NC0026921_NOV2016PC0456_20160916

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Certified Mail # 7012 3050 0019398 8277
Return Receipt Requested
September 15, 2016
Al H McMillan
Town of Parkton
PO Box 55
Parkton, NC 28371
SUBJECT: NOTICE OF VIOLATION
Tracking Number: NOV-2016-PC-0456
Permit No. NCO026921
Parkton WWTP
Robeson County
Dear Permittee:
PAT ,MCCRORY
Omm. or
DONkLD R. VAN, DFR-
se -IM C.YY
S- JAY ZHV11v1E.RNLkN
D-Trii:w
RECEIVEDINCDEQID'A
SEP 2 0 2016
Water Quality
Permitting Section
The North Carolina Division of Water Resources conducted an inspection of the Parkton WWTP on August 16,
2016. This inspection was conducted to verify that the facility is operating in compliance with the conditions and
limitations specified in NPDES WW Permit No. NC0026921. A summary of the findings and comments noted
during the inspection are provided in the enclosed copy of the inspection report.
The Bioassay Compliance inspection was conducted by Division of Water Resources staff from the Fayetteville
Regional Office. The following violation(s) were noted during the inspection:
Inspection Area Description of !Violation
Effluent Sampling Chronic Aquatic Toxicity "Fail' Result"
State of North Carolina I Environmental Quality I Water Resources
225 Green Street, Suite 714, Fayetteville, NC 28301-5043
910-433-3300

Mr. McMillian
Page 2
September 15, 2016
Comments
➢ A chronic toxicity sample was taken on August 16 and 18, 2016 and sent to the Division of Water Resources
Aquatic Toxicity Laboratory (located on Reedy Creek Road in Raleigh, NC) for testing. These samples
resulted in a "Fail Result" for the Chronic Toxicity Pass/Fail at 90%, and these results indicated that the
effluent would be predicted to have a negative water quality impact on the receiving stream. The failure of
this test was considered as a violation of the toxicity limitation specified in your NPDES Permit. The DWR
laboratory indicated that the pH for the samples were 5.8 and 4.1. Both pH's were below the permitted
limit of 6, however the 4.1 was significantly lower and could have contributed to the failure of this test.
The conductivity for these samples were 528 micromhos/cm and 571 micromhos/cm. While the Parkton
WWTP does not have a conductivity limit in their NPDES permit, these results are both above the 250
micromhos/cm limit that Waste Water Treatment Plants have if they have a limit. The high conductivity
and the low pH's together could have been the cause for the failure. The following week, Mr. Tim Little,
facility ORC, called the Fayetteville Regional Office to report high conductivity in the weekly sample that was
taken on August 23, 2016. Mr. Little stated he would begin checking the wastewater collection system to
see if he could locate the source of the high conductivity. Mr. Little also committed to testing the effluent
pH more frequently to ensure the effluent was meeting permit compliance.
➢ It was noted during the inspection that the new bar screen, grit chamber, new chlorine contact chamber,
and flow pacing equipment for chlorine were in operation.
➢ Maintenance records, ORC log, and laboratory data was up to date.
9 Laboratory records for the month of November 2015 and February 2016 were reviewed and no transcription
errors were found.
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.
To prevent further action, please respond in writing to this office within 30 days upon your receipt of this Notice
of Violation regarding your plans or measures to be taken to address the indicated violations and other identified
issues, if applicable.
➢ The FRO is offering to help with some process control testing for chronic toxicity if the town in interested.
The testing will be done with the help of the Aquatic Laboratory.
State of North Carolina I Environmental Quality I Water Resources
225 Green Street, Suite 714, Fayetteville, NC 28301-5043
910-433-3300

Mr. McMillian
Page 2
September 15, 2016
If you should have any questions, please do not hesitate to contact Mark Brantley with the Water Quality
Regional Operations Section in the Fayetteville Regional Office at 910-433-3300.
Sincerely,
I11
Belinda S. Henson, Regional Supervisor
Water Quality Regional Operations Section
Fayetteville Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS
Cc: WQS Fayetteville Regional Office - Enforcement File
NPDES Compliance/Enforcement Unit - Enforcement Fille
State of North Carolina I Environmental Quality I Water Resources
225 Green Street, Suite 714, Fayetteville, NC 28301-5043
910-433-3300

