NC0026913_NOV-2021-LV-0020 Response_20210115

TOWN OF SPARTA
P.O. BOX 99
SPARTA, NC 28675
Phone: [phone]
Fax: [phone]
Email: [e-mail]
TOWN COUNCIL MEMBERS:
Mike Parlier, Mayor Pro Tem
Cole Edwards
John Brady
Terry McGrady
Milly Richardson
To: Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
Wes Brinegar, Mayor
Ryan Wilmoth, Town Manager
Robert L. Lane, Chief of Police
Peggy Choate, Town Clerk
Whitney Ivey, Town Attorney
RCB-20210128-Recommend NFA or small CPA due
to conditions beyond their control and efforts to
ameliorate cause.
NOV-2021-LV-0020
From: Ryan Wilmoth, Manager Lon-NFA
Date: January 15, 2021
RE: Response to Notice of Violation & Intent to Assess Civil Penalty Letter
Mr. Snider,
The Town of Sparta is in receipt of the January 6, 2021 letter concerning the Notice of Violation
and Intent to Assess Civil Penalty from your office. We fully understand and accept
responsibility for the noted violation of our wastewater treatment facility operations. In
reviewing this matter internally with our team, we did identify potential for process
improvement, but we also identified some items of note that we felt should be shared for your
consideration.
On November 23, 2020 our WWTP Operator noticed a loss in water pressure at our facility and
discovered a potential water leak from the service line that feeds the facility. Our maintenance
division immediately began working to locate and repair the water disruption, but unfortunately,
the repair was quite intensive and time consuming due to some source tracing challenges, which
resulted in the restoration of water supply not being achieved until the late evening hours on
November 25, 2020. During this period of outage, the Chlorine and Sulfur Dioxide feeds were
not functioning properly due to a dependence on suction created by source water flow within our
system design. Additionally, during this same time period the Town of Sparta was in a
transitional phase with its analytical providers, switching from RNA to PACE. It was customary
for our previous analytical provider to make direct contact with our Operator in the event of an
out -of -range result value so that corrective action could be taken, unfortunately, this did not
occur with the new provider. To further compound the situation during this transition, the Town
was not provided sampling results for the entire month of November until December 2, 2020 and
December 6, 2020. The lack of timely results made any corrective action for this situation
impossible. Of note, our Operator did amend the original eDMR for the November 28, 2020

period for the Nitrogen level, as it was also found to be out of range, but states he failed to notice
the Fecal value being out of range as an oversight.
In closing, the Town of Sparta works diligently to ensure our wastewater treatment practices
align with current standards and follows all applicable laws and regulations, which hopefully is
demonstrated by our history of infrequent violations. We appreciate your professional discretion
in reviewing of our matter and respect your ultimate decision. Should you have any additional
questions or needs for the Town of Sparta, please do not hesitate to contact me directly.
Respectively,
Iic,
Ryan E. Wilmoth
Cc: Jenny Graznak

ROY COOPER
Governor
M[CHAEL 5. REGAN
Secretary
S. DANIEL SMITH NORTH CAROLINA
Director Envrrorirtrental Quality
Certified Mail # 7017 1450 0001 6450 0931
Return Receipt Requested
January 6, 2021
Bryan Edwards
Town of Sparta
PO Box 99
Sparta, NC 28675
SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY
Tracking Number: NOV-2021-LV-0020
Permit No. NC0026913
Sparta WWTP
Alleghany County
Dear Permittee:
A review of the November 2020 Discharge Monitoring Report (DMR) for the subject facility revealed the
violation(s) indicated below:
Limit Exceedance Violation(s):
Sample Limit Reported
Location Parameter Date Value Value Type of Violation
001 Effluent Coliform, Fecal MF, MFC Broth, 11/28/2020 400 1,502.35 Weekly Geometric Mean Exceeded
44.5 C (31616)
A Notice of Violation/Intent to Issue Civil Penalty is being issued for the noted violation of North Carolina General
Statute (G.S.) 143-215.1 and the facility's NPDES WW Permit. Pursuant to G.S. 143-215.6A, a civil penalty of
not more than twenty-five thousand dollars ($25,000.00) may be assessed against any person who violates or
fails to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S.
143-215.1.
North Carolina Depa rtment of Environmental Quality I division of Water Resources
Winston-Salem Reg °nalOffice 14,50 West}fafies MA Road, Suite300 I WinstonSalern, North CaTolr3 27105
336-776-9300

If you wish to provide additional information regarding the noted violation, request technical assistance, or
discuss overall compliance please respond in writing within ten (10) business days after receipt of this Notice. A
review of your response will be considered along with any information provided on the submitted Monitoring
Report(s). You will then be notified of any civil penalties that may be assessed regarding the violations. If no
response is received in this Office within the 10-day period, a civil penalty assessment may be
prepared.
Remedial actions should have already been taken to correct this problem and prevent further occurrences in the
future. The Division of Water Resources may pursue enforcement action for this and any additional violations of
State law. If the violations are of a continuing nature, not related to operation and/or maintenance problems,
and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by
Consent.
Reminder: Pursuant to Permit Condition 6 in Section E, the Permittee is required to verbally notify the Regional
Office as soon as possible, not to exceed 24 hours, from first knowledge of any non-compliance at
the facility including limit violations, bypasses of, or failure of a treatment unit. A written report may
be required within 5 days if directed by Division staff. Prior notice should be given for anticipated or
potential problems due to planned maintenance activities, taking units off-line, etc.
If you have any questions concerning this matter or to apply for an SOC, please contact Justin Henderson of
the Winston-Salem Regional Office at 336-776-9800.
Sincerely,
1- DocuSigned by:
L -Ju, T Jn jcr
"- 145B49E225C94EA...
Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
Cc: Laserfiche Files — (Electronic copy)
North Csro9ina Depa rtment of Env!ronrnentsl Qua:ity I D;vison of Water Resources
MnstonSa,ent Reflone:Office 1450 West Hanes IV i; Road., S u.te 300 I Winston-S m, North £aro.•na 27105
336-7 76-93D0

