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Home My WebLink AboutWQ0001284_NOV-2019-PC-0596_20190821 ROY COOPER Governor MICHAELS.REGAN Secretary 0 LINDA CULPEPPER NORTH CAROLINA Director Environmental Quality August 21, 2019 CERTIFIED MALL 7016 3560 0000 4428 5263 RETURN RECEIPT REQUESTED W.T.Barrett Jr., Mayor Town of Conway PO BOX 365 Conway,NC 27820 Subject: NOTICE OF VIOLATION NOV-2019-PC-0596 Compliance Evaluation Inspection Town of Conway Wastewater Irrigation System Permit Number W00001284 Northampton County Mayor Barrett, On August 20,2019, Rick Trone of the Raleigh Regional Office conducted a compliance evaluation inspection of the wastewater irrigation system for Town of Conway. The purpose of this inspection was to ensure compliance with the subject permit. During the inspection,the cooperation and assistance of Mr. Jeffrey Long,ORC,and Mr. Roger Coffield, Public Works Supervisor was helpful and appreciated. This compliance evaluation inspection consisted of the following: • Review of the permit; • Review of the owner/facility information; • Review of ORC logbooks,calibration documentation,Non-discharge wastewater monitoring reports(NDMR),Non-discharge application reports(NDAR),Compliance Monitoring Forms (GW-59)and; • On-site inspection of treatment components and spray fields The current permit was issued April 10, 2017 and expires on March 31,2022.Currently, Mr. Long is designated ORC with Mr.Johnny Young as backup ORC. Components of the wastewater system appeared to be overall well-maintained and operational. Water in the lagoon was free of floating solids and plenty of freeboard was available. The lagoon is fenced in and secured with a gate. The screen that prevents debris from entering the spray system form the lagoon was North Carolina Department of Environmental Quality I Division of Water Resources Raleigh Regional Office 1 3800 Barrett Drive I Raleigh.North Carolina 27609 �� W w 919.791.4200 in good condition and screenings are placed into a trash bin. The wet-well housing the weir and flow sensor was in good condition. The influent flowmeter was last calibrated October 2018 by ISI. The irrigation fields appeared to be in good condition with no evidence of ponding or runoff.Fields are a mixture of trees and grass which varies across all fields. Grass is kept mowed. The last representative soil analyses were conducted in April 2019 and recommended no lime be applied.A soil analyses was not completed in 2018.Please be sure this requirement is performed annually. Overall,the spray heads appeared to be in good condition,and a portion of the spray system(Field C)was activated and appeared to overall have good spray patterns and coverage. One spray head was observed to be inoperative, and another was not turning. The chlorination equipment appeared to be in good condition.At the time of the inspection,the facility had plenty of liquid hypochlorite available. The door to the room housing the hypochlorite was significantly damaged by rust and was unsecured. This door should be replaced as soon as possible,and the room secured against unauthorized entry(see violation below). NDMR records for 2018-2019 were reviewed. The facility is monitoring the effluent as required but is failing to report some parameters on NDMR's.The town has not reported values for Chlorides as required.Reviewing the Towns lab paperwork from the contract lab(Environment 1), it was observed that the Town is having the lab test for Chlorides,but it is unclear why these values have not been reported.Please ensure all required parameters are reported. Several random months of lab results were compared to NDMR forms and the ORC failed to sign the forms for some months(see violation below). The Town is utilizing outdated NDMR forms and the inspector requested the DWR Central Office send the facility up-to-date forms. Monitoring wells 1 and 4 were observed and appeared to be in good condition. Monitoring well 1 was unlocked but is of a design that requires a tool to remove the cap. Monitoring well 4 was locked. GW-59 reports for 2018-2019 have not been received by this office. A review of lab results indicates the facility is having the wells sampled as required.Please ensure GW-591s are submitted as required with certification forms and lab results included.Additionally,the current permit requires wells to be sampled for Total Phosphorous(TP). The facility is currently not having the wells sampled for this parameter.Please ensure well samples are analyzed for TP.(see below). NDAR forms for 2018-2019 were reviewed. 12-month floating totals for spray fields have not been reported for June 2019. 12-month floating totals=Sum of this month's monthly loading and previous 11 month's monthly loading.Please ensure 12-month floating totals are included on every NDAR submitted. The following permit condition violations were noted during the August 20,2019 compliance inspection and records review: in.Operation and Maintenance Requirements Condition 1,which states that, "The facilities shall be properly maintained and operated at all times."The door to the room housing the hypochlorite was significantly damaged by rust and was unsecured. This door should be replaced as soon as possible,and the room secured against unauthorized entry. IV.Monitoring and Reporting Requirements Condition 4.which states that, "The Permittee shall monitor effluent from the subject facilities at the frequencies and locations for the parameters specified in Attachment A."The facility is monitoring the effluent as required but is failing to report some parameters on NDMR's. The town has not reported values for Chlorides as required. Reviewing the Towns lab paperwork from the contract lab, it was observed that the Town is having the lab test for Chlorides,but it is unclear why these values have not been reported.The ORC failed to sign form NDMR for some months.Please ensure all required parameters are reported and forms are signed as required by the ORC and the Permittee. Once the facility receives up-to-date forms,these forms should be utilized. Condition 11 which states that,"Two copies of monitoring well sampling and analysis results shall be submitted on a Compliance Monitoring Form(G W-59)along with attached copies of laboratory analyses.....and one GW-59a certification form shall be submitted with each set of sampling results." This office has not received GW-59 reports for 2018-2019. The current permit requires wells to be sampled for Total Phosphorous(TP).The facility is currently not having the wells sampled for this parameter.Please ensure monitoring well sampling documentation submitted to DWR includes form GW-59,laboratory analyses,and the GW-59a Certification Form.Please send these documents for well sampling events from 2018-2019. Please ensure well samples are analyzed for TP. 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 deficiencies and other identified issues, if applicable. Please include in your response all corrective actions already taken and a schedule for completion of any corrective actions not addressed. Failure to comply with conditions in a permit may result in a recommendation of enforcement action, to the Director of the Division of Water Resources who may issue a civil penalty assessment of not more that twenty-five thousand ($25,000) dollars against any "person" who violates or fails to act in accordance with the terms, conditions, or requirements of a permit under authority of G.S. 143- 215.6A. If you have any questions about this inspection or this letter, please contact Rick Trone at rick.trone(a ncdenr.gov or 919-7914200. Sincer ly, 1ck G. Assistant Regional Supervisor Water Quality Regional Operations Raleigh Regional Office Attachments: EPA Water Compliance Inspection Report cc: Central Files RRO Files