WQ0001868_NOD-2018-PC-0323_20181129

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North Carolina Department of Environmental Quality  Division of Water Resources Quality  Raleigh Regional Office
1628 Mail Service Center  Raleigh, North Carolina 27699-1628
919.791.4200

November 30, 2018

George H. McGee, Mayor
Town of Severn
PO Box 401
Severn, NC 27877

Subject: Compliance Evaluation Inspection-Notice of Deficiency
NOD-2018-PC-0323
Town of Severn
Wastewater Irrigation System
Permit Number WQ0001868
Northampton County

Mayor McGee,
On November 20, 2018, Rick Trone of the Raleigh Regional Office conducted a compliance evaluation
inspection of the wastewater treatment and irrigation system serving the town of Severn. The purpose of
this inspection was to ensure compliance with the subject permit. During the inspection the cooperation
of M.E. Lassiter, Operator in Responsible Charge (ORC) and Troy Holloman, Back-up Operator in
Responsible Charge was helpful and appreciated.
This compliance evaluation inspection consisted of the following:
 Review of the permit and permit renewal documents;
 Review of the owner/facility information;
 Review of ORC logs, Non-discharge wastewater monitoring reports (NDMR), Non-discharge
application reports (NDAR), Groundwater quality monitoring report forms (GW-59) and;
 On-site inspection of treatment components

North Carolina Department of Environmental Quality  Division of Water Resources Quality  Raleigh Regional Office
1628 Mail Service Center  Raleigh, North Carolina 27699-1628
919.791.4200

The current permit was issued April 23, 2014 and expires February 28, 2019. Permit renewal documents
were received by this office on September 13, 2018.
NDMR and GW-59 documents from 2016-2018 were compared to lab bench sheets. The facility is
meeting all monitoring and reporting requirements including sampling for VOC’s every November in
monitoring wells. Documents related to monitoring wells and effluent were complete and available for
inspection. One transcription error for BOD was noted on the February 2018 NDMR (see below). The
facility frequently exceeds groundwater standards for Total Dissolved Solids.
NDAR forms were reviewed and are complete. NDAR 12-month totals are below limits specified in the
permit for all fields. Soil analyses are being conducted annually as required. ORC maintains a log of
lagoon freeboard levels and keeps track of other activities and maintenance at the facility. The facility has
not had a calibration performed on the effluent flowmeter (Badger Meter). This calibration should be
conducted as soon as possible to ensure accurate measurements (see below). The handheld pH meter is
calibrated daily, and proficiency test results were available indicating a passing score.
The system is as described in the permit. A lift station located in town houses a bar screen which is
cleaned twice per day. Signage near the treatment lagoon and spray fields was observed to be present. The
gate to the lagoon was open and should be kept locked to prevent unauthorized access (see below). Plenty
of freeboard was available in the lagoon which looked to be in satisfactory condition. The facility lacks a
residual management plan (see below). The ORC indicated no solids have been removed from the lagoon.
The spray fields need mowing and the ORC indicated this has not been completed due to recent wet
weather. The spray system was activated on fields 3 and 4. The spray pattern looked satisfactory and all
nozzles appeared to be working. No evidence of runoff or ponding was observed; however, this was
difficult to discern due to the thick vegetative cover.
At the time of the inspection, the wastewater treatment system appeared to be overall well maintained and
operational.
The following permit condition deficiencies were noted during the November 20, 2018 compliance
inspection and records review:
III. Operation and Maintenance Requirements
Condition 9, which states that, “Public access to the irrigation sites and wastewater treatment facilities
shall be prohibited…” The gate to the lagoon should be locked always. Please ensure a working lock is
present and that the gate is locked to prevent unauthorized access to the lagoon.
Condition 10, which states that, “the Permittee shall maintain a residual management plan…” The facility
does not currently have a residual management plan. The level of solids in the lagoon should be
determined and residuals should be properly removed and disposed of if necessary. The facility should
formulate a residual management plan as soon as possible.

North Carolina Department of Environmental Quality  Division of Water Resources Quality  Raleigh Regional Office
1628 Mail Service Center  Raleigh, North Carolina 27699-1628
919.791.4200

IV. MONITORING AND REPORTING REQUIREMENTS
Condition 3, which states that, “flow measurement devices selected shall be capable of measuring flows
with a minimum deviation of less than 10 percent from true, accurately calibrated at a minimum of once
per year….” During the site inspection, the ORC indicated that the flowmeter in the effluent pump house
has not been calibrated any time recently. Submit to this office documentation indicating a calibration has
been performed on the flow meter. Please ensure that calibration records are maintained at the facility for
inspection.
Condition 4, which states that, “The Permittee shall monitor the effluent from the subject facilities at the
frequencies and locations for the parameters specified in Attachment A...” A transcription error was noted
on the February 2018 NDMR for BOD. BOD was reported as 2.03 mg/L however, lab records received
from Environment 1 reported the result as 203 mg/L. Please submit an amended NDMR to correct this
error.
This office requests that you respond to this letter in writing within 30 days of receipt. Your
response should be sent to this office at the letterhead address. Your response should address the
following items as noted above. Please include in your response all corrective actions already taken and a
schedule for completion of any corrective actions not addressed.
If you have any questions about this inspection or this letter, please contact Rick Trone at
[e-mail] or 919-791-4257.
Sincerely,

Rick Bolich, L.G.
Assistant Regional Supervisor
Water Quality Regional Operations
Raleigh Regional Office

Attachments: EPA Water Compliance Inspection Report

cc:
Central Files
RRO Files