NC0032115_NOv2023LV0729_RESP_20231024

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Water Quality Lab & Operations, Inc.
P.O. Box 1167/ 1522 Tynecastle Highway
Banner Elk, NC 28604
Ph. 828-898-6277 Fax [phone]
October 24, 2023
Daniel Boss, Assistant Regional Supervisor
WQ Regional Operations Section
Asheville Regional Office
2070 U.S. Hwy 70
Swannanoa, NC 28778-8211
Re: Banner Elk WWTP, NOV-2023-LV-0729
Dear Mr. Boss:
In response to above Notice of Violation noted in the report, we acknowledge the exceedance of
N 13 on the days noted. During the time the violation occurred, the Town was experiencing high
traffic due to Independence Day and Highland Games events occurring in the area. As in years
past, local pump truck contractors were permitted to discharge portable restroom waste into the
collections system. During previous high -traffic events, this did not cause upset conditions in the
plant. We are unsure if there was a difference in volume or frequency in discharge compared to
previous years, but there was an upset as evidenced by our reported NH3 results.
As soon as we were aware of the conditions in the plant changing, we immediately implemented
mitigatory measures to address the issue. Although the following day's sample had decreased in
NH3 significantly, it was unfortunately short of preventing an exceedance and that contributed to
the monthly average exceedance noted in the Notice of Violation.
The work to mitigate the issue was ultimately effective, as all other parameters were compliant
during the time of the NH3 exceedance. While we did regrettably have a noncompliant DMR, we
kindly request that DEQ consider the work we did to mitigate the problem, and also note that the
plant's other parameters during that time were compliant. In addition, the plant, since the time of
the violation, has not had any other noncompliant discharges.
Thank you for the opportunity to address the notice of violation, and thank you for your time and
consideration. Please feel free to contact us if we can be of further assistance or provide
additional information.
Sinoy,
aul Isenhour
W.Q. Labs
Cc: Rick Owen, Justin Hodges