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rBel i nd a S. AensOr)
Iv\a 152-1-1. rZ
22.5 Greens4.,714,
Fay etf-evi lle,, N,.C. 2230 l - 504-3
:,ii,i,i,ii,:,i,i,„i,iII, lid,i„iir„i
Michael F. Easley, Govemor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
October 13, 2005
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Robert F. Adams, Mayor
Town of Parkton
PO Box 55
Parkton, NC 28371
SUBJECT: NOTICE OF VIOLATION
October 3, 2005 Compliance Evaluation Inspection
Town of Parkton
Parkton WWTP
Permit No: NC0026921
Robeson County
Dear Mr. Adams:
Enclosed please find a copy of the Compliance Evaluation Inspection Report from the inspection
conducted on October 3, 2005. The inspection was conducted by Mike Lawyer, Mark Brantley and
Belinda Henson as follow-up to a reconnaissance inspection conducted by Don Register and Mark
Brantley on August 26, 2005. After a telephone conversation between Mike Lawyer and Mr. Tim Murray
in which he relayed that he had resigned his role as Back-up ORC on the previous Friday, we were met at
the treatment plant by Mr. Jack Coe of your staff. The time and assistance given by Mr. Coe is greatly
appreciated. As a result of this inspection, the following items have been determined to be violations of
your NPDES permit (NC0026921):
1) Our records indicate Mr. Roy Lowder as the designated Operator in Responsible Charge (ORC) and
Mr. Tim Murray as the Back-up ORC. It is our understanding that Mr. Lowder resigned from his role as
ORC back in December 2004 and Mr. Murray took over the role. Our office however, has not received
any documentation regarding this. Please refer to Part II, Section C, Item 1 of your permit, which states in
part: Once the facility is classified, the Permittee shall submit a letter to the Certification
Commission designating the operator in responsible charge: b. Within 120 calendar days of: a
vacancy in the position of ORC or back-up ORC. In addition, with the recent resignation of Mr.
Murray, the Parkton WWTP is currently operating without a certified operator in either primary or back-
up capacity. It is of utmost importance that both an ORC and a Back-up ORC be designated immediately.
This must be done by completing the enclosed Water Pollution Control System ORC Designation Form
and submitting it directly to the Certification Commission.
•
2) According to Mr. Coe, both composite samplers located at the treatment plant are inoperable and have
been for approximately one month. When asked how samples are collected, Mr: Coe stated that grab
samples are taken by lowering a cup attached with a string into the manhole beyond the chlorine contact
chamber. Please refer to Part I, Section A (1) of your permit containing your effluent limitations and NoithCaiolina
!Naturally
North Carolina Division of Water Quality 225 Green Street — Suite 714 Fayetteville, NC 28301-5043 Phone (910) 486-1541 Customer Service
Internet h2o.enr.state.nc.us FAX (910) 486-0707 1-877-623-6748
An Equal Opportunity/Affirmative Action Employer — 50% Recycledll0% Post Consumer Paper
Mr. Adams
October 13, 2005
Page 2
monitoring requirements, which shows that many of your parameters are to be analyzed on composite
samples. Also, please refer to Part II, Section A of your permit, which defines a composite sample in part
as: A sample collected over a 24-hour period by continuous sampling or combining grab samples of
at least 100 ml in such a manner as to result in a total sample representative of the wastewater
discharge during the sample period.
3) During the August 26, 2005 reconnaissance inspection conducted by Don Register and Mark Brantley
of this office, several operation and maintenance items were noted. The grass throughout the treatment
plant was observed to be very high. Excessive vegetation was found in and around the oxidation ditches,
clarifiers and drying beds. Debris from the manual bar screen had not been removed. Chlorine gas
cylinders were found to be lying on the ground. Since this Reconnaissance inspection, the grass had been
mowed and most of the vegetation had been removed from the on-line oxidation ditch and clarifier. There
was still however, a large amount of algae present around the weirs of the clarifier that was greatly
inhibiting flow. The off-line oxidation ditch and clarifier still contained excessive amounts of vegetation
as well as all four of the plant's drying beds. Debris was still found on the manual bar screen and chlorine
gas cylinders were still on the ground. Please refer to Part II, 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.
