NC0020354_NOV CEI_19980326

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NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
March 26, 1998
CERTIFIED MAIL
RETURN RECEIPT REOUESTED
Mr. Walter Harris, Town Manager
Town of Pittsboro
P.O. Box 759
Pittsboro, NC 27312
RALEIGH REGIONAL OFFICE
Subject: Notice of Violation
Notice of Recommendation for Enforcement
Compliance Evaluation Inspection
Pittsboro WWTP
NPDES Permit No. NCO020354
Chatham County
Dear Mr. Harris:
The subject inspection was performed March 12, 1998 by Ted Cashion of my
staff. The cooperation of John Poteat, Grade IV ORC, was appreciated. Findings
during the inspection were as follows:
1. A review of self monitoring discharge monitoring report (DMR) data
submitted from January through December 1997 showed the following permit
violations as noted on Attachment A. Please include explanations on actions taken to
prevent future violations. North Carolina General Statutes allow civil penalties of up
to $10,000 be assessed per violation.
2. Sludge from the WWTP is disposed of via permit number WQ0000506 issued to
Wallace Woodall.
3. John Poteat is the Grade IV ORC; Wally Jenkins is the Grade II backup ORC.
4. The NPDES permit will expire February 28, 2001. You are reminded to submit a
request to renew the permit at least 180 days prior to the expiration of the permit.
5. A cursory check of DMR data and laboratory results for September 1997 showed
consistent reporting of results. It was discussed with Mr. Poteat during th_ n
that all values must be reported on the DMR as they appear on the labor
(ex. <1 results must be reported on the DMR as <1, not 1). Please ensure this
practice is complied with. �; . ti
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6. A check of the pH and D.O. meter records showed that docuM%*n of
3600 BARRETT DRIVE, SUITE 101, RALEIGH, NORTH CA�lO�IN^ 27609
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Mr. Harris
Page 2
calibration appears to be satisfactory. The pH buffer containers (4.0, 7.0, 10.0) did not have an
expiration date on the container. Mr. Poteat was instructed to contact Hach, the supplier, and
obtain the expiration date based on the lot numbers. If the buffers have expired please obtain new
unexpired buffer solutions. Please notify this office of the expiration dates.
7. Temperatures of the influent and effluent samplers are not recorded. Temperatures must be
recorded each day samples are collected to document proper sampling techniques are complied
with. Please commence recording of each sampler temperature daily, ensuring that the
temperatures are maintained between 0 and 4 degrees C, without freezing, as required.
8. Environment I commercial laboratory performs all laboratory analyses for the Town, except
for the on-site parameters.
9. Chain of custody forms must be fully completed showing sample collection times for each
parameter. Currently, sample collection times are not recorded on the form. As discussed with
Mr. Poteat, please ensure proper completion of the forms.
10. Mr. Poteat stated that effluent composite samples are collected on a time basis. Please
implement composite sample collection flow proportionally as described in Part II Section A. 8. of
the permit as soon as possible. Influent composite sampling may be performed based on time,
with samples collected at intervals no greater than 20 minutes, and at least 100 ml collected each
sample event.
11. High influent values for BOD and TSS were noted on September 16, July 10, and June 3.
These high concentrations may affect the treatment efficiency, and contribute to permit violations.
It is recommended that the Town investigate potential sources that may be
contributing/responsible for this loading on the plant. Mr. Poteat stated that the Town has a
grease trap inspection program, but that it is not fully implemented due to staff constraints. The
Town is encouraged to implement this program to prevent potential upsets and maximize
efficiency of the treatment plant.
12. Several days were noted on the DMR where the ORC was not on-site. Division regulations
require this facility to be visited by the ORC daily (Monday -Friday, excluding holidays). Mr.
Poteat stated that when he is not on-site, Mr. Jenkins, the backup ORC, visits the plant. When this
occurs, please indicate this by recording a `B" in the ORC on-site? box on the DMR.
13. The treatment plant units consist of a manual bar screen, automatic bar screen, influent pump
station (3 pumps), 2 aeration basins, 2 clarifiers, 3 tertiary filters, sludge thickener (polymer is
added to aid thickening), 2 aerobic sludge digesters, UV disinfection, ultrasonic flow meter, and
step aeration. One clarifier was being taken out of service due to damage. Pin floc was observed
discharging over the clarifier weir, possibly due to the other clarifier out of service.

