NC0082694_Compliance Evaluation Inspection_20220210

ROY COOPER
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ELIZABETH 5_ RISER
Secretory
$. DANIEL SMITH
Alrrclor
NORTH CAROL! NA
Ertrfronmertrai Qualify
February 10, 2022
CERTIFIED MAIL # 7018 3090 0001 2323 0416
RETURN RECEIPT REQUESTED
Mr. Bill Trudnak, Public Works Director
Town of Dallas
210 North Holland Street
Dallas, NC 28034
Subject: Compliance Evaluation Inspection
Notice of Violation and Intent to Assess Civil Penalty
Tracking Number NOV-2022-PC-0041
Dallas WTP
NPDES Permit No. NC0082694
Gaston County
Dear Mr. Trudnak:
Enclosed is a copy of the Compliance Evaluation Inspection for the inspection conducted at the subject
facility on January 25, 2022, by Ori Tuvia. Zachary Foreman's cooperation during the site visit was
much appreciated. Please advise the staff involved with this NPDES Permit by forwarding a copy of
the enclosed report.
At the time of the inspection it was discovered that the Waste Water Treatment backwash lagoon was
overflowing and bypassing the treatment units. The overflow is in direct violation of the following
permit statues:
1. Part II, Section C.2 , failure of Proper Operation and Maintenance
"The Permittee shall at all times properly operate and maintain all facilities and systems
of treatment and control (and related appurtenances) which are installed or used by the
Permittee to achieve compliance with the conditions of this permit. Proper operation and
maintenance also includes adequate laboratory controls and appropriate quality
assurance procedures. This provision requires the Permittee to install and operate
backup or auxiliary facilities only when necessary to achieve compliance with the
conditions of the permit [40 CFR 122.41(e)]. "
Proper Operation and maintenance of the backwash lagoon level would have prevented the
backwash from reaching a level that it would overflow.
North Carolina Department of Emwiranmenial Quailly I Division of Water Resources
Mooresville Regional offkc 1670 East Center Arexiue, State 301 I Mooresville, North Carolina 2 lIS
704663.1691

2. Part II, Section C.4(b)(2), Failure to give notice
"Unanticipated bypass. The Permittee shall submit notice of an unanticipated bypass as
required in Part II.E. 6. (24-hour notice)."
No notice was given to Mooresville Regional Office staff that bypass has occurred.
3. Part II, Section C.4(c), Prohibition of Bypass
"(1) Bypass from the treatment facility is prohibited and the Permit Issuing Authority
may take enforcement action against a Permittee for bypass, unless:
(A) Bypass was unavoidable to prevent loss of life, personal injury or severe
property damage;
(B) There were no feasible alternatives to the bypass, such as the use of auxiliary
treatment facilities, retention of untreated wastes or maintenance during normal
periods of equipment downtime. This condition is not satisfied if adequate backup
equipment should have been installed in the exercise of reasonable engineering
judgment to prevent a bypass which occurred during normal periods of equipment
downtime or preventive maintenance; and
(C) The Permittee submitted notices as required under Paragraph b. of this
section.
(2) Bypass from the collection system is prohibited and the Permit Issuing Authority may
take enforcement action against a Permittee for a bypass as provided in any current or
future system -wide collection system permit associated with the treatment facility.
(3) The Permit Issuing Authority may approve an anticipated bypass, after considering
its adverse effects, if the Permit Issuing Authority determines that it will meet the three
conditions listed above in Paragraph c. (1) of this section."
Facility has failed to prevent the bypass.
In addition to the bypass the following issues were observed and need to be addressed.
• The chlorine curve was out of date and was last done in 2019.
• The facility has been reporting Iron levels in ug/1 without conversion from mg/L;
EDMR's need to be amended to reflect the change.
• The drying beds are in need of maintenance, the drying bed walls had visible cracks
and one of the drying beds was full of vegetation.

A Notice of Violation and Notice of Recommendation for Enforcement, pursuant to G.S. 143-215.6A,
may result in a civil penalty of not more than twenty-five thousand dollars ($25,000.00) per day, per
violation and 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. You are requested
to respond to this Notice in writing within ten (10) days of receipt indicating your Plan of Action
to ensure future compliance.
The report should be self-explanatory; however, should you have any questions concerning this report,
please do not hesitate to contact Ori Tuvia at [phone], or at [e-mail].
Sincerely,
,-DocuSigned by:
A W H Pam►
F161 FB69A2D84A3...
for
W. Corey Basinger
Regional Supervisor
Mooresville Regional Office
Division of Water Resources
Cc: NPDES, MRO Files (Laserfiche)
Picture 1. Overflowing lagoon, January 25, 2022.