NC0026921_SOC Application_20031008

Michael F. Easley, Govemor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Coleen H. Sullins, Deputy Director
Division of Water Quality
November 13, 2003
The Honorable Tim Parnell, Mayor
Town of Parkton
P.O.Box55
Parkton, NC 28371
Subject: Non -Refundable Processing Fee
Special Order By Consent
EMC SOC WQ S03-013
Parkton WWTP
Robeson County
Permit No: NC0026921
Dear Mayor Pamell:
NOV 19 7nno
This letter is to acknowledge receipt of your application for a Special Order by Consent (SOC)
and check No. 5271 in the amount of $400.00 received from you on November 13, 2003.
By copy of this letter we are forwarding your application to the Fayetteville Regional Office for
review and processing.
If you have any questions concerning this Special Order by Consent, you may contact me in our
Raleigh Central Office at 919/733-5083, extension 532 or the Water Quality Section staff of our
Fayetteville Regional Office at 910-468-1541.
Cc:
s !IP.tnr 'irn iiC4Tr ?
SOC File S03-013
Central Files
Sincerely,
Vanessa E. Manuel
Point Source Compliance/Enforcement Unit
1617 Mail Service Center Raleigh, NC 27699-1617
[phone] Customer Service 1 800 623-7748

PAY
TO THE
ORDER OF.
FOR
TOWN OF PARKTON o2-89
P.O. BOX 55
PARKTON, NC 28371
Omni
le4471 3
0-144/14*-PLJ-c. le:ce .4 9 ! $ 0
-erc �.tl
r
National
Bank PARKTON. NORTH CAROLINA
THIS D:SFURi "'•'"n
r,S BEEN
APPSOVEC R_._.�i•E BY THE
LOCAL GOYEkr<N ENT BUDGET AND
FISCAL COKTi:OL ACT.
ii'0000527L11' 1:053LLL5351: 56 400024.6"
DATE

Hobbs, Upchurch &Associates, PA.
Consulting .Engineers
300 S.W: Broad Street • Post Office Box 1737 • Southern Pines, NC 28388
October 8, 2003
Mr. Roy Lowder, PWD
Town of Parkton
Post Offic Box 55
Parkton, NC 28371
Re: Town of Parkton
SOC
Robeson County, North -.Carolina,
Dear Mr. Lowder:
Please find enclosed the SOC Application.
➢ Have the Mayor sign and date the 4th page.
➢ Write check for $400.00 to NCDENR.
Send Application and Check to addresson the 4th page.
If you have any questions or need additional information, please feel free to call.
Sincerely,
HOBBS, UPCHURCH & ASSOCIATES, P.A.
Leonard McBryde III, E.I.
Enclosures
Southern Pines, NC • Telephone [phone] • Fax [phone] • e-mail: [e-mail]
Myrtle Beach • Nags Head • Raleigh • Charlotte • Beaufort