United States Environmental Protection Agency
Form Approved.
E P /�r!1 Washington, D.C. 20460
OMB No. 2040-0057
Water Compliance Inspection Report
App roval expires B-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 IN I 2 15 I 3 I NCO026921 Ill 12 16/08/16 17 18 I Q I 19 I G I 20 LJ
211 1 1 1 1 1 1 1 1 1 11 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 11 1 1 1 I I 166
Inspection Work Days Facility Self -Monitoring Evaluation Rating 81 QA --Reserved----
67 70 I, I 71 I„ I 72 LN] 731 I 174 75Ill 80
L-1
JData l I I
Section B: Facility
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES permit Number)
09'30AM 16/08/16
15/02/01
Parkton WWTP
Exit Time/Date
Permit Expiration Date
Loop Rd
12:OOPM 16!08116
19/07/31
Parkton NC 28371
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Timothy Edward Little/ORC/910-858-3360/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Timothy E Little,NCSR 1724 Saint Pauls NC 28384/Public Works
No
Director/910-474-6616/
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
® Permit ® Flow Measurement ® Operations & Maintenance ® Records/Reports
Self -Monitoring Program ® Facility Site Review
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Mark Brantley FRO WQ//910-433-3300 Ext.727/
16'
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
Bell* da S Hensan FRO WQ//910-433-3300 Ext.72E
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

NPDES ydrno/day Inspection Type (Cont.)
31 Nco026921 I11 12 16/08/16 17 18 JBI
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
The Bioassay Compliance inspection was conducted by Division of Water Resources staff from the
Fayetteville Regional Office. The following violation(s) were noted during the inspection:
Inspection Area Description of Violation:
Effluent Sampling Chronic Aquatic Toxicity "Fail" Result"
Comments
❑ A chronic toxicity sample was taken on August 16 and 18, 2016 -and sent to the Division of Water
Resources Aquatic Toxicity Laboratory (located on Reedy Creek Road in Raleigh, NC) for testing.
These samples resulted in a "Fail Result" for the Chronic Toxicity Pass/Fail at 90%, and these results
indicated that the effluent would be predicted to have a negative water quality impact on the receiving
stream. The failure of this test was considered as a violation of the toxicity limitation specified in your
NPDES Permit. The DWR laboratory indicated that the pH for the samples were 5.8 and 4.1. Both
pH's were below the permitted limit of 6, however the 4.1 was significantly lower and could have
contributed to the failure of this test. The conductivity for these samples were 528 micromhos/cm and
571 micromhos/cm. While the Parkton WWTP does not have a conductivity limit in their NPDES
permit, these result are both above the stream standard of 250 micromhos/cm. The high conductivity
and the low pH's together could have been the cause for the failure. The following week, Mr. Tim Little,
facility ORC, called the Fayetteville Regional Office to report high conductivity in the weekly sample that
was taken on August 23, 2016. Mr. Little stated he would begin checking the wastewater collection
system to see if he could locate the source of the high conductivity. Mr. Little also committed to testing
the effluent pH more frequently to ensure the effluent was meeting permit compliance.
❑ It was noted during the inspection that the new bar screen, grit chamber, new chlorine contact
chamber, and flow pacing equipment for chlorine were in operation.
❑ Maintenance records, ORC log, and laboratory data was up to date.
❑ Laboratory records for the month of November 2015 and February 2016 were reviewed and no
transcription errors were found.
Remedial actions should have already been taken to correct this problem and prevent further
occurrences in thefuture. The Division of Water Resources may pursue enforcement action for this
and any additional violations of State law. ,
To prevent further action, please respond in writing to this office within 30 days upon your receipt of this
Notice of Violation regarding your plans or measures to be taken to address the indicated violations and
other identified issues, if applicable.
❑ The FRO is offering to help with some process control testing for chronic toxicity if the town in
interested. The testing will be done with the help of the Aquatic Laboratory.
Page#