As a response to this Notice of Violation, you are asked to submit to this office a written Plan of Action
(POA) referencing the aforementioned violations to be received on or before October 31, 2005. This
POA should detail your plans to address these violations as well as dates as to when compliance with all
conditions of your permit will be met. Please be aware that not addressing permit violations such as these
can result in the assessment of civil penalties of up to $25,000 per day per violation.
Please refer to the enclosed inspection report for additional observations and comments. If you or your
staff has any questions, please call me at 910-486-1541.
Sincerely,
.060 ‘(0-A)
Belinda S. Henson
Regional Supervisor
Surface Water Protection Section
Enclosure
cc: Surface Water Protection Section Central Files
Fayetteville Regional Office Files
United States Environmental Protection Agency
EPA Washington, D.C. 20460
Water Compliance Inspection Report '
Form Approved.
OMB No. 2040-0057
Approval expires 8-31-98
Section A: National Data System Coding.(i.e., PCS)
Transaction Code
1 I NI 2 151
21I 1 1_1 1 1 1
NPDES yr/mo/day Inspection
31 NC0026921 111 121 05/10/03 117
Type Inspector FacType
181 cl 19LI 20LI
I I 1 1 1 1 I 1 1 1 1 1 1 1 I66
Remarks
1 1 1 1 1 1 1 1 1 1 1 1 I• 1 I I I I I I I I I I I
Inspection Work Days • Facility Self -Monitoring Evaluation Rating B1 QA------------ Reserved---------------
67 I. 169 70 12 I 711 I 721 NI 731 I 1 74 751 1 1 1 1 1 1 1 80
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
Parkton WWTP
Loop Rd
Parkton NC 28371
Entry Time/Date
09:00 AM 05/10/03
Permit Effective Date
04/12/01
Exit Time/Date
10:30 AM 05/10/03
Permit Expiration Date
09/07/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Robert F Adams, Mayor,PO Box 55 Parkton NC
28371/Mayor/910-858-3360/9108589808 No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit • Operations & Maintenance • Self -Monitoring Program • Sludge Handling Disposal
Facility Site Review • Effluent/Receiving Waters
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Mark Brantley ih d FRO WQ///
Mike Lawyer 7/1/1„ FRO WQ///
Belinda S Henson FRO WQ//910-486-1541 Ext_727/
Signature of Management
)60
Q A Reviewer Agency/Office/Phone and Fax Numbers Date
-716 -1 - 05
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Water Pollution Control System ORC Designation Form
WPCSOCC
NCAC 15A:08G .0201
General Information:
Permittee Owner/Officer Name:
Mailing Address:
City: State: Zip:
Telephone Number: ( )
Signature: Date:
Facility Information:
Facility:
Permit Number: County:
! SUBMIT A SEPARATE FORM FOR EACH TYPE OF SYSTEM !
Mark (X) Type of Facility Class (1 — 4) Class
Wastewater Plant Spray Irrigation N/A
Physical/Chemical Land Application N/A
Collection System Subsurface N/A
Operator in Responsible Charge:
Print Name:
Certificate Type and Grade:
Work Telephone:
Social Security # :
Certificate #:
Signature:
Back -Up Operator in Responsible Charge:
Print Name:
Certificate Type and Grade:
Work Telephone: ( )
Mail or Fax to:
Social Secu
Signature:
wPcsocc
1618 Mail Service Center
Raleigh, N.C. 27699-1618
Fax: 919/733-1338
,4074e-
w/mi, 4,45
4gc47
� l d1; f2U��t
1013)
NPDES yr/mo/day Inspection Type
NC0026921 /11 121 05/10/03 I17 181CI
(cont.) 1
Section D: Summary of Finding/Comments (Attach additional sheets of.narrative and checklists as necessary)
This inspection was performed as a follow-up to the Reconnaissance inspection conducted by Don Register and
Mark Brantley on -August 26, 2005. This inspection was scheduled with Mr. Tim Murray, Back-up ORC, who did not
arrive. A call was placed to Mr. Murray's cell phone shortly after 9:00am who stated that he had resigned his
role as Back-up ORC for the Parkton WWTP as of the previous Friday, September 30, 2005. After being informed
by the town clerk that the mayor was out of town, it was relayed that town maintenance personnel could meet us
at the treatment plant. We were met by Mr. Jack Coe who accompanied us throughout our inspection of the plant
and graciously answered our questions to the best of his ability. Although some improvements had been made
since the Reconnaissance inspection regarding grounds maintenance, there were still some major issues that had
not been addressed. One item of immediate concern was that two full chlorine gas cylinders were found to be
lying on the ground instead of the required secured and upright position. Three empty cylinders were found to
be upright yet not secured. This is quite risky to human health due to the poisonous nature of chlorine gas.
