NC0021865_NOV-2019-PC-0407 Response_20190606

Town Of Chadbourn
"The Stra nbeiv�� Capita/"
602 NORTH BROWN STREET•CHADBOURN, NORTH CAROLINA 23�31
TELEPHONE: [phone]
June 3, 2019
NC DEQ/DWR
Wilmington Regional Office
127 Cardinal Drive Extension
Wilmington, NC 28405
Subject: NOV Response
N O V-2019-P C-0407
Chadbourn WWTP
NPDES #NC0021865
Columbus County
Dear Ms. Sanchez -King,
The Town is in receipt of your NOV &Intent to Assess Civil Penalty dated May 17, 2019. The Town
received the letter on May 22, 2019. We request that no civil penalties be assessed for these violations
and offer the following comments:
• Recordkeeping —There were two separate violations related to recordkeeping. The Town has
experienced recurring turnover in the WWTP operator/ORC position in the past year as well as
the Town Manager's position. Each new operator at the plant had different methods of
maintaining records. In addition, in cleaning the office, files were often moved or stored in a
way they cannot be easily identified or located. The Town has dedicated a staff member to be
the permanent WWTP operator.
• Record kee ping/TRC meter annual calibration curve — A file search found no TRC calibration
curve. The WWTP staff that would have been responsible for producing the curve is no longer
with the Town and we have no way to know if the curves were done. The current ORC will have
the TRC meter calibration curve done within the next two weeks.
• Record keeping/Annual Wastewater Report — A file search at Town Hall produced the
Wastewater Annual Reports for the years: 2014, 2016, and 2017. An affidavit of publication
from The News Reporter was found to indicate that the annual report for 2017 was available at
Town Hall. While we feel the annual report was also done in 2015, we have not been able to
locate documentation at this time. There were also cover letters with some of the annual
reports that seem to indicate that the reports were mailed to the Wilmington Regional Office.
The 2018 annual wastewater report will be completed shortly.

• Flow Measurement/Effluent — The Town feels that this NOV is in contradiction of the regulation
concerning continuous flow measurement. The definition of continuous flow measurement in
the NPDES permit states "flow monitoring that occurs without interruption throughout the
operation hours of the facility. Flow shall be monitored continually except for the infrequent
times ... The flow meter at the WWTP does operate without interruption and the flow is
displayed both as an MGD reading and in a totalizer. The flow is recorded each day. If needed,
the totalizer reading will also be recorded daily. In looking at the monitoring regulations,
Section15A NCAC 02B .0505 MONITORING REQUIREMENTS states "All water pollution control
facilities shall install, operate, and maintain continuous flow measuring with recording devices
or totalizing devices ... This language reinforces the permit definition that a flow meter must
operate continuously and that a totalizer is acceptable as a recording device.
• Additional items that were asked to be addressed:
o Aeration Basin leak —One half the width of the aeration basin has been uncovered in an
attempt to locate the possible leak. The water from the leak is being captured and
contained and pumped back to aeration basin. The water is so clear; we were having
second thoughts as to its source. The water tested positive for chlorine residual and a
pH comparison with the mixed liquor showed that pH to be different. This week, we will
have a fecal coliform analysis done on the leakage. The Town will continue to pursue
the source of the water and take the necessary steps to correct.
o Sampler Temperature —The WWTP staff will record the sampler temperature.
We thank you for your consideration in this matter. We would also like to offer our thanks for
acknowledging the improvements in plant operations following the recent construction/startup and
hurricane impacts.
Sincerely,
John Bauer, Town Manager
Town of Chadbourn