WQ0003299_NOV-2022-PC-0574_Response Received_20221102

NC Dept of Environmental Quality
CS
P. O. BOX 327 • SEABOARD, NC 27876
NOV 2 2022
Raleigh Regional Office
Ph: [phone] • Fax: [phone]
October 25, 2022
Ms. Vanessa Manuel, Assistant Regional Supervisor
Division of Water Resources, Raleigh Regional Office
3800 Barrett Drive
1628 Mail Service Center
Raleigh, NC 27699
SUBJECT: Response to NOV Letter dated September 27, 2022
NOV No. NOV-2022-PC-0574
Wastewater Surface Irrigation System
Permit Number: WQ0003299
Town of Seaboard
Northampton County, NC
Dear Ms. Manuel:
Comment items 1 through 5 in subject letter are repeated below followed by responses:
I. The 7.425-million-gallon storage lagoon continues to experience multiple large bubbles
in the liner resulting in a significant reduction in storage capacity. Permit condition II.
1. states that "The Permittee shall maintain and operate the subject non -discharge
facilities so there is no discharge to surface waters, nor any contravention of
groundwater or surface water standards. In the event the facilities fail to perform:
satisfactorily, including the creation of nuisance conditions due to improper operation
and maintenance, or failure of the irrigation areas to assimilate the effluent, the
Permittee shall take immediate corrective actions, including Division required actions,
such as the construction of additional or replacement wastewater treatment or disposal
facilities. 115A NCAC 02T .0108 (b) (I) (Ay."
Response: The Town is aware of the issue with the large bubbles in the liner in the Effluent
Storage Structure. Previous bids for the replacement of the liner system exceeded the Town's
financial ability to fund the improvements. The Town made application in the recent DWI
September application cycle for funding to address the upgrade of WWTP assets. The additional
funding requested in addition to funding previously received is anticipated to provide the funding

necessary to replace the existing Effluent Storage Structure with a new structure with the_same
capacity. Completion of this work is anticipated to require two to three years.
2. Monitoring wells 6, 7, and 8 (MW-6, MW-7, MW-8) appeared to be well maintained. The
concrete cap at the base of monitoring well 9 (MW-9) is undermined and may be
allowing surface flow to enter the water table. The vault lid hinge for monitoring well 10
(MW-10) is broken, there is no seal/plug in the pvc well pipe, and no lock was present on
the vault at the time of this inspection. Permit condition IL 3. states "Groundwater
monitoring wells shall be constructed in accordance with 15A NCAC 02C.0108
(Standards of Construction for Wells Other than Water Supply), and any other
jurisdictional laws and regulations pertaining to well construction. [15A NCAC 02C
.0108J."Facility staff were advised to repair the damaged well structures as soon as
possible.
Response: The damaged well structures will be repaired by the end of November.
3. No Operation and Maintenance Plan was available on the day of this inspection. Permit
condition III. 2. states "The Permittee shall maintain an Operation and Maintenance
Plan, which shall include operational functions, maintenance schedules, safety
measures, and a spill response plan. [15A NCAC 02T.0507(a)J." Within 30 days of
receipt of this letter please provide an Operation and Maintenance Plan to this office.
Response: An O&M Plan and a Spill Response Plan are attached for your reference. The Plans
are currently under review and may be further updated.
4. The facility maintains three irrigation spray fields totaling 35.10 acres planted with
sycamore trees. The trees appeared to be healthy, and the Town keeps other vegetation
to a minimum. The spray heads appeared to be accessible for maintenance. Public
access to the spray fields restricted. A function check was performed during this
inspection and none of the spray heads appeared to be functioning properly. The spray
heads that were emitting did not have enough pressure to actuate the spray heads'
rotational function. This results in effluent ponding and overland flow near the spray
head risers. Permit condition III. 5. states that, "adequate measures shall be taken to
prevent effluent ponding in or runoff from the irrigation sites... [15A NCAC 02T
.0507(c)J" At least 25 spray head risers were broken and bypassing the spray heads.
There was evidence of broken sub -surface lateral lines resulting in effluent surfacing and
ponding. Saturated conditions in the spray fields have been noted during past Division
inspections going back several years. Christine Bass indicated the Town owns additional
land near the existing spray fields which at some point in the future may be used for
irrigation of the Town's treated wastewater.
