NC0021717_Comments (LV-2024-0216)_20240813

OE `",�KF RECEIVED
�� wakes, TOWN OF WILKESBORO
�O Lf ruttuum Awn AUG 1 3 2024
• • P.O.Box 1056.203 West Main Street
Wilkesboro,North Carolina 28697 NCDEQ/DWR/NPDES
1/C04,P Ev 1�1 www.wilkesboronc.org
ORAT Phone [phone] • Fax[phone]
August 7, 2024
Lon T. Snider, Regional Supervisor
Wastewater Branch
Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Civil Penalty Assessment Payment
NPDES Permit No. NC0021717
Town of Wilkesboro Cub Creek WWTP
Case No. LV-2024-0216
Dear Mr.Snider,
I am writing in response to the recent civil penalty assessment issued to the Town of Wilkesboro
Cub Creek WWTP for the NPDES permit violations in the month of March.We acknowledge the
validity of this penalty and would like to confirm our commitment to continuing to address the
issues that resulted in these violations.We understand the importance of complying with our
P
regulatory requirements and are remitting the full payment outlined in the notice.Along with this
payment,we would like to provide more detail of our consistent efforts to alleviate these
noncompliant challenges.
Aside from SIU collaboration, increased funding, and a plant upgrade that I will address later,the
plant supervisor and personnel have met with consultants, created additional action plans, and
made many adjustments to improve the effluent quality.While we had recently started facing a
higher strength influent loading and aggressive filamentous bacteria causing limited settleability
and overloading of the plant's capability at that time, a heavy rainfall event peaked the plant beyond
effective treatment resulting in these violations.While the operators followed heavy rainfall
procedures put in place, unfortunately,the loading was too overwhelming. Our focus before and
beyond this event is to better control our industrial influent, remove the harmful bacteria,greater
treatment, and produce better settling.The ORC and Lab Supervisor met with Maryland
Biochemical to further analyze the activated sludge and Tyson for the different bacteria and
microbes. From this meeting,we were able to build an aeration plan,as well as adding additional
micro-organisms to allow for better nitrification and remove the organic acids feeding the
filamentous.We later met with a consultant from NCRWA to review the plant's current condition
and started a more aggressive wasting plan to offset the additional solids loading.This meeting was
also very enlightening to other small process changes that could be made to reach our goals.
DALE L.ISOM KENNETH D.NOLAND DONNA RHODES NELLIE ARCHIBALD JIMMY HAYES
Mayor Town Manager Interim Town Clerk RUSSELL F.FERREE Mayor Pro Tem
[e-mail] ANDREW"ANDY"SOOTS
Council Members

In addition to these few operational changes, among many others,we are proactively upgrading
and repairing equipment, instead of previous plans to wait until the plant upgrade.The UV System
has been supplied with new bulbs and sleeves for stronger disinfection. Clarifier#2 is scheduled
for a rebuild this month as it has been offline for an extended period.This will create an additional
one hundred thousand gallons of treatment. Lastly,the digestor air systems have been modified to
allow for better aeration in the digestors, creating lower inhibition to the activated sludge from the
filtrate.
Not only are we making progressive operational changes at the plant, but our pretreatment
coordinator has also worked very closely with our largest SIU,who contributes seventy-five percent
of our influent flow,to help cover treatment of the additional loading and highly reduce the strength
moving forward.They have paid over eighty thousand dollars in required surcharges to assist in
covering the additional operational costs. In April,while it was vital for us to accept additional flow
to lower their basins, it allowed them to replace two valves to better control flow and assist with
future dredging and cleaning of both basins.Also,there has been a Diffused Air Flotation Unit
installed in the last train of their pretreatment to remove additional solids, oil and grease, and other
nutrients from their influent, effectively lessening their loading.
Lastly, I believe it is important to illustrate the support the Town provides for the wastewater
treatment plant to be able to treat all municipal and industrial waste received while attempting to
maintain permit compliance.This plant is very dependent on chemicals and polymer to satisfy their
water quality standards. From 2018 through this year,the chemical budget has increased over three
hundred percent. Personnel increased almost forty percent in 2018 from the previous year, staffing
the plant twenty-four hours a day, and an additional sixty percent since then.We continue to
introduce higher operational costs each year, averaging at least a twelve percent escalation,
including additional investments towards employee training, more thorough maintenance
programs, and equipment improvements.
Although these items may not solve all challenges mentioned year over year,we are implementing
every possible strategy to produce efficient operations until the new plant is built and running.This
project commenced in 2019,faced many modifications, and we are currently stalled waiting on a
meeting with the LGC and their approval.We are fully funded up to seventy-five million dollars,with
the authorization to construct and a new permit that includes expansion to the current designed
flow of 8 MGD. It is apparent this will be necessary to consistently meet current permit limits, and
future growth and regulatory requirements. Until then, our approach remains to stay proactive and
committed to eliminating these violations and addressing all concerns.We appreciate your
cooperation and understanding as we continue to rectify this situation. Please advise of any
additional measures that need to be taken or if any further information is required.
Thank you,
Lu..._...c.,
Kenneth D. Noland
Town Manager