NC0086053_NOV-2019-LV-0261 Response_20190507

IDynamls,Inc.
P.O. Box 50636, Knoxville, TN 37950
Phone: [phone]
May 7, 2019
Mr. G. Landon Davidson, P.G., Regional Supervisor
Ms. Mikal Wilmer
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
2090 US HWY 70
Swannanoa, NC 28778-8211
RE: Response to Notice of Violation
Pilot Travel Center #393
Permit #NC0086053
Tracking # NOV-2019-LV-0261
Haywood County, NC
Transmitted by: Federal Express
Mr. Davidson and Ms. Wilmer:
MAY - 8 2019
Water Cltrar+.
Dynamis, Inc. (Dynamic), has been authorized by Pilot Travel Centers LLC (Pilot), to prepare a written
response to the Notice of Violation (NOV) dated April 9, 2019 and issued by the North Carolina
Department of Environmental Quality (DEQ) Division of Water Resources (DWR) for the above
referenced facility. Pilots Environmental Department received this letter and date stamped it, April 16,
2019.
We have prepared a comment and response to comment format, in order to properly address the items in
the letter:
DMR Comment #1: A review of the February 2019 Discharge Monitoring Report (DMR) for the subject
facility revealed the violation(s) indicated below:
LimitExceedance Volation(s):
Sample
Parameter
Date
Limit Value
Reported
Type of Violation
Location
Value
001 Effluent
BOD, 5-Day
212012019
45
50
Daily Maximum
(20 Deg. C)
Exceeded
Concentration
(C0310)

Pilot Travel Center# 393
Waynesville, NC
Remedial actions, if not already implemented, should be taken to correct any noted problems.
The Division of water resources. may pursue enforcement actions for this and any additional
violations.
Response & Action Taken: The source of the slight biological oxygen demand 5-day (BODS)
exceedance in the 2/20/2019 weekly sampling was due to lower than normal dissolved oxygen
levels in the WWTP tanks, which caused the BOD5 concentration to be slightly elevated in this
one weekly sample. The WWTP operator made aeration rate adjustments at the WWTP. The
subsequent weekly sample collected on 2/27/2019, indicated a BOD5 concentration of 43 mg/L,
which was below the daily maximum permit limit. Further aeration adjustments were made to
\ lower BOD5 concentrations.
Weekly BOD5 samples were subsequently collected on 3/6/2019, 3/13/2019, 3/20/2019, and
3/27/2019. The BOD5 concentrations were: 17.8 mg/L, 40 mg/L, 5.5 mg/L, and 18.3 mg/L,
which were below the daily maximum permit limit of 45 mg/L. There were no permit limits
exceedances for any of the sampling parameters in the 3/2019 monitoring period.
It appears that the BOD5 daily maximum exceedance in the 2/20/2019 weekly sample was an
isolated occurrence, due to a waste water operational and maintenance issue. Dynamis and the
WWTP operations and maintenance contractor will continue to monitor the sampling
concentrations, and perform maintenance as needed to maintain permit compliance.
Thank you in advance for your time and assistance in resolving these issues. Pilot, their waste water
operation and maintenance contractor, and the WWTP operator are committed to operating and
maintaining this WWTP in a regulatory compliant manner. Please contact me with any questions or
concerns that you may have.
Respectfully Submitted,
Alan J. Fass, P.G.
Environmental Program Manager
Dynamis, Inc.
Tel. [phone] Ext. 208
Email alanfassna,dynamis-inc.com
cc: Joey Cupp, Director of Environmental, Pilot Travel Centers LLC, 5508 Lonas Drive, Knoxville,
TN 37909
Keith Carlton, Environmental Project Manager, Pilot Travel Centers LLC, 5508 Lonas Drive,
Knoxville, TN 37909
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