NC0036935_NOV-2021-MV-0008 Response_20210201

Feb 1, 2021
Mr. Daniel Boss, Asst. Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ
2090 US Hwy. 70, Swannanoa, NC 28778
Subject: Pine Mtn. Lakes WWTP NPDES NC0036935
Burke County; NOV-2021-MV-0008; Response
Dear Mr. Boss
We are in receipt of the subject NOV (notice of violation) for continuous flow monitoring, issued by you and
the Asheville Regional Office, and received by Pine Mtn. Lakes WWTP on or about January 28, 2021.
Issuance of the most recent NPDES permit NC0036935 requiring continuous flow monitoring did not occur
until November 1, 2020, at which time I was employed by Pine Mtn. as the ORC. Prior to this the system was
contract operated by Envirolink and a non-functional flow meter was in service. I did not receive any
documentation from Envirolink as to needs and issues identified by NCDEQ, until I was emailed a copy of the
permit in late October 2020. I contacted Ms. Edie Stitts, Pine Mtn. POA President with concerns about
sampling costs and other requirements and spoke with Ms. Linda Wiggs of your office. She in turn notified
me a Flow meter would need to be working at the facility. I researched the situation and contacted KDT
Service Technologies (Mr. Ken Street) regarding Pine Mtn. and their needs for a flow meter. He reviewed
pictures of the existing Parshall flume on the effluent and quoted a price, of which I immediately forwarded
to Ms. Stitts and she issued a PO for same (I have attached invoice from KDT Service Technologies for the
meter). The meter was delayed from order by almost 2 weeks, and was received and installed on Nov. 23rd
2020. From Nov. 1 until Nov. 23rd, 2020, I was reading the effluent weir and staff gauge each day I was at the
WWTP and recorded my readings. Each Day in November 2020 you have mentioned in the NOV, I was not
physically at the WWTP, including holidays such as Thanksgiving. As you are aware of the Operator rules
08G, I cannot put data down on a report, unless I have actually observed the data, and could not do so until
after Nov. 23rd, 2020. After this date we have data for each day of the monitoring period, each month.
Also, Pine Mtn. WWTP is permitted at a flow limit of 20,000 gal./day, and so is considered a minor facility
per EPA guidelines and Clean Water Act. In most cases per those guidelines, continuous flow measurement
is not required until flow is over 30,000 gal./day. We were wondering why Pine Mtn is singled out for this
requirement? Since assuming the role as ORC, I have offered guidance and suggestions to Pine MTn. POA as
to how to get into compliance and stay in compliance and have started and kept up communications with
your office to maintain this process. This was not the case with the previous operator. Pine Mtn. hopes this
response answers questions and address all concerns regarding NOV-2121-MV-0008. Should you have
questions or need additional information, please let us know.
Sincerely,
Donald R. Price, Pine Mtn. ORC Grade IV Cert. no. 10536
Cc: Attachments
Edie Stitts, Pine Mtn. POA Pres.
Linda Wiggs, NCDEQ-DWR-ARO-WQROs