NC0021717_NOV-2021-PC-0311 Response_20210628

TOWN OF WILKESBORO
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P.O. Box 1056.203 West Main Street
Wilkesboro, North Carolina 28697
www.wilkesboronc.org
Phone [phone] • Fax [phone]
June 24, 2021
Mr. Lon T. Snider, Regional Supervisor
Winston Salem Regional Office
Division of Water Resources, NCDEQ
450 West Hanes Mill Road, Suite 300
Winston-Salem, NC 27105-7407
SUBJECT: Response to Notice of Violation — Failure to Enforce
NOV-2021-PC-0311
Cub Creek Waste Water Treatment Plant
NPDES Permit No. NCO021717
Dear Mr. Snider,
NC Department of
Environmental Quality
Received
JUN 2 8 2021
Winston-Salem
Regional Office
This letter is being submitted in response to the Notice of Violation received for failure to enforce our
Pretreatment Program. This NOV is regarding our SIU, Wilkes County Landfill, for exceeding their TRC
ammonia limit two of the three samples during the first six months of 2020. We issued Notice of
Violations for both instances. The SIU worked diligently with the town to correct the issue then reached
compliance and continues to maintain. As previously mentioned, upon discovery of inadequate
enforcement during the PAR review, we did correct the actions by placing the SIU in SNC and issuing a
public notice.
In addition to the above actions, we have implemented multiple items to ensure the Cub Creek WWTP
Pretreatment program maintains compliance moving forward. After attending additional trainings and
reviewing numerous resources, I have applied my learnings to organizing a stricter program. I partnered
with the lab analyst to adjust SIU testing schedules so that there is additional time in the six-month
period to allow our SIUs to correct the issue, reach compliance, and avoid SNC. To be more proactive,
especially when concerns arise, we have scheduled increased communication with our SIUs to review
sample analysis reporting and current operations. We have reanalyzed our ERP, SLID, all SIU permits,
and additional pretreatment items to ensure that we have a clear understanding of our expectations for
our specific program. We now recognize the importance of following the ERP and its requirements
closely.
MIKE INSCORE KENNETH D. NOLAND JAMES K. BYRD NELLIE ARCHIBALD JIMMY HAYES
Mayor Town Manager Town Clerk RUSSELL F. FERREE Mayor Pro Tem
[e-mail] ANDREW "ANDY" SOOTS
Council Members

TOWN OF WILKESBORO
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P.O. Box 1056.203 West Main Street
Wilkesboro, North Carolina 28697
www.wilkesboronc.org
Phone [phone] • Fax [phone]
We appreciate your leniency in this matter. if you have any questions or concerns, please contact to me
at 336-981-1078 ext. 5002.
Sincerely,
Amber Garwood
Town of Wilkesboro
Pretreatment Coordinator
MIKE INSCORE KENNETH D. NOLAND JAMES K. BYRD NELLIE ARCHIBALD JIMMY HAYES
Mayor Town Manager Town Clerk RUSSELL F. FERREE Mayor Pro Tern
[e-mail] ANDREW "ANDY" SOOTS
Council Members