WQ0002284_NOV-2021-LV-0885, 0886 & 0581 Response_20211212

December 12, 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-LV-088S, NOV-LV-0886, and Nov-PC-0581 Response
Dear Mr. Tankard;
I am writing in response to the Notice of Violations, issued November 29, 2021, for the Kinnakeet Shores
Waste Water Treatment System, Permit No. WQ0002284.
We have reviewed the violations and are providing the following response.
Exceeded Daily and Monthly Parameters
First Solution to Parameter Violations
The monitoring parameters are being affected by the external clarifier sweeps
being out of service at this time. The sweeps are operated by a speed reducer
and is proprietary equipment that was discontinued. We have worked over the
past year to build and rebuild the external clarifier's speed reducers, even using
the internal clarifier's speed reducer. We have been desperately looking to find
a replacement. The company that made the original gear reducer has been
bought and sold three times. We have FINALLY located the source and are
working to get one gear reducer on order at the purchase cost of $6,000.00
each plus delivery and installation. We are working with the manufacturer, as of
today, for an expedited delivery and will have an answer for you by your next
inspection. We plan to order the second gear reducer for the internal clarifier
once we ascertain the replacement part works properly. This will have both
clarifier's repaired, hopefully in the immediate future.
in addition to the gear reducers, we are having both clarifiers return pumps
rebuilt. The estimated cost of these repairs is $8,000.00 of which we will pay in
advance.

Second Solution to Parameter Violations
Immediately following the repair of the external clarifier, we priced, the past
Friday, the removing of the solids from the filter and re -bedding the filter with
approved filter sand. The filter sand material will be delivered on site and
waiting for the clarifier repair prior to the delivery of the gear reducer. The
current estimated cost for the re -bedding of the filter is $15,000 to $20,000.00.
The combined expenditures for getting the clarifiers and the filter online is estimated to be $44,000.00.
We are expediting the repairs of the external clarifier and the filter to be completed as soon
as possible with an expedited delivery of the gear reducer, or at the latest, by mid -March based off the
original quote. Well before flows increase with vocational rental demands. These repairs will provide the
treatment components necessary to bring the parameters in compliance with permit. During the off
season months, we expect to continue to exceed limits until these repairs are made. I will update your
office with the equipment delivery status and expenditures for the repairs.
Inspection Violations noted at the November 16, 2021, inspection.
Roof Repair As I have responded before, I do not feel this is a permit issue and needs to be
taken out of the permit parameters. Please advise how this can be addressed.
Treatment Clarifiers Addressed in above response.
Treatment
Clarifier and Filter repairs addressed above. Solids in Clarifier are being
returned to the head of the plant, but the sweeps are not preventing solids from
Overflowing into filter. The detailed plan for repair addressed above.
End of Use Monitoring wells are being sourced and estimated. Monitoring wells will be
expedited after the clarifier and filter repairs are complete.
Stand by Power
Spray irrigation has not worked in over 12 to 15 years as documented on the
NDAR-1 reports. We are evaluating the spray irrigation solution.
The operator did not demonstrate the generator as it has been noted in the last
four inspections that the generator does not produce power. The generator
was installed at the cost of $17,000.00. Due to the corrosive environment the
generator is not working. As of today, we have found a company that can
provide a solution and are working to provide them with the generator
specifications. I can provide you with updates as work progresses.

Solids in Clarifier and
Treatment Filter
Solids in Clarifier are being retuned to the head of the plant. The Treatment
filter will have all solids pumped and removed by pump truck, filter will be
pressure washed and then the new filter media installed.
In the Notices of Violation, the three items that do not have a correction plan in place is the roof, the
spray irrigation, and the site map. in my previous responses I have noted an exception to the roof as a
permit parameter. I have noted with documentation from my engineer that the site map should not be
required. I am asking for a new schedule on the spray irrigation as the system has not been in operation
for over a decade and not a violation until this year. The treatment components and monitoring wells
are first priority and resolutions for these items is being implemented.
Just please note that in the past two years, we spent $15,000.00 on the rebuilding of the Dory lift station
pumps and $9,439.71 on blower motors for the plant, totaling $24,439.71. Repairs and
maintenance have been ongoing. We will be spending an estimated $50,000.000 on the facility prior to
the start of the 2022 peak rental season totaling 74,439.71 that combined with the 17,000.00 spent on
the generator, monies spent on repairs and equipment will total $91,439.71.
Tha
owell
Out :: nks/Kinnakeet Associates, LLC