WQ0035784_NOV-2020-PC-0330 Response_20200807

=IRPB SXems
Construction Services • Contract Operations • Maintenance
August 7, 2020
Mr. Lon Snider
Regional Supervisor
Water Quality Section
NCDWQ- WSRO
450 W. Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
Re: Revised Notice of Violation/NOV-2020-PC-0330/Cottages of Boone/WQ0035784
Dear Mr. Snider,
This letter is in response to your 7-28-20 NOV letter to Cottages of Boone attached.
I will attempt to respond to your letter in outline form to match your referenced letter.
Please excuse the lengthy responses but understand the membrane treatment system at
this site is very complex and is unlike any typical wastewater treatment system.
Per the outline in your letter we will address each the same as follows:
1. Minor leaking valves serving membrane. Our main objective daily is to keep
this system operational and compliant. Over the years we have replaced most of
the valves on the membranes and most every other part as well. Most of the
valves in the system are air activated motorized valves. To keep these valves
tracking properly to full close and full open is a major task that if not tracking
right will shut down entire system. Since these valves are constantly opening and
closing the seals and most wear items latterly wear out. We replace 4-6 entire
valves per year and repair as needed others throughout the year. A drip from a
valve that couldn't fill up a bucket in a week is not a major focus in our daily
work. We will attempt to replace the gaskets in leaking valves.
Note: The entire building contains a collection drain system that takes process
water from screen room and various other parts to a dedicated collection pump
tank which flows back to the equalization chamber.
2. NDAR Review -irrigation zones repairs in a timely manner. We have relied on
our drip tubing installer from Lenoir to make repairs to the drip fields. Like most
specialized contractors, they keep very busy and it taks longer to make repairs
than we would like. We often have to place several calls before repairs are made.
If we knew of a more reliable source for repairs, we would gladly try them out.
Repair parts and labor are very limited in the Boone Area. We try our best to
have an extra part on hand and reorder immediately when used. A repair this
week usually requires another repair in another zone next week. Repairs to the
P.O. Box 1325 Asheville, N.C. 28802
(828)-251-1900 (828)-251-1945

Notice of Violation/NOV-2020-PC-0330/Cottages of Boone/WQ0035784 8/7/20
drip system is a minimum 3-person job and our Lenoir sub will deploy 4-6
workers when they make repairs. We do not have the personnel on hand to make
these repairs with our own personnel. Our operator has also had a major near -
death experience with a poisonous snake, so our field investigation is limited.
Some repairs require fair weather to access and make the repairs which is very
limited at this location. We have had several repairs that appear fixed during the
repair and testing only to fail after the repair personnel has left the site. Since a
major leak will shut down the entire system, we sometimes turn off a problem
zone to keep system flowing. A day of shut down or in climate weather will
typically cause a 1-foot rise in the wet weather tank so we focus on dripping
whenever possible with the most reliable zones.
You made mention of chronic failures to repair and maintain the system.
Chronic repairs are part of this type of system. Whether due to deer, squirrels,
fallen tree limbs, solenoid valve wear, or a weak spot in piping, leaks occur and
require repairs. The irrigation zones are steep and thick. We at times need to wait
until the ground is dry enough to access and make the repairs.
Not having access to dose all six irrigation zones has most likely contributed
to the previously documented noncompliant freeboard issues- We disagree
with this statement and are certain weather conditions are the leading cause for
freeboard issues. We have about 18 days of actual usable freeboard in our wet
weather tank and wet weather, wet soil conditions, freezing weather, ice & snow
accumulation are the freeboard issues.
We know Odom Engineering has been working on a dual use permit to allow
discharge into the closest receiving stream for this site. I would encourage your
office to make every effort to ensure this permit is in place before winter or we
will repeat the potential environmental effluent spills again.
3. During inspection, a minor leak from valve on the outlet pipe of the
equalization tank was observed -my understanding that this was a drip that could
not fill a bucket in a week. We will remove the insulation and tighten the packing
of the valve. This work if not complete will be complete within the next week.
