WQ0021491_NOV-2020-PC-0504_20201204

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
December 4, 2020
CERTIFIED MAIL # 70181130 00001608 2446
RETURN RECEIPT REQUESTED
Mr. Matt Settlemyer, Town Manager
Town of Mocksville
171 S Clement St.
Mocksville, NC 27028
SUBJECT: Notice of Violation — (NOV-2020-PC-0504)
Compliance Evaluation Inspection
Dutchman Creek WWTP
NPDES Permit No. NCO021491
Davie County
Dear Mr. Settlemyer,
On November 30, 2020, North Carolina Division of Water Resources, staff persons Justin
Henderson and Alex Lowe performed a compliance evaluation inspection of the subject facility.
Present during this inspection were Chip White, ORC (Envirolink), Josh Powers, Area Manager
(Envirolink), Chuck Willis, P.E. (Town of Mocksville), and Brian Moore, Public Works Director
(Town of Mocksville). This type of inspection consists of two basic parts: an in -office file review
and an on -site inspection of the treatment facility.
This inspection reflects non-compliance with Permit No. NC0021491. The following violations
require your attention and action:
1) BOD exceedances for both weekly and monthly average limits have continuously and
consistently been documented on monthly Discharge Monitoring Reports, submitted in
accordance with Permit Condition Part I Section A. (4). Reportedly, these violations are due
to a combination of limited solids storage provided by the current treatment design as well as
an insufficient and inadequately sized pre-treatment system in operation at the facility's one
contributing Significant Industrial User (SIU).
Reportedly, as of 1010112020, the SIU's pre-treatment system had been upgraded and
adequately sized to pre -treat the volume of waste presently generated by that facility. A
projected completion date of January 2021 was reported by Chuck Willis, P.E., for the
treatment system upgrades, previously approved for the WWTP. These previously approved
upgrades are expected to provide a significant increase in solids storage while concurrently
D � North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office [ 450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105
NOh �HCARO UHA
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providing effluent treatment that is projected to improve effluent quality sufficiently enough to
allow compliance with the effluent limits established in Permit Condition Part I Section A. (1).
2) The weirs on the Clarifier #1 do not appear to be level. Effluent was observed crossing the
weir of this Clarifier at various rates in several locations.
This is a repeat and continuing violation that was previously documented in a Notice of
Violation issued March 27, 2019.
3) The influent splitter box is continuing to provide unequal distribution of flow between the three
separate treatment trains present within the current treatment plant.
This is a repeat and continuing violation that was previously documented in a Notice of
Violation issued March 27, 2019.
4) The Return Activated Sludge (RAS) and Waste Activated Sludge (WAS) pumps associated
with Clarifier #1 need repair and/or replacement, as leakage was observed within the pump
vault that housed these pumps. Accumulation was significant enough that a pump had been
temporarily installed within the pump vault to pump the leakage back into the aeration basin.
5) The influent composite sampler was not maintaining temperature within the specified
temperature range of 0-6 degrees Celsius during the entire compositing period. The
thermometer located within this sampler had a reading of 9 degrees Celsius at the time of this
inspection.
The ORC notified Mr. Henderson later that same day that a temperature sensor in this
composite sampler had been identified as the problem. A replacement sensor had been
ordered and that ice would be utilized during the interim to ensure the sample was
maintained within the specified temperature range during the entire compositing period.
6) Failure to provide maintenance/replacement of influent pumps in a timely manner. The WWTP
has three influent pumps present within the influent pump station. At the time of this inspection
the following status was provided by the ORC: One of the three influent pumps is non -
operable, one is in need of service as it is not capable of operation at full capacity, and one
pump is operating without issue.
This office received notification that the day after this inspection the one influent pump that
was previously operating without issue had "burnt up " during the night. The plant currently
is down to one partially operating influent pump.
7) The facility's 2019 Annual Performance Report was reviewed as part of this inspection and
was determined to be incomplete. Permit Condition Part II Section E (12) states: The report
shall summarize the performance of the treatment system, as well as the extent to which the
facility was compliant with applicable Federal or State laws, regulations and rules pertaining
to water quality. However upon review, it was determined that there was no summary provided
for the number nor description of effluent limit violations that were incurred by the subject
facility during the reporting period intended to be summarized by this report.

