WQ0006941_NOV-2021-PC-0145_20210222

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
February 22, 2021
CERTIFIED MAIL No, 7018 1130 0000 1608 2262
RETURN RECIPET REQUESTED
Jerry Hatchett, Maintenance Director
Caswell County Schools
P.O. Box 160
Yanceyville, North Carolina 27379
SUBJECT: Notice of Violation (NOV-2021-PC-0145)
Permit No. WQ0006941
Stoney Creek Elementary School, Wastewater Irrigation System
Caswell County
Dear Mr. Hatchett:
On February 15, 2021 Division of Water Resources staff person Caitlin Caudle
performed a scheduled announced compliance inspection. Glenn Price, ORC, was
present during the entire inspection. A review of records, treatment facilities, and
irrigation fields was completed. The facility was found the be noncompliant with the
subject permit. The following violations were noted:
A. Per Permit Condition 111.1 "the Permittee shall maintain an Operation and
Maintenance Plan, which at a minimum shall include operational functions,
maintenance schedules, safety measures, and a spill response plan." At the time
of inspection, an Operation and Maintenance Plan and Spill Response Plan were
not on site and available for review. This has previously been noted in an
inspection dated May 26, 2016. Ms. Caudle requested that Mr. Price send
electronic copies of the Operation and Maintenance Plan and Spill Response
Plan. Please review the subject permit for what documents are required to
be kept on site. Moving forward, please keep a copy of the Operation and
Maintenance Plan and Spill Plan on site and ensure all emergency contact
information is correct.
B. Per Permit Condition 111.3 "a suitable year round vegetative cover shall be
maintained at all times, such that crop health is optimized, allows for even
distribution of effluent and allows inspection of the irrigation system." At the time
of inspection there were at least two sprinkler heads with saplings growing
directly beside them. The saplings were as tall or taller than the sprinkler heads.
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NOR! H CAHOI INA
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105
336.776.9800
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These saplings can prevent even distribution of effluent during the Spring and
Summer as the leaves on the saplings will disrupt the effluent spray from the
sprinkler head. This can cause effluent to concentrate in one area resulting in
ponding, or runoff depending on the slope or the irrigation field. Please remove
these saplings as soon as possible, and take steps to prevent the saplings
from regrowing.
At the time of inspection multiple trees and branches had fallen around the
sprinkler heads, and in the wettable area of the sprinkler heads. These downed
trees and branches will prevent even distribution of effluent during irrigation
events. As mentioned above, this can cause ponding or runoff from the irrigation
field when effluent is concentrated in one area. The Division understands that
these downed trees and branches are recent occurrences resulting from
inclement weather the past weekend. Please remove these trees and
branches from the wettable area of the irrigation field as soon as possible.
Once trees and branches are removed, inspect the irrigation field and
equipment to ensure no further repairs are needed.
C. Per Permit Condition 111.9 "Public access to the irrigation sites and wastewater
treatment facilities shall be prohibited." At the time of inspection, the gate for the
access road to the irrigation field was unusable, the gate to the irrigation field
was open and a lock was not present, and the fence surrounding the irrigation
field was in severe disrepair. Please place a lock on the gate of the irrigation
field, and keep the gate closed and locked when personnel are not at the
irrigation field. Please repair the fence surrounding the irrigation field as
soon as possible.
D. Per Permit Condition 111.14 "a protective vegetative cover shall be established
and maintained on all earthen embankments (i.e., outside of 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 grown on the earthen dikes or embankments. Earthen embankment areas
shall be mowed or otherwise controlled and accessible." At the time of
inspection, vegetation was waist high on the lagoon embankment and saplings
were growing on the embankment, particularly around the chlorinator and first
compartment of the lagoon. Please mow the lagoon embankments as soon as
possible, remove the saplings, and take steps to ensure there is no
regrowth of the saplings.
Several areas on the lagoon embankment had no vegetation present. When
possible, establish a suitable vegetative cover where none is present on
the lagoon embankment.