Mr. Harris
Page 3
14. The effluent appeared clear and free of excess solids.
15. One sludge digester was full, and the other digester had approximately 2 feet of freeboard.
Efforts must be made as soon as possible to remove sludge or the Town must consider
constructing additional sludge storage capacity.
16. Mr. Poteat stated that a new UV system was installed mid February 1998, and that this
should prevent additional fecal coliform violations. The last inspection report dated February 7,
1997 stated that the UV needed to be replaced. Several DMRs , as far back as January 1997, also
included comments that UV system failure caused fecal violations. Please explain in detail the
delay in installing adequate disinfection equipment, and what efforts the Town took in the interim
period to comply with fecal coliform permit limits.
17. Please provide this office an update on the Town's efforts to reduce inflow and infiltration
(I/1) to the collection system. Include in your response resources expended in 1997, areas where
I/1 work occurred in the Town, estimated volume of UI removed, etc. Also include a schedule of
I/1 activities to be performed during 1998. In the last inspection report dated February 7, 1997,
the Town was instructed to provide this office with an 1/I progress report for the work completed
in 1996 and work planned for 1997. Our files do not contain a copy of this information. Please
submit a copy of this report. Several DMR comments include that permit violations occurred due
to inflow to the plant, thus reducing I/1, by the Town's own admission, will prevent permit
violations.
18. The compliance status for the plant was checked as compliant on the January 1997 DMR,
however, the facility was noncompliant with fecal coliform limits. Please ensure that the Town is
aware of any permit violations (weekly, daily, or monthly limits and/or monitoring requirements)
that occur during a month, that the appropriate compliance status is noted on the back of the
DMR, and provide an explanation on corrective actions taken in respect to equipment, operation,
maintenance, etc., and a time table for improvements to be made when noncompliant.
19. Mr. Poteat stated that the sewer line near the WWTP that experienced the release of
approximately 10,000 gallons on or about December 31, 1997 may be damaged. Please have this
line evaluated and repair/replace as necessary. Please inform this office of the status of this
investigation.
20. The 3 lift stations that serve the Town were inspected. There was no evidence of overflow at
any station. The Northwoods High School lift station test alarm did not operate. Please have this
repaired as soon as possible. Generators at the Northwoods High School and Townsends were
operational. There is no generator at the Pittsboro Christian Village lift station. We recommend
that the Town consider placing a generator at this location. Mr. Poteat stated the Town does not
have access to this lift station (fenced with locked gate). Efforts must be made to have access to
this station. None of the lift stations have a telemetry system. We recommend the Town consider

Mr. Harris
Page 4
installing telemetry at each location for early warning of failures. Mr. Poteat also stated that the
lift stations are checked 3 times per week. We recommend that lift stations be checked on a daily
basis.
21. Mr. Poteat stated the flow meter was calibrated August 20, 1997, which complies with
Division requirements of annual calibration.
22. Mr. Poteat stated that the Town is beginning to implement a pretreatment program due to
Hydro Tube, a metal finisher, with average flow of approximately 500 gpd of process water.
There are no other significant industrial users in the Town.
Please respond in writing by April 13, 1998 to items 1, 6, 7, 9, 10, 11, 16, 17, 19, and 20
detailing actions the Town will take/has taken to address these items. Due to the volume and
magnitude of the permit violations noted, this office may recommend to the Director of the
Division that an enforcement action be prepared against the Town of Pittsboro. Your response to
the above items, and any other information you wish to include in your response, will be presented
to the Director for his consideration in any action taken.
The Division's Technical Assistance and Certification Unit is available upon written
request to offer consultation on the operation and maintenance of the plant at no cost to the
Town. Please contact Bo McMinn at 919-733-0026 regarding this service.
If you have any questions concerning this notification please contact Mr. Cashion at 919-
571-4700 ext. 250.
Sincerel
Kenneth chuster, P.E.
Regional Supervisor
cc: Melinda Greene, EPA
Chatham Co. Health Dept.
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CEN-rRA ' FILES

