NC0026689_LM-2020-0005_20200302

410,
OF D,F,vRECEN
NCr MAR 0 2 2020
M CAROti' NCDECIDwRIN�'DES
TOWN OF DENTON
February 26,2020
North Carolina Department of Environmental Quality
Division of Water Resources
450 West Hanes Mill Road
Suite 300
Winston-Salem, NC 27105
Subject: NOTICE OF VIOLATION &ASSESSMENT OF CIVIL PENALTY
Case Number: LM-2020-0005
Permit No. NC0026689
Town of Denton
Denton WWTP
Davidson County
Dear Mr.Snider:
We are writing in response to your letter dated January 27,2020 NOTICE OF VIOLATION &ASSESSMENT
OF CIVIL PENALTY Case No. LV-2020-0005, and would like to provide justification as to why a civil
penalty of any amount would impede our efforts in rectifying the issues we are experiencing.
For some time now we have been experiencing issues in meeting the permit limit for
Dichlorobromomethane.When we began experiencing these issues we reached out to the State for
assistance. On August 24, 2017 Mr.Jim Gonsiewski visited the plant to offer assistance and gave his
recommendations for additional testing.While on site at the WWTP,we collected the additional
samples for analysis.The results, received some 10 days later, showed that the pollutant was present in
the water used for disinfection.The water entering the WWTP for disinfection of the wastewater stream
showed a concentration of 14.1 ug/L.The water distribution system nor the Water Treatment Facility
are required to test for this contaminant,but are required to test for TTHM's.The distribution system
has an MCL of 60 ug/L for combined trihalomethanes.
On October 12,2017 Mr. Eric Hudson of NCDEQ,visited the plant to give recommendations for this
issue.After reviewing data and the plant layout his recommendations were;
1. Install a%2 h.p.jet pump with a small pressurized storage tank, pressure stitch,check valve, and
back washable discharge filter,with a suction line of the pump piped into the chlorine contact
chamber approximately 2 feet below the surface.
201 W. Salisbury Street
P.O. Box 306 Phone: [phone]
Denton,NC 27239 Fax: [phone]
This institution is an equal opportunity provider and employer

2. Install a%z h.p. submersible pump with a small pressurized storage tank, pressure tank, pressure
switch,check valve,and (back-washable) discharge filter,with the pump installed into the
chlorine contact chamber approximately 2 feet below the surface.
3. Install a water well on plant property.
We contacted Piedmont Chlorinator Services and showed them the recommendations given to us by Mr.
Hudson and he went to work on designing a system and ordering parts needed.The new disinfection
water feed system was placed online on March 4th 2019.A%h.p.centrifugal pump with an inline
strainer was installed with the suction located 4 feet below water line in Sulfur Dioxide chamber at end
of chlorine contact chamber.
Upon receipt of our May sampling,we showed the limit had been exceeded and we began a cleaning
project to find and remove organics from the waste stream.We drained and pressure washed secondary
clarifiers as well as the side walls of the chlorine contact chamber.We continued to pay attention to the
cleanliness of these areas but we still exceeded the parameter limit. Upon data review during cold
weather months we do not have an issue, but once the water warms up above 20°C,we see the
Dichlorobromomethane levels increase.
Upon receipt of the Notice of Violation and Intent to Assess civil penalty we contacted NC Rural Water
Association for assistance. Mr. Dwight Lancaster made two recommendations;
1. Reduce chlorine feed (lbs./day)to a level where we still meet fecal coliform limits but reduce
the chlorine that can create the pollutant.
2. Install a sump pump at end of chlorine contact chamber with an aspirator installed on the
discharge of the pump. He then said that Piedmont Chlorinators had installed this type of
system at another municipality recently.
I have contacted Piedmont Chlorinators and explained what had been suggested by NC Rural Water. Eric
Howie of Piedmont Chlorinator is ordering parts needed for this aeration system.As no additional
plumbing or power is needed,this project will not take very long to implement.
We have installed the pump with aspirator as suggested.We have reduced the chlorine feed to a level
where we are not exceeding the fecal coliform limits but have reduced the pounds per day fed.
On January 17th2020,we received an inspection by Paul DiMatteo and Jenny Graznak. I showed them
what we have accomplished and expressed my concerns over the collection methods of this analyte as it
appears to contradict what is published in the Standard Methods. Namely,the NPDES permit has this
listed as a Composite sample, but all TTHMs are collected as a Grab samples. Mrs. Graznak said she
would look into this.We have also began conducting additional test per her recommendations.We are
collecting Influent composite samples and then 24 hours later collecting effluent Composite and Grab
samples.As of the date of this letter we have not received the results from these tests. Mrs. Graznak left
me her contact information in which I will be informing her of the results. Being February and our
wastewater stream in 13°C,we do not anticipate exceeding the limits.
Lastly,we have met with a representative from NCRWA, Mr. Roger Hicks,who has contacts at
Appalachian State University biology department and he is seeking their assistance in this as well.One
hypothesis is the possibility of using Peroxone as a disinfecting agent. I await the results of their
research.