The manual bar' screen contained`a considerable amount of debris that had not been removed causing an odor,
which could attract flies and other nuisance pests. Although the plant is equipped with two secondary -
clarifiers, the one that has been taken off-line still contains large amounts of vegetation and the exposed
metal is suffering from extensive rust. Most of the vegetation had been removed from the operating secondary
clarifier, however there was an excessive amount of algae present around the weirs, which was inhibiting flow.
Regarding the plant's two oxidation ditches, the one that has been taken off-line along with one of the
clarifiers has become overrun with weeds and woody vegetation. The spray coming from the operating oxidation
ditch appeared to be light in color indicating poor -treatment. Proper treatment in an oxidation ditch would be
indicated by a medium brown color showing that the aerobic bacteria present in the ditch have enough "food" to
digest. All four of the plant's drying beds contained excessive amounts of vegetation. The composite sampler
was found to be inoperable and it was relayed :by Mr. Coe that grab samples were being taken and analyzed
instead of the required composite samples. Lab records and DNB's could not be reviewed because none were
available on site. With the previous resignation of Mr. Roy Lowder, ORC and now Mr. Tim Murray, Back-up ORC,
the Town of Parkton WWTP has been and as of- this inspection is operating without a certified operator. All of -
the aforementioned items are required conditions of your NPDES permit. Noncompliance with such conditions are
considered to be violations and subject you to possible civil penalties up to the amount of $25,000 per day
per violation.
Permit: NC0026921 Owner - Facility: Parkton WWTP
Inspection Date: 10/03/2005 Inspection Type: Compliance Evaluation
Permit
(If the present permit expires in 6 months or less). Has the permittee submitted a new application?
Is the facility as described in the permit?
Are there any special conditions for the permit?
Is access to the plant site restricted to the general public?
Is the inspector granted access to all areas for inspection?
Comment
Operations & Maintenance
Is the plant generally clean with acceptable housekeeping?
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge
Judge, and other that are applicable?
Comment Considerable amount of screenings on bar screen that have not been removed. Full Chlorine gas
cylinders are lying on the ground. Empty cylinders are not secured. Excessive vegetation in the off-line oxidation
ditch, off-line clarifier and all four of the drying beds.
Bar Screens
Type of bar screen
a.Manual
b.Mechanical
Are the bars adequately screening debris?
Is the screen free of excessive debris?
Is disposal of screening in compliance?
Is the unit in good condition?
Comment: Considerable amount of debris not removed from bar screen.
Secondary Clarifier
Is the clarifier free of black and odorous wastewater?
Is the site free of excessive buildup of solids in center well of circular clarifier?
Are weirs level?
Is the site free of weir blockage?
Is the site free of evidence of short-circuiting?
Is scum removal adequate?
Is the site free of excessive floating sludge?
Is the drive unit operational?
Is the return rate acceptable (low turbulence)?
Is the overflow clear of excessive solids/pin floc?
Is the sludge blanket level acceptable? (Approximately Y% of the sidewall depth)
Comment Weirs were blocked with excessive accumulation of algae.
Oxidation Ditches
Are the aerators operational?
Are the aerators free of excessive solids build up?
Is the foam the proper color for the treatment process?
