NC0026441_NOV-2023-MV-0200_20240206

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Public works and Utilities
January 18, 2024
Attn: Vanessa E. Manuel, Assistant Regional Supervisor
1617 Mail Service Center
Raleigh, NC 27699-1617
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Subject: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY i)`Pio/'- t Tracking Number: NOV-2023-MV-0200 ror`
NPDES Permit # NCO026441
Town of Siler City
Chatham County
Dear Vanessa E. Manuel,
This letter is in response to the NOV & Intent for Civil Penalty issues on December 15, 2023, for the
sampling frequency of LCD Downstream, LCU Upstream, RRD Downstream, and RRU Upstream for June
2023:
It is believed that these violations occurred due to a misunderstanding regarding the proper protocol
regarding these samples. I have attached an email chain that reflects the conversations between Cheng
Zhang and myself. On August loth I received an email regarding missing information on the DMR and the
sampling frequencies of the rivers. I responded on August 14`h stating that I had updated the missing
information and went on to discuss the river sample confusion I was having. Where I also informed Cheng
Zhang that due to my confusion the July and August samples were done in the same manner as June.
Therefore, would be in violation as well. The next email I received from Cheng Zhang was on October 18'h
asking about sampling frequency in August for the rivers. I responded to that email on October 19`i' the
river samples were conducted the same as in June and that on August 14`h that I informed him of that. Cheng
Zhang then responded to both my August 14'h and October 19'h emails on October 20'h his understanding
of how the sampling was expected to be performed. By then I had already gained a better understanding of
these samples, and we were compliant in our river sampling for September. On December 12'h Cheng Zhang
reached out again regarding the sampling frequencies for July and August. I responded on December 15'h
that we had already been in communication regarding these sampling frequency concerns. I believe that
this was a misunderstanding due to our first time having to sample them at this frequency and we now
understand what is needed. I do not foresee we will have this violation in the future.
Brittany York
W WTP Superintendent
PO Box 769.311 N Second Avenue
Siler City, NC 27344-0769
Brittany York
[e-mail]
Phone: [phone]
www.silercity.org
To advance a framework for our success bwouuh balanced governance, dvnamic partnerships, and an engaged community.

Sincerely
.,�,/,_.
Brittany York
WWTP Superintendent
Town of Siler City
Cc: Hank Raper —Town Manager, Chris McCorquodale— Utility Director
i
Brittany York Brittany York
W WTP Superintendent [e-mail]
PO Box 769 •311 N Second Avenue Phone: [phone]
Siler City, NC 27344-0769 www.silercity.org
1'a adrunce u/rmmcwwk/or uur ai<thrna,gh bahm, cd(lot ermill. Jtnanrc partnerships, nmd fill coacu( ed [nmrruillih'.

From: Brittany York <[e-mail]>
Sent: Monday, August 14, 2023 4:57 PM
To: Zhang, Cheng <[e-mail]>
Cc: Bobbie Hill <bhillCcDsilercitv.org>
Subject: [External] RE: June DMR
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Good afternoon,
June 19th was an observed holiday so Effluent conductivity was not collected on that day. Would you like us to update
the DMR with an H in the field?
As for the river sample for week 1 of June, those samples were not collected because of the short week and transition
from May to June. I think we were thinking of it wrong. Can you please explain how that is typically done during times
when there is not a whole week at the beginning of the month or the end? July and August will reflect the same way.
Does these samples need to have a day in between? For example with only 2 days in a week do we collect samples on
both days or only one because the other samples earlier in the week were collected as well? Should we just think about
it in 3 samples per week (specific days like Mon, Wed, Frid) regardless of where it falls in the month? I think there was
just a little confusion there on our end. Can you just specify how you need to see it being done and we will ensure
moving forward it's done correctly?
Thank you for your help
Brittany York
WW Superintendent
Town of Siler City
919-742-4581 Office
919-742-5499 Fax
[e-mail]
From: Zhang, Cheng <[e-mail]>
Sent: Thursday, August 10, 2023 3:56 PM
To: Brittany York <[e-mail]>
Subject: June DMR
Ec Addised This email originated from outside of the Town of Siler City, NC
Missing parameters:
Effluent conductivity on June 19";
Upstream and downstream for the week of June 3rd: conductivity, nitrate/nitrite, ammonia, TKN, DO, pH, total
phosphorous, and temperature, three times per week, reported only once for the week.

Please revise the DMR if you have the data, thanks.
Cheng Zhang
Environmental Specialist II
Raleigh Regional Operations Section
Division of Water Resources
919 791 4259 office
919 817 3856 cell
919 788 7159 fax
cheng.zh ang (o)d eg. nc.aov
Please note that my email has changed
1628 Mail Service Center
Raleigh, NC 27699-1628
.._ �D Q��
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
Email correspondenre to and iron this adds ess my be subject to the North Car6ina Final is Records Law and may be disclosed to third parties by an authonzad
state official.