Response: The Town has awarded a contract to Ralph Hodge Construction Company for the
replacement of all 293 existing sprinkler risers and sprinkler heads. Work is expected to begin
on or before next Monday, October 31 and be completed on or before December 31, 2022. The
site has recently been cleaned to provide access for the work.

5. The spray field equipment is in a state of disrepair that prevents calibration. Facility
staff did not have any records for past calibrations available at the time of this
inspection. Permit condition III. 7. states that "Irrigation equipment shall be tested
and calibrated once per permit cycle. [15A NCAC 02T .0507(d)]. " Please provide
calibration information to this office within 30 days of the irrigation equipment being
repaired to a state that allows for calibration.
Response: Please note the WWTP influent metering equipment is being calibrated monthly at
this time to ensure accuracy. The Town will request the Company calibrating the influent
metering system to also calibrate the spray field metering equipment at their next visit in
November.
If you have any questions, please do not hesitate to contact me.
Sincerely,
Geraldine Langfor
Mayor
cc: McDavid Associates, Inc.

NC Dept of Environmental Quality
NOV 2 2022
Raleigh Regional Office
TOWN OF SEABOARD
WWTP
OPERATED UNDER PERMIT NO. WQ0003299
PRELIMINARY OPERATION
AND
MAINTENANCE MANUAL
TO ADDRESS THE EXISTING
WWTP
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DISCUSSION
The Town of Seaboard currently owns and operates an existing 134,000 GPD wastewater treatment and
surface irrigation system known as the Town of Seaboard WWTP. The facility is operated under Permit
Number WQ0003299.
The existing facility consists of the following individual units:
• Manual Barscreen
• Open Channel Influent Flow Measurement
• Influent Sampler
• Two 1,954,000 Gallon Treatment Lagoons
• One 1,500,000 Gallon Treatment / Storage Lagoon
• Chlorination Facilities
• One 7,425,000 Gallon Storage Lagoon with Full Synthetic Liner
• Three Irrigation Pumps (Each Rated at 235 GPM)
• Three Irrigation Fields Each with 11.7 Acres (35.1 Acres Total)
• 293 Irrigation Sprinkler Heads
• Five Groundwater Monitoring Wells
INDIVIDUAL TREATMENT PLANT UNITS
BAR SCREEN
The operation and maintenance of the manual bar screen consists of observing daily and removing any
accumulation on the barscreen with a rake. Trash should be allowed to dry and be removed to a covered
trash can and periodically be disposed of at the county landfill.
INFLUENT FLOW METER
Calibrate flow meter at least once per year. Record the flow at the same time each day.
INFLUENT SAMPLER
Collect all influent samples required by the Wastewater Irrigation Permit. Provide samples to the Contract
Laboratory. Additionally, record temperature, pH, DO, and rainfall.
TREATMENT LAGOONS ONE AND TWO
Gauges to monitor waste levels in the two treatment lagoons shall be provided. These gauges shall have
readily visible permanent markings, at inch or tenth of a foot increments, indicating the following
elevations: maximum liquid level at the top of the temporary liquid storage volume; minimum liquid level
at the bottom of the temporary liquid storage volume; and the lowest point on top of the dam. Observe the
freeboard levels and record them for each lagoon. Lagoon freeboard should be a minimum of two feet.
Their levels should be equal between each lagoon should be the same. If not, this is a sign that the pipe
between Lagoon One and Lagoon Two may be plugged. A portable pump could be used to transfer
wastewater between the two lagoons. The pipe between the two lagoons should be maintained clear.
Dispose or utilize generated residuals in a Division -approved manner. A protective vegetative cover shall
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be established and maintained on all berms, pipe runs, erosion control areas, surface water diversions, and
earthen embankments (i.e., outside 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 grow
on the earthen dikes or embankments. Earthen embankments shall be kept mowed or otherwise controlled
and accessible.
TREATMENT / STORAGE LAGOON
Wastewater flows by gravity from Treatment Lagoon Two to the Treatment/Storage Lagoon. Insure the
pipe between them remains clear. A gauge to monitor waste level in this lagoon shall be provided. This
gauge shall have readily visible permanent markings, at inch or tenth of a foot increments, indicating the
following elevations: maximum liquid level at the top of the temporary liquid storage volume; minimum
liquid level at the bottom of the temporary liquid storage volume; and the lowest point on top of the dam.