Permit: NCO026921 Owner - Facility: Parkton VVWTP
Inspection Date: 08/16/2016 Inspection Type: Bioassay Compliance'
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? ® ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ® ❑ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment:
Permit
Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new
❑
❑
®
❑
application?
M
❑
❑
❑
Is the facility as described in the permit?
®
❑
❑
❑
# Are there any special conditions for the permit?
❑
❑
®
❑
Is access to the plant site restricted to the general public?
®
❑
❑
❑
Is the inspector granted access to all areas for inspection?
®
❑
❑
❑
Comment:
Record Keeping
Yes No NA NE
Are records kept and maintained as required by the permit?
®
❑
❑
❑
Is all required information readily available, complete and current?
M
❑
❑
❑
Are all records maintained for 3 years (lab. reg. required 5 years)?
0
❑
❑
❑
Are analytical results consistent with data reported on DM Rs?
0
❑
❑
❑
Is the chain -of -custody complete?
0
❑
❑
❑
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
Are DMRs complete: do they include all permit parameters?
®
❑
❑
❑
Has the facility submitted its annual compliance report to users and DWQ?
®
❑
❑
❑
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator
❑
❑
®
❑
on each shift?
Is the ORC visitation log available and current?
®
❑
❑
❑
Is the ORC certified at grade equal to or higher than the facility classification?
■
❑
❑
❑
Is the backup operator certified at one grade less or greater than the facility classification?
®
❑
❑
❑
Is a copy of the current NPDES permit available on site?
®
❑
❑
❑
Page# 3

Permit: NCO026921 Owner - Facility: Parkton WWTP
Inspection Date: 08/16/2016 Inspection Type: Bioassay Compliance
Record Keeping Yes No NA NE
Facility has copy of previous year's Annual Report on file for review? ® ❑ ❑ ❑
Comment:
Flow Measurement - Effluent
Yes No NA NE
# Is flow meter used for reporting?
®
❑
❑
❑
Is flow meter calibrated annually?
®
❑
❑
❑
Is the flow meter operational?
®
❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
❑
❑
®
❑
Comment:
Bar Screens
Yes No NA NE
Type of bar screen
■
❑
❑
❑
a.Manual
❑
❑
❑
❑
b.Mechanical
®
❑
❑
❑
Are the bars adequately screening debris?
®
❑
❑
❑
Is the screen free of excessive debris?
N
❑
❑
❑
Is disposal of screening in compliance?
®
❑
❑
❑
Is the unit in good condition?
N
❑
❑
❑
Comment:
Grit Removal
Yes No NA NE
Type of grit removal
■
❑
❑
❑
a.Manual
❑
❑
❑
❑
b.Mechanical
®
❑
❑
❑
Is the grit free of excessive organic matter?
®
❑
❑
❑
Is the grit free of excessive odor?
N
❑
❑
❑
# Is disposal of grit in compliance?
®
❑
❑
❑
Comment:
Secondary Clarifier
Yes No NA NE
Is the clarifier free of black and odorous wastewater?
■
❑
❑
❑
Is the site free of excessive buildup of solids in center well of circular clarifier?
®
❑
❑
❑
Are weirs level?
®
❑
❑
❑
Page# 4

Permit: NCO026921 Owner - Facility: Parkton vWVTP
Yes No NA NE
Are the aerators operational?
0
❑
Inspection Date: 08/16/2016 Inspection Type: Bioassay Compliance
❑
Are the aerators free of excessive solids build up?
®
❑
Secondary Clarifier
Yes No NA NE
Is the site free of weir blockage?
0
❑
❑
❑
Is the site free of evidence of short-circuiting?
0
❑
❑
❑
Is scum removal adequate?
®
❑
❑
❑
Is the site free of excessive floating sludge?
0
❑
❑
❑
Is the drive unit operational?
0
❑
❑
❑
Is the return rate acceptable (low turbulence)?
0
❑
❑
❑
Is the overflow clear of excessive solids/pin floc?
0
❑
❑
❑
Is the sludge blanket level acceptable? (Approximately Y. of the sidewall depth)
®
❑
❑
❑
Comment:
Oxidation Ditches
Yes No NA NE
Are the aerators operational?
0
❑
❑
❑
Are the aerators free of excessive solids build up?
®
❑
❑
❑
# Is the foam the proper color for the treatment process?
0
❑
❑
❑
Does the foam cover less than 25% of the basin's surface?
0
❑
❑
❑
Is the DO level acceptable?
0
❑
❑
❑
Are settlebmeter results acceptable (> 30 minutes)?
❑
❑
❑
❑
Is the DO level acceptable?(1.0 to 3.0 mg/I)
0
❑
❑
❑
Are settelometer results acceptable?(400 to 800 ml/I in 30 minutes)
❑
❑
❑
0
Comment:
Disinfection -Gas
Yes No NA NE
Are cylinders secured adequately?
0
❑
❑
❑
Are cylinders protected from direct sunlight?
0
❑
❑
❑
Is there adequate reserve supply of disinfectant?
0
❑
❑
❑
Is the level of chlorine residual acceptable?
0
❑
❑
❑
Is the contact chamber free of growth, or sludge buildup?
0
❑
❑
❑
Is there chlorine residual prior to de -chlorination?
0
❑
❑
❑
Does the Stationary Source have more than 2500 lbs of Chlorine (CAS No. 7782-50-5)?
1:11
❑
0
❑
If yes, then is there a Risk Management Plan on site?
❑
❑
0
❑
If yes, then what is the EPA twelve digit ID Number? (1000- -____)
If yes, then when was the RMP last updated?
Comment:
Page# 5

Permit: NCO026921 Owner - Facility: Parkton VWVTP
Inspection Date: 08/16/2016 Inspection Type: Bioassay Compliance
Yes No NA NE
Is automatically activated standby power available?
M
❑
De -chlorination
Yes No NA NE
Type of system ?
Liquid
❑
❑
❑
Is the feed ratio proportional to chlorine amount (1 to 1)?
E
❑
❑
❑
Is storage appropriate for cylinders?
®
❑
❑
❑
# Is de -chlorination substance stored away from chlorine containers?
E
❑
❑
❑
Comment:
❑
❑
❑
Are the tablets the proper size and type? ❑ ❑ ® ❑
Are tablet de -chlorinators operational? ❑ ❑ ® ❑
Number of tubes in use?
Comment:
Standby Power
Yes No NA NE
Is automatically activated standby power available?
M
❑
❑
❑
Is the generator tested by interrupting primary power source?
M
❑
❑
❑
Is the generator tested under load?
■
❑
❑
❑
Was generator tested & operational during the inspection?
❑
❑
❑
M
Do the generator(s) have adequate capacity to operate the entire wastewater site?
®
❑
❑
❑
Is there an emergency agreement with a fuel vendor for extended run on back-up power?
❑
❑
❑
Is the generator fuel level monitored?
M
❑
❑
❑
Comment
Influent Sampling
Yes No NA NE
# Is composite sampling flow proportional?
❑
❑
®
❑
Is sample collected above side streams?
❑
❑
❑
Is proper volume collected?
M
❑
❑
❑
Is the tubing clean?
E
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
®
❑
❑
❑
Celsius)?
Is sampling performed according to the permit?
•®
❑
❑
❑
Comment:
Effluent Sampling Yes No NA NE
Is composite sampling flow proportional? ❑ ❑ ® ❑
Is sample collected below all treatment units? E ❑ ❑ ❑
Page# 6

Permit: NCO026921 Owner - Facility: Parkton WNlrP
Inspection Date: 08/16/2016 Inspection Type: Bioassay Compliance
Effluent Sampling
Yes No NA NE
Is proper volume collected?
®
❑
1-10
Is the tubing clean?
®
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
®
❑
❑
❑
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type ® ❑ ❑ ❑
representative)?
Comment:
Upstream/ Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, and ® ❑ ❑ ❑
sampling location)?
Comment:
Page# 7