Brittany York
From: Zhang, Cheng <[e-mail]>
Sent: Wednesday, October 18, 2023 8:42 AM
To: Brittany York
Cc: Bobbie Hill
Subject: July and August DMR issues
Be Adviscd: This email originated from outside of the Town of Siler City, NC
Brittany,
BIMS shows missing upstream/downstream monitoring for the week of August 5`b, only two sampling events were
reported, permit requires three times; also missing was total effluent flow for the month of August. Has
upstream/downstream sampling being down in the last couple of day in July? Please double check. Thanks.
Cheng Zhang
Environmental Specialist II
Raleigh Regional Operations Section
Division of Water Resources
919 791 4259 office
919 817 3856 cell
919 788 7159 fax
cheng.zhang(cDdeg. nc. aov
Please note that my email has changed
1628 Mail Service Center
Raleigh, NC 27699-1628
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.

Brittany York
From:
Brittany York
Sent:
Thursday, October 19, 2023 12:13 PM
To:
Zhang, Cheng
Cc:
Bobbie Hill
Subject:
RE: July and August DMR issues
Good morning,
I have updated the August DMR to reflect the Total Flow. That was an oversight on my behalf.
There was no upstream/downstream monitoring performed on July 31" and the first week of August upstream/
downstream was only performed twice. However, the last week of August they were performed on 8/28, 8/30, and 9/1.
There was some confusion on our part about how these samples needed to be collected and if a day needed to be
between samples.
On 8/14/2023, 1 responded to an email you had sent regarding June's upstream/downstream sampling that there was
some confusion regarding these samples and also informed you that July and August would reflect the same as June. In
further research, I gained a better understanding of how these samples need to be conducted and September's DMR will
reflect that.
Any guidance would be appreciated to ensure we are doing our part to comply with our permit requirements.
I apologize for any inconvenience. We are working hard to keep everything straight and navigate the changes the last
year has brought. Thank you for your patience.
Thank you!
Brittany York
WW Superintendent
Town of Siler City
919-742-4581 Office
919-742-5499 Fax
[e-mail]
From: Zhang, Cheng <[e-mail]>
Sent: Wednesday, October 18, 2023 8:42 AM
To: Brittany York <[e-mail]>
Cc: Bobbie Hill <[e-mail]>
Subject: July and August DMR issues
Be Advised: This email originated from outside of the Town of Slier City, NC
Brittany,

BIMS shows missing upstream/downstream monitoring for the week of August 5", only two sampling events were
reported, permit requires three times; also missing was total effluent flow for the month of August. Has
upstream/downstream sampling being down in the last couple of day in July? Please double check. Thanks.
Cheng Zhang
Environmental Specialist II
Raleigh Regional Operations Section
Division of Water Resources
919 7914259 office
919 817 3856 cell
919 788 7159 fax
cheno.zhano(a deo.nc.goy
Please note that my email has changed
1628 Mail Service Center
Raleigh, NC 27699-1628
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
Email coi respandence to and from this address maybe subject to the North Carolina Public Records Law and maybe disclosed to third parties by an authorized
state official

Brittany York
From:
Zhang, Cheng <[e-mail]>
Sent:
Friday, October 20, 2023 9:56 AM
To:
Brittany York
Cc:
Bobbie Hill
Subject:
RE: [External] RE: June DMR
U- Be Advised: This email originated from outside of the Town of Siler City, NC
Please revise June DMR by marking June 191h as holiday for effluent conductivity. For instream monitoring, the frequency
is three times per week between June and September, my understanding is samples can be collected on consecutive
days (does not have to be Mon., Wed., and Fria, the week ended on June V falls in June, there should have been three
samplings. Let me know if you have questions, thanks.
Cheng Zhang
Environmental Specialist II
Raleigh Regional Operations Section
Division of Water Resources
919 7914259 office
919 817 3856 cell
919 788 7159 fax
cheng.zhang(ddeg.nc.Rov
Please note that my email has changed
1628 Mail Service Center
Raleigh, NC 27699-1628
VQ
Email correspondence to and from this address is subject to the
North Carolina Public Records Lani and may be disclosed to third parties.
From: Brittany York <[e-mail]>
Sent: Monday, August 14, 2023 4:57 PM
To: Zhang, Cheng <[e-mail]>
Cc: Bobbie Hill <[e-mail]>
Subject: [External] RE: June DMR
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Good afternoon,