The inspection findings described above in Numbers 2-6 constitute separate and individual
violations of Permit Condition Part IL Section C. (2) which states: The Permittee shall at all times
properly operate and maintain all facilities and system of treatment and control (and related
appurtenances) which are installed or used by the Permittee to achieve compliance with the
conditions of this permit. Proper operation and maintenance also includes adequate laboratory
controls and appropriate quality assurance procedures.
Please reply in writing to this letter within 15 business days of receiving it. Your written reply
should address each of the noted violations and provide a corrective action plan along with an
anticipated implementation/completion schedule to remediate them.
Please be aware that violations of your NPDES permit, or the NC statutes and regulations under
which it is promulgated, are subject to fines of up to $25,000 per day, per violation, as set forth
in NC General Statute (NCGS) 143-215.6A, Enforcement Procedures, Civil Penalties. Your
response will be considered in any further enforcement actions.
If you have any questions regarding the inspection or this report, please contact Justin Henderson
or me at [phone].
Sincerely,
DocuSiiggned by:
LL145ME22�C
l a%M�Cr
4EA...
Lon T. Snider, Regional Supervisor
Water Quality Regional Operations
Division of Water Resources, WSRO
cc: Chip White, ORC- cwhite&envirolinkinc.com
Laserfiche Files — (electronic copy)

United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040-0057
Water Compliance Inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 IN 1 2 u 3 I NC0021491 I11 121 20/11/30 I17 18I � I 19 I s I 20L]
21111I I I I I I I II I I I I I I I I I I I I I I I I I I I I I I I II I I I I I r6
Inspection
Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved -------------------
67
I 72 I ni I 71 I 74 79 I I I I I I I80
701 I 71 I LL -1 I I
LJ
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES Dermit Number)
12:OOPM 20/11/30
14/11/01
Dutchman Creek WWTP
295 Garwood Rd
Exit Time/Date
Permit Expiration Date
Mocksville NC 27028
03:OOPM 20/11/30
19/06/30
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Robert Charles White/ORC/336-503-2383/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Christine W Bralley,171 S Clement St Mocksville NC
27028//336-753-6701/3367519187 No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit 0 Flow Measurement Operations & Maintenar Records/Reports
Self -Monitoring Progran 0 Sludge Handling Dispo: Facility Site Review Effluent/Receiving Wate
Laboratory
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
J �LL�rn DWR/WSRO WQ/336-776-9701/
�USltlit �WL Viblit 12/2/2020
5F352596F81 B496...
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
DocuSigned by:
oti '? Snider 12/2/2020
FL
'-- 145B49E225C94EA...
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

