WQ0001284_CEI & NOV-2019-PC-0696_20190821

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
NORTH CAROLINA
Environmental Quality
August 21, 2019
CERTIFIED MAIL 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 WQ0001284
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
DE Q✓A North Carolina Department or Environmental Quality ! Division of Water Resources
_ Raleigh Regional Office . 3800 Barrett Drive , Raleigh. North Carolina 27609
r 9193914200

1(
' �' in -good -condition and screenings are placed into a trash bin. The wet -well housing the weir and flow
sensor %yas in -good condition. The influent flowmeter was last calibrated October 2018 by ISL 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-59's 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:
III. 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

Ik
Condition 4, which states that, "The Pennittee 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 (GW-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.troncenedenr.gov or 919-7914200.
Sincerely,
Aicklich, L.G.
Assistant Regional Supervisor
Water Quality Regional Operations
Raleigh Regional Office
Attachments: EPA Water Compliance Inspection Report
cc:
Central Files
RRO Files

Compliance Inspection Report
Permit: W00001284 Effective: 04+1pl17 Expiration: C3131122 Owner: Town of Conway
SOC: Effective: Expiration! Facility: Town of Conway WWTF
County: Northampton 520 Phillips Hill Rd
Region: Raleigh
Conway NC 27620
Contact Person: W Thomas Barrett Title: Mayor Phone: [phone]
Directions to Facility:
Highway 158 to Conway. Left onto Hwy 35 (N Church t.). Right cn Ph hips Hill Rd. Gravel driveway to plant is on the left.
System Classifications: SI,
Primary ORC: Jeffrey Carl Long Certification_ 993136 Phone: [phone]
Secondary ORC(s):
On -Site Representative(s)!
Related Permits:
Inspection Date: 0812012019 Entry Time: 09:45AM
Primary Inspector: Rick V Trone
Secondary Inspector(s):
Reason for Inspection: Routine
Permit Inspection Type. Wastewater Irrigation
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Miscellaneous Questions Treatment
Treatment Lagoons End Use -Irrigation
Wells
(See attachment summary)
Exit Time: 11:45AM
Phone: [phone]
Inspection Type: Compliance Evaluation
Record Keeping
Treatment Disinfection
Page 1 of 6

Permit: WQ0001284 Owner - Facility: Town of Conway
Inspection Date: 08/20/2019 Inspection Type : Comphance Evaluation Reason for Visit: Routine
Inspection Summary:
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 ownerifacility 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 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 flowmeler 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-59's 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:
III. 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
Page 2 of 6

Permit: W00001284 Owner -Facility: Town of Conway
Inspection Date: 08/20/2019 Inspection Type: Compliance Evaluation Reason for Visit: Routine
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 lest 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 slates that, "Two copies of monitoring well sampling and analysis results shall be submitted on a
Compliance Monitoring Form (GW-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.
Page 3 of 6

Permit: WOOOD1284 Owner - Facility: Town of Conway
Inspection Date: 08120/2019 Inspection Type ; Compliance Evaluation
Reason for Visit: Routine
Type
Yes No NA NE
Infiltration System
Lagoon Spray, LR
11
Single Family Spray, LR
❑
Activated Sludge Spray, LR
0
Activated Sludge Spray, HR
Activated Sludge Drip, LR
❑
Recycle/Reuse
❑
Reuse (Quality)
Single Family Drip
Treatment
Yes No NA NE
Are Treatment facilities consistent with those outlined in the current permit?
Do all treatment units appear to be operational? (if no, note below.)
moon
Comment:
Treatment Disinfection
Yes No NA NE
Is the system working?
■
Do the fecal coliform results indicate proper disinfection?
0 m 0❑
Is there adequate detention time (-30 minutes)?
m 00
Is the system properly maintained?
11 m 00
If gas, does the cylinder storage appear safe?
0 0 .
is the fan in the chlorine feed room and storage area operable?
Is the chlorinator accessible?
0 0■ 11
If tablets, are tablets present?
Are the tablets the proper size and type?
Is contact chamber free of sludge, solids, and growth?
0 0 0O
If UV, are extra UV bulbs available?
0 ❑ No
If UV, is the UV intensity adequate?
0 ❑ No
# Is it a dual feed system?
❑ ❑ No
Does the Stationary Source have more than 2500 Ibs of Chlorine (CAS No. 7782-50-5)?
0 ❑ m D
If yes, then is there a Risk Management Plan on site?
❑ ❑ no
If yes, then what is the EPA twelve digit ID Number? (1000-=_)
If yes, then when was the RMP last updated?
Comment: Fecal numbers for facility effluent are very hi-gh.
The door to the room housing the hypochlorite was significantly damaged by rust and was
unsecured.
Page 4 of 6

