WQ0004823_NOV-2018-LV-0820 Response_20190104

Enviro-Tech
William G. Freed, Inc.
PO Box 69
Harbinger, NC 27941-0069
Robert Tankard
Environmental Resources, Water Quality
Washington Regional Office
943 Washington Square Mall
Washington NC
Subject: Pine Island Currituck, LLC.
NOV-2018-LV-0820
Mr. Tankard,
TelepX&ftb;q )'491-5277
FAX (2WQ091-5777
January 4, 2019
The following is in response to NOV-2018-LV-0820 received Dec 26, 2018 prepared by the
operator on behalf of the Pine Island Currituck, LLC.
Concerning the Ammonia violation for the sample date of June 19, 2018 all plant operational
parameters were within optimal ranges. Nitrification is a high-level function and the "ramp up"
of summer comes faster than the biology can grow.
We have experienced this before and have been aggressive in staying on top of this issue.
Because of our experience in 2017 and as preparation for the 2018 season we purchased and fed
vitamin supplements and nitrifying bacteria to the plant to help it ramp up faster than through
natural processes. We fed the supplements from April until early June. We exhausted our supply
of supplement and believed that we were far enough into the summer that the plant would keep
up. The June 19'' sample followed a 100,000 gallon per day increase in flow over the 7 days
prior. Clearly this was the beginning of the tourism season. The plant went from 230,000
average daily flow to 330,000 average daily flow between the 12'h and the 19''. We are pleased
that we were able to perform at the level that we did. We realize that we need to adjust
supplement quantities and plan to do so for 2019.
The permit limits extrapolated for PICC, LLC, allows us to discharge up to 2,702 lbs of
ammonia per year to the golf course. Based on our normal monitoring protocols as dictated by
the permit, we extrapolate that the plant has sent 25.36 pounds of Ammonia to the golf course
over the entire year of 2018. This number includes the violation referenced. Although we
recognize the finding, we believe that there was not material environmental damage that would
justify a significant monetary enforcement action.
The cost of the supplements, etc. was $2,344.27 plus operator time dosing and monitoring the
change of the plant biology. The outcome of the dosing was positive and addressed the problem
identified in 2017; we improved from four minor exceedances in 2017 to 1 minor exceedance in
2018. Clearly we will be using the same program in 2019, and as stated earlier, adjusting
supplement quantity to lengthen the duration of dosing. We believe that this will alleviate any
further issue moving forward.

Thanks for your time and consideration concerning this matter. I would ask that some
consideration be given to the improvement in effluent quality. The ammonia exceedance is not-9e,,,
difficult to understand and we are making good progress, however if we identify a known`
deficiency in the plant or process that we know is a significant factor we will correct it and notify
you as well.
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William G. Freed
Enviro-Tech
President