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WQ0001284_PC 2024 0019 CASE FILE_20240722
Docusign Envelope ID: EA8C8C4D-A2C6-446A-A24F-65245625603A DIVISION OF WATER RESOURCES - CIVIL PENALTY ASSESSMENT Violator: Town of Conway Facility Name: Town of Conwav WWTF Permit Number: WO0001284 County: Northamuton Case Number: PC-2024-0019 ASSESSMENT FACTORS 1) The degree and extent of harm to the natural resources of the State, to the public health, or to private property resulting from the violation; The degree and extent of harm has not been quantified. Without required monthly reporting, the facility is unable to determine if the amount of effluent and concentration of nutrients (i.e. ammonia) in wastewater can lead to the degradation of groundwater. 2) The duration and gravity of the violation; Because of the lack of reporting, the duration and gravity of the violation is undetermined. 3) The effect on ground or surface water quantity or quality or on air quality; Because of the lack of reporting, we cannot assess the potential impact on groundwater or surface water quality. 4) The cost of rectifying the damage; The cost of rectifying the damage is not documented. 5) The amount of money saved by noncompliance; It is not believed that any money was saved by these violations. Any money saved by noncompliance is de minimis. 6) Whether the violation was committed willfully or intentionally; There is no evidence that the violations were committed willfully or intentionally. 7) The prior record of the violator in complying or failing to comply with programs over which the Environmental Management Commission has regulatory authority; and There have been no penalty assessments issued in the past 12 months to the permittee for violations occurring at Town of Conway WWTF. 8) The cost to the State of the enforcement procedures. $122.39 gd�nDo'c�ulSiwgene'd by 7/22/2024 372DCBCB61EE4A8 Date Michael Hall, Regional Supervisor Water Quality Regional Operations Section Raleigh Regional Office Division of Water Resources, NCDEQ Docusign Envelope ID: EA8C8C4D-A2C6-446A-A24F-65245625603A Docusign Envelope ID: EA8C8C4D-A2C6-446A-A24F-65245625603A ROY COOPER ELIZABETH S. BISER , Secretory RICHARD E. ROGERS.M NORTH CAROLINA Dir w, Environmental Quality Certified Mail # 7017 2680 0000 2237 34551 Return Receipt Reauested July 22, 2024 Walter Lee Duke, Mayor Town of Conway 301 W Main St Conway, NC 27820 SUBJECT: Assessment of Civil Penalty for Violations of the Reporting Requirements Case No. PC-2024-0019 Town of Conway WWTF Non -discharge Permit No. WQ0001284 Northampton County Dear Permittee: This letter transmits a notice of a civil penalty assessed against Town of Conway in the amount of $622.39 (includes $122.39 in enforcement costs). This assessment is based upon the following facts: the August 2023 non -discharge application report ("NDAR-1') was not filed with the Division of Water Resources within the thirty (30) calendar days after the end of the reporting period for which the report is made [per 15A NCAC 02B .0506]. Resort Period Due Date Resort Tvoe Days Late August 2023 9/30/2023 NDAR-1 289 A Notice of Violation (NOV-2024-PC-0048) was sent to you for failure to submit the NDAR-1 [August 2023] no later than the thirtieth (30th) day following the reporting period. This notice was received by you on February 4, 2024. Within said notice, you were informed to "submit the missinq report within fifteen (15) days of receipt of the notice to prevent further action." The [NDAR-1 August 2023] NDAR-1 has not been received. awaen axgwnai owe I aeon ern nrwe < a,I�pn Nmnco�wim nape Docusign Envelope ID: EA8C8C4D-A2C6-446A-A24F-65245625603A The State's enforcement costs in this matter may be assessed against Town of Conway pursuant to NCGS. 143-215.3(a)(9) and NCGS 143B-282.1(b)(8). Based upon the above facts, I conclude as a matter of law that Town of Conway violated the terms, conditions or requirements of Non -discharge Permit No. WQ0001284 and G.S. 143-215.65 in the manner and extent shown above. In accordance with the maximums established by G.S. 143-215.6A(a)(2), a civil penalty may be assessed against any person who violates the terms, conditions or requirements of a permit required by G.S. 143-215.1(a). Based upon the above findings of fact and conclusions of law, and in accordance with authority provided by the Secretary of the Department of Environmental Quality and the Director of the Division of Water Resources, I, Michael Hall, Regional Supervisor, Raleigh Regional Office hereby make the following civil penalty assessment against Town of Conway: $500.00 For violation of NCGS 143-215.65 and NPDES Permit 8-2023, for failing to submit the Discharge Monitoring Report for WQ0001284. $122.39 Enforcement Costs $622.39 TOTAL AMOUNT DUE Pursuant to G.S. 143-215.6A(c), in determining the amount of the penalty I have taken into account the Findings of Fact and Conclusions of Law and the factors set forth at G.S. 143B-282.1(b), which are: (1) The degree and extent of harm to the natural resources of the State, to the public health, or to private property resulting from the violation; (2) The duration and gravity of the violation; (3) The effect on ground or surface water quantity or quality or on air quality; (4) The cost of rectifying the damage; (5) The amount of money saved by noncompliance; (6) Whether the violation was committed willfully or intentionally; (7) The prior record of the violator in complying or failing to comply with programs over which the Environmental Management Commission has regulatory authority; and (8) The cost to the State of the enforcement procedures. Within thirty (30) days of receipt of this notice, you must do one of the following: (1) Submit payment of the penalty, OR (2) Submit a written request for remission, OR (3) Submit a written request for an administrative hearing Docusign Envelope ID: EA8C8C4D-A2C6-446A-A24F-65245625603A Option 1: Submit payment of the penalty: Payment should be made directly to the order of the Department of Environmental Quality (do not include waiver form). Payment of the penalty will not foreclose further enforcement action for any continuing or new violation(s). Please submit payment to the attention of: Water Quality Permitting Section NC DEQ/Division of Water Resources 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Option 2: Submit a written request for remission or mitigation including a detailed justification for such request: Please be aware that a request for remission is limited to consideration of the five factors listed below as they may relate to the reasonableness of the amount of the civil penalty assessed. Requesting remission is not the proper procedure for contesting