NPDES yr/mo/day Inspection Type (Cont.)
NCO021491 I11 12I 20/11/30 117 18 i c i
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
On November 30, 2020, North Carolina Division of Water Resources, staff persons Justin Henderson
and Alex Lowe performed a compliance evaluation inspection of the subject facility. Present during this
inspection were Chip White, ORC (Envirolink); Josh Powers, Area Manager (Envirolink), Chuck Willis,
P.E. (Town of Mocksville), and Brian Moore, Public Works Director (Town of Mocksville). This type of
inspection consists of two basic parts: an in -office file review and an on -site inspection of the treatment
facility. This inspection reflects non-compliance with Permit No. NC0021491. The following violations
require your attention and action:
1) BOD exceedances for both weekly and monthly average limits have continuously and consistently
been documented on monthly Discharge Monitoring Reports, submitted in accordance with Permit
Condition Part I Section A. (4). Reportedly these violations are due to a combination of limited solids
storage, provided by the current treatment design, as well as an insufficient (inadequately sized)
pre-treatment system in operation at the facility's one contributing Significant Industrial User (SIU).
Reportedly as of 10/01/2020 the SIU's pre-treatment system had been upgraded and adequately sized
to pre -treat the volume of waste presently generated by that facility. A projected completion date of
January 2021 was reported by Chuck Willis, P.E., for the treatment system upgrades, previously
approved for the WWTP. These previously approved upgrades are expected to provide a significant
increase in solids storage while concurrently providing effluent treatment that is projected to improve
effluent quality sufficiently enough to allow compliance with the effluent limits established in Permit
Condition Part I Section A. (1).
2) The weirs on the Clarifier #1 do not appear to be level. Effluent was observed crossing the weir of
this Clarifier at various rates in several locations.
This is a repeat and continuing violation that was previously documented in a Notice of Violation issuec
March 27, 2019.
3) The influent splitter box is continuing to provide unequal distribution of flow between the three
separate treatment trains present within the current treatment plant.
This is a repeat and continuing violation that was previously documented in a Notice of Violation issuec
March 27, 2019.
4) The Return Activated Sludge (RAS) and Waste Activated Sludge (WAS) pumps associated with
Clarifier #1 were in need of repair and/or replacement, as leakage was observed within the pump vault
that housed these pumps. Accumulation was significant enough that a pump had been temporarily
installed within the pump vault to pump the leakage back into the aeration basin.
5) The influent composite sampler was not maintaining temperature within the specified temperature
range of 0-6 degrees Celsius during the entire compositing period. The thermometer located within this
sampler had a reading of 9 degrees Celsius at the time of this inspection.
The ORC notified Mr. Henderson later that same day that a temperature sensor in this composite
sampler had been identified as the problem. A replacement sensor had been ordered and that ice
would be utilized during the interim to ensure the sample was maintained within the specified
temperature range during the entire compositing period.
6) Failure to provide maintenance/replace of influent pumps in a timely manner. The WWTP has three
Page#

Permit: NCO021491
Inspection Date: 11/30/2020
Owner -Facility: Dutchman Creek WWTP
Inspection Type: Compliance Evaluation
influent pumps present within the influent pump station. At the time of this inspection the following
status was provided by the ORC: One of the threeinfluent pumps is non -operable, one is in need of
service as it is not capable of operation at full capacity, and one pump is operating without issue.
This office received notification that the day after this inspection the one influent pump that was
previously operating without issue had "burnt" up during the night. The plant currently is down to one
partially operating influent pump.
7) The facility's 2019 Annual Performance Report was reviewed as part of this inspection and was
determined to be incomplete. Permit Condition Part II Section E (12) states: The report shall
summarize the performance of the treatment system, as well as the extent to which the facility was
compliant with applicable Federal or State laws, regulations and rules pertaining to water quality.
However upon review, it was determined that there was no summary provided for the number nor
description of effluent limit violations that were incurred by the subject facility during the reporting perioi
intended to be summarized by this report.
The inspection findings described above in Number 2-6 constitute separate and individual violations of
Permit Condition Part II. Section C. (2) which states: The Permittee shall at all times properly operate
and maintain all facilities and system of treatment and control (and related appurtenances) which are
installed or used by the Permittee to achieve compliance with the conditions of this permit. Proper
operation and maintenance also includes adequate laboratory controls and appropriate quality
assurance procedures.
Page#