Additional deficiencies per outline and action required:
1. One recirculating pump RAS PACO is not operational. Incorrect -both pumps
are operational and working. The pump started leaking recently and became in
need of changing out with spare PACO on site. We are changing this pump out
this week and will have removed pump repaired again at a pump repair shop.
This repair has been delayed since the shut off valve feeding this pump is not
working properly and had to be replaced as well. The valve was ordered and will
be replaced within the next week.
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Notice of Violation/NOV-2020-PC-0330/Cottages of Boone/WQ0035784 8/7/20
2. Membrane feed Sulzer pump out of operation- The pump recently lost a seal
and is the third pump or spare for skid. This pump seal went out prior to your
visit and is scheduled for repairs this week as well. Parts are on site.
3. Alarm test on irrigation tank -this alarm typically goes off when the dose tank is
full and treated water then goes to the wet weather tank automatically. This dose
tank has never overflowed. We will make sure the float and control work
properly. This is a 20-ft tank and can not be inspected by our operator without
maintenance personnel and equipment.
4. Soil sampling missing parameters -we have used our Pace lab sub to coordinate
the testing with another lab. We attempt to review results to see if matches the
list in the permit and did not notice the missing results. We have asked Pace to
review this and will forward results as available.
5. Soil results parameter units -The soil results in general are a little Greek to us
since we only deal with this in this annual test. Again, we will ask Pace to review
and revise these results.
6. Wet weather and upset tank minor leaks -Not observed during inspection but
mentioned in honesty by operator when tanks are full. These tanks were approved
by State and are a bolt & sealant design. Wide temperature changes will expand
and contract these tanks and cause minor leaks. We have had the manufacturer
repair the tanks in the past and a few spots required the tanks to be emptied and
repaired from the inside. We will coordinate repairs when we observe the tanks
leaking.
7. Stormwater runoff upslope of two storage tanks -The owners have had this
work priced and we will follow-up to see what is needed to have this work
complete. No evidence of foundation erosion has been observed to date.
Concerns and or Reminders
1. Soil sampling results were not available at the time of inspection. I personally
was going to bring the entire file to this inspection. I was not able to attend with
another emergency but forwarded 3 years of results by email the day after
inspection per request. All test results are available online from each lab we use.
We make copies of all reports to keep at site and usually deliver in my visits to
the site. Covid and other issues have delayed this delivery. We will make sure
copies are on site for review.
2. The exchangeable sodium percentage (ESP) reported for some zones in 2018
and 2019 soils reports was elevated -We are not aware of sodium in the effluent
but will test for this. We will review soil sampling procedures to make sure we
follow industry standards.
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Notice of Violation/NOV-2020-PC-0330/Cottages of Boone/WQ0035784 8/7/20
3. The exchangeable sodium percentage (ESP) values in 2020 are inconsistent
when compared to 2017, 2018, and 2019 results -We have sampled the same
way from the beginning with the only change in 2020 being, we sampled in the
beginning of the year and not at year end to avoid the rush of all end of year
requirements. We again will review our sampling techniques and procedures.
4. There is evidence of the public accessing and entering the wastewater
irrigation system -We have not noticed any missing signs but will review this
again and request support by ownership.
5. Drip irrigation system calibration has not been completed yet -Not required
until April 2022, but we will make sure this is performed as required.
6. Split sampling of monitoring wells in November 2020-We will let you know
when we will try to sample the wells to let you split samples.
Please understand our operator and staff take great effort to make sure this system
functions properly. Many hours of repairs, phone calls, and sleepless nights are normal
to keep this system functional. We have no room for error in that an outage of any part of
the system will result in an eventual overflow condition. Our operator, Dale Holman, has
performed above and beyond for years and is the best suited person for this project with
wastewater experience and mechanical know how to perform at a high level. An NOV
letter like this when you can literally drink the effluent is very disappointing to say the
least. We will continue to do our best to ensure this system is functional and compliant.
I trust this answers your issues and feel free to contact me anytime if I need to provide
any further information or assistance.
Udx F4411
Robert Barr
Cc: Patrick Mitchell
Client/files
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