whether the violation(s) occurred or the accuracy of any of the factual statements contained in the civil penalty assessment document. Because a remission request forecloses the option of an administrative hearing, such a request must be accompanied by a waiver of your right to an administrative hearing and a stipulation and agreement that no factual or legal issues are in dispute. Please prepare a detailed statement that establishes why you believe the civil penalty should be remitted, and submit it to the Division of Water Resources at the address listed below. In determining whether a remission request will be approved, the following factors shall be considered: (1) whether one or more of the civil penalty assessment factors in NCGS 143B-282.1(b) was wrongfully applied to the detriment of the petitioner; (2) whether the violator promptly abated continuing environmental damage resulting from the violation; (3) whether the violation was inadvertent or a result of an accident; (4) whether the violator had been assessed civil penalties for any previous violations; or (5) whether payment of the civil penalty will prevent payment for the remaining necessary remedial actions. Please note that all evidence presented in support of your request for remission must be submitted in writing. The Director of the Division of Water Resources will review your evidence and inform you of his decision in the matter of your remission request. The response will provide details regarding the case status, directions for payment, and provision for further appeal of the penalty to the Environmental Management Commission's Committee on Civil Penalty Remissions (Committee). Please be advised that the Committee cannot consider information that was not part of the original remission request considered by the Director. Therefore, it is very important that you prepare a complete and thorough statement in support of your request for remission. In order to request remission, you must complete and submit the enclosed "Request for Remission of Civil Penalties, Waiver of Riaht to an Administrative Hearina, and Stipulation of Facts" form within thirty (30) days of receipt of this notice. The Division of Water Resources also requests that you complete and submit the enclosed "Justification for Remission Request." Both forms should be submitted to the following address: Water Quality Permitting Section NC DEQ/Division of Water Resources 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Docusign Envelope ID: EA8C8C4D-A2C6-446A-A24F-65245625603A Option 3: File a petition for an administrative hearina with the Office of Administrative Hearinas: If you wish to contest any statement in the attached assessment document you must file a petition for an administrative hearing. You may obtain the petition form from the Office of Administrative Hearings. You must file the petition with the Office of Administrative Hearings within thirty (30) days of receipt of this notice. A petition is considered filed when it is received in the Office of Administrative Hearings during normal office hours. The Office of Administrative Hearings accepts filings Monday through Friday between the hours of 8:00 a.m. and 5:00 p.m., except for official state holidays. The petition may be filed by facsimile (fax) or electronic mail by an attached file (with restrictions) - provided the signed original, one (1) copy and a filing fee (if a filing fee is required by NCGS §150B-23.2) is received in the Office of Administrative Hearings within seven (7) business days following the faxed or electronic transmission. You should contact the Office of Administrative Hearinas with all questions reaardina the filina fee and/or the details of the filina process. The mailing address and telephone and fax numbers for the Office of Administrative Hearings are as follows: 6714 Mail Service Center Raleigh, NC 27699 6714 Tel: (919) 431-3000 Fax: (919) 431-3100 One (1) copy of the petition must also be served on DEQ as follows: General Counsel Department of Environmental Quality 1601 Mail Service Center Raleigh, North Carolina 27699-1601 Please indicate the case number (as found on page one of this letter) on the petition. Failure to exercise one of the options above within thirty (30) days of receipt of this letter, as evidenced by an internal date/time received stamp (not a postmark), will result in this matter being referred to the Attorney General's Office for collection of the penalty through a civil action. Please be advised that additional penalties may be assessed for violations that occur after the review period of this assessment. If you have any questions, please contact Dorothy Robson with the Division of Water Resources staff of the Raleigh Regional Office at (919) 791-4241 or via email at dorothy.robson@deq.nc.gov. Sincerely, U" VAW Michael Hall, Regional Supervisor Water Quality Regional Operations Section Raleigh Regional Office Division of Water Resources, NCDEQ ATTACHMENTS Cc: WQS Raleigh Regional Office - Enforcement File NON -DISCHARGE Compliance/Enforcement Unit - Enforcement File Docusign Envelope ID: EA8C8C4D-A2C6-446A-A24F-65245625603A JUSTIFICATION FOR REMISSION REOUEST Case Number: PC-2024-0019 County: Northampton Assessed Party: Town of Conway Permit No.: WQ0001284 Amount Assessed: $622.39 Please use this form when requesting remission of this civil penalty. You must also complete the 'Request For Remission, Waiver of Right to an Administrative Hearing, and Stipulation of Facts"form to request remission of this civil penalty. You should attach any documents that you believe support your request and are necessary for the Director to consider in evaluating your request for remission. Please be aware that a request for remission is limited to consideration of the five factors listed below as they may relate to the reasonableness of the amount of the civil penalty assessed. Requesting remission is not the proper procedure for contesting whether the violation(s) occurred or the accuracy of any of the factual statements contained in the civil penalty assessment document. Pursuant to N.C.G.S. § 143B-282.1(c), remission of a civil penalty may be granted only when one or more of the following five factors apply. Please check each factor that you believe applies to your case and provide a detailed explanation, including copies of supporting documents, as to why the factor applies (attach additional pages as needed). (a) one or more of the civil penalty assessment factors in N.C.G.S. 143B-282.1(b) were wrongfully applied to the detriment of the petitioner (the assessment factors are listed in the civil penalty assessment document); (b) the violator promptly abated continuing environmental damage resulting