Permit: NCO021491 Owner -Facility: Dutchman Creek WWTP
Inspection Date: 11/30/2020 Inspection Type: Compliance Evaluation
Operations & Maintenance Yes
No
NA
NE
Is the plant generally clean with acceptable housekeeping? 0
❑
❑
❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable
❑
❑
❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: Plant is currently undergoing an equipment and treatment desgin upgrade, therefore
construciton debris was observed throughout the facility. ORC indicated that pH, Settleable
Solids. and DO are analvzed in aeration basins as Drocess control.
Permit
(If the present permit expires in 6 months or less). Has the permittee submitted a new
application?
Is the facility as described in the permit?
# Are there any special conditions for the permit?
Is access to the plant site restricted to the general public?
Is the inspector granted access to all areas for inspection?
Comment:
Flow Measurement - Influent
# Is flow meter used for reporting?
Is flow meter calibrated annually?
Is the flow meter operational?
(If units are separated) Does the chart recorder match the flow meter?
. i�Ti1uTT'ii�
Aerobic Digester
Is the capacity adequate?
Is the mixing adequate?
Is the site free of excessive foaming in the tank?
# Is the odor acceptable?
# Is tankage available for properly waste sludge?
Yes No NA NE
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Yes No NA NE
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Yes No NA NE
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Comment: Facility ORC and Town's P.E. both acknowlegde that plant is constrained by the limited
solids handling storage that current treatment equipment provides. Each concurred that this
issue is responsible for the consistent BOD exceedances documented by the plant, and
also is the reason that the current upgrades are being pursued.
Effluent Pipe
Is right of way to the outfall properly maintained?
Yes No NA NE
❑ ❑ ❑
Page# 4

Permit: NCO021491 Owner -Facility: Dutchman Creek WWTP
Inspection Date: 11/30/2020 Inspection Type: Compliance Evaluation
Effluent Pipe Yes No NA NE
Are the receiving water free of foam other than trace amounts and other debris? ❑ ❑ ❑
If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ ❑
Comment: Unable to evaluate or see effluent pipe as it was submerged as a result of recent rainevent
and high flow of stream at discharge location at the time of this inspection
Pump Station - Influent
Is the pump wet well free of bypass lines or structures?
Is the wet well free of excessive grease?
Are all pumps present?
Are all pumps operable?
Are float controls operable?
Is SCADA telemetry available and operational?
Is audible and visual alarm available and operational?
Yes No NA NE
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Comment: Facility had three influent pumps present, however one was inoperable, and another was in
need of service as reported by the ORC.
Yes No NA NE
Type of bar screen
a.Manual
b.Mechanical
❑
Are the bars adequately screening debris?
❑
0
❑
❑
Is the screen free of excessive debris?
0
❑
❑
❑
Is disposal of screening in compliance?
M
❑
❑
❑
Is the unit in good condition?
0
❑
❑
❑
Comment: A significant amount of rags/debris was observed in the aeration basin. Accumulations of
rags were observed on the floating
surface aerators present in the aeration basins.
Secondary Clarifier
Is the clarifier free of black and odorous wastewater?
Is the site free of excessive buildup of solids in center well of circular clarifier?
Are weirs level?
Is the site free of weir blockage?
Is the site free of evidence of short-circuiting?
Is scum removal adequate?
Yes No NA NE
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Page# 5

