NC0021423_NOV-2018-PC-0394_20181022

DocuSign Envelope ID: A06CE41B-56C7-4752-8FC2-EE4037AOF991
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NORTH CAROLINA
Effirbwmental Qualfjy
Certified Mail # 7017 2620 0000 9759 3547
Return Receipt Requested
October 22, 2018
Richard Canipe
Town of Spruce Pine
PO Box 189
Spruce Pine, NC 28777-0189
SUBJECT: NOTICE OF VIOLATION
Tracking Number: NOV-2018-PC-0394
Failure to Implement Pretreatment Program
Permit No. NCO021423
Program: Spruce Pine
Mitchell County
Dear Permittee:
The North Carolina Division of Water Resources (DWR) has determined that the Town of Spruce Pine's Pretreatment
Program has failed to meet the minimum requirements as specified in 15A NCAC 2H .0900 and 40 CFR 403.8 (f).
Specifically, the Town of Spruce Pine has failed to submit required documents and failed to take enforcement in a
timely fashion.
The Pretreatment Compliance inspection was conducted by Division of Water Resources staff from the Asheville
Regional Office. The following violation(s) were noted during the inspection:
Inspection Area Description of Violation
Pretreatment
Failed to submit required documents.
Pretreatment Failed to take enforcement action in timely manner.
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North Carolina Department of Environmental Quality I Division of Water Resources
2090 U.S. 70 Highway, Swannanoa, NC 28778
828-296-4500

DocuSign Envelope ID: A06CE41B-56C7-4752-8FC2-EE4037AOF991
A pretreatment compliance inspection was conducted by the Division on September 11, 2018. At that time, it was
discovered that the Town has failed to submit documents required by previous inspections:
1. The 7/8/2016 Pretreatment Compliance Audit letter required an updated enforcement response plan (ERP)
to address specific items by September 30, 2016.
2. The 7/8/2016 Pretreatment Compliance Audit letter required updates to the headworks analysis (HWA)
average WWTP and uncontrollable flow by September 30, 2016.
During the pretreatment compliance inspection conducted on September 11, 2018 it was discovered that the Town
failed to take timely enforcement against Bombardier for total suspended solids (TSS) violations:
3. Violations of the TSS limit occurred in May 2017. The NOV was not sent until August 2018. The current ERP
requires action by the pretreatment coordinator within 14 days of receiving the data.
To prevent further enforcement action, perform the following actions by the indicated due date:
4. Respond in writing by November 30, 2018 addressing the causes of noncompliance and all actions that
will be taken to prevent the recurrence of similar situations.
5. Submit an updated ERP to the PERCS Unit, attention Vivien Zhong, by November 30, 2018. A model
plan can be found on the web site: https://deq.nc.gov/about/divisions/water-resources/water-resources-
permit-guidance/pretreatment-gu ide/other-downloads
6. Provide updates average WWTP flow and updated uncontrollable flow to the PERCS Unit, attention Vivien
Zhong, by November 30, 2018.
7. As a reminder, an updated short-term monitoring plan is due by May 1, 2019. A model plan may be found
at the same web page as in item #5.
Items # 1 and 2 are over 30 days late and therefore constitute Significant Non -Compliance and the Town of Spruce
Pine will be included on the EPA Quarterly Non -Compliance Report.
If you have any questions, please contact Linda Wiggs at [phone] [email: [e-mail]] or Vivien
Zhong at [phone] [email: [e-mail]].
Sincerely, DocuSigned by:
E17A38285848C_
G. Landon Davidson, P.G., Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ
Ec: WQS Asheville Regional Office Server, Laserfiche
PERCS-Vivien Zhong
G:\WR\WQ\Mitchell\Wastewater\Municipal\21423 Spruce Pine WWTP\Pretreatment\9-2018 PCI\20181022_NC0021423_NOV2018PC0394.rtf
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Ups1.M1 gFiire�nW G1Wfr�
North Carolina Department of Environmental Quality I Division of Water Resources
2090 U.S. 70 Highway, Swannanoa, NC 28778
828-296-4500