from the violation (i.e., explain the steps that you took to correct the violation and prevent future occurrences); (c) the violation was inadvertent or a result of an accident (i.e., explain why the violation was unavoidable or something you could not prevent or prepare for); (d) the violator had not been assessed civil penalties for any previous violations; (e) payment of the civil penalty will prevent payment for the remaining necessary remedial actions (i.e., explain how payment of the civil penalty will prevent you from ,performing the activities necessary to achieve compliance). EXPLANATION: Docusign Envelope ID: EA8C8C4D-A2C6-446A-A24F-65245625603A STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY COUNTY OF NORTHAMPTON IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND STIPULATION OF FACTS Town of Conway ) Town of Conway WWTF ) PERMIT NO. WQ0001284 ) CASE NO. PC-2024-0019 Having been assessed civil penalties totaling $622.39 for violation(s) as set forth in the assessment document of the Division of Water Resources dated Julv 22, 2024, the undersigned, desiring to seek remission of the civil penalty, does hereby waive the right to an administrative hearing in the above -stated matter and does stipulate that the facts are as alleged in the assessment document. The undersigned further understands that all evidence presented in support of remission of this civil penalty must be submitted to the Director of the Division of Water Resources within thirty (30) days of receipt of the notice of assessment. No new evidence in support of a remission request will be allowed after (30) days from the receipt of the notice of assessment. This the day of , 20 SIGNATURE ADDRESS TELEPHONE MONITORING REPORT(MR) VIOLATIONS for: Permit: W00001284 MRS Betweel 8 - 2023 and 8 - 2023 Region: % Facility Name: % Param Name% County: % Major Minor: % PERMIT: WQ0001284 ReDortlna Violation MONITORING REPORT PPI 08-2023 08-2023 Report Date: 07/15/24 Page 1 of 1 Violation Category:% Program Category: Subbasin:% Violation Action: % FACILITY: Town of Conway - Town of Conway WWTF COUNTY: Northampton REGION: Raleigh VIOLATION UNIT OF CALCULATED % LOCATION PARAMETER DATE FREQUENCY MEASURE LIMIT VALUE Over VIOLATION TYPE VIOLATION ACTION 10/31/23 Late/Missing NDMR Proceed to Enforcement Case 10/31/23 Late/Missing NDAR-1 Proceed to Enforcement Case DocuSign Envelope ID: OC27C212-2C59-4721-13947-1MF000MNF ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director Certified Mail # 7020 3160 0000 4115 2404 Return Receipt Rea nested Walter Lee Duke, Mayor Town of Conway 301 W Main St Conway, NC 27820 NORTH CAROLINA Environmental Quality January 29, 2024 SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY Tracking Number: NOV-2024-PC-0048 Permit No. WQ0001284 Town of Conway WWTF Northampton County Dear Permittee: A review of the August 2023 Non -Discharge Analysis Report (NDAR1) for the subject facility revealed the violation(s) indicated below: Reoortina Violationlsl: Sample Location Parameter Date Type of Violation 10/31/2023 Late/Missing NDAR-1 A Notice of Violation/Intent to Issue Civil Penalty is being issued for the noted violation of North Carolina General Statute (G.S.) 143-215.1 and the facility's Non -discharge Permit. Pursuant to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) may be assessed against any person who violates or fails to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S. 143-215.1. If you wish to provide additional information regarding the noted violation, request technical assistance, or discuss overall compliance please respond in writing within ten (10) business days after receipt of this Notice. A review of your response will be considered along with any information provided on the submitted Monitoring Report(s). You will then be notified of any civil penalties that may be assessed regarding the violations. If no response is received in this Office within the 10-day period, a civil penalty assessment may be prepared. D_E Q North Carolina Department of Environmental Quality I Division of Water Resources v Raleigh Regional Office 1 3800 Barrett Drive I Raleigh, North Carolina 27609 919.791.4200 DocuSign Envelope ID: OC27C212-2C59-4721-13947-1D2F000A5D5F Remedial actions should have already been taken to correct this problem and prevent further occurrences in the future. The Division of Water Resources may pursue enforcement action for this and any additional violations of State law. If the violations are of a continuing nature, not related to operation and/or maintenance problems, and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by Consent. Reminder: Pursuant to Permit Condition 6 in Section E, the Permittee is required to verbally notify the Regional Office as soon as possible, not to exceed 24 hours, from first knowledge of any non-compliance at the facility including limit violations, bypasses of, or failure of a treatment unit. A written report may be required within 5 days if directed by Division staff. Prior notice should be given for anticipated or potential problems due to planned maintenance activities, taking units off-line, etc. If you have any questions concerning this matter or to apply for an SOC, please contact Chris Smith of the Raleigh Regional Office at 919-791-4200. Cc: Laserfiche Sincerely, ADo'c'u,Siigned by: -' I Y V l.11�(�C t �GIA.I� 372DCBCB61EE4A8... Michael Hall, Regional Supervisor Water Quality Regional Operations Section Raleigh Regional Office Division of Water Resources, NCDEQ North Carolina Department of Environmental Quality I Division of Water Resources v Raleigh Regional Office 1 3800 Barrett Drive I Raleigh, North Carolina 27609 919.791.4200 DocuSign Envelope ID: OC27UZ12-2C59-4721-B947-1C2F000A5D5F ROY COOPER Governor ELIZABETH S. BISER Secretary €LICHARD E. ROGERS, JR. Director Certified Mail # 7020 3160 0000 4115 2404 Return Rereint Requested, Walter Lee Duke, Mayor Town of Conway 301 W Main St Conway, NC 27820 Postal r. CERTIFIED Only DomeStic Mail la + ru 7 ZiV - IYl Getified Mail fee I G rappropriate) Extra Services & Fee co y]ck bou, add fes as postmark •ak b Return ReC60 (""'I 5 ��'�`� � �Aetum RocaSPti��ci liars NORTH CARQLINI C3 QCertrodMalRestr`tedOerrvny 5 6nvfranmenraIQuattl [] QAdullSlgnatureFiKu"d p {]Adult Slgn©turn i;cbillat dOeNveM S posy �a WAITER LEE IWYE, MA'rOR Total Po TOWN OF CONWAY �^ rrl $ 301 W MAIN STREET Sent TO CONWAY, NC 27820 Q WQ:NOV & INT To ASSESS of CIVIL PENALTY/NOV-202A-PC rU S'trBBr d WQ0001284/TOWN of CONWAy 2A ORTHA -,_ __ .