ATTACHMENT A
Page 1 of 2
Monthly Average
Violations:
Parameter
Date
Result
Permit Limit
Fecal coliform
9701
837/100 ml
200/100 ml
Fecal coliform
9702
23,710/100 ml
200/100 ml
BOD
9702
15.6 mg/1
10 mg/l
NH3
9702
5.29 mg/1
2.3 mg/l
BOD
9703
13 mg/l
10 mg/1
N113
9703
6.98 mg/l
2.3 mg/1
Fecal coliform
9703
1539/100 ml
200/100 ml
BOD
9704
6.5 mg/1
5.0 mg/l
BOD
9705
6.4 mg/1
5.0 mg/l
NH3
9705
4.62 mg/l
1.0 mg/l
Fecal coliform
9705
3769/100 ml
200/100 ml
Fecal coliform
9706
247/100 ml
200/100 ml
Fecal coliform
9707
1020/100 ml
200/100 ml
Fecal coliform
9708
506/100 ml
200/100 ml
Fecal coliform
9710
457/100 ml
200/100 ml
Fecal coliform
9711
514/100 ml
200/100 ml
Weekly Average
Violations:
Week of
Result
Permit Limit
Parameter
Fecal coliform
971123
1292/100 ml
400/100 ml
Fecal coliform
971109
574/100 ml
400/100 ml
Fecal coliform
971102
1030/100 ml
400/100 ml
Fecal coliform
971026
441/100 ml
400/100 ml
Fecal coliform
971019
1172/100 ml
400/100 ml
Fecal coliform
971012
408/100 ml
400/100 ml
Fecal coliform
971005
1048/100 ml
400/100 ml
Fecal coliform
970803
2447/100 ml
400/100 ml
Fecal coliform
970810
681/100 ml
400/100 ml
Fecal coliform
970629
2165/100 ml
400/100 ml
Fecal coliform
970706
2829/100 ml
400/100 ml
Fecal coliform
970713
439/100 ml
400/100 ml
Fecal coliform
970720
538/100 ml
400/100 ml
Fecal coliform
970727
657/100 ml
400/100 ml
Fecal coliform
970601
795/100 ml
400/100 ml
Fecal coliform
970622
725/100 ml
400/100 ml
BOD
970518
13.6 mg/l
7.5 mg/l
Fecal coliform
970518
600,000/100 ml
400/100 ml
Fecal coliform
970511
7421/100 ml
400/100 ml
Fecal coliform
970525
426/100 ml
400/100 ml
BOD
970323
23 mg/l
15 mg/l
Fecal coliform
970316
6419/100 ml
400/100 ml

Effluent Monitoring Violations
Effluent temperature is required to be monitored daily; appears to have been monitored 3/week
for most months.
ATTACHMENT A
# of Values
# of
Date
Page 2 of 2
Required
Fecal coliform
970323
110,086/100 ml
400/100 ml
BOD
970209
18.6 mg/1
15 mg/1
BOD
970223
16.3 mg/l
15 mg/1
Fecal coliform
970202
82,578/100 ml
400/100 ml
Fecal coliform
970209
75,595/100 ml
400/100 ml
Fecal coliform
970216
8145/100 ml
400/100 ml
Fecal coliform
970223
6214/100 ml
400/100 ml
Effluent Monitoring Violations
Effluent temperature is required to be monitored daily; appears to have been monitored 3/week
for most months.
# of Values
# of Values
# of
Date
Parameter
Required
Reported
Violations
Week of August 31
NH3
3/week
2
1
Week of July 27
BOD
3/week
2
1
cc 11
TSS
3/week
2
1
°L "
NH3
3/week
2
1
°C
Fecal
3/week
2
1
Week of Feb. 9
D.O.
3/week
2
1
Stream Monitoring
Violations
# of Values
# of Values
# of
Date
Parameter
Required
Reported
Violations
UL)slream
Week of June 1
D.O.
3/week
1
2
66 "
Fecal
3/week
1
2
6° "
Temp.
3/week
1
2
°° 17
Cond.
3/week
1
2
Downstream
Week of June 1
D.O.
3/week
1
2
t° "
Fecal
3/week
1
2
71
Temp.
3/week
1
2
77Cond.
3/week
1
2
Influent Monitoring
Violations
Week of Feb. 2
BOD
3/week
2
1
Week of Feb. 2
TSS
3/week
2
1