occurred on 4/25, where the measurement was observed but inadvertently left
unreported. With this exception, the facility has otherwise been compliant in meeting all pH monitoring
requirements.
Missed monthly sampling:
The facility is required to conduct monthly monitoring for BOD, Fecal Coliform, TSS, Total Nitrogen, Ammonia
Nitrogen, Nitrate, TKN, and Phosphorous. The misstep occurred when the recently onboarded operator
inadvertently labeled the monthly samples as "monitoring well' samples on the chain -of -custody form, rather than
specifying that they should be analyzed as effluent wastewater samples as stipulated by the permit. Consequently,
the samples were improperly analyzed, rendering them invalid. This oversight unfortunately resulted in the
subsequent exclusion of the required monthly samples, resulting in a monitoring violation.
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 mmills&envirolinkinc.com, or Donald Feller at dfellergenvirolinkinc.com with any
further questions or comments.
Sincerely,
50---
Wen De Tam
The Cottages of Boone
CC:
Donald Feller, Envirolink, Inc.
Todd Robinson, Envirolink, Inc.