Record the freeboard daily. Flow from the Treatment/Storage Lagoon to the Irrigation Holding Pond is by
both gravity and by two 200 GPM, 5 HP — 4" turbine pumps. A relationship with a pump maintenance
contractor should be retained to care for the pumps. A protective vegetative cover shall be established and
maintained on all berms, pipe runs, erosion control areas, surface water diversions, and earthen
embankments (i.e., outside 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 grow on the
earthen dikes or embankments. Earthen embankments shall be kept mowed or otherwise controlled and
accessible.
CHLORINE CONTACT
The Chlorine Contact Time is provided in a chamber between Lagoon Number Two and the Treatment /
Storage Lagoon. The operator should observe the chlorine contact chamber occasionally and remove any
accumulation of solids that may build up in the structure.
CHLORINATION EQUIPMENT
Chlorination is provided with the existing chlorinator and 150 lb. chlorine gas cylinders. Daily chlorine
usage should be recorded. A full spare 150 pound cylinder should be maintained at all times. Chlorination
is not seasonal. Chlorination equipment and gas feed must be maintained at all times when there is flow
into the wastewater treatment facility. The operators should be trained in the safe handling of gaseous
chlorine. Chlorine gas detection equipment should be maintained.
EFFLUENT FLOW MONITORING
All effluent monitoring is by grab samples after the chlorine contact. Samples should be taken at a minimum
as frequently as outlined in the Permit.
IRRIGATION HOLDING POND
The water level in the Irrigation Holding Pond will vary based on influent flow, rainfall, and irrigation.
Monitor freeboard daily. A minimum freeboard of 2 feet should be maintained. Ideally, going into the rainy
season of late fall, this pond should be approaching its lowest water level. A protective vegetative cover
shall be established and maintained on all berms, pipe runs, erosion control areas, surface water diversions,
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and earthen embankments (i.e., outside 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 grow on the earthen dikes or embankments. Earthen embankments shall be kept mowed or otherwise
controlled and accessible.
IRRIGATION PUMPS 1 2 & 3
There are three 235 GPM centrifugal irrigation pumps. The header will allow pumps to serve each spray
field. Routine operation is for one specific pump to be assigned to each spray field. Records should be kept
for the operation of each pump. A relationship with a pump maintenance contractor should be retained to
care for the pumps. The pump flow meters should be calibrated annually.
THREE IRRIGATION SITES
There are three Irrigation Fields with a total of 293 irrigation nozzles. Maintain vegetative cover on the
irrigation sites, such that crop health is optimal, allows even effluent distribution, and allows inspection
of the irrigation system. Take measures to prevent effluent ponding in or runoff from the irrigation sites.
Do not irrigate treated effluent during inclement weather, or when the soil is in a condition that will cause
ponding or runoff. Irrigation equipment shall be tested and calibrated once per permit cycle. Only treated
effluent from the Town of Seaboard WWTF shall be irrigated on the permitted irrigation sites.
Do not allow vehicles or heavy machinery on the irrigation area, except during equipment installation
or maintenance activities. Prohibit public access to the wastewater treatment, storage, and irrigation
facilities.
Maintain records tracking the amount of effluent irrigated. These records shall include the
following information for each irrigation site listed in Attachment B:
Date of irrigation;
Volume of effluent irrigated;
Site irrigated;
Length of time site is irrigated;
Continuous weekly, monthly, and year-to-date hydraulic (inches/acre) loadings;
Continuous monthly and year-to-date loadings for any non -hydraulic parameter
specifically limited in Attachment B of the Permit;
Weather conditions; and
Maintenance of cover crops.
SAFETY
The primary methods of achieving safety are through training and securing the facilities. The WWTP and
the storage facilities are fenced off from the public. The irrigation sites have signage advising the public
that irrigation water is treated wastewater effluent.
The plant operator should obtain a copy of the OSHA standards applicable to sewage treatment plants as
soon as possible. They may be obtained by request from:
Department of Labor
1-800-LABOR NC
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Ask for Education and Training
An emergency telephone list which may be wall -mounted at the WWTP. In case of emergency the Seaboard
Fire Department or Northampton County Sheriffs Department should be notified. First Aid should be
administered only by trained personnel.
The required "Hazard Communication Plan" and MSDS sheets of all hazardous materials along with a Red
Cross Manual should be readily available.
Safety equipment at the treatment facility should include first aid kits, fire extinguishers, gas masks and
chlorine cylinder emergency repair kits. These items should be checked regularly to insure that they are
complete and operational. Medical supplies should be regularly checked for expiration dates and be
replaced as necessary. Additional safety equipment available to the operator consists primarily of tools and
regular Town equipment. Additional equipment and supplies may be obtained from any of the local
business in the County
No equipment is to be serviced without being "cut-off' with all electrical power sources eliminated.