The plastic liner for the second compartment of the lagoon had multiple spots
where vegetation was growing on, or through, the liner. Please remove this
vegetation and make the necessary repairs to the lagoon liner as needed.
E. Per Permit Condition V.1 "the Permittee shall provide adequate inspection and
maintenance to ensure proper operation of the wastewater treatment and
irrigation facilities" and Permit Condition V.2 "the Permittee or their designee
shall inspect the wastewater treatment and irrigation facilities to prevent
malfunctions, facility deterioration and operator errors resulting in discharges,
which may cause the release of wastes to the environment, a threat to human
health or a public nuisance." At the time of inspection, a leak was present at a
valve leading to the irrigation field. Mr. Price was not aware of the leak until Ms.
Caudle pointed it out. Please repair the leak as soon as possible, and ensure
no further repairs are needed to the irrigation pump or associated piping.
Moving forward, please ensure that adequate inspections and maintenance
are performed to prevent malfunctions and further degradation of the
facility.
The following items of concern were noted:
1. Per Permit Condition 1.1 a permit renewal application using Division approved
forms must be submitted no later than six months prior to the expiration of the
current permit. To date, a permit application has not been submitted. Please
submit a permit renewal application as soon as possible.
2. Per Permit Condition 111.6 "all irrigation equipment shall be tested and calibrated
once per permit cycle." Mr. Price stated that the irrigation system has not been
calibrated for this permit cycle. Please calibrate the irrigation system before
the expiration of the current permit on August 31, 2021.
3. Per Permit Condition 111.10 "residuals generated from the wastewater treatment
facilities shall be disposed or utilized in accordance with 15A NCAC 02T .1100.
The Permittee shall maintain a residual management plan pursuant to 15A
NCAC 02T .0508" and Permit Condition IV.8 "a record shall be maintained of all
residuals removed from this facility. This record shall be maintained at the facility
for a period of no less than five years, and shall be available to the Division upon
request..." An 11,000 gallon septic tank is included in the permit description but
Mr. Price stated that the septic tank is not part of the wastewater treatment
stream, and no residuals have been removed from the system to his knowledge.
If the septic tank is no longer part of the wastewater treatment system,
please request to remove the septic tank from the permit description
during permit renewal. If the septic tank is still in use, please provide Ms.
Caudle of any residual removal records within fifteen (15) days of receipt of

this notice. Based on the information provided a residuals management
plan may need to be developed to address the residuals contained within
the wastewater system.
4. Per Permit Condition IV.11 the Permittee shall notify the Winston Salem
Regional Office of any non-compliance events. At the time of inspection, the
effluent level in the second compartment of the lagoon was approaching 2 feet.
Per Permit Condition 111.12 "freeboard in the 413,610 gallon two compartment
lagoon shall not be less than two feet at any time." If the freeboard level of the
lagoon is less than 2 feet at any time, please be sure to notify the Winston
Salem Regional Office within 24 hours or the next business day.
5. At the time of inspection, a copy of the subject permit was not available for
review. Mr. Price stated that a copy of the permit is kept in the school's office.
The school was closed during the inspection and the permit was not available.
Moving forward, please ensure a copy of the permit is available for review.
6. According to Mr. Price, Donald Kidney is the designated Back Up ORC. Division
hard files show that an ORC designation form was submitted October 23, 2018
designating Neal McDuffie as Back Up ORC. Division Electronic files show that
Donald Kidney is the designated Back Up ORC but his operating license is
invalid. Please provide clarification to the intended back up ORC and ORC,
or provide a complete operator designation form to designate the correct
operators.
Your immediate attention to the violations and concerns noted above is greatly
appreciated. This office requires that you provide a written response within thirty
(30) calendar days following receipt of this notice. Your response should include the
following: actions that were taken to remedy the violations and concerns, actions
proposed with a timeline for completion, and any proposed plants to prevent future
violations from occurring.
Please refer to the enclosed compliance inspection report for additional observations
and comments. A follow up inspection will be scheduled in 90-120 days. If you have any
questions regarding this notice, please contact Caitlin Caudle or me at the letterhead
address and/or phone number, or by email at [e-mail] or
[e-mail].
Sincerely,
DocuSigned by:
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145849E225C94EA...
Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ_WSRO

enc: Compliance inspection Report
Operator Designation Form
cc: Caswell County Environmental Health — electronic copy
Glenn Price — electronic copy ([e-mail])
WSRO Electronic Files
DWR Laserfiche File WQ0006941