NC0059200_NOV2022LV0088, 0089, 0090 Response_20220209

P.O. Box 1325 Asheville, N.C. 28802
(828)-251-1900 (828)-251-1945

February 9, 2022

Mr. Daniel Boss
North Carolina Department of
Environment and Natural Resources
Water Quality Section
2090 U.S. Highway 70
Swannanoa, NC 28778

Re: NOV-2022-LV-0088/NOV-2022-LV-0089/NOV-2022-LV-0090
NPDES Permit NC0059200 Trillium Links & Village LLC
Jackson County

Dear Daniel,

This letter is written on behalf of the Trillium Links & Village LLC to provide
information as to remedial action taken to the above referenced facility. RPB Systems,
Inc. is the contract operations firm, which operates this facility.

NOV-2022-LV-0088:
As outlined in your January 26, 2022 letter we exceeded a daily maximum BOD with
213 mg/L, 21.1 mg/L, and 21.3 mg/L which resulted in a violation for the monthly
average of 5 mg/L with a 65.42 mg/L average. We exceeded a daily maximum Fecal
with 60,000 #/100mg, 60,000 #/100mg, 6,000 #/100mg, and 90,000 #/100mg which
resulted in a violation for the monthly average of 200 #/100mg with a 37,339.98#/100ml
average. We also violated the daily maximum TSS with 192 mg/L and 34 mg/L resulting
in a monthly average of 69.38 mg/L over the 20 mg/L monthly average limit.

All of these violations were result of damage or tears in the membranes in the WWTP.
Replacement membranes had been ordered for several months and delays have occurred
in delivery do to covid issues according to the manufacturer.

NOV-2022-LV-0089:
As outlined in your January 26, 2022 letter we exceeded a daily maximum BOD with
23.4 mg/L, 12.2 mg/L, and 10.6 mg/L which resulted in a violation for the monthly
average of 5 mg/L with a 12.9 mg/L average. We exceeded a daily maximum Fecal with
6,000 #/100mg, 6,000 #/100mg, 6,000 #/100mg, and 6,000 #/100mg which resulted in a
violation for the monthly average of 200 #/100mg with a 6,000 #/100ml average. We
also violated the daily maximum TSS with 105 mg/L and 60 mg/L resulting in a monthly
average of 48.35 mg/L over the 20 mg/L monthly average limit. We also violated the
daily maximum NH3Nwith 17 mg/L resulting in a monthly average of 4.4 mg/L over the
3 mg/L monthly average limit.
NOV-2022-LV-0088/NOV-2022-LV-0089/NOV-2022-LV-0090 2/9/22
NC0059200, Jackson County, North Carolina RPB Systems, Inc.
Page | 2

All of these violations were result of damage or tears in the membranes in the WWTP.
Replacement membranes had been ordered for several months and delays have occurred
in delivery do to covid issues according to the manufacturer.

NOV-2022-LV-0090:
As outlined in your January 26, 2022 letter we exceeded a daily maximum BOD with
18.1 mg/L and 39.5 mg/L which resulted in a violation for the monthly average of 5 mg/L
with a 17.18 mg/L average. We exceeded a daily maximum Fecal with 900 #/100mg,
700 #/100mg, and 6,000 #/100mg which resulted in a violation for the monthly average
of 200 #/100mg with a 247.96 #/100ml average.

All of these violations were result of damage or tears in the membranes in the WWTP.
Replacement membranes had been ordered for several months and delays have occurred
in delivery do to covid issues according to the manufacturer.

Summary:
The membranes were finally replaced on 11/18/21. The original order was still
outstanding but the vender substituted another clients order due to construction delays to
Trillium. We have seen a large improvement in the performance of the WWTP and new
membranes so far. We still recommend to the owner to consider a design modification
to the WWTP since these membranes are too fragile and do not hold up with the
conditions of the site.

I trust you will call if you have any further questions or concerns.

Robert Barr

Robert Barr