NC0026689_NOI_NOV2020LV0466_Response_20200630 (4)

TOWN OF DENTON
June 30,2020
North Carolina Department of Environmental Quality
Division of Water Resources
450 West Hanes Mill Road
Suite 300
Winston-Salem, NC 27105
Subject: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY
Tracking Number: NOV-2020-LV-0466
Permit No. NCO026689
Denton WWTP
Davidson County
Dear Mr. DiMatteo:
We are writing in response to your letter dated June 15, 2020 NOTICE OF VIOLATION & INTENTTO ACCESS
CIVIL PENALTY Tracking No.: NOV-2020-LV-0466, and would like to provide justification as to why a civil
penalty of any amount would impede our efforts in rectifying the issues we are experiencing.
We are continuing to focus on the cleanliness of the chlorine contact chamber as we feel the organics that
get trapped in it is the culprit. We have followed all recommendations given to us from State officials as
well as that of the North Carolina Rural Water Association. We have recognized that as the water warms up
above 20°C that we see the formations of the Dichlorobromomethane and this is when we put in place all
apparatus that has been suggested. The following is a list of the things we have done as well as steps we
take to combat this pollutant;
• Installed a submersible pump with an aspirator before sampling area to give effluent a
boost of oxygen to help strip the Dichlorobromomethane from water.
• Installed a disinfectant recirculation pump to use the plants effluent to re -chlorinate the
water in lieu of using Town water which was found to contain large amounts of
Dichlorobromomethane.
• Increased draining and cleaning of clarifiers and chlorine contact chamber.
• Increased disinfection and cleaning of tertiary filters.
201 W. Salisbury Street
P.O. Box 306 Phone: [phone]
Denton, NC 27239 Fax: [phone]
This institution is an equal opportunity provider and employer

• Reduced the chlorine pounds per day feed as well as decreased Sulfur Dioxide feed but also
maintaining limits of fecal coliform colonies.
As I have explained, we have continued to seek out and find solutions for this issue. We ask that no
monetary fine be levied against the Town of Denton as any amount will impede our efforts to return to
compliance and maintain compliance. Please note that as of the writing of this letter we have returned to
compliance. The results for April and May 2020 were <1.00 ug/L.
Lastly, We submitted our NPDES Permit application on May 18, 2020 as it expires February 28, 2021, in it
we have requested that Dichloribromomethane be removed citing EPA Rule 391-3-6.03 (S)(e)(iv) which
states the in stream concentration for Dichlorobromomethane shall not exceed 17 ug/L under average or
higher flow conditions. Based on historical monitoring of this parameter, the effluent concentration would
not cause exceedance of this standard.
Thank you for your consideration and attention in this matter.
Sincerely,
W4j JJ . qJ 0
Troy B. Branch
Town of Denton WWTP ORC
201 W. Salisbury Street
P.O. Box 306 Phone: [phone]
Denton, NC 27239 Fax: [phone]
This institution is an equal opportunity provider and employer