SPILL REPORTING
Part II E. (6) entitled "Twenty-four Hour Reporting" states:
1. The permittee shall report to the central office of the appropriate regional office any noncompliance
which may endanger health or the environment. Any information shall be provided orally within
24 hours from the time the permittee became aware of the circumstances. A written submission
shall also be provided within five (5) days of the time the permittee becomes aware of the
circumstances. The written submission shall contain a description of the noncompliance, and its
cause; the period of noncompliance, including exact dates and times, and if the noncompliance has
not been corrected, the anticipated time it is expected to continue; and steps taken or planned to
reduce, eliminate, and prevent reoccurrence of the noncompliance.
2. The following shall be included as information which must be reported within 24 hours under this
paragraph:
a. Any unanticipated bypass which exceeds any effluent limitation in the permit.
b. Any upset which exceeds any effluent limitation in the permit.
c. Violation of a maximum daily discharge limitation for any of the pollutants listed by the
Director in the permit to be reported within 24 hours.
3. The Director may waive the written report on a case -by -case basis for reports under paragraph b.
above of this condition if the oral report has been received within 24 hours.
Direct telephonic and written reports to the following:
Raleigh Regional Office
Water Quality Program Supervisor
Division of Water Resources
3800 Barrett Drive
Raleigh, North Carolina 27609
Telephone [phone]
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Division of Water Resources
Water Quality Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Telephone [phone]
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NC Dept of Environmental
Quality
Nov 2 2022
Raleigh Regional Office
SEABOARD, NORTH CAROLINA
COMMUNICATION, ASSESSMENT, and
SPILL RESPONSE PROCEDURE
PREPARED BY
OPERATIONS SUPERINTENDENT, ORC
PIKEVILLE, NORTH CAROLINA
OCTOBER 25, 2022
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PURPOSE:
This plan is to be implemented in the event of a Sanitary Sewer Overflow, (SSO) or spill within
the Collection System or at the WWTP. The plan was developed to insure the key personnel response to
every spill event within sixty (60) minutes of a reported event.
INITIAL RESPONSE:
Spills reported to or detected by collection system personnel require immediate attention. The
Collection System ORC or his appointed Back-up Operator will make the preliminary assessment of the
spill within 15 minutes after receiving report. That assessment includes visiting the spill site. The ORC or
Back-up will determine the appropriate response and request assistance from key personnel as necessary.
The attached call back list will be maintained current and be ranked according to essential response
including, i.e. equipment operators. Local contractor may be employed as deemed necessary.
Key personnel will, upon assessing the site, continue to document the event and determine the
severity, magnitude, and potential environmental impact. Every effort should be made to minimize the
spill event consistent with the containment and source control section of this plan. The safety of the
responder should in no way be compromised.
Key personnel should implement recovery actions to eliminate the cause of obstruction and/or
system failure as outlined in this plan.
POST SPILL RESPONSE, (REPORTING):
After containment is achieved, the Division of Water Quality, (DWQ) must be contacted as soon
as possible but, in no case later than 24 hours after initial detection if;
I) The spill has reached surface waters, "Waters of the State" or
2) The spill exceeds one thousand gallons, (1,000 gals.)
Every small spill must be logged on site including time, date, approximate volume, name of
responder.
Spills that are fully contained and removed quickly and are less than one thousand gallons are not
required to be reported to DWQ. However, a full spill report form will be filled out and kept on file.
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KEY PERSONNEL CONTACT NUMBERS
UPDATED: BY:
Semi-annual Town Clerk
CONTACT/TITLE TELEPHONE#
POLICE DEPARTMENT
IF NEEDED FOR TRAFFIC CONTROL WORK [phone]
FIRE & RESCUE
EMERGENCY 911
OFFICE [phone]
OPERATIONS SUPERINTENDENT ORC WORK [phone]
Jeffrey Long HOME [phone]
CELL [phone]
BACK UP ORC WORK [phone]
Chief John Young HOME [phone]
CELL [phone]
TOWN CLERK WORK [phone]
Christine HOME [phone]
CELL [phone]
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SOURCE CONTROL AND CONTAINMENT
PROCEDURE
Depending on the nature of the spill or overflow, the initial assessment should indicate
the priority of source control and/or containment.
