NC0021717_NOV-2021-PC-0311_20210611

ROY COOPER
Governor
DIONNE DELLFGATTI
Secretary
S. DANIEL SMITH
Director
Ms. Amber Garwood
Town of Wilkesboro
P.O. Box 1056
Wilkesboro, NC 28697
NORTH CAROUNA
Environmental Quality
June 11, 2021
CERTIFIED MAIL #: 7018 1130 00001612 5563
RETURN RECEIPT REQUESTED
SUBJECT: Notice of Violation — Failure to Enforce in Pretreatment Program
NOV-2021-PC-0311
Cub Creek Wastewater Treatment Plant
NPDES Permit No. NCO021717
Wilkes County
Dear Ms. Garwood,
The Pretreatment staff of the Division of Water Resources at the Winston-Salem Regional Office has
reviewed the Pretreatment Annual Report (PAR) covering January through December 2020. While the
latest submitted copy demonstrates compliance with NCAC 2H .908(b) and the Comprehensive Guidance
for North Carolina Pretreatment Programs (see letter dated May21, 2021), the initial version illuminated
a failure to properly implement enforcement action within the pretreatment program.
During the first six-month period of 2020, the Town failed to determine Significant Non -Compliance (SNC)
status for Wilkes County Landfill (IUP #1004). According to the Town of Wilkesboro's 2020 Pretreatment
Annual Review, two of three ammonia samples reported in this period (specifically those collected on
February 13, 2021 and February 25, 2021) were issued violations for exceedances of Technical Review
Criteria limits.
In accordance with the Town of Wilkesboro's Enforcement Response Plan, and by the definitions of SNC
laid out in 40 CFR 403.8(f)(2)(viii)(B), the failure to place Wilkes County Landfill in SNC constitutes a
violation of permit conditions.

The WSRO acknowledges that since this violation was brought to your attention, your team has taken the
following steps to comply with permit conditions: retroactively placed Wilkes County Landfill in SNC
for the first six-month period of 2020, issued a Public Notice of SNC, and updated your PAR to reflect
the changes to the compliance status of the SIU. It is requested that, in addition to these actions, a written
response be submitted to this Office by Friday, June 25, 2021, addressing the Town's actions to prevent
the recurrence of this type of violation.
Thank you for your cooperation on this issue, and for your continued support of the Pretreatment
Program. If you have any questions, please contact Alex Lowe of the WSRO at [phone] or
alex.lowekncdenr. goy.
Sincerely,
Docu Signed by:
4.
OD2D3CE3F1 B7456.._
for Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
cc: DWR Laserfiche Files
WSRO Electronic Files
Municipal Permitting Unit
North Carolina Department of Environmental quality I Division of Water Resources
Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 3MO 1 Winston-Salem. North Carolina 27105
&M.776.9800