NC0046809_Response to Notice_20241011

October 3, 2024
Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
Subject: Notice of Violation
Tracking Number: NOV-2024-NW-0106
Permit No. NC0046809
Cornerstone Conference and Resource Center WWTP
Guilford County
Mr. Snider,
Thank you for allowing Cornerstone Conference Center the opportunity to respond to the Notice of Violation dated
September 25, 2024; received September 30, 2024. Our response below is in regard to the frequency violations cited for
the June 2024 monitoring period.
The Cornerstone Conference Center had no flow during the month of June. Frequency violations were cited for every
week of the month due to missing weekly Upstream and Downstream Dissolved Oxygen (DO) and Temperature samples.
Given the facility's no flow condition, we refer to Section D.1. Representative Sampling of our permit, which states:
"Samples collected and measurements taken, as required herein, shall be representative of the permitted discharge." With
no effluent entering the receiving stream, any upstream or downstream samples would not have accurately represented the
facility's performance or its impact upon the waterbody. Therefore, we contend that the facility should not be considered
in violation for the absence of Upstream and Downstream sampling data on the June 2024 DMR. The absence of flow
means there were no changes to the characteristics of the receiving stream to observe or measure, and any samples taken
would not have been representative as required by our permit.
Upon review of the June eDMR, it was discovered that the "no flow" checkbox on the main reporting page was
inadvertently left unchecked. We believe this clerical error may have triggered an automated non-compliance alert in NC-
DEQ's BIMS system. It's worth noting that in previous months of no -flow conditions, we consistently checked this box
and received no violations, leading us to conclude that this deviation from our standard data entry protocol likely triggered
the violation status of these parameters. To address this issue, we have revised the June report to correctly indicate the no -
flow status by checking the appropriate box.
We appreciate your consideration of these circumstances and are available to provide any additional information that may
be helpful in reviewing this matter. It is always our goal to remain in compliance with regulations set forth by the Division
of Water Resources. It is our request that our cooperation and action in these matters be taken into account by the Division
when proceeding with enforcement.
Si cerely,
Darrell Gaines
Western NC Conference Center
CC:
Todd Robinson, Envirolink, Inc.
Ronald Wall, Envirolink, Inc.