NC0021491_Remission Request (LV-2021-0246)_20211012

AP" 94ts
Mocksville Town Hall .: ; Phone [phone]
171 S. Clement Street ?;;; ;; Fax [phone]
Mocksville, NC 27028 liawwotad,`' www.mocksvillenc.org
SVIlta
October 5, 2021 RECEIVED
Mr. Lon T. Snider, Regional Supervisor l)( � 202�
Water Quality Regional Operations Section
Winston-Salem Regional Office NCDEQ/DW�NPDES
Division of Water Resources,NCDEQ
Subject:Notice of Violation& Assessment of Civil Penalty
for Violations of North Carolina General Statute(G.S.) 143-215.1(a)(6)
and NPDES WW Permit No. NC0021491
Town of Mocksville
Dutchman Creek WWTP
Case No. LV-2021-0246
Davie County
Mr. Snider,
Thank you for allowing the Town of Mocksville the opportunity to respond to the Notice of
Violation dated September 21, 2021; received September 24, 2021. This response pertains to the
(1) BOD weekly average violation cited for the weekly period ending October 3, 2020.
As the Division is aware, the Town has been undergoing a capital upgrade project that was still
in progress at the time,with the focus being to improve the facility's solids handling capabilities
' and expand clarifier capacity. The challenges in BOD removal presented by existing plant
limitations at that time were also exacerbated by the untreated discharge and high effluent solids
being received from the SIU. Data from the September 2020 eDMR report indicates 1,032 mg/L
of influent BOD received on 9/29. At this time, the plant's limited treatment faculties could not
support adequate BOD removal at such acuity. The BOD results reported for 9/29 and 9/30 were
6.64 mg/L and 28.9 mg/L respectively, which resulted in a weekly average exceedance.
The SIU completed their installation of a Diffused Air Flotation pretreatment system on October
1S`, 2020; which significantly lowered influent BOD loading moving forward. Upon installation
of the pretreatment system, the BOD results reported for Thursday 10/1 were within compliance,
at 2.45 mg/L. No violations otherwise occurred during the month of October.
The renovations to the Dutchman Creek WWTP are currently in their end stages and are
anticipated to be complete before the end of this year. We believe that the Town of Mocksville
and Envirolink staff have aggressively responded to these issues and are confident that upon
completion of the construction that effluent quality will be greatly improved. It is our request that

the Division consider the significant investment being made and how these efforts impacted
effluent quality when deciding whether to assess a civil penalty.
Sincerely,
Ken Gamble
Town of Mocksville
CC:
Todd Robinson, Envirolink
Joshua Powers, Envirolink

JUSTIFICATION FOR REMISSION RE VEST
County: Davie
Case Number:
To vrt of Moksville
0 �
Assessed Party: Amount Assessed: Mil
Permit No.: NC0021491
Facts"form to request the ofR this civil penalty.
thisform when requesting remission of this civil penalty. You must also complete the "Request For Remission,it
Please use
request and are necessary for the Director to constide
Waiver of Right to an Administrative Hearing,and Stipulation of
You should attach any documents that youPlbelievesebesupport your
request for remission. Please be aware that a rage amount of the civil limited
penaltytassesse consideration
quests factual
auating your
factorsg
listed below as they may relate to the reasonableness of t occurred or the accuracy of any of th
remission is not the proper procedure for contesting whether the violation(s)
civilpenalty assessment document. Pursuant to N.i•G•please check each factormission of that you a civil
penalty
statements contained granted
in the five factors apply.penalty may be granted only when one or more of the following of supporting documents,as to why the
believe applies to your case and provide a detailed explanation,including copies
lies(attach additional pages as needed).
factor applies were wrongfully applied to the
detriment(a)
.G.S.
one more of the nivil penassessmelty nt factorsment carre listed tors in in the civil penalty assessment docrmrent);
of the petitioner(the a
x (b) the violator promptly abated continuing
environmental damage resulting from the violation(i.e.,explain the
steps that you took to correct the violation and prevent future occurrences); the violation was unavoidable or
x (c) the violation was inadvertent or a result of an accident(i.e., explainwhy
something you could not prevent or prepare for);
(d) the violator had not been assessed civil penalties for any previous violations;
of the civil penalty will prevent payment for the remaining necessary remedial actions achieve(►.e., explain
(e) paymentrorn performing the activities necessary
how payment of the civil penalty will prevent you f P f •
compliance).
E�(PI,ANATIUN:
As the Division is aware, the Town has been undergoing a capital upgrade project that was still in progr
ess at the time, with the focus being to improve the facility's solids handling capabilities and expand cla
rifler capacity. The challenges in BOD removal presented by existing plant limitations at that time were
also exacerbated by the untreated discharge and high effluent solids being received from the SIU. Data
from the September 2020 eDMR report indicates 1,032 mg/L of influent BOD received on 9/29. At this t
ime, the plant's limited treatment faculties could not support adequate BOD removal at such acuity. Th
e BOD results reported for 9/29 and 9/30 were 6.64 mg/L and 28.9 mg/L respectively, which resulted in
a weekly average exceedance.
The SIU completed their installation of a Diffused Air Flotation pretreatment system on October 1st, 20
20; which significantly lowered influent BOD loading moving forward. Upon installation of the pretreatm
ent system, the BOD results reported for Thursday 10/1 were within compliance, at 2.45 mg/L. No viola
tions otherwise occurred during the month of October.

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
COUNTY OF DAVIE ECEN
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN CT 2021
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
vo STIPULATION OF FACTS �DDE.(.IDWNPDES
Town of Mocksville )
Dutchman Creek WWTP )
PERMIT NO.NC0021491 )
CASE NO. LV 202JI-p2d6
Having been assessed civil penalties totaling$602.18 for violation(s)as set forth in the assessment document of the Division
of Water Resources dated September 16,2021,the undersigned,desiring to seek remission of the civil penalty,does hereby
waive the right to an administrative hearing in the above-stated matter and does stipulate that the facts are as alleged in the
assessment document. The undersigned further understands that all evidence presented in support of remission of this civil
penalty must be submitted to the Director of the Division of Water Resources within thirty(30)days of receipt of the notice
of assessment. No new evidence in support of a remission request will be allowed after(30)days from the receipt of the
notice of assessment. /
This the `J day of
,20
SIGNATURE •
ADDRESS
/7/ S_ c - - — ..cfi
gic�s r/:c7 d� z 76 zR--
TELEPHONE
33G-7 '3-‘70