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wq0038695_response to NOV-2021-DV-0389, NOV-2021-MV-0016, NOV-2020-PC-0265, NOD-2021-PC-0451, NOV-2021-LM-0075_20210930
Quible Quible & Associates, P.C. ENGINEERING • ENVIRONMENTAL SCIENCES • PLANNING • SURVEYING SINCE 1959 September 30, 2021 Robert Tankard NCDEQ, DWR 943 Washington Square Mall Washington, NC 27889 Re: Response to NOV OBX Waterpark Adventure WWTP — Permit No. W00038695 Currituck County, NC Dear Mr. Tankard, P.O. Drawer 870 !Iffy Hawk, NC 27949 Phone: 252-491-8147 Fax: 252-491-8146 web: quible.com On behalf of OBX Waterpark Adventure, LLC, Quible & Associates, PC, hereby acknowledge receipt of the following Notice of Violations/Deficiency: NOV-2021-MV-0076 (dated August 26, 2021) NOV-2020-PC-0265 (dated March 24, 2021) NOD-2021-PC-0451 (dated August 26, 2021) NOV-2021-LM-0075 (dated August 26, 2021) It should be acknowledged that although one of the occurrences is dated August 2019, the Notices were just received on August 30, 2021, all at once. Upon learning of a Notice, we advised that the Permittee provide a copy of the Notice, determine whether the Operator is/was aware of the potential deficiencies and advise the Operator to correct the reporting violations so those don't reoccur, and depending upon Operator feedback consult with Amphidrome (treatment process provider) if there were treatment deficiencies, and advised of the need to provide a response to the Division within 10 days of receiving Notice. In the following days, additional Notices were discovered and we looped in Keith Dobie, with B.O. Paine, the Amphidrome treatment process provider. Mr. Dobie was able to determine the Operator of the facility. We were able to conduct a virtual conference on September 27, 2021 among the following attendees: Ken Ellis, Damian Dondero, and Jonathan Credle (Operator); H2OBX Waterpark Keith Dobie and Seth Dobie; B.O. Paine Warren Eadus and Michael Strader; Quible & Associates, P.C. A copy of the agenda, and subsequent action list (in red italics) is enclosed for reference. We offer the following in response to the received Notices: 1. The primary Operator changed from Irvin W. Edwards, Jr., Atlantic Coast Underground, to Jonathon Credle. Mr. Edwards, Atlantic Coast Underground, is now the back-up Operator. 2. The primary Operator needs proper training from the treatment process provider to ensure familiarity with the specific treatment operations and maintenance. Mr. Dobie, B.O. Paine, has scheduled an on -site visitation in late November to meet with and provide adequate training for Mr. Credle. 3. Remote communications are needed at the Facility to allow the Amphidrome treatment providers access to data for the purposes of making necessary adjustments, with the assistance from the Operator. H2OBX is working with their security system provider, Johns Brothers, as well as looking into Stridelinx to set up reliable communications between the Facility and treatment provider. This will assist with Operator training and trouble shooting. 4. A recommended spare parts and equipment list will be provided to H2OBX by B.O. Paine. 5. The exceedance of permit limit occurrence was determined to be a result of a faulty/malfunctioning air valve. The Operator addressed the issue by replacing the valve. Other reporting deficiencies were determined to have occurred during a time the Operator was out of work due to Covid-19, when a back-up Operator stepped in. During that same time period, it was discovered that the UV lights had been turned off temporarily. It is our understanding that reporting and exceedance occurrences have been resolved by the Operator. 6. Please recognize that with continued training, remote communications, maintaining spare parts and equipment, and open dialog between Operator and treatment provider, the Facility as designed, permitted, and constructed should not exceed permit limits in the future. In addition to the above noted discussions, we did discuss other items as stated in the enclosed agenda. Proper idling of the system during the off-season was discussed. In addition, Quible & Associates, P.C. will be assisting H2OBX with the Permit Renewal application process. During the permit renewal process, we will likely be requesting the removal of the chlorine testing from the permit, given the UV disinfection. It should be noted that we previously requested removal of the requirement to meter/measure the volume being discharged from the groundwater lowering system, via email transmittal to Nathaniel Thornburg dated May 11, 2018 with the transmittal of the final engineering certification package (after prior discussions). Please do not hesitate to contact us at (252) 491-8147, or mstrader@quible.com, should you have any questions or require additional information. Sincerely, Quible & Associates, P.C. Michael W. Strader, Jr., P.E. encl: as stated cc: OBX Waterpark Adventure, LLC File MEMORANDUM To: Ken Ellis From: Warren D. Eadus Date: September 28, 2021 Notes from 09/27/21 in red italics Re: H2OBX WWTP Ken: cl �uible SINCE 1959 & Associates, P.C. ENGINEERING * CONSULTING * PLANNING ENVIRONMENTAL SCIENCES * SURVEYING Phone: (252) 261-3300 Fax: (252) 261-1260 Web: www.quIble.eom Need to schedule a meeting with the following people to discuss wastewater treatment plant NOV resolution, maintenance and operation moving forward: Damian Dondero Jonathan Credle Michael Strader Warren Eadus Keith Dobie Agenda: ddondero@h2obxwaterpark.com jcredle©h2obxwaterpark.com mstrader@quible.com eadus©quible.com keithdobiebopaine.co 1. NOV Resolution a. Written response to NOV's—Michael Strader with input from Jonathan Credle 2. Amphidrome specific training a. BO Paine to provide to Jonathan 3. Required equipment list a. Automation Direct Stridelinx a. Damian/Jonathan contact Johns Brothers or other provider to bring cable wifi etc. b. Spare Parts a. Keith Dobie to generate spare parts list 4. System Idle (Offseason) a. Jonathan and BO Paine to address during training 5. Permit renewal a. Go ahead and get this process started —correct time to make permit adjustments