NC0021491_NOV-2021-PC-0418 Response_20210917

Mocksville Town Hall
171 S. Clement Street
Mocksville, NC 27028
Phone [phone]
Fax [phone]
www.mocksvillenc.org
September 17, 2021
Subject: Notice of Violation (NOV-2021 -PC-041 8)
Intent to Assess Civil Penalties
For Violations of NPDES Permit Conditions
Dutchman Creek WWTP
NPDES Permit: NC0021491
Davie County
Mr. Smith,
Thank you for allowing the Town of Mocksville the opportunity to respond to the Notice of Violation
dated September 7, 2021; received September 10, 2021. Below is our response to the concerns that have
been brought forward in this notice.
A Division -approved revised sampling plan was executed by Mr. Nicholas Coco of NCDEQ-DWR's
NPDES Municipal Permitting Unit in April of 2021 to address a lapse in the 2017 NPDES permit renewal
process. The expedited plan requires that (3) Effluent Pollutant Scans be taken in the months of April,
August, and December of 2021; and that (4) Secondary Species tests be conducted with each upcoming
routine toxicity sampling event, as determined by Ms. Cindy Moore, Aquatic Toxicology Branch,
NCDEQ-DWR. A concurrent revised Headworks Short Term Monitoring Plan was developed in March
of 2021, in collaboration between Envirolink Staff, Ms. Kristin Litzenberger, and Mr. Michael
Montebello of the NPDES Municipal Permitting Unit, NCDEQ-DWR, Winston-Salem Division.
The sampling requirements as part of the original Headworks Analysis Short Term Monitoring Plan
(HWA-STMP) were not met within the required time frame. Quarterly HWA sampling initially had a
scheduled completion date of December, 2020; with sampling to begin in the 4th quarter of 2019. The
former designated pretreatment program coordinator was notified via email by Ms. Deborah
Gore, NCDEQ-DWR, PERCS Unit Supervisor on 2/26/2019 of the upcoming HWA sampling
requirements. The individual responsible for pretreatment program coordination and for the NPDES
permit renewal process left the company shortly after, and to the best of our knowledge, no relevant
parties were informed of the original short-term monitoring requirements as presented by Ms. Gore; nor
of the status of the permit renewal. This lapse in communication resulted in the above monitoring delays.
The revised HWA-STMP stipulates that the sampling requirements established in the original STMP
are to be taken in the months of March, April, July, and October of 2021. Thus far, the
expedited sampling plan has been adhered to as required. The final sample set will be collected this
upcoming October. The remaining components of the Pretreatment Annual Report (PAR) are otherwise
complete and were submitted to the NPDES Municipal Permitting Unit on 3/5/2021. An effluent pollutant
scan was conducted on April 8, 2021; however, due to inadvertent delays, the effluent pollutant scan

NOV-2021-PC-0418 — Page 2
testing for August has been rescheduled. Arrangements have been made for the second effluent pollutant
scan to be collected during the week of September 20 - 24, 2021. The final test will be conducted in
December of 2021. Secondary Species testing is scheduled to begin the week of October 4th
We appreciate NC-DEQ's willingness in granting us the time and opportunity to revisit and resolve the
matters outstanding. We are working hard to comply with the revised plans provided by the Division. It is
our request that our attention in these matters be taken into account when proceeding with enforcement.
Town of Mocksville
CC:
Todd Robinson, Envirolink
Joshua Powers, Envirolink