DMR REVIEW RECORD
Winston-Salem Regional Office
Facility Name: Sparta WWTP Permit Number: NC0026913
Report Period: November 2020
Prior Assessments: 0 Enforcement Factor: 1.00
Waterbody
Outfall # Outfall Description Waterbody Name Classification
001 Effluent to the Little River Little River C
Weekly Average Limit Violations
Sample Location: Outfall 001 - Effluent
Violation Unit of Limit Calculated % Over
Date Parameter
Frequency Measure Value Value Limit
Action
11/28/2020 Coliform, Fecal MF, MFC Broth, 3 X week #/100m1 400 1502.40 275.6
44.5 C
Reporting Violations
Sample Location: Outfall 001 - Upstream
Violation Unit of Violation
Date Parameter Frequency Measure Type
Action
11/30/2020 Hardness, Total (as CaCO3) Quarterly mg/I Sampling Location Missing
Other Violations/Staff Remarks:
NOD for Fecal exceedance; BPJ for Hardness as it is required quarterly and quarter is not over yet.
Supervisor Remarks:
Jenny — NOI for fecal violation; BPJ for hardness with a comment in BIMS
Completed by: Justin Henderson Date: 12/16/2020
Assistant Regional
Supervisor Sign -off: JG Date: 1/5/2021
Regional
Supervisor Sign -off: Date:

Prior 12-Month Enforcement History
Permit Number: NC0026913 Report Period: November 2020
Monitoring Violation
Sample Location: Outfall 001 - Effluent
Violation Report Violation
Date Period Parameter Type
NOD
NOV CPA
11/1/2019 11-2019 Flow, in conduit or thru Frequency Violation NOD-2020-MV-0005
treatment plant
11/2/2019 11-2019 Flow, in conduit or thru Frequency Violation NOD-2020-MV-0005
treatment plant
11/3/2019 11-2019 Flow, in conduit or thru Frequency Violation NOD-2020-MV-0005
treatment plant
11/4/2019 11-2019 Flow, in conduit or thru Frequency Violation NOD-2020-MV-0005
treatment plant
11/5/2019 11-2019 Flow, in conduit or thru Frequency Violation NOD-2020-MV-0005
treatment plant
11/6/2019 11-2019 Flow, in conduit or thru Frequency Violation NOD-2020-MV-0005
treatment plant
11/7/2019 11-2019 Flow, in conduit or thru Frequency Violation NOD-2020-MV-0005
treatment plant
11/8/2019 11-2019 Flow, in conduit or thru Frequency Violation NOD-2020-MV-0005
treatment plant
11/9/2019 11-2019 Flow, in conduit or thru Frequency Violation NOD-2020-MV-0005
treatment plant
11/10/2019 11-2019 Flow, in conduit or thru Frequency Violation NOD-2020-MV-0005
treatment plant
11/11/2019 11-2019 Flow, in conduit or thru Frequency Violation NOD-2020-MV-0005
treatment plant
11/12/2019 11-2019 Flow, in conduit or thru Frequency Violation NOD-2020-MV-0005
treatment plant
11/13/2019 11-2019 Flow, in conduit or thru Frequency Violation NOD-2020-MV-0005
treatment plant
11/14/2019 11-2019 Flow, in conduit or thru Frequency Violation NOD-2020-MV-0005
treatment plant
11/15/2019 11-2019 Flow, in conduit or thru Frequency Violation NOD-2020-MV-0005
treatment plant
11/16/2019 11-2019 Flow, in conduit or thru Frequency Violation NOD-2020-MV-0005
treatment plant
11/17/2019 11-2019 Flow, in conduit or thru Frequency Violation NOD-2020-MV-0005
treatment plant

Monitoring Violation
Sample Location: Outfall 001 - Effluent
Violation Report Violation
Date Period Parameter Type
NOD
NOV CPA
11/18/2019 11-2019 Flow, in conduit or thru Frequency Violation NOD-2020-MV-0005
treatment plant
11/19/2019 11-2019 Flow, in conduit or thru Frequency Violation NOD-2020-MV-0005
treatment plant
11/20/2019 11-2019 Flow, in conduit or thru Frequency Violation NOD-2020-MV-0005
treatment plant
11/21/2019 11-2019 Flow, in conduit or thru Frequency Violation NOD-2020-MV-0005
treatment plant
11/28/2019 11-2019 Flow, in conduit or thru Frequency Violation NOD-2020-MV-0005
treatment plant
11/29/2019 11-2019 Flow, in conduit or thru Frequency Violation NOD-2020-MV-0005
treatment plant
11/30/2019 11-2019 Flow, in conduit or thru Frequency Violation NOD-2020-MV-0005
treatment plant
Other Violation
Violation Report Violation
Date Period Parameter Type
NOD
NOV CPA
2/21/2020 12-2019
Aquatic toxicity
permit limit violation
NOV-2020-TX-0003