-- 70203150000041152404 January 29, 202 SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY Tracking Number: NOV-2024-PC-0048 Permit No. WQ0001284 Town of Conway WWTF Northampton County Dear Permittee: A review of the August 2023 Non -Discharge Analysis Report (NDAR1) for the subject facility revealed the violation(s) indicated below: Reoortina Violation(sh Sample Location parameter Date Type of Violation 10/31/2023 Lace/Missing NDAR-1 1 S ENDER: COMPLETE THIS SECTION MMENOW , I compLETE THIS SECTION ON DELIVE17Y A Notice of Viola tion(Intent to 10 Statute (G.S.) 143-215.1 and tht n Complete items 1, 2, and 3. A. Signature a print your name and address on the reverse X lV � � Adept not more than twenty-five thous so that we can return the card to you. ❑ Addressee B. ec 'ved (Printed Name) C. p t , O:. elvey fails to act in accordance with tl" ■ Attach this card to the back of the mailpiece, IMA i� or on the front if space permits. u 143-� 1 �' 1, 1. Article Addressed to: D. is delivery address different from Item 1? © Yes li YES. enter delivery address below: ❑ No If you wish to provide additions discuss overall compliance plea review of your response will be Report(s). You will then be no, response is received in this prepared- WALTER LEE 0LKE, MAYOR TOWN OF CONWAY 301 W MAlN STREET CONWAY, NC 27870 WQtNOV & INT To ASSESS Or CIVIL PENALTY/NOV-1424-PC-4048 WQ0001284/70WN OE CONWAY WWTf/NORTHA 70703160000041152404 MAl/29/2024 1111111lI 1K I11111 II IIII 1111 I{ 111111111111111 9590 9402 3415 7227 6630 84 a cr i- N„mhrar iTransfer from service label] 7020 316D 0000 4115 2404 PS Form 3811, July 2015 PSN 7530-02-000-9050 3. Service Type ult Slgrlatt3re Adult S€gnahrre Restricted Delivery It Ceirtified MaflQ BCt Ma9 t eovieted 1wiv-s Collect on Delivery 0 Collect on Delivery Restricted Delivery Q Insured Mall I Mail Restricted Delivery 5001 ❑ Priority Mall Expresso • Registered Maur" 0 PAOStcred Matt Restricted eI very ettRAReee ellpt for Slgnature Confimmill nT" Signature contumatlon Restrict®d De[Ivery Domestic Fletum Ftecelpt Permit: WQ0001284 Region: Raleigh Penalty Assessment Penalty Case Approved Amount PC-2002-0018 06/24/03 $2,000.00 LM-2009-0007 02/12/09 $350.00 Total Cases: 2 $2,350.00 Total Penalties: Permit Enforcement History by Permit Facility: Town of Conway WWTF County: Northampton Remission Enforcement EMC Enforcement Request Conference Hearing Costs Damages Received Held Held $292.03 07/11 /03 $199.46 03/16/09 06/03/09 $491.49 $2,841.49 Owner: Town of Conway Collection Has Memo Sent Payment Case To AGO Total Paid Balance Due Plan Closed $2,292.03 $0.00 No 09/09/03 $449.46 $0.00 No 06/26/09 $2,741.49 $0.00 Total Penalties after $2,741.49 ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director THE HONORABLE TOMMY BARRETT TOWN OF CONWAY POST OFFICE BOX 365 CONWAY, NORTH CAROLINA 27820 Dear Mayor Barrett: NORTH CAROLINA Environmental Quality May 26, 2022 Subject: Permit No. WQ0001284 Town of Conway WWTF Wastewater Irrigation System Northampton County In accordance with your permit renewal request received March 2, 2022, we are forwarding herewith Permit No. WQ0001284 dated May 26, 2022, to the Town of Conway for the continued operation of the subject wastewater collection, treatment, and irrigation facilities. The following modifications to the subject permit are as follows: The irrigation area was reduced from 18.5 acres to 15.9 acres in the July 25, 2002. Since the permitted annual irrigation rate remains 109.2 inches over 15.9 acres, the permitted flow is reduced to 129,089 gallons per day (GPD). This permit shall be effective from the date of issuance through August 31, 2028, shall replace Permit No. WQ0001284 issued April 10, 2017, and shall be subject to the conditions and limitations therein. The Permittee shall submit a renewal application no later than March 4, 2028. Please pay attention to the monitoring requirements listed Attachments A, B, and C for they may differ from the previous permit issuance. Failure to establish an adequate system for collecting and maintaining the required operational information shall result in future compliance problems. The Division has removed the following permit conditions since the last permit issuance dated April 10, 2017: ➢ Old Condition I.1 — The hypochlorite delivery feed system is no longer in need of repair. ➢ Old Condition VL2 — This condition has been removed because permits are not voidable. The following permit conditions are new since the last permit issuance dated April 10, 2017: ➢ Condition IV.9.b — Maintenance logs shall now include the date of irrigation equipment calibration. ➢ Condition VL2 — The permit shall only remain effective so long as the nature and volume of wastes adheres to the guidelines described within the permit. �DNorth_E Carolina Department of Environmental Quality j Division of Water Resources 512 North Salisbury Street 11617 Mail Service Center f Raleigh, North Carolina 27699-1617 NORTH GAROLINA o-aw aMoev. IRS MW�Q..]; 919,707.9000 The Honorable Tommy Barrett May 26, 2022 Page 2 of 2 If any parts, requirements, or limitations contained in this permit are unacceptable, the Permittee has the right to request an adjudicatory hearing upon written request within 30 days following receipt of this permit. This request shall be in the form of a written petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed with the Office of Administrative Hearings at 6714 Mail Service Center, Raleigh, NC 27699-6714. Otherwise, this permit shall be final and binding. If you need additional information concerning this permit, please contact Cord Anthony at (919) 707-3655 or cord. anthonvnncdenr.eov. Sincerely, Richard E. Rogers, Jr., Director Division of Water Resources cc: Northampton County Health Department (Electronic Copy) Raleigh Regional Office, Water Quality Regional Operations Section (Electronic Copy) Laserfiche File (Electronic Copy) Digital Permit Archive (Electronic Copy) NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION DEPARTMENT OF ENVIRONMENTAL QUALITY RALEIGH WASTEWATER IRRIGATION SYSTEM PERMIT In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as amended, and other applicable Laws, Rules, and Regulations PERMISSION IS HEREBY GRANTED TO Town of Conway Northampton County FOR THE operation of a 129,089 gallon per day (GPD) wastewater collection, treatment, and irrigation facility consisting of the: continued operation of a wastewater collection system consisting of. approximately 500 linear feet (LF) of 8-inch and 10-inch gravity sewer; a 260 gallon per minute (GPM) pump station; approximately 2,500 LF of 6-inch force main; and all associated piping, valves, controls, and appurtenances; the continued operation of a wastewater treatment system consisting of. a 65 day storage/treatment lagoon; a liquid hypochlorite pump and feed system; a 600 GPM spray irrigation pump station; and all associated piping, valves, controls, and