As I have explained,we have continued to seek out and find solutions for this issue.We ask that this fine
be rescinded,as any amount will impede our efforts to remain in compliance. Please note that as of the
writing of this letter we have returned to compliance.The results for December 2019 and January 2020
were<1.0 ugh .
Thank you for your consideration and attention in this matter.
Sincerely,
(jzfj14.1:17_
Troy B. Branch
Town of Denton WWTP ORC

JUSTIFICATION FOR REMISSION REOUEST
Case Number: LM-2020-0005 County: Davidson
Assessed Party: Town of Denton
Permit No.: NC0026689 Amount Assessed: $744.12
Please use this form when requesting remission of this civil penalty. You must also complete the "Request For Remission,
Waiver of Right to an Administrative Hearing, and Stipulation of Facts"form to request remission of this civil penalty.
You should attach any documents that you believe support your request and are necessary for the Director to consider in
evaluating your request for remission. Please be aware that a request for remission is limited to consideration of the five
factors listed below as they may relate to the reasonableness of the amount of the civil penalty assessed. Requesting
remission is not the proper procedure for contesting whether the violation(s)occurred or the accuracy of any of the factual
statements contained in the civil penalty assessment document. Pursuant to N.C.G.S. § 143B-282.1(c),remission of a civil
penalty may be granted only when one or more of the following five factors apply. Please check each factor that you
believe applies to your case and provide a detailed explanation,including copies of supporting documents,as to why the
factor applies(attach additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C.G.S. 143B-282.1(b)were wrongfully applied to the
detriment of the petitioner(the assessment factors are listed in the civil penalty assessment document);
(b) the violator promptly abated continuing environmental damage resulting from the violation(i.e., explain the
steps that you took to correct the violation and prevent future occurrences);
i/ (c) the violation was inadvertent or a result of an accident(i.e., explain why the violation was unavoidable or
something you could not prevent or prepare for);
(d) the violator had not been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary remedial actions (i.e., explain
how payment of the civil penalty will prevent you from performing the activities necessary to achieve
compliance).
EXPLANATION:

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
COUNTY OF DAVIDSON
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
) STIPULATION OF FACTS
Town of Denton )
Denton WWTP )
)
PERMIT NO.NC0026689 ) CASE NO. LM-2020-0005
Having been assessed civil penalties totaling$744.12 for violation(s)as set forth in the assessment document of the Division
of Water Resources dated January 24,2020,the undersigned,desiring to seek remission of the civil penalty,does hereby
waive the right to an administrative hearing in the above-stated matter and does stipulate that the facts are as alleged in the
assessment document. The undersigned further understands that all evidence presented in support of remission of this civil
penalty must be submitted to the Director of the Division of Water Resources within thirty(30)days of receipt of the notice
of assessment. No new evidence in support of a remission request will be allowed after(30)days from the receipt of the
notice of assessment.
This the day of lye11 V--r11 ,20 a0
RECEIVED SIGNATURE
MAR 02 2020 ADDRESS
NCDEQ/DWRINPDES -Td x °-
-PC 36,C 3a6
Del xi-on t\)C 2-723q
TELEPHONE
33& -K51- AZ,