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Home My WebLink AboutNC0040011_NOI_NOV2022LV0710_&_NOV2020LV0711_Response_20201020N TOWN OF YANCEYVILLE INCORPORATED "Tradition with Vision" 1986 October 20, 2020 Lon T. Snider, Regional Supervisor Water Quality Regional Operations Section Winston-Salem Regional Office 450 West Hanes Mill Rd. Winston-Salem, NC 27105 NC Department of Environmental Quality Received OCT 2 3 2020 Winston-Salem Regional Office Re: Notice of Violation and Intent to Assess Civil Penalty; Tracking Notice of Violation and Intent to Assess Civil Penalty; Tracking: Notice of Deficiency; Tracking ##NOD-2020-MV-0106 Dear Mr. Snider, On October 9, 2020, the Town of Yanceyville received the above -referenced Notices of Violation and Notice of Deficiency. This letter is being sent within the required ten business day window to respond and to explain some of the issues associated with the violations and deficiencies noted. The wastewater plant experienced high flows during the time period when the violations occurred, resulting in washout of solids/bacteria. This contributed to the high ammonia and BOD violations. Solids in the effluent are difficult to disinfect, and this in turn led to the fecal coliform violations. In addition, this washout of nitrifying bacteria led to the June ammonia violation, as it took time for the nitrifying bacteria to grow and for the plant to recover from the washout. Rainfall during the April -May 2020 time frame was significant. The website Usclimatedata.com lists 4.07 inches of rain for April and 3.78 inches in May at Yanceyville. There were significantly higher local amounts. Appended to this document is a listing of the influent flows for May; note that the design flow for this facility is 0.45 mgd. There are very high flows starting May 18, 2020. The Town of Yanceyville in partnership with Inframark, the firm contracted by the Town to operate and maintain the wastewater plant, acknowledges and does not dispute the violations, however we request that NCDEQ recognize the mitigating factors and underlying root causes that are not under our control. Inframark has implemented a more robust Process Control Monitoring Plan to allow greater visibility of operational data and to improve response and recovery time when these types of events occur. We welcome any further discussion. With respect to the Notice of Deficiency for not collecting the hardness sample, Inframark has instituted a corrective action plan including sampling plan review, chain of custody review, sample tracking and management notification in the event of a late sample. These corrective actions are designed to ensure that all samples are collected within the required time period. Best regards, Brian Collie 158 E. Church Street • P.O. Box 727 • Yanceyville, North Carolina 27379 (336) 694-5431 Fax (336) 694-1499 www.yanceyvillenc.gov ROY COOPER Coveraar MICHAEL S REGAN secmwy S. DANIEL SMITH DJmtor Certified Mail # 7018 1130 0000 1612 9875 Return Receipt Requested Brian Collie, Manager Town Town of Yanceyville PO Box 727 Yanceyville, NC 27379 NORTH CAROLINA £nvbv#taewefuf Quality October 5, 2020 SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY Tracking Number: NOV-2020-LV-0710 Permit No. NCO040011 Yanceyville WWTP Caswell County Dear Permittee: A review of the May 2020 Discharge Monitoring Report (DMR) for the subject facility revealed the violation(s) indicated below: Limit Exceedance Violation(s): Sample Location Parameter Limit Reported Date Value Value Type of Violation 001 Effluent Nitrogen, Ammonia Total (as 5/2/2020 6.9 10.8 Weekly Average Exceeded N) - Concentration (CO630) 001 Effluent BOD, 5-Day (20 Deg. C) - 5/9/2020 27 42.8 Weekly Average Exceeded Concentration (C0310) 001 Effluent BOD, 5-Day (20 Deg. C) - 5/23/2020 27 29.1 Weekly Average Exceeded Concentration (C0310) 001 Effluent Nitrogen, Ammonia Total (as 5/23/2020 6.9 9.7 Weekly Average Exceeded N) - Concentration (CO610) 001 Effluent BOD, 5-Day (20 Deg. C) - 5/30/2020 27 29.1 Weekly Average Exceeded Concentration (C0310) 001 Effluent Coliform, Fecal MF, MFC Broth, 5/30/2020 400 600 Weekly Geometric Mean Exceeded 44.5 C (31616) Nord+ Camino Department of Eftwonmental Quality I Dnsion of Water Peaaenxs WaseonSalam Na(amal office 1460 Weu Nunes Mil fioa0, Suet 300 I WOrmiaSekm, North Comk* 27106 336-776-3300 Limit Exceedance Violation(s): Sample Limit Reported Location Parameter Date Value Value Type of Violation 001 Effluent BOD, 5-Day (20 Deg. C) - 5/31/2020 18 29.54 Monthly Average Exceeded Concentration (C0310) 001 Effluent Nitrogen, Ammonia Total (as 5/31/2020 2.3 3.71 Monthly Average Exceeded N) - Concentration (CO610) A Notice of Violation/Intent to Issue Civil Penalty is being issued for the noted violation of North Carolina General Statute (G.S.) 143-215.1 and the facility's NPDES WW Permit. Pursuant to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) 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. If you wish to provide additional information regarding the noted violation, request technical assistance, or discuss overall compliance please respond in writing within ten (10) business days after receipt of this Notice. A review of your response will be considered along with any information provided on the submitted Monitoring Report(s). You will then be notified of any civil penalties that may be assessed regarding the violations. If no response is received in this Office within the 30-day period, a civil penalty assessment may be prepared. Remedial actions should have already been taken to correct this problem and prevent further occurrences in the future. The Division of Water Resources may pursue enforcement action for this and any additional violations of State law. If the violations are of a continuing nature, not related to operation and/or maintenance problems, and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by Consent. Reminder: Pursuant to Permit Condition 6 in Section E, the Permittee is required to verbally notify the Regional Office as soon as possible, not to exceed 24 hours, from first knowledge of any non-compliance at the facility including limit violations, bypasses of, or failure of a treatment unit. A written report may be required within 5 days if directed by Division staff. Prior notice should be given for anticipated or potential problems due to planned maintenance activities, taking units off-line, etc. If you have any questions concerning this matter or to apply for an SOC, please contact Ron Boone of the Winston-Salem Regional Office at 336-776-9800. cc: Laserfiche Sincerely, CLoSip� by T t5wx taseeeexzscsaea... Lon T. Snider, Regional Supervisor Water Quality Regional Operations Section Winston-Salem Regional Office Division of Water Resources, NCDEQ Nona Camino Department of Eavionmental Qaaihy 10msbn of Warr Resoamos WnsmnSalem Rot*mipffice 1450 West Nines Ma Roow,Suoe 300 I WiastonSabm, NoM Omer 2710.5 ""' 336-776-8800 DMR REVIEW RECORD Winston-Salem Regional Office Facility Name: Yanceyville WWTP Permit Number: NCO040011 Report Period: May 2020 Prior Assessments: 0 Enforcement Factor: 1.00 Waterbody Outfall # Outfall Description Waterbody Name Classification 001 Effluent to Country Line Creek Country Line Creek C Monthly Average Limit Violations Sample Location: Outfall 001 - Effluent Violation Unit of Limit Calculated % Over Date Parameter Frequency Measure Value Value Limit Action 5/31/2020 BOD, 5-Day (20 Deg. C) - Weekly