NC0000400_NOVNOI2023LV0282_RESP_20230504

May 4th,2023
Daniel Boss, Assistant Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
Asheville Regional Office
2090 U.S. Highway 70
Swannanoa, N.C. 28778

Subject: Notice of Violation
Limit Exceedance Violation
Monthly Average Total Fluoride Exceedance

Dear Mr. Boss
This letter is provided in response to the above-referenced notice of violation, dated April 24th,
2023. The KT Plant (The Quartz Corp/Pine Mountain), NPDES Permit Number NC0000400, unfortunately
has exceeded the permit for Monthly Fluoride "pounds per day" average discharge. The permit limit is
132lbs/day average and the discharge average for the month was 133.9lbs/day. Listed below will be a
brief overview of the KT plant wastewater treatment facility and the findings of an investigation The TQC
KT plant conducted after knowledge of the Fluoride Monthly Average exceedance.
The KT plant wastewater treatment facility is composed of 3 settling ponds, a lower primary
pond, two secondary (upper and middle) ponds and a solids waste screw to remove solids. At any given
time only two ponds are used in series. Either the middle pond is fed from the KT plant or the upper
pond. Once in the upper or middle pond, the wastewater then overflows to the lower pond before
exiting through a v-notch weir and flow meter to be discharged. Settling of solids is achieved with the
aid of polymer/flocculant in either the upper or middle pond. PH is adjusted prior to either pond with
the addition of lime. Flow is measured daily, and weekly samples are collected at the weir and lab
analyzed.
After calculations determined The Quartz Corp. KT plant was in exceedance of the permit, after
notifying the Ashville Regional Office, The Quartz Corp management assessed the wastewater facility
and plant to understand what may have contributed to the monthly average exceedance. Listed below
are results of the assessment and corrective actions taken to prevent the exceedance in the future.
Rainfall: The KT plant wastewater treatment facility is a series of settling ponds that constitute
the wastewater facility. While it is an old outdated system and allows for little to no ability to actively
treat the wastewater for Fluorides and TSS, the KT plant does add Lime for pH adjustment and to aid in
precipitation of fluorides, polymer is added for TSS. Rainfall can drastically hinder the ability to treat the
water. Further, excess rainfall can drastically increase our effluent discharge making our effluent
numbers higher than TQC uses. For the month of March, the Spruce Pine area received 8.78 inches of
rainfall. The KT plant watershed and plant wide stormwater gathers a significant amount of rainfall that
enters our wastewater settling ponds that increases the wastewater discharge, therefore, inflating the
daily numbers. The amount of actual "process water" used by the plant is very stable, but actual
discharge numbers fluctuate drastically with rainfall. These elevated numbers due to rain not only
increase Turbidity and TSS but affect the pounds per day conversion of Fluorides.
The KT plant has been in the planning phase for a major plant improvement project for some
time and one of the main aspects of the project is a filter plant for wastewater treatment. Approval for
the project has been granted and preliminary work has started. With this project some components of
the old wastewater system must be removed or updated. One change was the removal the waste screw
and pump box. With the removal of the pump box, the pH probe for lime addition had to be relocated
to another pump box closer to the plant, prior to the solids waste screw. After the assessment it was
discovered the pH probe was being blinded by excess solids in the pump box, giving a false pH reading to
the control room resulting in a decrease of calcium/lime that aids in Fluoride precipitation. There was a
change in pH range for testing in the month of March. The pH of the first two sample collections of the
month changed from 7.3 and 7.4 to 6.7 and 6.8 for the last two weeks of March. After the investigation,
it was found the calcium/lime addition has decreased as a result of the pH probe being blinded by
excess solids in the pump box. To correct the problem, KT plant has implemented a schedule to pump
down the solids from the pump box each shift, reducing the amount of solids and allowing the pH
adjustment system to function properly and dose the correct amount of calcium/lime in the system.

TQC regrets that the Monthly Fluoride Limit was exceeded. Excess rainfall is a factor that cannot
be controlled easily in the current setup, but calcium/lime addition can be controlled. Corrective actions
have been put in place to prevent the lack of lime entering the system. TQC does and will continue to
take steps to control and prevent any wastewater effluent limit exceedances from occurring in the
future. One major control in preventing any exceedances will be the future construction of a modern
wastewater facility that will give more control on treating effluent before being released back into the
environment. The wastewater facility is a two-year project that currently is in the final stages of
engineering, and the beginning stages of construction at this time.

If you have other comments or concerns, please feel free to contact me.
Sincerely,

John Silver
TQC Environmental Manager
[e-mail]
828-765-8979
797 Altapass Rd
Spruce Pine, NC 28777