appurtenances; and the continued operation of a wastewater irrigation system consisting of. a 15.9 acre spray irrigation area; and all associated piping, valves, controls, and appurtenances to serve the Town of Conway WWTF, with no discharge of wastes to surface waters, pursuant to the application received March 2, 2022, and in conformity with the Division -approved plans and specifications considered a part of this permit. This permit shall be effective from the date of issuance through August 31, 2028, shall replace Permit No. WQ0001284 issued April 10, 2017, and shall be subject to the following conditions and limitations: I. SCHEDULES 1. The Permittee shall request renewal of this permit on Division -approved forms no later than March 4, 2028. [15A NCAC 02T .0105(b), 02T .0109] WQ0001284 Version 5.0 Shell Version 200201 Page 1 of 8 IL PERFORMANCE STANDARDS The Permittee shall maintain and operate the subject non -discharge facilities so there is no discharge to surface waters, nor any contravention of groundwater or surface water standards. In the event the facilities fail to perform satisfactorily, including the creation of nuisance conditions due to improper operation and maintenance, or failure of the irrigation areas to assimilate the effluent, the Permittee shall take immediate corrective actions, including Division required actions, such as the construction of additional or replacement wastewater treatment or disposal facilities. [15A NCAC 02T .0108(b)(1)(A)] 2. This permit shall not relieve the Permittee of their responsibility for damages to groundwater or surface water resulting from the operation of this facility. [15A NCAC 02T .0108(b)(1)(A)] 3. Groundwater monitoring wells shall be constructed in accordance with 15A NCAC 02C .0108 (Standards of Construction for Wells Other than Water Supply), and any other jurisdictional laws and regulations pertaining to well construction. [15A NCAC 02C .0108] 4. The wastewater collection facilities shall be properly maintained and operated at all times. The following performance criteria shall be met: a. The collection system shall be effectively maintained and operated at all times to prevent discharge to land or surface waters, and to prevent contravention of groundwater or surface water standards. b. A map of the collection system shall be developed and maintained. c. An operation and maintenance plan shall be developed, implemented, and maintained. d. Pump stations not connected to a telemetry system shall be inspected every day (i.e., 365 days per year) unless otherwise approved. Pump stations connected to a telemetry system shall be inspected at least once per week. e. High -priority sewers shall be inspected at least once every six months. f. A general observation of the entire collection system shall be conducted at least once per year. g. Overflows and bypasses shall be reported to the Raleigh Regional Office in accordance with 15A NCAC 02B .0506(a), and public notice shall be provided as required per G.S.143-215.1C. h. A grease control program shall be developed, implemented, and maintained. i. Right-of-ways and easements shall be maintained. J. Inspection and maintenance records shall be maintained for a period of at least three years, except for the map, which shall be maintained for the life of the system. [15A NCAC 02T .0403(a)] 5. Effluent quality shall not exceed the limitations specified in Attachment A. [15A NCAC 02T .0108(b)(1)(A)] 6. Application rates, whether hydraulic, nutrient, or other pollutant, shall not exceed those specified in Attachment B. [15A NCAC 02T .0108(b)(1)(A)] 7. The Permittee shall connect the irrigation system to a rain or moisture sensor designed to prevent irrigation during precipitation events or wet conditions. [ 15A NCAC 02T .0505(x)] WQ0001284 Version 5.0 Shell Version 200201 Page 2 of 8 8. Wastewater irrigation fields permitted prior to December 30, 1983 have a compliance boundary that is either 500 feet from the wastewater irrigation area, or at the property boundary, whichever is closest to the wastewater irrigation area. Any exceedance of groundwater standards at or beyond the compliance boundary shall require corrective action. Division -approved relocation of the compliance boundary shall be noted in Attachment B. Multiple contiguous properties under common ownership and permitted for use as a disposal system shall be treated as a single property with regard to determination of a compliance boundary. [15A NCAC 02L .0106(e), 02L .0107(a), 02T .0105(h), G.S. 143-215.1(1), G.S. 143-215.1(k)] 9. The review boundary is midway between the compliance boundary and the wastewater irrigation area. Any exceedance of groundwater standards at or beyond the review boundary shall require preventative action. [15A NCAC 02L .0108] 10. The Permittee shall apply for a permit modification to establish a new compliance boundary prior to any sale or transfer of property affecting a compliance boundary (i.e., parcel subdivision). [ 15A NCAC 02L .0107(c)] 11. No wells, excluding Division -approved monitoring wells, shall be constructed within the compliance boundary except as provided for in 15A NCAC 02L .0107(g). [15A NCAC 02L .0107] 12. Except as provided for in 15A NCAC 02L .0107(g), the Permittee shall ensure any landowner who is not the Permittee and owns land within the compliance boundary shall execute and file with the Northampton County Register of Deeds an easement running with the land containing the following items: a. A notice of the permit and number or other description as allowed in 15A NCAC 02L .0107(f)(1); b. Prohibits construction and operation of water supply wells within the compliance boundary; and c. Reserves the right of the Permittee or the State to enter the property within the compliance boundary for purposes related to the permit. The Director may terminate the easement when its purpose has been fulfilled or is no longer needed. [15A NCAC 02L .0107(f)] 13. The facilities permitted herein have no setbacks. The original permit (Permit No. 7947) pre -dates administrative code 15A NCAC 02H .02190), which was effective October 1, 1987. Since no modifications or expansions have been made to the originally permitted facility, the facility is still covered under the 15A NCAC 02H .0200 rules effective February 1, 1976, which contain no setback requirements. [15A NCAC 02H .0200] III. OPERATION AND MAINTENANCE REOUIREMENTS 1. The Permittee shall operate and maintain the subject facilities as anon -discharge system. [15A NCAC 02T .0500] 2. The Permittee shall maintain an Operation and Maintenance Plan, which shall include operational functions, maintenance schedules, safety measures, and a spill response plan. [15A NCAC 02T .0507(a)] 3. Upon the