mg/l 18 29.50 64.1 Concentration 5/31/2020 Nitrogen, Ammonia Total (as N) - Weekly mg/l 2.30 3.70 61.4 Concentration Weekly Average Limit Violations Sample Location: Outfall 001- Effluent Violation Unit of Limit Calculated % Over Date Parameter Frequency Measure Value Value Limit Action 5/9/2020 BOD, 5-Day (20 Deg. C) - Weekly mg/l 27 42.80 58.5 Concentration 5/23/2020 BOD, 5-Day (20 Deg. C) - Weekly mg/l 27 29.10 7.8 Concentration 5/30/2020 BOD, 5-Day (20 Deg. C) - Weekly mg/l 27 29.10 7.8 Concentration 5/30/2020 Coliform, Fecal MF, MFC Broth, Weekly #/100ml 400 600 50.0 44.5 C 5/2/2020 Nitrogen, Ammonia Total (as N) - Weekly mg/l 6.90 10.80 56.5 Concentration 5/23/2020 Nitrogen, Ammonia Total (as N) - Weekly mg/l 6.90 9.70 40.6 Concentration Other Violations/Staff Remarks: Recommend NOI. Supervisor Remarks: LOWNOI NOI-2020-LV-0710 Completed by: Ron Boone Date: Assistant Regional Supervisor Sign -off: Regional Supervisor Sign -off. LTS Permit Number: NCO040011 Date: Date: 9/29/2020 Prior 12-Month Enforcement History Report Period: May 2020 Limit Violation Sample Location: Outfall 001 - Effluent Violation Report Violation Date Period Parameter Type NOD NOV CPA 2/29/2020 2-2020 Flow, in conduit or thru Monthly Average NOV-2020-LV-0467 treatment plant Exceeded 4/4/2020 4-2020 Nitrogen, Ammonia Total (as Weekly Average NOV-2020-LV-0633 N) - Concentration Exceeded 4/25/2020 4-2020 Nitrogen, Ammonia Total (as Weekly Average NOV-2020-LV-0633 N) - Concentration Exceeded 4/25/2020 4-2020 Coliform, Fecal MF, MFC Weekly Geometric NOV-2020-LV-0633 Broth, 44.5 C Mean Exceeded 4/30/2020 4-2020 Nitrogen, Ammonia Total (as Monthly Average NOV-2020-LV-0633 N) - Concentration Exceeded ROY COOPER Governor MICHAEL & REGAN safe wy S. DANIEL SMITH Dtrtctor Certified Mail # 7018 1130 0000 1612 9868 Return Receipt Reauested Brian Collie, Manager Town Town of Yanceyville PO Box 727 Yanceyville, NC 27379 NORTH CAROLINA Eenrprtn tol Qttoury October 5, 2020 SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY Tracking Number: NOV-2020-LV-0711 Permit No. NCO040011 Yanceyville WWTP Caswell County Dear Permittee: A review of the June 2020 Discharge Monitoring Report (DMR) for the subject facility revealed the violation(s) indicated below: Limit Exceedance Violation(s): Sample Location Parameter Date Limit Value Reported Value Type of Violation 001 Effluent Nitrogen, Ammonia Total (as 6/6/2020 6.9 11.1 Weekly Average Exceeded N) - Concentration (C0610) 001 Effluent Nitrogen, Ammonia Total (as 6/30/2020 2.3 3.1 Monthly Average Exceeded N) - Concentration (C0610) A Notice of Violation/Intent to Issue Civil Penalty is being issued for the noted violation of North Carolina General Statute (G.S.) 143-215.1 and the facility's NPDES WW Permit. Pursuant to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) 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. North rim6na Oepartmeatof Eav MMWtM Qealty I Chvs ftof Water Resootces 4A P WermaEaiam Re6wns4 0f os, 1 450 West Hand M* Road, SwW 300 1 Wnstoobtem, North Cam#m 2 105 33s-776-980o If you wish to provide additional information regarding the noted violation, request technical assistance, or discuss overall compliance please respond in writing within ten (10) business days after receipt of this Notice. A review of your response will be considered along with any information provided on the submitted Monitoring Report(s). You will then be notified of any civil penalties that may be assessed regarding the violations. If no response is received in this Office within the 10-day period, a civil penalty assessment may be prepared. Remedial actions should have already been taken to correct this problem and prevent further occurrences in the future. The Division of Water