NC0026921_Application (ATC)_20040513

e4.tbi A.r ' . Michael F. Easley
,rti ,, Governor
William G.Ross,Jr.,Secretary
c?<
_ Y - North Carolina Department of Environment and Natural Resources
Alan W.Klimek, P.E.,Director
Coleen H.Sullins, Deputy Director
Division of Water Quality
May 13, 2004
The Honorable Tim Parnell, Mayor
Town of Parkton
P. O. Box 55
Parkton, North Carolina 28371
Subject: Application for Special Order by Consent
Parkton WWTP
EMC SOC WQ S03-013
NPDES Permit NC0026921
Robeson County
Dear Mayor Parnell:
This is to acknowledge receipt of your revised Special Order by Consent(SOC) application
package on April 12, 2004. Your revised application will be forwarded to the Division's
Fayetteville Regional Office for review and processing.
If you have questions concerning this SOC application, you may contact staff in the in the
Fayetteville Regional Office at 910/486-1541.
Sincerely,
/3(4-fri—e-4-445t__
Vanessa E. Manuel
Point Source Compliance/Enforcement Unit
Cc: DWQ Fayetteville Regional Office
SOC File S03-013
Central Files
ATA
NCDENR
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone] Customer Service
1 800 623-7748

.. MAY 1 2 2004 1
April 2, 2004
DENR - WATER QUALITY
POINT SOURCE BRANCH
Coleen Sullins,Deputy Director
NC Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh N.C. 26799-1617
RE: Town of Parkton
SOC Revision 'So 3-D/3
Dear Deputy Director Sullins:
Please find enclosed the revised Special Order by Consent (SOC) Application and Attachments
for the Town of Parkton.
The Town of Parkton would like to request a revision of the original SOC Application. The
original application requested an additional flow of 70,000 gallons per day (GPD). We would
like to revise that request to be increased to 80,000 GPD of total additional flow. The Town
requests this flow, as there are areas at the municipal limits that could be annexed into the Town.
This annexation is vital to obtaining desperately needed revenues to keep the Town solvent.
The Town of Parkton understands that we are liable for the outstanding penalties that have
accrued. We ask that the penalties be incorporated in the SOC as stipulated penalties to be held
in abeyance unless the SOC is not fully met. We also understand that if we fail to meet the terms
and conditions of the SOC the Town will have to pay those penalties upon notification by the
Division of Water Quality.
Further, the Town or Parkton has chosen to eliminate it's discharge by utilizing the regional
approach as the mechanism to obtaining NPDES permit compliance. It is the intent of the Town
of Parkton to eliminate the discharge as noted in the SOC application and we will ask that the
NPDES permit to be rescinded when the discharge has been eliminated.
Thank you for your understanding of our situation as the Town's financial status continues to be
a challenge for all those concerned. It is our goal to obtain compliance in the most timely and
cost effective manner possible. If you have any questions or need additional information, please
feel free to give me a call at(910) 858-3360.
Sincerely,
THE TOWN OF PARKTON
Mayor Robert Adams
Enclosures

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
APPLICATION FOR A SPECIAL ORDER BY CONSENT
(INFORMATION REQUIRED FOR FACILITIES REQUESTING AN SOC)
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 Robert Adams
3. Mailing Address: Post Office Box 55
City: Parkton State: North Carolina Zip: 28371
Telephone No.: ( 910 ) 858-3360
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 I.4. above): N/A
3. Issuance Date of Permit: January 1, 2000
4. Expiration Date of Permit: July 31,2004
HI.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 returned to compliance and actions taken to return 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). 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 80,000 gallons per day. The total non-domestic Flow requested is 0.00 gallons per day. The
total additional Flow is 80,000 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.
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.
THIS APPLICATION PACKAGE WILL NOT BE ACCEPTED BY THE DIVISION OF WATER
QUALITY 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.

I f the SOC is for a Company/Industry/Other,the person signing the SOC must be an upper
management official(Le.President, Vice President).
If the SOC is for a School District, the person signing the SOC must be the Superintendent of Schools.
Applicant's Certification:
I, Mayor Robert Adams , 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 Robert Adams
Print Name of Signing Official
Signature of 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

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:
Discharge Limitations
Effluent Characteristic 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:
1998 1999 2000 2001 2003
Discharge
Parameter C o 0 2 a own 2 o az) Q al own• 0 o az 2 ca
ti O 2 Q Q 2 Q Ca ti O z L1 ti w ¢ Q 0 N u. ti ti
Flow X X X X X
Daily
BOD X X X
(5 day)
Daily TSS
NH3N X X
Daily
Fecal XXXX XX XXXX X XXX XXX X
Coliform
pH X
Effluent
Toxicity X X X X X X XXXXXX X X XXXX
Testing
The 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.
Estimated
Project 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 18,000 gpd
TOTAL ADDITIONAL FLOW REQUESTED 80,000 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's 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
(I/I) 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 Director, 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.