EON EL
STATE OF NORTH CAROLINA - pECENED
PARTMENT OF:ENVIRONMENT AND NATURAL:RESOURCES
i DIVISION OF WATER QUALITY NOV 0 3 2003
, APPLICATION FOR A SPECIAL ORDER BY CONSENT
•(INFORMATION REOUIRED FOR FACILITIES REQUESTING AN SOC)
VINTEB 0.05\bli San'101
Dischaw.Compance Ett •
I. GENERAL INFORMATION:
1. Applicant (corporation, individual, or other): Town of Parkton
2. Print or Type Owner's or Signing Official's Name and Title (the person who is legally responsible for the
facility and its compliance): Mayor Tim Parnell
1 t) F\
• 3. MailingAddreSs:POst Office Box 55 1 1 T •
i
City: Parkton State NC , Zip:128371:. ' ' .,,Li NOV 1 3 • 2003 \
f_)
• Telephone No.: [phone] L
bDiti - W.I,TER QUALITY
. , ... .. ... HINT SOnCE BUNCH
4. Facility Name: (subdivision, facility, or establishment name - must be consistent with name on the permit
issued by the Division of Water Quality): Town of Parkton Wastewater Treatment Plant
5. Application Date: September 5, 2003
6. County where project is located: Robeson
II. PERMIT INFORMATION FOR THE FACILITY REQUESTING THE SOC
1. Permit No.: NC0026921
2. Name of the specific wastewater treatment facility (if different from 1.4. above): NA
3. Issuance Date of Permit: January 1, 2000
4. Expiration Date Of Permit: July 31, 2004
III. COMPLIANCE HISTORY FOR FACILITY REQUESTING THE SOC
..•
Please attach a listing of SOC(s) and amendments, Judicial Order(s) and amendments, EPA 309 letter(s), EPA
Administrative Order(s),•Civil Penalty Assessment(s), Notices of Violation(s), etc. issued for this
facility during the Past 5 years This listing must contain the issue dates, reasons for issuance, when the
facility returnedto compliance and actions taken to retum the facility to compliance.
IV
ADDITIONAL FLOW OR REALLOCATION OF EXISTING FLOW
Only facilities owned by a unit of government may request to add additional Flow to the treatment system as
part of this SOC in accordance with NCGS 143-215.67(b).
1 out of 4 pages

Please be advised that additional Flow will be allowed under a SOC only in extreme circumstances. These
circumstances include elimination of other discharges that are non compliant with their NPDES Permit or
continual non-compliance of the Flow parameter as specified in the original SOC. These circumstances do not
include failure by the.facility to properly remove Infiltration and Inflow. When requesting the additional Flow,
the facility must include justification as to why this Flow is needed, and supporting documents to show progress
to eliminate any Flow problem causes (i.e., efforts undergone to eliminate Inflow and Infiltration into the plant).
If the requested additional flow is non domestic, the facility must be able to demonstrate the ability to
effectively treat the waste, and the waste will not adversely impact the wastewater system or it's ability to
dispose of or utilize residuals. The non -domestic waste must be similar to domestic strength either before or
after pretreatment. The applicant must provide a detailed analysis of all parameters reasonably expected to be
contained in the proposed non -domestic wastewater. The total domestic additional Flow requested is 70,000
gallons per day. The total non -domestic Flow requested is 0.00 gallons per day. The total additional Flow is
70,000 gallons per day.
If a reallocation of existing additional Flow is needed the facility must provide justification as to why this
reallocation is needed.
Please be advised that the actual additional Flow, if any, that could be allowed as part of this requested
SOC-will be determined by a complete analysis of any projected adverse impact that could be expected as
the result of this additional wastewater on the wastewater treatment facility and the surface waters.
V. EXPLANATION AS TO WHY SOC IS NEEDED:
Provide a detailed explanation why the SOC is being requested. Please address the following issues: (Attach as
many pages as required to fully explain).
1. Existing or unavoidable future violations(s) of Permit Limitations(s)
2. Existing or unavoidable future violations(s) of Permit Conditions(s)
3. Magnitude, duration and dates(s) of all existing Violations
4. Explanation for any existing or unavoidable future violation(s) along with any mitigating factor(s)
5. Expected duration of any existing or unavoidable future violation(s)
VI. EXPLANATION OF ACTIONS TAKEN BY THE APPLICANT TO MAXIMIZE THE EFFICIENCY
OF THE FACILITY PRIOR TO REQUESTING THE SOC:
Please attach a very specific detailed explanation of the actions taken. Please address the following issues:
1.•Describe the existing treatment process and any modifications that have been made in an effort to
correct and avoid violations of effluent limitations.
2. Changes made to facility operations such as use of polymers, more frequent wasting of solids,
additional aeration, additional operators, etc.
3. Collection system rehabilitation work completed or scheduled (including dates).
4. Coordination with pretreatment facilities for municipalities or production facilities for industries.
Identify any non -compliant significant industrial users and measure(s) taken or proposed to be taken to
bring the pretreatment facilities back into compliance.
5. If the SOC is being requested for failure to meet permit effluent limitations, the applicant must submit a
report prepared by an independent consultant (a professional with expertise in the wastewater
treatment) or by the Municipal Compliance Initiative Program of the Construction Grants and Loans
Section of the Division of Water Quality. This report must address the following:
a) An evaluation of all existing treatment units, operational procedures and recommendations as
to how the efficiencies of these facilities can be maximized.
2 out of 4 pages

b) A certification that these facilities could not be operated in a manner that would achieve
compliance with final permit limitations.
c) The effluent limitations that the facility could be expected to meet if operated at their
maximum efficiency during the term of the requested SOC (Be sure to consider interim
construction phases listed in section VII. 4 of this application).
6. Any other actions taken to correct problems prior to requesting the SOC.
VII. REQUESTED TIME SCHEDULE TO BRING THE FACILITY INTO COMPLIANCE WITH ALL
PERMIT CONDITIONS AND STATE REGULATIONS/STATUTES
The applicant must submit a detailed listing of activities along with time frames that are necessary to bring the
facility into compliance. This schedule must include interim dates as well as a final compliance date. The
schedule should address such activities as:
1. Request any needed permit(s).
2. Submit plans, specifications and appropriate engineering reports to DWQ for review and approval.
3. Begin construction.
4. Occurrence of major construction activities that are likely to effect facility performance (units out of
service, diversion of flows, etc.).
5. Complete construction.
6. Achieve compliance with all effluent limitations.
7. Complete specific Infiltration/Inflow work.
8. Have all pretreatment facilities achieve compliance with their pretreatment permits.
9. Conduct needed Toxicity Reduction Evaluations (TRE).
VIII. IDENTIFY FUNDING SOURCES TO BE USED TO BRING THE FACILITY INTO COMPLIANCE
The applicant must provide an explanation as to the sources of funds utilized to complete the work needed to
bring the facility into compliance. Possible funding sources include but are not limited to loan commitments,
• bonds, letters of credit, block grants and cash reserves. This explanation must demonstrate that the funds are
available or can be secured in the time to meet the schedule outlined as part of this application.
'THE DIVISION OF WATER QUALITY WILL NOT ACCEPT THIS APPLICATION PACKAGE
UNLESS ALL OF THE APPLICABLE ITEMS ARE INCLUDED WITH THE SUBMITTAL.
Required Items:
a. One (1) original and two (2) copies of the completed and appropriately executed application form,
along with all required attachments.
b. The non-refundable Special Order by Consent (SOC) processing fee of four hundred dollars
($400.00). The check must be made payable to The Department of Environment, and Natural
Resources.
If the SOC is for a City / Town the person signing the SOC must be the Mayor.
If the SOC is for a Company / Industry / Other, the person signing the SOC must be an upper
management official (i.e. President, Vice President).
If the SOC is for a School District, the person signing the SOC must be the Superintendent of Schools.
3 out of 4 pages

Applicant's Certification:
I, Mayor Tim Parnell, attest this application for a Special Order by Consent (SOC) has been
reviewed by me and is accurate and complete to the best of my knowledge. I understand if all required parts of this
Amendment application are not completed and if all required supporting information and attachments are not
included, this application package will be returned as incomplete. Furthermore, I attest by my signature that I fully
understand an upfront penalty may be imposed as part of obtaining a Special Order by Consent, and the upfront
penalty satisfies as full settlement all past violations prior to entering into a Special Order by Consent. Reference to
Upfront penalties for Special Orders by Consent may be found in the North Carolina Administrative Code (NCAC
.1206 (c) (3).
Mayor Tim Parnell
Print Name of Signing Official
Signature of t 1 n
Signing Official Date
THE COMPLETED APPLICATION PACKAGE, INCLUDING ALL SUPPORTING
INFORMATION AND MATERIALS, SHOULD BE SENT TO THE FOLLOWING ADDRESS:
NORTH CAROLINA DIVISION OF WATER QUALITY
WATER QUALITY SECTION
POINT SOURCE BRANCH
1617 MAIL SERVICE CENTER
RALEIGH, NORTH CAROLINA 27699-1617
TELEPHONE NUMBER: 919/733-5083, ext. 530
4 out of 4 pages

SOC ATTACHMENT
III. COMPLIANCE HISTORY FOR FACILITY REQUESTING THE SOC
The current NPDES permit discharge monitoring limits for the Town of Parkton
WWTP are as follows:
Effluent Characteristic
Discharge Limitations
Monthly Weekly
Average Average
Flow
0.2 mgd
-
BOD (5 day), (4/1 - 10/31)
15.0 mg/1
22.5 mg/1
BOD (5 day), (11/1 — 3/31)
24.0 mg/1
36.0 mg/1
TSS (85% removal)
30.0 mg/1
45.0 mg/1
NH3 as N, (4/1 - 10/31)
5.0 mg/1
-
NH3 as N, (11/1 - 3/31)
9.0 mg/1
-
Fecal Coliform
200.0 / 100 ml
400.0 / 100 ml
The following table indicates specific violations of monitored discharge limits
where a Notice of Violation was issued and civil penalties were assessed against
the Town of Parkton since December of 1997:
Discharge
1998
1999
2000
2001
2003
t.
°d' a
Ar-•Gt,
March
,
`�
2tiC/�OZA
a)
.rt
on
c4i
o
g
March
r4
c.
�2@v�OA2
E
V
p
u
0
May
7-1
o
4OZ
3
o
Dec.
►,r��
a
May
7-1
Aug.
A
March
2002 I
Gz.
March
May
c
titi
.>.
Parameter
Flow
XXX
X
X
Daily BOD
(5 day)
X
X
X
Daily TSS
NH3N
X
,
X
Daily
Fecal
Coliform
XXXX
XX
XXXX
X
XXX
XXX
X
pH
X
Effluent
Toxicity
Testing
X
X
X
XXX
XXXXXX
XX
X
NXX
The total amount of •penalties for these violations is $19,538.27.

IV. ADDITIONAL FLOW OR REALLOCATION OF EXISTING FLOW
The following breakdown is for additional flows needed for two planned projects
that would connect to the Town of Parkton sewer system plus an allocation for
anticipated system growth.
Proiect
Estimated
WW Flows
118 Lot Subdivision 42,500 gpd
28 Lot Subdivision 10,000 gpd
26 Lot Subdivision 9,500 gpd
subtotal 62,000 gpd
Allocation for Anticipated Growth 8,000 gpd
TOTAL ADDITIONAL FLOW REQUESTED 70,000 gpd
The sewer system study currently underway undoubtedly will reveal inflow and
infiltration sources that can be readily repaired. This combined with the Town of
Parkton ongoing.program to alleviate system inflow will negate impact of these
new connections.
V. , EXPLANATION AS TO WHY SOC IS NEEDED
This application for Special Order by Consent is necessitated by the failure of
existing treatment works to consistently comply with the parameters of its
NPDES discharge permit. The fines levied by DWQ for violations referenced
above have created a financial hardship for the Town of Parkton and its citizens.
Town of Parkton has aggressively pursued finding and repairing sources of inflow
and infiltration WI) into the sewer collection system and has made significant
progress in recent months. The Town has received state funding and has
rehabilitated a majority of the town's sewer mains. . However, the consensus of
opinion of all parties involved; town officials, consultants and regulatory officials
is that the present Wastewater Treatment Plant is undersized and regionalization
or expansion is needed to serve the long term needs of the town.
-For these reasons, the SOC seems an appropriate course of action while the town
continues with collection system repairs and seeks other funding options.