1) When the source can be isolated through valves, plugs or other methods, the flow
should be discontinued immediately or reduced to the least possible volume.
2) If the pumps on the location are not operating the control panel should be
checked for;
a. Power ON?
b. Check breaker.
c. Breaker closed, check thermal overloads. (External button).
d. Overload good, Check fuses, if you are trained to do so.
e. Is pump straining? (Clogged with debris?)
f. Do you smell a burnt motor?( contact vendor from list)
g. Call for Electrician. (From attached list.)
3) Containment methods will typically include;
a. Sand or dirt dikes and dams. (Small streams, creeks.)
b. Holes or pits. (To prevent run off to surface waters.)
If the spill event resulted from an area wide power outage you should contact Power Company
and identify your site as critical. You must have account number for location.
If the problem is mechanical in nature, retrieve parts from inventory and make repairs. Re -order
parts as they are used!
If the problem results from sewer blockage call for jet rodding machine. (In house or contractor
from list??)
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KEY CONTRACTORS AND VENDORS
WATER AND SEWER CONTRACTORS:TELEPHONE#'S
Plumbing, Trenching and Digging
KBS Construction, Inc.
Central Builders
Sewer Pump Trucks, Septic Tank Hauler, ETC.
[phone]
[phone]
A-1 Mills Septic Service [phone]
Keen Plumbing (Jet Vac) [phone]
Pearson Pump (Pump Maintenance) [phone]
Electrical Contractors
Nationwide Electrical Services [phone]
Williams & Lamm Electric [phone]
Sister Agencies
Northampton County Normal Flours [phone]
After Hours Emergency [phone]
City of Rocky Mount [phone]
Power Company
Roanoke Electric Cooperative [phone]
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Parts and Equipment Vendors
SUPPLY
Lime
Straw
Merritt Piping and Fabrication [phone]
Ferguson [phone]
HD Supply [phone]
Carolina Plumbing Supply, Inc. [phone]
RESPONSE SUPPLIES
LOCATION VENDOR PHONE #
Shop Southern States [phone]
Calypso Farm Supply [phone]
Shop Southern States [phone]
Calypso Farm Supply [phone]
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SPILL OCCURRING ON:
MAJOR INTERCEPTOR RIGHT OF WAY
1. Put up warning tape "DO NOT ENTER "around SSO site to restrict
access.
2. In open areas lime, remove debris and lime site rotor -till if needed. Re-
seed and mulch with straw.
3. In areas where there are under growth and small trees, flush area with
potable water until no waste remains. Wait twelve to twenty four hours
then lime the area. Be certain that lime does not flush to receiving
stream.
NOTE: DO NOT LIME IF RAIN HAS BEEN FORECAST.
IN CITIZEN'S YARD
1. Till entire area if possible. Apply lime and follow with seed and straw.
2. If waste/debris not visible apply lime and 2 inches of top soil and mix
thoroughly. Apply lime lightly, seed and mulch.
ON ASPHALT OR CONCRETE
1. Set up containment at or near the storm drainage system. Do not let the
spill enter the storm drain system.
2. Put up Black or Red "DO NOT ENTER "tape around the SSO area.
3. Spread lime on spillage and sand or other material to a depth of one
inch. Let this material absorb for one hour, then sweep up. Dispose of
debris appropriately. If spill is still evident repeat application.
4. After removing the contaminated material, wash down area with high
pressure water and bleach.
5. Pump clean up materials and wash water into sanitary sewer.
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IN A CREEK OR STREAM
1. Take conductivity readings of the creek upstream and downstream to
determine were temporary dam should be placed.
2. The dam should be constructed near a manhole which is accessible to the
jet rodder and vacuum truck.
3. Dam should be placed below the spill as indicated by low conductivity
reading.
4. Construct a dam sized to contain the flow of water plus any flush water
added during clean up.
5. Station to pumps at clean up site, one to use one for back-up.
6. Have a back hoe at the site for dam repairs as needed.
7. Wash down all rip rap in stream bed until no residue is evident.
8. Put up warning tape "DANGER DO NOT ENTER".
At spill site and 400 feet down stream.
9. Pull stream samples for fecal coliform. Upstream and Downstream.
10. Repeat sampling until normal, background counts 500 cts/100 ml.
11. If settled sludge is evident sweep bottom until clean.
12. If creek or stream is recreational water notify the affected community
and local officials as soon as the problem is discovered.
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