June 19`h was an observed holiday so Effluent conductivity was not collected on that day. Would you like us to update
the DMR with an H in the field?
As for the river sample for week 1 of June, those samples were not collected because of the short week and transition
from May to June. I think we were thinking of it wrong. Can you please explain how that is typically done during times
when there is not a whole week at the beginning of the month or the end? July and August will reflect the same way.
Does these samples need to have a day in between? For example with only 2 days in a week do we collect samples on
both days or only one because the other samples earlier in the week were collected as well? Should we just think about
it in 3 samples per week (specific days like Mon, Wed, Frid) regardless of where it falls in the month? I think there was
just a little confusion there on our end. Can you just specify how you need to see it being done and we will ensure
moving forward it's done correctly?
Thank you for your help
Brittany York
WW Superintendent
Town of Siler City
919-742-4581 Office
919-742-5499 Fax
[e-mail]
From: Zhang, Cheng <[e-mail]>
Sent: Thursday, August 10, 2023 3:56 PM
To: Brittany York <[e-mail]>
Subject: June DMR
Sc Advised: This email originated from outside of the Town of Siler City, NC
Missing parameters:
Effluent conductivity on June 19";
Upstream and downstream for the week of June V: conductivity, nitrate/nitrite, ammonia, TKN, DO, pH, total
phosphorous, and temperature, three times per week, reported only once for the week.
Please revise the DMR if you have the data, thanks.
Cheng Zhang
Environmental Specialist II
Raleigh Regional Operations Section
Division of Water Resources
919 791 4259 office
919 817 3856 cell
919 788 7159 fax
cheng.zhanq(d.deg. nc. gov
Please note that my email has changed
1628 Mail Service Center
Raleigh, NC 27699-1628

Brittany York
From:
Brittany York
Sent:
Monday, October 23, 2023 1:20 PM
To:
Zhang, Cheng
Cc:
Bobbie Hill
Subject:
RE: [External] RE: June DMR
I have updated the June DMR. Thank you for the information
Thank you!
Brittany York
WW Superintendent
Town of Siler City
919-742-4581 Office
919-742-5499 Fax
[e-mail]
From: Zhang, Cheng <[e-mail]>
Sent: Friday, October 20, 2023 9:56 AM
To: Brittany York <[e-mail]>
Cc: Bobbie Hill <[e-mail]>
Subject: RE: [External] RE: June DMR
This email originated from outside of the Town of Slier City, NC
Please revise June DMR by marking June 191h as holiday for effluent conductivity. For instream monitoring, the frequency
is three times per week between June and September, my understanding is samples can be collected on consecutive
days (does not have to be Mon., Wed., and Fri.), the week ended on June 31 falls in June, there should have been three
samplings. Let me know if you have questions, thanks.
Cheng Zhang
Environmental Specialist II
Raleigh Regional Operations Section
Division of Water Resources
919 791 4259 office
919 817 3856 cell
919 788 7159 fax
cheng.zhang(3deg.nc.¢ov
Please note that my email has changed
1628 Mail Service Center
Raleigh, NC 27699-1628
Emad correspondence to and from this address is subject to the

Brittany York
From: Brittany York
Sent: Friday, December 15, 2023 10:41 AM
To: Zhang, Cheng
Cc: Bobbie Hill
Subject: RE: August DMR upstream/downstream sampling
Good morning,
I have had a chance to review the information and email chain regarding the upstream/downstream sampling.
On 8/14/2023, 1 responded to an email you had sent regarding June's upstream/downstream sampling that there was
some confusion regarding these samples and also informed you that July and August would reflect the same as June. In
further research, I gained a better understanding of how these samples need to be conducted and September's DMR will
reflect that.
Also, on 10/19/2023 1 responded to an email regarding the August 511 upstream/downstream sampling. I stated in my
email response the following statement regarding the July and August sampling, There was no upstream/downstream
monitoring performed on July 31' and the first week of August upstream/ downstream was only performed twice.
However, the last week of August they were performed on 8/28, 8/30, and 9/1. There was some confusion on our part
about how these samples needed to be collected and if a day needed to be between samples.
I think we are on track to perform these tests correctly in the future.
Should you have any questions please let me know.
Thank you!
Brittany York
WW Superintendent
Town of Siler City
919-742-4581 Office
919-742-5499 Fax
[e-mail]
From: Zhang, Cheng <[e-mail]>
Sent: Wednesday, December 13, 2023 3:16 PM
To: Brittany York <[e-mail]>
Cc: Bobbie Hill <[e-mail]>
Subject: RE: August DMR upstream/downstream sampling
This email originated from outside of the Town of Siler City, NC
I will have to send out a NOV if the issue is not resolved, please respond, thanks.
Cheng Zhang
Environmental Specialist II
Raleigh Regional Operations Section
Division of Water Resources

919 7914259 office
919 817 3856 cell
919 788 7159 fax
cheng.zhang(d)deg.nc.eov
Please note that my email has changed
1628 Mail Service Center
Raleigh, NC 27699-1628
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Zhang, Cheng
Sent: Tuesday, December 12, 2023 1:46 PM
To: Brittany York <[e-mail]>
Cc: Bobbie Hill <[e-mail]>
Subject: August DMR upstream/downstream sampling
Brittany and Bobbie,
Was upstream/downstream sampling conducted on July 31, 2023? BIMS shows only two sampling for the week of
August 5`h. Thanks.
Cheng Zhang
Environmental Specialist II
Raleigh Regional Operations Section
Division of Water Resources
919 791 4259 office
919 817 3856 cell
919 788 7159 fax
cheng.zhang(ZDdeg. nc. aov
Please note that my email has changed
1628 Mail Service Center
Raleigh, NC 27699-1628
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties