NC0021491_NOV-2021-PC-0418_20210921

Mocksville Town Hall
171 S. Clement Street
Mocksville, NC 27028
Phone [phone]
Fax [phone]
www.mocksvillenc.org
Memorandum
To: S. Daniel Smith
Director
Division of Water Resources, NCDEQ
From: Envirolink, Inc.
and the Town of Mocksville
Dutchman Creek WWTP
Date: September 21, 2021
Subject: REVISION TO ORIGINAL RESPONSE
for Case No. NOV-2021-PC-0418
• Intent to Assess CIVIL PENALTIES
for Violations of NPDES Permit Conditions
Dutchman Creek WWTP
NPDES Permit: NC0021491
Davie County
The purpose of this memorandum is to inform the reviewer of an amendment we have made to
the response letter submitted on September 17th, 2021.
The original response states that the Effluent Pollutant Scan testing required for the August 2021
period had not been met within the required time frame. According to an update received on
September 20, 2021, an Effluent Pollutant Scan was completed on August 25th, 2021.
Our response letter below has been revised to reflect this updated information.
CC:
Ken Gamble, Town Manager, Town of Mocksville
Josh Powers, Envirolink Inc.
Todd Robinson, Envirolink, Inc.
Sydney Carpenter, NC-DEQ DWR, Compliance and Expedited Permitting Unit

Attachments:
Response to Notice of Violation and Intent to Assess Civil Penalties
for Case no. NOV-2021-PC-0418
September 21, 2021
Subject: Notice of Violation (NOV-2021-PC-0418)
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 Tenn 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. Effluent Pollutant Scan testing has been conducted on April 8, 2021 and August 25th,
2021; with the final test to be conducted in December of 2021. Secondary Species testing is
scheduled to begin the week of October 4'1'.

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.
Sincerely,
en Gamble
Town of Mocksville
CC:
Todd Robinson, Envirolink
Joshua Powers, Envirolink