NC0020656_WWTP Bypass_20050912

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
September 12, 2005
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Robert Ellis, Treatment Plants Director
City of Laurinburg
PO Box 249
Laurinburg, NC 28353
SUBJECT: NOTICE OF VIOLATION
Bypass at Leith Creek WWTP
Permit Number NC0020656
Scotland County
Dear Mr. Ellis:
On August 1, 2005, Mike Lawyer of our office received a call from Ms. Sherri Monroe of your
staff reporting that an overflow had occurred that morning from the lift station located at the
Leith Creek WWTP (NC0020656). According to Ms. Monroe, a total of 1,500,000 gallons of
untreated sewage bypassed the plant's treatment processes with approximately 1,000,000 gallons
entering Leith Creek. The cause of the bypass as reported by Ms. Monroe was due to heavy
amounts of rain in a short period of time as well as pump station equipment failure. The large
volume of sewage that was lost was attributed to the fact that the Leith Creek WWTP is not
staffed twenty-four hours a day and that although the overflow probably began sometime during
the night before, it was not discovered until the following morning when staff arrived at around
7:00am. It was relayed to Ms. Monroe that a written report would need to be sent to this office
within five days pertaining to the exact cause and details of the bypass.
Don Register and Mike Lawyer of this office made a visit to the Leith Creek WWTP on the
afternoon of August 1, 2005. This visit was conducted to physically assess the situation, speak
with staff at the plant regarding the events and document the affected areas with photographs.
During this visit it was discussed that the pumps that send excess flow to the equalization basin
failed to operate due to starter malfunctions, which in turn caused the overflow. Mr. Register
inquired as to why these pumps were not equipped with telemetry in order to alert staff during
such situations. Staff responded that this would be considered.
A few days after the August 1, 2005 event, you had a conversation with Mr. Register concerning
some of the details of the bypass. You expressed that the influent station was indeed equipped
with an auto -dialer, which transmits to the water plant first and then to the police depai tiiient and
that you were trying to find out who acknowledged the call. Upon further investigation, you
discovered that someone on your staff had intentionally deactivated the telemetry system
N°o thCarolintr
Natural/if
North Carolina Division of Water Quality 225 Green Street — Suite 714 Fayetteville, NC 28301-5043 Phone [phone] Customer Service
Internet: h2o.enr.state.nc.us FAX [phone]
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper

Mr. Ellis
Page 2
September 12, 2005
preventing it from notifying personnel who could have responded and minimized the extent of
the overflow or possibly prevented the bypass altogether. This information was relayed to me by
telephone and also included with the five-day report that our office received on August 5, 2005.
Please refer to Section C, Item 2 of your permit, which states in part: The Permittee shall at all
times provide the operation and maintenance resources necessary to operate the existing
facilities at optimum efficiency. The Permittee shall at all times properly operate and
maintain all facilities and systems of treatment and control (and related appurtenances)
which are installed or used by the Permittee to achieve compliance with the conditions of
this permit.
Please refer to Section C, Item 4c(1) of your permit, which states in part: Bypass from the
treatment facility is prohibited and the Permit Issuing Authority may take enforcement
action against a Permittee for bypass, unless: (A) Bypass was unavoidable to prevent loss of
life, personal injury or severe property damage; (B) There were no feasible alternatives to
the bypass, such as the use of auxiliary treatment facilities, retention of untreated wastes or
maintenance during normal periods of equipment downtime.
As a response to this Notice of Violation, you are asked to submit to this office a written Plan of
Action (POA) to be received on or before September 30, 2005. This POA should include at a
minimum your plans to prevent such a bypass from occurring in the future.
Please be advised that this notice does not prevent the Division of Water Quality from taking
enforcement actions for the violation as noted, or for any past or future violations. The Division
of Water Quality has the authority to levy a civil penalty of not more than $25,000 per day per
violation.
If you have any questions, please contact me at 910-486-1541.
Sincerely,
Belinda S. Henson
Regional Supervisor
Surface Water Protection Section
BSH: ML/ml
cc: DWQ Central Files
S
;a ettevill�le
Don Regis er, ayetteville Regional Office
Mike Lawyer, Fayetteville Regional Office

T
&Uj of Caurithurg
OFFICE OF THE TREATMENT PLANTS DIRECTOR
September 27, 2005
Ms. Belinda S. Henson
Regional Supervisor
Surface Water Protection Section
225 Green Street — Suite 714
Fayetteville, NC 28301-5043
Re: Response to Notice of Violation
Bypass At Leith Creek WVI
Permit Number NC0020656
Scotland County
Dear Ms. Henson:
In response to your letter dated, September 1
for all staff to follow in hopes to` prevent' ove;
new daily log sheets for the Main and —
action with all employees': signaturesia,
Sincerely,
obuzA.v26_,
Robert A. Ellis
Treatment Plants Director
Cc: Craig F. Honeycutt, City Manager
SEP 2 9 20
ketra
All -America City
'1111'
1956 AL 1967
2005,we have developed a Plan of Action
ows in the futurelWe have enclosed our
mp Stations and also our written plan of
o follow the plan
603 LAUCHWOOD DRIVE • P.O. BOX 249 • LAURINNBURG, N.C. 28353 • PHONE: [phone] • FAX: [phone]

Plan of Action Leith Creek WWTP Main and E.Q. Pump Station
1) Physically check both stations, daily record status.
2) Wet Well in E.Q. Pump Station Water Level as low as possible. 1/2 of pump
exposed (out of water)
3) All floats tested & operating properly:
4) Auto dialer tested and operating properly. (i.e. On Monday's staff will simulate an
alarm to call -out. Tuesday — Fridays, staff will call auto dialer to check status and
record.)
5) When high water alarm is present, contact the Director to determine what actions
to initiate. First personnel to observe high water alarm should stay on -site until an
additional personnel arrives.
6) I will never disable an auto dialer at any pump station site.
I agree to follow this plan of action to help prevent future sanitary sewer overflows.
Robert A. Ellis, Director
Cale Pevey (Operator Training)
Burl Cox (Operator)
James McQueen (Plant Maintenance Worker)
(},r»on (+ i, l ( J1lo0IA
Ricky Odom (Chief Operator WWTP)

Month
Leith Creek WWTP Main Pump Station
Day
Emp.
Pump #1
Pump #2
Pump #3
Pump #4
Control Float Pump Station
Control Float EQ Basin
Sump Pump
Initials
Status
Status
Status
Status
Status
Status
Status
AM/PM
AM/PM
AM/PM
AM/PM
AM/PM
AM/PM
AM/PM
1
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30
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31
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(1)
Primed
(2)
Needed Priming
(3)
Floats Ok
(4)
Floats Failed
(5)
Electric Ok
(6)
Electric Failure

Month
Leith Creek EQ Pump Station
Day
Emp.
Auto -Dialer
Pump #1
Pump #2
Pump #3
Off,Lead,Lag,Stand-by 1, High Water Floats
Initials
Status
Status
Status
Status
Status
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
(1)
Primed
(2)
Needed Priming
(3)
Floats Ok
(4)
Floats Failed
(5)
Electric Ok
(6)
Electric Failure