Water Pollution Control System Operators Certification Commission's (WPCSOCC) classification of the subject non -discharge facilities, the Permittee shall designate and employ a certified operator in responsible charge (ORC), and one or more certified operators as back-up ORCs. The ORC or their back-up shall operate and visit the facilities as required by the WPCSOCC. [15A NCAC 02T .0117] WQ0001284 Version 5.0 Shell Version 200201 Page 3 of 8 4. The Permittee shall maintain vegetative cover on the irrigation sites, such that crop health is optimal, allows even effluent distribution, and allows inspection of the irrigation system. [15A NCAC 02T .05 07(b)] 5. The Permittee shall take measures to prevent effluent ponding in or runoff from the irrigation sites listed in Attachment B. [15A NCAC 02T .0507(c)] 6. The Permittee shall not irrigate treated effluent during inclement weather, or when the soil is in a condition that will cause ponding or runoff. [15A NCAC 02T .0505(x)] 7. Irrigation equipment shall be tested and calibrated once per permit cycle. [15A NCAC 02T .0507(d)] 8. Only treated effluent from the Town of Conway WWTF shall be irrigated on the sites listed in Attachment B. [15A NCAC 02T .0501] 9. The Permittee shall not allow vehicles or heavy machinery on the irrigation area, except during equipment installation or maintenance activities. [15A NCAC 02T .0507(e)] 10. The Permittee shall prohibit public access to the wastewater treatment, storage, and irrigation facilities. [I5A NCAC 02T .0505(q)] 11. The Permittee shall dispose or utilize generated residuals in a Division -approved manner. [15A NCAC 02T .0508, 02T .I 100]. 12. The Permittee shall not divert or bypass untreated or partially treated wastewater from the subject facilities. [15A NCAC 02T .05050)] 13. Freeboard in the 65 day storage/treatment lagoon shall not be less than two feet at any time. [15A NCAC 02T .0505(d)] 14. A gauge to monitor waste levels in the 65 day storage/treatment lagoon shall be provided. This gauge shall have readily visible permanent markings, at inch or tenth of a foot increments, indicating the following elevations: maximum liquid level at the top of the temporary liquid storage volume; minimum liquid level at the bottom of the temporary liquid storage volume; and the lowest point on top of the dam. [15A NCAC 02T .0507(f)] 15. A protective vegetative cover shall be established and maintained on all berms, pipe runs, erosion control areas, surface water diversions, and earthen embankments (i.e., outside toe of embankment to maximum allowable temporary storage elevation on the inside of the embankment). Trees, shrubs, and other woody vegetation shall not be allowed to grow on the earthen dikes or embankments. Earthen embankments shall be kept mowed or otherwise controlled and accessible. [ 15A NCAC 02T .0507(g)] 16. Metering equipment shall be tested and calibrated annually. [15A NCAC 02T .0507(d)] IV. MONITORING AND REPORTING REOUIREMENTS 1. The Permittee shall conduct and report any Division required monitoring necessary to evaluate this facility's impact on groundwater and surface water. [15A NCAC 02T .0108(c)] 2. A Division -certified laboratory shall conduct all analyses for the required effluent, groundwater, and surface water parameters. [ 15A NCAC 02H .0800] 3. Flow through the treatment facility shall be continuously monitored, and daily flow values shall be reported on Form NDMR. Facilities with a permitted flow less than 10,000 GPD may estimate their flow from water usage records provided the water source is metered. [15A NCAC 02T .0105(k), 02T .0108(c)] WQ0001284 Version 5.0 Shell Version 200201 Page 4 of 8 4. The Permittee shall monitor the treated effluent at the frequencies and locations for the parameters specified in Attachment A. [15A NCAC 02T .0108(c)] 5. The Permittee shall maintain records tracking the amount of effluent irrigated. These records shall include the following information for each irrigation site listed in Attachment B: a. Date of irrigation; b. Volume of effluent irrigated; c. Site irrigated; d. Length of time site is irrigated; e. Continuous weekly, monthly, and year-to-date hydraulic (inches/acre) loadings; f. Continuous monthly and year-to-date loadings for any non -hydraulic parameter specifically limited in Attachment B; g. Weather conditions; and h. Maintenance of cover crops. [15A NCAC 02T .0108(c)] 6. Freeboard (i.e., waste level to the lowest embankment elevation) in the 65 day storage/treatment lagoon shall be measured to the nearest inch or tenth of a foot, and recorded weekly. Weekly freeboard records shall be maintained for five years, and shall be made available to the Division upon request. [15A NCAC 02T .0108(c)] 7. Three copies of all monitoring data (as specified in Conditions IV.3. and IVA.) on Form NDMR for each PPI and three copies of all operation and disposal records (as specified in Conditions IV.5. and IV.6.) on Form NDAR-1 for every site in Attachment B shall be submitted on or before the last day of the following month. If no activities occurred during the monitoring month, monitoring reports are still required documenting the absence of the activity. All information shall be submitted to the following address: Division of Water Resources Information Processing Unit 1617 Mail Service Center Raleigh, North Carolina 27699-1617 [15A NCAC 02T .0105(1)] 8. The Permittee shall maintain a record of all residuals removed from this facility. This record shall be maintained for five years, and shall be made available to the Division upon request. This record shall include: a. Name of the residuals hauler; b. Non -Discharge permit number authorizing the residuals disposal, or a letter from a municipality agreeing to accept the residuals; c. Date the residuals were hauled; and d. Volume of residuals removed. [15A NCAC 02T .0508(b)] 9. A maintenance log shall be kept at this facility. This log shall be maintained for five years, and shall be made available to the Division upon request. This log shall include: a. Date of flow measurement device calibration; b. Date of irrigation equipment calibration; c. Visual observations of the plant and plant site; and d. Record of preventative maintenance (e.g., changing of equipment, adjustments, testing, inspections and cleanings, etc.). [15A NCAC 02T .0507(h)] WQ0001284 Version 5.0 Shell Version 200201 Page 5 of 8 10. Monitoring wells MW-I, MW-3, and MW-4 shall be sampled at the frequencies and for the parameters specified in Attachment C. All manning, well construction forms, well abandonment forms and monitoring data shall refer to the hermit number and the well nomenclature as provided in Attachment C and Fiaure 1. [15A NCAC 02T .0105(m)] 11. Two