Regional Inspectors' Checklist for Fle9d Parameters
Facility Name: Parkton WWTP
Regional Plant Inspector: Mark Brantley
NPDES #:
Regional Inspector Contact #: 910-433-3327
Field Lab Certification #:
Region: FRO
Lab Contact: Tim Little
Date:
I. Check the parameter(s) performed at this site for reporting purposes.
• Total Residual Chlorine (TRC) H Temperature (TEMP) E] Specific Conductivity (SC)
• pH Z Dissolved Oxygen (DO) El Settleable Residue (SETT)
General Laboratory (note anv exceptions in section XI)
Are instruments, meters, probes, photometric cells, etc. maintained in good condition?
Z
Yes El
No
Are standards, reagents and consumables used within manufacturer expiration dates?
[TRC gel standard is exempt.]
IN Yes Ll No
00 i*] OW6061411,46 W
V 10 IJ 00
'A
Date of sample collection*
Time of sample collection*
Y/
Z Yes
❑ No
What is the assigned/observed value of the daily check standard?
Sample collector's initials or signature
V
Is a 5 -point calibration verification performed? Note date of last verification: 8-8-2016
Z Yes
El No
Date of sample analysis*
V11
Ll No
True values: Z pg/L 0 mg/L 10 35 50 200 400
Time of sample analysis*
V/
What program are samples analyzed on?
Analyst initials or signature
V
V/
V11
✓
Sample location
V/
V
V,
✓
*Date and time of sample collection and analysis may be the same for in situ or on-site measurements.
Total Residual Chlorine meter make and model:
Hach DR2800
Is a check standard analyzed each day of use? (Circle one: gel or liquid standard) gel
Z Yes
❑ No
What is the assigned/observed value of the daily check standard?
Is a 5 -point calibration verification performed? Note date of last verification: 8-8-2016
Z Yes
El No
Alternatively, does the lab construct a linear regression, using 5 standards, to calculate
results? Note date of last calibration curve constructed:
Z Yes
Ll No
True values: Z pg/L 0 mg/L 10 35 50 200 400
Obtained values: Z pg/L 0 mg/L _9 32 - _47— = 194 423�_
What program are samples analyzed on?
Are results reported in proper units? Check one: X pg/L E] mg/L
Are results reported between the facility's permit limit and the compliance limit of 50 pg/L?
If value is less than the low standard, report as "<x", where x=low standard conc.
Yes
Z Yes
❑ No
E] No
Are samples analyzed within 15 minutes of collection?
Z Yes
❑
No
-N`
pH meter make and model:
Eco sense pH
10A
Is the pH meter calibrated with at least 2 buffers per mfg's instructions each day of use?
Note buffers used: 4, 7, 10
Z Yes
❑ No
Is the pH meter calibration checked with an additional buffer each day of 'use? Note check
buffer used: 7
Z Yes
❑ No
Does the check buffer read within ±0.1 S.U. of the known value?
Z Yes
El No
Are the following items documented:
Meter calibration?
Z Yes
❑ No
Check buffer reading?
Z Yes
❑ No
Are samples analyzed within 15 minutes of collection?
Z Yes
El No
Are sample results reported to 0.1 pH units?
Z Yes
0 No

XI. Additional comments:
A follow up visit be the Certification Section was recommended just to be sure all procedures are up to date.
Please submit a copy of this completed form to the Laboratory Certification program at:
DWQ Lab Certification, Chemistry Lab, Courier# 52-01-01
Electronic copies may be emailed to linda.chavisCc_Mcdenr..gov.
Revision 04/20/2012
What instrument(s) is used to measure temperature? Check all that apply: El pH meter
E DO meter D Conductivity meter E] Digital thermometer E] Glass thermometer
Is the instrument/thermometer calibration checked at least annually against a NIST
traceable or NIST certified thermometer?
Z Yes E] No
Are temperature corrections (even if zero) posted on the instrument/thermometer?
Z
Yes ❑ No
Are samples measured in situ or on-site? [REQUIRED - there is no holding time for
-temperature]
Z Yes ❑ No
Are sample results reported in degrees C?
Z Yes
0 No
DO meter make and model:
YSI model 55
Is the air calibration of the DO meter performed each day of use?
Z Yes E] No
Are the following items documented:
Meter calibration?
Z Yes El No
Are samples analyzed within 15 minutes of collection?
Z Yes El No
Are results reported in mg/L?
Z Yes [:1 No
_V
Conductivity meter make and model:
-is the meter calibrated daily according to the man'ufacturer's instructions? Note standard
used (this is generally a one -point calibration):
Is a daily check standard analyzed? Note value:
Are the following items documented:
Meter calibration?
Are samples analyzed within 28 days of collection?
Are results reported in pmhos/cm some meters display equivalent pS/cm units)?
-A,
Does the laboratory have an Imhoff Cone in good condition?
Is the sample settled for I hour?
Is the sample agitated after 45 minutes?
-
-
Are the following items documented:
Volume of sample analyzed? Note volume analyzed:
-
Date and time of sample analysis (settling start time)?
-
Time of agitation after 45 minutes of settling?
Sample analysis completion (settling end time)?
Are samples analyzed within 48 hours of collection?
Are results reported in ml/L?_
- -1 ",
P-000 IF ti "D _M
-V
_. M
"X
XI. Additional comments:
A follow up visit be the Certification Section was recommended just to be sure all procedures are up to date.
Please submit a copy of this completed form to the Laboratory Certification program at:
DWQ Lab Certification, Chemistry Lab, Courier# 52-01-01
Electronic copies may be emailed to linda.chavisCc_Mcdenr..gov.
Revision 04/20/2012