NC0021491_NOV2023PC0403_Response Letter_20230825

Mocksville Town Hall
171 S. Clement Street
Mocksville, NC 27028
Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
SUBJECT: Notice of Violation
Tracking Number: NOV-2023-PC-0403
Permit No. NC0021491
Davie County
Mr. Snider,
dt
Incorporated
1839
■ A
Phone [phone]
Fax [phone]
www.mocksvillenc.om
Thank you for allowing us the opportunity to respond to the Notice of Violation dated July 27, 2023,
received August 7, 2023. This response is in regard to the Pretreatment Compliance Inspection of the
Town of Mocksville conducted on June 28, 2023, by Ms. Tricia Lowery (NCDEQ). The Town of
Mocksville currently has (1) active SIU, Brakebush Brothers Inc. (IUP #0004) -- a chicken processing
facility located in Mocksville, NC (Davie County). Our responses to the findings presented in your letter
are provided below.
Finding: Permittee did not conduct annual inspection of SlU (in 2022).
Response: In response to this concern, we have created a recurring work order in our CMMS system
reminding staff to conduct an annual inspection of the SIU. Aside from 2022, inspections of the
Brakebush facility were otherwise performed every year that the SIU was active.
An annual inspection of the SIU was conducted on August 8, 2023. The facility was observed to be well
maintained. The SIU has overall been highly communicative with the Town and the POTW's wastewater
treatment plant operations staff.
Finding: PAR was inadequate and missing several required documents when submitted in March 2023.
Permittee submitted missing documentation after PAR was reviewed by the Division, however, the
allocation table was not submitted, and as of 7/27/2023, has not been submitted.
Response: The Town of Mocksville received correspondence from NCDEQ dated June 15, 2023 stating
that the PPS and SNCR forms were not included with the PAR package that was submitted in March
2023. A discrepancy in understanding arose when it was not stated in the Pretreatment Program Info
Database sheet that a PPS, SNCR, and AT would need to be included in the package. In response to this
concern, the SNCR and PPS forms were submitted immediately upon awareness, on June 21, 2023. The
Division later requested a copy of the AT in July. In addition, all personnel have gone through additional
pretreatment program compliance training and are required to obtain refresher training annually.

Response: The allocation table was immediately emailed to Ms. Lowery upon awareness. An allocation
table was last completed in March of 2022 at the time of the renewal of the SIU's Industrial User Permit.
The POTW's NPDES permit was renewed in March of 2023, however, it was determined that no changes
were needed to be made to the AT, nor were any adjustments needed to the pretreatment program, since
there were no updates made to the WWTP's NPDES permit that would directly impact pretreatment. In
response to this concern, pretreatment program coordination staff conducted a thorough review of rule
15A NCAC 02H .0916 (c)(4)(A) to ensure that we remain compliant with this requirement in the future.
Sincerely,
I
Kenneth Gamble, Town Manager
Town of Mocksville
CC:
Tricia Lowery, NCDEQ
Joshua Powers, Envirolink, Inc.
Todd Robinson, Envirolink, Inc.
Madelyn Mills, Envirolink, Inc.
August 22, 2023