copies of the monitoring well sampling and analysis results shall be submitted on a Compliance Monitoring Form (GW-59), along with attached copies of laboratory analyses, on or before the last working day of the month following the sampling month. The Compliance Monitoring Form (GW-59) shall include this permit number, the appropriate well identification number, and one GW-59a certification form shall be submitted with each set of sampling results. All information shall be submitted to the following address: Division of Water Resources Information Processing Unit 1617 Mail Service Center Raleigh, North Carolina 27699-1617 [15A NCAC 02T .0105(m)] 12. An annual representative soils analysis (i.e., Standard Soil Fertility Analysis) shall be conducted on each irrigation site listed in Attachment B. These results shall be maintained at the facility for five years, and shall be made available to the Division upon request. Each Standard Soil Fertility Analysis shall include the following parameters: Acidity Base Saturation (by calculation) Calcium Cation Exchange Capacity Copper [I5A NCAC 02T .0108(c)] 13. Noncompliance Notification: Exchangeable Sodium Percentage Magnesium Manganese Percent Humic Matter pH Phosphorus Potassium Sodium Zinc The Permittee shall report to the Raleigh Regional Office, telephone number (919) 791-4200, within 24 hours of first knowledge of the following: a. Treatment of wastes abnormal in quantity or characteristic, including the known passage of a hazardous substance. b. Any process unit failure (e.g., mechanical, electrical, etc.) rendering the facility incapable of adequate wastewater treatment. c. Any facility failure resulting in a discharge to surface waters. d. Any time self -monitoring indicates the facility has gone out of compliance with its permit limitations. e. Ponding in or runoff from the irrigation sites. Emergencies requiring reporting outside normal business hours shall call the Division's Emergency Response personnel at telephone number (800) 662-7956, (800) 858-0368, or (919) 733-3300. All noncompliance notifications shall file a written report to the Raleigh Regional Office within five days of first knowledge of the occurrence, and this report shall outline the actions proposed or taken to ensure the problem does not recur. [15A NCAC 02T .0108(b)(1)(A)] WQ0001284 Version 5.0 Shell Version 200201 Page 6 of 8 V. INSPECTIONS 1. The Permittee shall perform inspections and maintenance to ensure proper operation of the wastewater treatment and irrigation facilities. [15A NCAC 02T .0507(i)] 2. The Permittee shall inspect the wastewater treatment and irrigation facilities to prevent malfunctions, facility deterioration, and operator errors that may result in discharges of wastes to the environment, threats to human health, or public nuisances. The Permittee shall maintain an inspection log that includes the date and time of inspection, observations made, and maintenance, repairs, or corrective actions taken. The Permittee shall maintain this inspection log for a period of five years from the date of the inspection, and this log shall be made available to the Division upon request. [15A NCAC 02T .0507(h), 02T .0507(i)] 3. Division authorized representatives may, upon presentation of credentials, enter and inspect any property, premises, or place related to the wastewater treatment and irrigation facilities permitted herein at any reasonable time for determining compliance with this permit. Division authorized representatives may inspect or copy records maintained under the terms and conditions of this permit, and may collect groundwater, surface water, or leachate samples. [G.S. 143-215.3(a)(2)] VI. GENERAL CONDITIONS 1. Failure to comply with the conditions and limitations contained herein may subject the Permittee to a Division enforcement action. [G.S. 143-215.6A, 143-215.613, 143-215.6C] 2. This permit is effective only with respect to the nature and volume of wastes described in the permit application, and Division -approved plans and specifications. [G.S. 143-215.1(d)] 3. Unless specifically requested and approved in this permit, there are no variances to administrative codes or general statutes governing the construction or operation of the facilities permitted herein. [15A NCAC 02T .0105(n)] 4. The issuance of this permit does not exempt the Permittee from complying with all statutes, rules, regulations, or ordinances that other jurisdictional government agencies (e.g., local, state, and federal) may require. [15A NCAC 02T .0105(c)(6)] 5. If the permitted facilities change ownership, or the Permittee changes their name, the Permittee shall submit a permit modification request on Division -approved forms. The Permittee shall comply with all terms and conditions of this permit until the permit is transferred to the successor -owner. [G.S. 143- 215.1(d3)] 6. The Permittee shall retain a set of Division -approved plans and specifications for the life of the facilities permitted herein. [15A NCAC 02T .0105(o)] 7. The Permittee shall maintain this permit until the proper closure of all facilities permitted herein, or until the facilities permitted herein are permitted by another authority. [15A NCAC 02T .01050)] WQ0001284 Version 5.0 Shell Version 200201 Page 7 of 8 8. This permit is subject to revocation or modification upon 60-day notice from the Division Director, in whole or part for: a. violation of any terms or conditions of this permit or Administrative Code Title 15A Subchapter 02T; b. obtaining a permit by misrepresentation or failure to disclose all relevant facts; c. the Permittee's refusal to allow authorized Department employees upon presentation of credentials: i. to enter the Permittee's premises where a system is located or where any records are required to be kept; ii. to have access to any permit required documents and records; iii. to inspect any monitoring equipment or method as required in this permit; or iv. to sample any pollutants; d. the Permittee's failure to pay the annual fee for administering and compliance monitoring; or e. a Division determination that the conditions of this permit are in conflict with North Carolina Administrative Code or General Statutes. [15A NCAC 02T .0110] 9. Unless the Division Director grants a variance, expansion of the facilities permitted herein shall not occur if any of the following apply: a. The Permittee or any parent, subsidiary, or other affiliate of the Permittee has been convicted of environmental crimes under G.S. 143-215.613, or under Federal law that would otherwise be prosecuted under G.S. 143-215.613, and all appeals of this conviction have been abandoned or exhausted. b. The Permittee or any parent, subsidiary, or other affiliate