NC0040339_NOV LTR dated 1-28-2019 Response_20190205

North Carolina Department of Agriculture
and Consumer Services
N.C. Forest Service
Steven W. Troxler
Commissioner
N.C. Forest Service
Region 3
14 Gaston Mountain Road
Asheville, NC 28806
January 31, 2019
Daniel Boss
Environmental Specialist
Water Quality Regional Operations Section
Division of Water Resources
2090 U.S. Highway 70
Swannanoa, NC 28778-8211
SUBJECT: NCFS Response to Notice of Violation & Intent to Assess Civil Penalty
Permit No. NCO040339
B.H. Corpening Forestry Training Center (a.k.a. Mountain Training Facility, MTF)
Avery County
Dear Mr. Boss,
Scott Bissette
Assistant Commissioner
We received the referenced Notice of Violation (NOV) on 01-28-2019 and regret to hear that the management of the MTF
Waste Water Treatment Plant (WWTP) is not being performed in accordance with permit standards. KACE Environmental,
our contracted service provider and Operator in Responsible Charge (ORC) for WWTP operation and maintenance, will also
be providing a written response to this NOV.
The following violations were noted during your inspection conducted on 11-06-2018.
1. Septic Tank — The visual alarm is not working for the dosing tank.
2. Effluent Sampling — The facility has not recorded flow in the last 3-years and no samples have been analyzed.
As you are aware, Regional Forester Greg Smith, Chasity Webb (facility manager), and I have since had multiple
conversations with you and with KACE Environmental personnel to determine the cause of stated deficiencies and to identify
the actions and/or procedures that will prevent their future occurrence. Chasity, KACE Environmental, and I will also be
meeting with you tomorrow, 02-01-2019, at MTF to discuss corrective actions in detail.
Regarding the visual alarm, you stated via phone that this is a very minor deficiency and that the vast majority of WWTPs that
you inspect have similar issues. Inspection by MTF maintenance staff indicated that some of the wiring was severed or
disconnected. As such, this will be an expedient repair and we will determine at tomorrow's meeting if it will be performed
by KACE Environmental or by the NCFS.
As you explained, the lack of effluent sampling is a different situation and indicates a need for revisions in the sampling
process. KACE Environmental has been making the requisite 2 visits per week but visits have not coincided with system
discharge. Samples have not been taken due to there being no effluent present at the time of visit. As such, analysis of
discharge content has not been possible. It was good to hear, however, that the sample obtained during your inspection, due
to flow occurrence at that time, was in compliance with permit standards for pollutants and contaminants.
1616 Mail Service Center, Raleigh, North Carolina 27699-1600
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As a remediation for the second violation, we are working with KACE Environmental to alter scheduling to ensure that visits
occur during periods of positive flow. In addition, MTF personnel will be observing and logging system effluent to hopefully
identify a discharge pattern. We will be doing so per the methodology requested in yesterday's e-mail. If successful, we can
communicate the results to KACE Environmental so they can coordinate site visits accordingly. Ken Deaver, the owner of
KACE Environmental, has also proposed using the system pump to force a flow for routine samples, or installing a time -
switch to ensure positive flow during scheduled visits. We will discuss the viability of these options in more detail at
tomorrow's meeting.
We intend to bring the operation and maintenance of our WWTP into full compliance with permit standards. Thank you for
bringing this matter to our attention and let us know if you need additional information and/or clarification.
Sincerely,
Caleb Jones
Asst. Regional Forester — Fire Control
NC Registered Forester 91592
MTF Supervisor
NC Forest Service / Region 3
[phone]
[phone]
[e-mail]
CC: NCFS Regional Forester & Division Director, Greg Smith
NCFS State Forester, David Lane
NCFS MTF Facility Manager, Chasity Webb
KACE Environmental