NC0071528_Response to NOV 2023-LM-0045_20230719

July 18, 2023
Mr. Andrew H. Pitner, P. G., Assistant Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
Subject: Notice of Violation and Intent to Assess Civil Penalty
Tracking Number: NOV-2023-LM-0045
Permit No. NCO071528
Lake Norman Woods WWTP
Catawba County
Mr. Pitner,
Thank you for allowing the Lake Norman Woods HOA the opportunity to respond to this Notice of Violation
dated July 7, 2023; received July 10, 2023. This response pertains to the (3) frequency violations for Total
Residual Chlorine and Flow, (1) BOD daily maximum exceedance, (1) NH3N daily maximum exceedance, and
(1) subsequent NH3N monthly average exceedance events that occurred during the May 2023 monitoring period.
The BOD and NH3N exceedances were caused by various complications with plant infrastructure that have
adversely affected the plant's operations at the time that these violations occurred. While no ammonia nitrogen
daily maximum exceedances occurred, the overall average was enough to exceed the permitted limit. To mitigate
elevated BOD levels, operators have been brushing down and agitating the bottom of the aeration basin to
increase biological activity in the plant. Capital improvements to the wastewater treatment facility are currently in
progress, with an anticipated completion time of 90 days maximum.
Frequency Violations for Total Residual Chlorine (TRC) for the weeks ending 5/20/2023 and 5/27/2023; as well
as for Flow for the week ending 5/27/2023, were due to a reporting error that has since been corrected through
amendment of the eDMR. TRC samples during these weeks were collected on 5/17, 5/18, 5/24, and 5/26. Flow
was collected on 5/23, 6/ 1, and 6/2.
We believe that the Lake Norman Woods HOA and WWTP operational staff have responded to these issues to the
best of our ability and in good faith. We are confident that upon completion of the reconstruction efforts that
effluent quality will be greatly improved. It is always our goal to remain in compliance with regulations set forth
by the North Carolina Division of Water Resources. As a small community association, it is very expensive for us
to make such repairs. In the event of considering financial enforcement, we request that the Division take this
factor into account when proceeding with enforcement.
Sincerely,
s
Dale Norman
Lake Norman Woods HOA
CC:
Todd Robinson, Envirolink, Inc.
Josh Powers, Envirolink, Inc.