VI. EXPLANATION OF ACTIONS TAKEN BY THE APPLICANT TO MAXIMIZE
THE EFFICIENCY OF THE FACILITY PRIOR TO REQUESTING THE SOC
The Town of Parkton has taken multiple steps to ensure that future violations do
not occur. Modifications include repairs at the wastewater treatment plant,
collection system rehabilitation, personnel changes, and operational changes. The
following paragraphs outline work that has been completed by the Town and
provide information about ongoing projects to eliminate excess inflow and
infiltration from the sewer collection system.
• The former ORC, Mr. Leonard Green, did not operate and maintain the
wastewater treatment plant in accordance with state regulations. Based on
his poor performance Mr. Green has been relieved of duty. His final day
as an employee of the Town of Parkton was October 31, 2000. Mr. Roy
Lowder, the Parkton Public Works Direction, is the ORC.
• Mr. Don Register with NCDENR conducted a technical assistance visit on
June 12, 2000. In a letter dated June 22, 2000 Mr. Register outlined tasks
that should be completed by the Town to help improve system operation.
The Town has implemented all recommendations made by Mr. Register.
Specific actions are described in the following paragraphs:
> Mr. Register noted that influent flow to the aeration basins was not
split equally. To correct this, Mr. Lowder placed a flat block in the
#1 channel to divert a more equal portion of the flow to basin #2.
This has helped equalize the flow between the two basins during
high -flow conditions and reduces the load that was placed on basin
#1.:
> Inspection of the digester identified inoperable valves and a broken
supernatant draw -off. Valves on the waste line from the clarifier to
the digester were also inoperable. The condition of the equipment
indicated that the solids handling portion of the system was not
being utilized. The Town has replaced the inoperable equipment
and is wasting sludge to the digester. The Town spent $1,373.65
to repair the solids handling equipment.
> The technical inspection indicated that the sand on the drying beds
should be replenished. The Town spent $1,000.00 to purchase
approximately 50 tons of sand for the drying beds. The Town is
now utilizing the digester and drying beds to waste sludge.
> As suggested by Mr. Register, the Town now turns off the brush
aerators during high -flow periods to prevent solids washout from
the clarifier. This operational change has helped prevent additional
violations due to excessive flows in the collection system. •

> Mr. Register provided instruction to the Town staff regarding
operation of the flow -paced chlorinator. The unit was not being
utilized properly, which resulted in fecal coliform violations. The
Town now monitors the chlorine feed equipment and the residual
chlorine levels to ensure effective operation. A pocket chlorinator
unit has been purchased to allow close monitoring of the residual
chlorine level. The Town spent $375.19 to purchase the
equipment.
> During' the technical review it was noted that adequate logs were
not being maintained at the WWTP. Data needed to evaluate
system operation was not available due to poor record keeping.
The temporary ORC has worked to keep detailed daily logs at the
treatment plant. To facilitate data collection,' the Town has
purchased equipment to fix the pH meter and has purchased new
sampling equipment. A permanent continuous sampling unit has
been installed to monitor the WWTP effluent. Previously the ORC
utilized a portable sampling unit to collect effluent samples. In
addition, a new portable sampler has been purchased to monitor
influent to the WWTP. The total cost of the new equipment is
$6,538.00. The new monitoring equipment provides accurate data
that is utilized to evaluate treatment efficiency and make
operational decisions.
•
In addition to the equipment and operational changes
recommended by Mr. Register, the Town has purchased a
new flow meter and chart recorder for the WWTP. The
cost of the equipment totals $1,800.00. The equipment will
provide the town with more accurate flow data during high -
flow conditions. The previous flow meterwould become
submerged during rain events, which made readings
unreliable. The new flow meter will allow the Town to
evaluate I/I to the plant and continue its existing I/I
reduction program.
• The Town of Parkton received a grant from the Clean
Water Management Trust Fund (CWMTF) to help
complete inflow . and infiltration repairs in the collection
system. The project included rehabilitation of over 10,400
linear feet of sewer lines and approximately 1,200 vertical
feet of manholes. The repair project was completed in
2001. Combined with other projects, the rehabilitation
completed slip lining for all sewer lines and manholes in
the. Parkton system. The projects should reduce I/I in the
collection system, thereby resulting in reduced flows at the
WWTP.

