WQ0002284_NOV-2021-PC-0434 & LV-0775 Response_20211102

November 02, 2021
Robert Tankard
Division of Water Quality
Washington Regional Office
Washington, North Carolina
Reference: Outer Banks/Kinnakeet Associates, LLC
Kinnakeet Shores Collection System
Permit No. WQCS00295
NOV-2021-PC-0434 and NOV-LV-0775 Response
Dear Mr. Tankard:
I am writing in response to the Notice of Violations, issued August 25, 2021 and October 14,
2021 for the Kinnakeet Shores Waste Water Treatment System, Permit No. WQ0002284.
We have reviewed the violations and are providing the following response.
NOV-2021-PC-0434 Violations:
End Use -Reuse:
Irrigation equipment is not operational. WARO believes all water is going to the
irrigation/high-rate pond. Required monitoring wells have not yet been
installed.
Response: See Page 2 relative to Monitoring Wells.
Treatment Clarifiers: Clarifiers were observed during the inspection and were not working.
Response:
The external clarifier's drive shaft broke and was repaired. The external clarifier
was operating, however the drive shaft repair failed. The plant operates on one
clarifier under normal conditions. We are working to find replacements to repair
the external clarifier and have a back-up for the external clarifier and restore the
internal clarifier. Mr. Pharr is currently looking for a speed reducing motor that
turns the chain that operates the clarifier as well as continuing to look for
clarifiers. We have the funds set aside to pay for the clarifiers when they are
available. Unfortunately, we are being exposed to the same circumstances
everyone is in getting parts and repair parts. Secondly it appears Mr. Pharr has
located a source to rewind our existing motors. This is a major positive in
rectifying these circumstances.

Mr. Tankard
Page 2
Treatment Flow
Measurement -Effluent ORC stated the flowmeter is in need of repair.
Standby Power:
Response:
It was determined through Hach Technologies that the sensory board was bad.
The Flow meter was replaced with an exact model from another system.
ORC stated that the generator wasn't currently working.
Generator is not working. New batteries were purchased for the generator. We
are working to bring in an outside source to diagnose and repair.
Monitoring Wells Permittee failed to install monitoring wells.
Permittee, through Engineer Mark Bissell has located a well driller to install the
wells as required for Outer Banks/Kinnakeet Associates, LLC. Installer is in the
final stages of recovering from hip surgery to complete the installation of 100%
of the wells within 90 days. 1 personally will be speaking with the driller
tomorrow to engage him financially.
Damaged Roof Permittee failed to repair damaged roof.
We would like to repair the damaged roof, but as this not a treatment
component to the waste water plant and was installed for aesthetics for the
community, 1 would ask that this condition of the permit be omitted and the
permit modified.
Permittee failed to submit required waivers and site map
For the setback waiver violation Mr. Bissell researched the permit history and
noted that the WWTP was built under Permit EQ0002284 that was issued on
January 31, 2003 which did not have a setback requirement from the storage
pond to the habitable residences under separate ownership. This requirement
was added with the August 2008 renewal after the facility was constructed and
had been in operation for several years. Mr. Bissell believes that the Permitee
should not be required to get after -the -fact waivers in this instance. 1 look
forward to any other questions or discussion on this matter.

Mr. Tankard
Page 3
Treatment Filters: The ORC stated the traveling bridge filter is not working. Filter has not worked
now for several inspections.
Response:
The traveling bridge filter works by hand but not automatic. At the time of the
inspection on August 17, the traveling bridge was not operated manually at the
request of the inspector. Mr. Pharr and I are searching the marketplace for the
requisite motor.
*Response: Outer Banks/Kinnakeet Associates, LLC does not generate enough funds
from utility revenues to pay ongoing normal operating expenses. However, we are
currently seeking the financial requirement to make the requisite repairs within 30 to 90
days. We are preparing for a 20+ year rate increase while still operating off the original
rate that was assigned day 1. We have in essence been paying the utility rates of our
customer base for 20+ years. We have not applied for a rate increase in 20 plus years
and are still operating off the original rate that was assigned day one. We are applying
for a rate increase with the North Carolina Utility Commission. We will seek an interim
rate change while we are working through the increase process.
Due to the significant impact of Covid 19, the inability to secure parts has dramatically
impacted our response over the past year. Secondly, with strict and intense heart
related matters and essentially 90 days of treatment at the Cleveland Clinic, 1 am on the
mend.
NOV-2021-LV-0775 Violations:
Limit Exceedance Violation(s):
Sample
Location Parameter
Date
Limit Reported
Value Value
Type of Violation
001 Nitrogen, Ammonia Total as 7/1/2021 6 7.7 Daily Maximum Exceeded
N) (00610)
Nitrogen, Ammonia Total (as 7/7/2021 6 8.5 Daily Maximum Exceeded
N) (00610)

Mr. Tankard
Page 4
001 BOD, 5-Day (20 Deg. C) 7/13/2021 15 16 Daily Maximum Exceeded
(00310)
001 Nitrogen, Ammonia Total (as 7/31/2021 4 5.48 Monthly Average Exceeded
N) (00610)
Summer temperatures effected treatment and exceeded monthly limit for Nitrogen on
July 1 by 1.7 mgl, on July 7 by 2.5 mgl, on July 31 by 1.48 mgl was addressed in
operations with increasing air in the treatment. Adjustments were made to include
increase air to treatment.
Summer temperatures effected treatment and exceeded BOD limits by 3 mgl on July 7
and by 1 mgl on July 13. Adjustments were made and corrected as BOD testing on July
22 and July 27 were within limits.
Sample
Location Parameter Date Type of Violation
001 Chloride (as CI) (00940) 7/31/2021 Parameter Missing
Was tested but not reported
001 Solids, Total Dissolved- 180 Deg.0 7/31/2021 Parameter Missing
Was tested but not reported
(70300)
002 Oxygen, Dissolved (DO) (00300) 7/31/2021 Parameter Missing
Was tested not reported
003 Oxygen, Dissolved (DO) (00300) 7/31/2021 Parameter Missing
Was tested but not reported
The missing parameters are sampled 3 times per year. The items were tested but not
reported on the NDMR. An amended NDMR is attached and will be filed. The Chloride
and Total dissolved solids were tested on the 22nd of July. A copy of the Lab report is also
attached. The Dissolved Oxygen is an onsite grab sample, also done on the 22nd of July.
Mr. Bissell suggested that I should request removal of the NOVs based upon the updated
information provided by Mrs. Pharr as some of the information was inadvertently left
out of the report.

Mr. Tankard
Page 5
I want to apologize to you, Sarah and your staff for the complete inconsistencies in the
operations of Outer Banks/Kinnakeet Associates, LLC. It has been a very difficult eight years, my health
matters, and now we can accentuate the positives of a great real estate market. FINALLY !! Robert, we
are finally where we were in 2005 and 2006 with this emergence. We are now beginning to see
consistent revenues from other assets that can be utilized for Outer Banks/Kinnakeet Associates, LLC.
Again, please accept my apologies as we begin to move forward in the latest surge that Pat Weston
mentioned to you this week. We have waited and waited but now it has finally occurred.
Also, I want to thank David and Michelle Pharr, and children, for the absolutely incredible work
they have done with this facility. Also, my sincerest thanks to Mark Bissell, Bissell Professional Group
who designed this 3.5 million dollar facility for me and the incredible work he has done to assist me
through these very difficult times. It will be nice to create the consistencies in which we can generally
operate business in a positive manner.
Lastly, if there is any additional information needed, please let me know.
Best regards,
Ray E. Hollowell, Jr.
Outer Banks/Kinnakeet Associates, LLC