Pennit: W00001284 Owner - Facility: Town of Conway
Inspection Date: 0812012019 Inspection Type: Compliance Evaluation Reason for Visit.
iCt a is
Record Keeping
Yes No NA NE
Is a copy of current permit available?
■ ❑ ❑ ❑
Are monitoring reports present: NDMR?
■ ❑ ❑ ❑
NDAR?
■ ❑ ❑
Are flow rates less than of permitted flow?
. ❑ 0 ❑
Are flow rates less than of permitted flow?
■ ❑ ❑ ❑
Are application rates adhered to?
■ ❑ ❑
Is GW monitoring being conducted, if required (GW-59s submitted)?
❑ ■ ❑ ❑
Are all samples analyzed for all required parameters?
❑ ■ ❑
Are there any 2L GW quality violations?
❑ ❑ .
Is GW-59A certification form completed for facility?
❑ ■ ❑ ❑
Is effluent sampled for same parameters as GW?
■ ❑ ❑ ❑
Do effluent concentrations exceed GW standards?
❑ ❑ ❑ ■
Are annual soil reports available?
. ❑ ❑ ❑
# Are PAN records required?
❑ ❑ ■ ❑
# Did last soil report indicate a need for lime?
❑ ❑ ■ ❑
If so, has it been applied?
❑ ❑ ■ ❑
Are operational logs present?
. ❑ 130
Are lab sheets available for review?
■ ❑ ❑ ❑
Do lab sheets support data reported on NDMR?
. ❑ ❑ ❑
Do lab sheets support data reported on GW-59s?
❑ ■ ❑ ❑
Are Operational and Maintenance records present?
■ ❑ ❑ ❑
Were Operational and Ma.nlenance records complete?
■ ❑ ❑ ❑
Has perm ttee been free of public complaints in fast 12 months?
■ Cl ❑ ❑
Is a copy of the SOC read_ly available?
❑ ❑ ■ ❑
No treatment units bypassed since last inspection?
❑ ❑ ■ ❑
Comment., 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 re wired. 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 re orted.
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.
Additionally, the current Permit requires wells to be sampled for Total Phosohorous (TP). The
facility is currently not having the wells salInDled for this parameter.
End Use-Irrfvation
Are buffers adequate?
Is the cover crop type specified in permit?
Is the crop cover acceptable?
Yes No NA NE
■❑❑❑
❑❑■❑
■❑❑❑
Page 5 of 6

permit: W00001284 Owner . Facility Town of Conway
Inspection Date: 0812012019 Inspection Type _ Compl ante Evaluation Reason for Visit: Routine
Is the site condition adequate? N ❑ ❑ ❑
Is the site free of runoff ? ponding? 0 C] ❑ ❑
Is the acreage specified 'n the permit being utilized? 0 ❑
Is the application equipment present? M 0 0
Is the application equipment operational? C1 M 0 ❑
Is the disposal field free of iimittng slopes?
Is access restricted and2or signs posted during active site use? 0
Are any supply wells within the CB? ■
Are any supply wells wit�lin 250' of the CB? ❑ ❑ ❑ 0
Flow close Is the closest water supply well? ED 1:1 ❑ ■
Is municipal water available n the area? 0 ❑ El M
# Wo only: Does the permit call for monitoring wells? M ❑
Are GW monitoring wells located properly wl respect to RB and CB?
Are GW monitoring wells properly constructed, including screened interval? 0 0 1:1
Are monitor.ng wells damaged? ❑ ❑ ❑
Comment: Overall, the spray heads apoeared to be in good condition, and a portion of the spray system
Field C was activated and ai3peared to overall have good spray atterns and coverage. One
spray head was observed to be inoperative, and another was not turnino^
Page 6 of 6