of the Permittee has previously abandoned a wastewater treatment facility without properly closing the facility. c. The Permittee or any parent, subsidiary, or other affiliate of the Permittee has not paid a civil penalty, and all appeals of this penalty have been abandoned or exhausted. d. The Permittee or any parent, subsidiary, or other affiliate of the Permittee is currently not compliant with any compliance schedule in a permit, settlement agreement, or order. e. The Permittee or any parent, subsidiary, or other affiliate of the Permittee has not paid an annual fee. [15A NCAC 02T .0120(b), 02T .0120(d)] 10. This permit shall not be renewed if the Permittee or any affiliation has not paid the required annual fee. [I5A NCAC 02T .0120(c)] Permit issued this the 26th day of May 2022 NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION Richard E. Rogers, Jr., Director Division of Water Resources By Authority of the Environmental Management Commission Permit Number WQ0001284 WQ0001284 Version 5.0 Shell Version 200201 Page 8 of 8 ATTACHMENT A — LIMITATIONS AND MONITORING REQUIREMENTS Permit Number: WQ0001284 Version: 5.0 PPI 001— WWTF Effluent EFFLUENT CHARACTERISTICS PCs Parameter Description Units of Code Measure 00310 BOD, 5-Day (20 °C) mg/L 00940 Chloride (as Cl) mg/L 50060 Chlorine, Total Residual mg/L 31616 Coliform, Fecal MF, M-FC Broth, 44.5 °C #/100 mL . 50050 Flow, in Conduit or thru Treatment Plant GPD 00610 Nitrogen, Ammonia Total (as N) mg/L 00625 Nitrogen, Kjeldahl, Total (as N) mg/L 00620 Nitrogen, Nitrate Total (as N) mg/L 00600 Nitrogen, Total (as N) mg/L 00400 pH su . 00665 Phosphorus, Total (as P) mg/L 70300 Solids, Total Dissolved — 180 °C mg/L 00530 Solids, Total Suspended mg/L 1. 3 x Year sampling shall be conducted in February, June, and September. Monthly Average 129,089 EFFLUENT LIMITS Monthly I Daily Minimum I Daily Maximum Geometric Mean MONITORING REQUIREMENTS Measurement Sample Frequency Type Monthly Grab 3 x Year' Grab Weekly Grab Monthly Grab Continuous Recorder Monthly Grab Monthly Grab Monthly Grab Monthly Grab Weekly Grab Monthly Grab 3 x Year i Grab Monthly Grab WQ0001284 Version 5.0 Attachment A Page 1 of 1 ATTACHMENT B — APPROVED LAND APPLICATION SITES AND LINHTATIONS Town of Conway — Town of Conway WWTF IRRIGATION AREA INFORMATION Field Owner A Town of Conway B Town of Conway C Town of Conway D Town of Conway Totals County Latitude Longitude Northampton 36.447986' -77.215266' Northampton 36.446989' -77.214308' Northampton 36.445892' -77.214528' Northampton 36.445611' -77.215686' Net Acreage 2.39 4.50 4.50 4.50 15.89 Dominant Soil Series GyB2 — Gritney Sandy Clay Loam GxB — Gritney Sandy Loam GxB — Gritney Sandy Loam GxB — Gritney Sandy Loam Permit Number: WQ0001284 Version: 5.0 APPLICATION LIMITATIONS Parameter Hourly Yearly Rate Max 01284 — Non -Discharge Application Rate -- 109.2 01284 — Non -Discharge Application Rate -- 109.2 01284 — Non -Discharge Application Rate -- 109.2 01284 — Non -Discharge Application Rate -- 109.2 Units inches inches inches inches WQ0001284 Version 5.0 Attachment B Page 1 of 1 ATTACHMENT C — GROUNDWATER MONITORING AND LIMITATIONS Permit Number: WQ0001284 Version: 5.0 Monitoring Wells: MW-1, MW-3, and MW-4 GROUNDWATER CHARACTERISTICS GROUNDWATER STANDARDS MONITORING REQUIREMENTS PCS Code Parameter Description Daily Maximum Frequency Measurement Sample Type Footnotes 00680 Carbon, Tot Organic (TOC) mg/L 3 x Year Grab 1,6 00940 Chloride (as Cl) 250 mg/L 3 x Year Grab 1 31616 Coliform, Fecal MF, M-FC Broth, 44.5 °C #/100 mL 3 x Year Grab 1 00610 Nitrogen, Ammonia Total (as N) 1.5 mg/L 3 x Year Grab 1 00620 Nitrogen, Nitrate Total (as N) 10 mg/L 3 x Year Grab 1 00400 pH 6.5-8.5 su 3 x Year Grab 1,2 00665 Phosphorus, Total (as P) mg/L 3 x Year Grab 1 70300 Solids, Total Dissolved - 180 °C 500 mg/L 3 x Year Grab 1 GWVOC Volatile Compounds (GW) Present: Yes/No Annually Grab 1, 4, 5 82546 Water Level, Distance from measuring point feet 3 x Year Calculated 1, 2, 3 1. 3 x Year monitoring shall be conducted in February, June, and September; Annual monitoring shall be conducted in September. 2. The measurement of water levels shall be made prior to purging the wells. The depth to water in each well shall be measured from the surveyed point on the top of the casing. The measurement of pH shall be made after purging and prior to sampling for the remaining parameters. 3. The measuring points (top of well casing) of all monitoring wells shall be surveyed to provide the relative elevation of the measuring point for each monitoring well. The measuring points (top of casing) of all monitoring wells shall be surveyed relative to a common datum. 4. Volatile Organic Compounds (VOC) - In September only, analyze by one of the following methods: a. Standard Method 6230D, PQL at 0.5 gg/L or less b. Standard Method 621 OD, PQL at 0.5 gg/L or less c. EPA Method 8021, Low Concentration, PQL at 0.5 gg/L or less d. EPA Method 8260, Low Concentration, PQL at 0.5 gg/L or less e. Another method with prior approval by the Water Quality Permitting Section Chief Any method used shall meet the following qualifications: a. A laboratory shall be DWR certified to run any method used. b. The method used shall include all the constituents listed in Table VIII of Standard Method 6230D. c. The method used shall provide a PQL of 0.5 gg/L or less that shall be supported by laboratory proficiency studies as required by the DWR Laboratory Certification Unit. Any constituents detected above the MDL but below the PQL of 0.5 gg/L shall be qualified (estimated) and reported. 5. If any volatile organic compounds (VOC) are detected as a result of monitoring as provided in Attachment C, then the Raleigh Regional Office supervisor, telephone number (919) 791-4200, shall be contacted immediately for further instructions regarding any additional follow-up analyses required. 6. If TOC concentrations greater than 10 mg/L are detected in any downgradient monitoring well, additional sampling and analysis shall be conducted to identify the individual constituents comprising this TOC concentration. If the TOC concentration as measured in the background monitor well exceeds 10 mg/L, this concentration will be taken to represent the naturally occurring TOC concentration. Any exceedances of this naturally occurring TOC concentration in the downgradient wells shall be subject to the additional sampling and analysis as described above. 7. Monitoring wells shall be reported consistent with the nomenclature and location information provided in Figure 1 and this attachment. WQ0001284 Version 5.0 Attachment C Page 1 of 1 Figure 1 -Vicinity Map 4,MW-4 Town of Conway VWVTF y Field A T eatment/ terage 1 Field B 01 Field C Fiefd D MW-3