Resources may pursue enforcement action for this and any additional violations of State law. If the violations are of a continuing nature, not related to operation and/or maintenance problems, and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by Consent. Reminder: Pursuant to Permit Condition 6 in Section E, the Permittee is required to verbally notify the Regional Office as soon as possible, not to exceed 24 hours, from first knowledge of any non-compliance at the facility including limit violations, bypasses of, or failure of a treatment unit. A written report may be required within 5 days if directed by Division staff. Prior notice should be given for anticipated or potential problems due to planned maintenance activities, taking units off-line, etc. If you have any questions concerning this matter or to apply for an SOC, please contact Ron Boone of the Winston-Salem Regional Office at 336-776-9800. Sincerely, Co«�sq..4 by: T L oti .5.aw 145"E225C91E _ Lon T. Snider, Regional Supervisor Water Quality Regional Operations Section Winston-Salem Regional Office Division of Water Resources, NCDEQ cc: Laserfiche North CaNine Department of fn+nronmsntY Qaa9fty I Om on of Water Resoonxs _ WnsmnSe4m Rgdonel0fise 450Wm Nws M8 Rosd,Sute 3CO I Winxmo4SWam, North Giotos 27105 '^ 336-776-9wo DMR REVIEW RECORD Winston-Salem Regional Office Facility Name: Yancevville W WTP Permit Number: NCO040011 Report Period: June 2020 Prior Assessments: 0 Enforcement Factor: LW I Waterbody Outfall # Outfall Description Waterbody Name Classification 001 Effluent to Country Line Creek Country Line Creek, C Monthly Average Limit Violations i Sample Location: Outfall 001- Effluent Violation Unit of Limit Calculated % Over Date Parameter Frequency Measure Value Value Limit Action 6/30/2020 Nitrogen, Ammonia Total (as N) - Weekly mgA 2.30 3.10 34.8 Concentration Weekly Average Limit Violations Sample Location: Outfall 001-Effluent Violation Unit of Limit, Calculated % Over Date Parameter Frequency Measure Value Value Limit Action 6/6/2020 Nitrogen, Ammonia Total (as N) - Weekly mg/l 6.90 11.10 60.9 Concentration Daily Limit Violations j Sample Location: Outfall 001 - Effluent Violation Unit of Limit Calculated % Over Date Parameter Frequency Measure Value Value. Limit Action I 6/6/2020 Chlorine, Total Residual 2 X week ugA 28 30 7.1 No Action, BPJ 6/8/2020 Chlorine, Total Residual 2 X week ugA 28 49 75.0 No Action, BPJ 6/10/2020 Chlorine, Total Residual 2 X week ugA 28 29 3.6 No Action, BPJ 6/12/2020 Chlorine, Total Residual 2 X week ugA 28 44 57.1 No Action, BPJ 6/17/2020 Chlorine, Total Residual 2 X week ugA 28 36 28.6 No Action, BPJ 6/18/2020 Chlorine, Total Residual 2 X week ugA 28 40 42.9 No Action, BPJ 6/21/2020 Chlorine, Total Residual 2 X week ugA 28 40 42.9 No Action, BPJ Other Violations/Staff Remarks: Recommend NOL Supervisor Remarks: Lon-NOI NOI-2020-LV-0711 Completed by: Assistant Regional Supervisor Sign -off. Regional Supervisor Sign -off: LTS Permit Number: NCO040011 Ron Boone Date: 9-24-2020 Date: Date: 9/29/2020 Prior 12-Month Enforcement History Report Period: June 2020 Limit Violation Sample Location: Outfall 001 - Effluent Violation Report Violation Date Period Parameter Type NOD NOV CPA 2/29/2020 2-2020 Flaw, in conduit or thru Monthly Average NOV-2020-LV-0467 treatment plant Exceeded 4/4/2020 4-2020 Nitrogen, Ammonia Total (as Weekly Average NOV-2020-LV-0633 N) - Concentration Exceeded 4/25/2020 4-2020 Nitrogen, Ammonia Total (as Weekly Average NOV-2020-LV-0633 N) - Concentration Exceeded 4/25/2020 4-2020 Colifonn, Fecal MF, MFC Weekly Geometric NOV-2020-LV-0633 Broth, 44.5 C Mean Exceeded 4/30/2020 4-2020 Nitrogen, Ammonia Total (as Monthly Average NOV-2020-LV-0633 N) - Concentration Exceeded