• To identify points of inflow in the sewer system the Town
completed smoke testing in key areas. Numerous broken
cleanouts and interconnected floor drains were identified.
The Town has repaired the cleanouts and property owners
have sealed interconnected floor drains. The smoke testing
also identified two storm drains that are connected into the
sewer collection system. These storm drains were installed
by the North Carolina Department of Transportation as part
of road improvements in the town. The Town is working
with the DOT to disconnect the storm drains from the
sewer system. ' Eliminating these inflow points should
significantly impact flows at the WWTP during storm
events.
In the past the Town of Parkton has made significant changes to ensure effective
operation of its wastewater collection and treatment system. Most notably, the
Town has hired a Public Works Director to take responsibility for the wastewater
system. The previous ORC was a part-time employee who served as ORC for
other wastewater treatment facilities in the area. Due to the operator's other
responsibilities, operation and maintenance needs at the Parkton WWTP were
neglected. The Public Works Director is a full-time employee reporting directly
to the Mayor and Aldermen. He is held accountable for system operation and
permit compliance. Mr. Lowder began to assume more reasonability for system
operation in' the mid-2000 as performance issues were handled with Mr. Greene.
The town has spent over $11,000.00 to complete repairs and purchase needed
equipment. In addition, the Town is contributing $15,750.00 in local funds to
match the CWMTF grant received for the ongoing inflow/infiltration project.
The Town of Parkton received a North Carolina Rural Economic Development
Capacity Grant in 2002.. This grant will be used to study the town's wastewater
system, provide a Capital Improvement Plan, and to study the current rate
structure. The rate study will evaluate the current water and sewer rate structure.
It is expected that a rate increase will need to be implemented. The Town
understands that adequate funds must be in place to help complete future upgrade
and repair projects. The new rate structure will provide funds for system
operation and maintenance, as well as capital reserves for future projects. The
Public Works Director has indicated that rehabilitation of the pump stations in the
collection system is a maintenance priority.
VII. REQUESTED TIME SCHEDULE TO BRING FACILITY INTO
COMPLIANCE WITH ALL PERMIT CONDITIONS AND STATE
REGULATIONS/STATUTES

. Lf.
Apply for Project Grant Funding through North Carolina
State Construction Department December 2003
Apply for Project Grant Funding through N.C. Rural
Development Center Supplemental Grant Program March 2004
Receive notification of grant awards, begin project design September — December 2004
*Obtain approval of permit application to DENR August 2005.
*Advertise for Bidding Construction of Project September 2005
*Project Award November 2005
*Begin Construction January 2005
*Complete Construction December 2005
*Comply with Final Effluent Limits January 2006
* Denotes activity subject to attainment of suitable amount of grant
funding to finance project
REQUESTED SOC INTERIM PERMIT LIMITS:
Effluent Characteristic
Discharge Limitations
Monthly Weekly
Average Average
Flow
0.2 mgd
-
BOD (5 day), (4/1. - 10/31)
15.0 mg/1
22.5 mg/1
BOD (5 day), (11/1 — 3/31)
24.0 mg/1
36.0 mg/1
TSS (85% removal)
30.0 mg/1
45.0 mg/1
NH3 as N, (4/1 - 10/31)
5.0 mg/1
-
NH3 as N, (11/1 - 3/31)
9.0 mg/I
-
Fecal Coliform
200.0 / 100 ml
400.0 / 100 ml
VIII. IDENTIFY FUNDING SOURCES TO BE USED TO BRING THE FACILITY
INTO COMPLIANCE
North Carolina State Construction — State and Tribal Assistance Program
North Carolina Rural Development Center - Supplemental Grant Program
United States Department of Agriculture — Loan/Grant Program