Permit: NCO021491
Owner -Facility: Dutchman Creek WWTP
Inspection Date: 11/30/2020
Inspection Type: Compliance Evaluation
Secondary Clarifier
Yes
No
NA
NE
Is the site free of excessive floating sludge?
0
❑
❑
❑
Is the drive unit operational?
0
❑
❑
❑
Is the return rate acceptable (low turbulence)?
0
❑
❑
❑
Is the overflow clear of excessive solids/pin floc?
E
❑
❑
❑
Is the sludge blanket level acceptable? (Approximately'/
of the sidewall depth) 0
❑
❑
❑
Comment: The weir on Clarifier 1 appear unlevel as various rates of discharge was observed in multiplE
locations along the weir. Excessive solids build up in the center well of each of the three
clarifiers was observed during this inspection.
Aeration Basins
Mode of operation
Type of aeration system
Is the basin free of dead spots?
Are surface aerators and mixers operational?
Are the diffusers operational?
Is the foam the proper color for the treatment process?
Does the foam cover less than 25% of the basin's surface?
Is the DO level acceptable?
Is the DO level acceptable?(1.0 to 3.0 mg/1)
Yes No NA NE
Ext. Air
Surface
•
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•
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■
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■
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•
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•
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Comment: One of the two surface aerators in Aeration Basin 3 was inoperable during this inspeciton,
and had reportedly must went down the morning of the inspection.
Disinfection -Gas
Are cylinders secured adequately?
Are cylinders protected from direct sunlight?
Is there adequate reserve supply of disinfectant?
Is the level of chlorine residual acceptable?
Is the contact chamber free of growth, or sludge buildup?
Is there chlorine residual prior to de -chlorination?
Does the Stationary Source have more than 2500 Ibs of Chlorine (CAS No. 7782-50-5)?
If yes, then is there a Risk Management Plan on site?
If yes, then what is the EPA twelve digit ID Number? (1000- - )
If yes, then when was the RMP last updated?
IYTsLl[•7►/_9►1:4
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Comment: Aeration was present wihtin the contact chamber, therefore evaluation of sludge build-up or
growth was limited.
Page# 6

Permit: NC0021491
Inspection Date: 11/30/2020
Disinfection -Gas
De -chlorination
Type of system ?
Is the feed ratio proportional to chlorine amount (1 to 1)?
Owner -Facility: Dutchman Creek WWTP
Inspection Type: Compliance Evaluation
Is storage appropriate for cylinders?
# Is de -chlorination substance stored away from chlorine containers?
Comment:
Are the tablets the proper size and type?
Are tablet de -chlorinators operational?
Number of tubes in use?
Comment:
Yes No NA NE
Yes
No
NA
NE
Gas
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Pumps-RAS-WAS
Yes
No
NA
NE
Are pumps in place?
0
❑
❑
❑
Are pumps operational?
❑
❑
❑
❑
Are there adequate spare parts and supplies on site?
❑
0
❑
❑
Comment: RAS & WAS pumps for Clarifier 1 were leaking
to the extent that a temporary
pump
had
been installed in the pump vault to transfer the accumulated leakage to aeration basin 1.
Standby Power
Is automatically activated standby power available?
Is the generator tested by interrupting primary power source?
Is the generator tested under load?
Was generator tested & operational during the inspection?
Do the generator(s) have adequate capacity to operate the entire wastewater site?
Is there an emergency agreement with a fuel vendor for extended run on back-up power?
Is the generator fuel level monitored?
Comment:
Laboratory
Are field parameters performed by certified personnel or laboratory?
Are all other parameters(excluding field parameters) performed by a certified lab?
# Is the facility using a contract lab?
Yes No NA NE
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Yes
No
NA
NE
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Page# 7

Permit: NCO021491 Owner -Facility: Dutchman Creek WWTP
Inspection Date: 11/30/2020 Inspection Type: Compliance Evaluation
Laboratory
Yes
No
NA
NE
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
❑
0
❑
❑
Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
❑
❑
0
❑
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
❑
❑
0
❑
Comment: The influent composite sampler was not maintaining temperature at or bleow 6.0 degrees C
at time of this inspection.
Influent Sampling
Yes
No
NA
NE
# Is composite sampling flow proportional?
0
❑
❑
❑
Is sample collected above side streams?
0
❑
❑
❑
Is proper volume collected?
0
❑
❑
❑
Is the tubing clean?
0
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
❑
0
❑
❑
Celsius)?
Is sampling performed according to the permit?
0
❑
❑
❑
Comment: Composite sampler thermometer indicated temperature was at 9 degrees C at time of this
inspection.
Effluent Sampling
Is composite sampling flow proportional?
Is sample collected below all treatment units?
Is proper volume collected?
Is the tubing clean?
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
representative)?
Comment:
Yes No NA NE
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Page# 8