Does the foam cover less than 25% of the basin's surface?
Is the DO level acceptable?
Are settleometer results acceptable (> 30 minutes)?
Is the DO level acceptable?(1.0 to 3.0 mg/I)
Yes No NA NE
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Permit: NC0026921 Owner - Facility: Parkton VWVfP
Inspection Date: 10/03/2005 Inspection Type: Compliance Evaluation
Oxidation Ditches
Are settelometer results acceptable?(400 to 800 ml/I in 30 minutes)
Comment: Spray from aerator appeared light-colored, indicating inadequate treatment. The off-line ditch has
considerable amount of vegetation.
Disinfection -Gas
Are cylinders secured adequately?
Are cylinders protected from direct sunlight?
Is there adequate reserve supply of disinfectant?
Is the level of chlorine residual acceptable?
Is the contact chamber free of growth, or sludge buildup?
Is there chlorine residual prior to de -chlorination?
Comment: At the time of inspection, empty cylinders were upright, but not secured and full cylinders were lying on
the ground. All cylinders were in direct sunlight.
Effluent Sampling
Is composite sampling flow proportional?
Is sample collected below all treatment units?
Is proper volume collected?
Is the tubing clean?
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type representative)?
Comment: Sampler was not functioning at the time of inspection and it was stated that the sampler had not been
functioning for approximately one month. Samples are being collected by the one-time grab method.
Aerobic Digester
Is the capacity adequate?
Is the mixing adequate?
Is the site free of excessive foaming in the tank?
Is the odor acceptable?
Is tankage available for properly waste sludge?
Comment:
Drying Beds
Is there adequate drying bed space?
Is the sludge distribution on drying beds appropriate?
Are the drying beds free of vegetation?
Is the site free of dry sludge remaining in beds?
Is the site free of stockpiled sludge?
Is the filtrate from sludge drying beds returned to the front of the plant?
Is the sludge disposed of through county landfill?
Is the sludge land applied?
(Vacuum filters) Is polymer mixing adequate?
Comment: Facility has four drying beds, which all contain excessive vegetation.
Yes No NA NE
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Town ofParkton's WWTP
Subject: Town of Parkton's WWTP
From: Belinda Henson <Belinda.Henson@ncmail.net>
Date: Tue, 15 Nov 2005 14:52:06 -0500
To: "Dale. Lopez" <Dale.Lopez@ncmail.net>, don register <don.register@ncmail.net>, Mark Brantley
<Mark.Brantley@ncmail.net>, mike lawyer <mike.lawyer@ncmail.net>
I talked with the mayor for the Town of Parkton, Robert Adams today. I explained he
was late on two NOV response letters for the WWTP. He assured me he was working on
them. I told Mr. Adams we should have the responses to both NOVs no later than
*November 30th*. I also gave him the option of 1 response letter for both NOVs.
I explained to him how important it was to respond in a timely manner to our NOVs
and the possible consequences.
To assist the mayor with response to us, I also faxed a copy of both inspection
reports over to Philip Schroder (ORC). I talked with Philip also about the NOV
letters and he had not seen them or the mayor had not mentioned them. I also told
Philip we needed both responses no later than *November 30th*.
Belinda S. Henson
Regional Supervisor
NC DENR-Division of Water Quality
Surface Water Protection Section
Fayetteville Regional Office
(910)486-1541
1 of 1 11/15/2005 2:55 PM
MEMORY TRANSMISSION REPORT
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SENT PAGES
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TIME : NOV-15-265 03:52PM
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009
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MEMORY TRANSMISSION REPORT
TIME : NOV-17-2005 10:55AM
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NAME
FILE NUMBER : 803
DATE : NOV-17 10:53AM
TO : 8653849
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Aft7;27-12
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FAYETTEVILLE REGIONAL OFFICE
FAYETTEVILLE, NORTH CAROLINA 28301-5043
VOICE: 910-486-1541
Fax: 910-486-0707
To. Phi) ; e Scr:
Fax #: <,“,s - .S53-4+43'
From: 022V, ct CD
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