WQ0003299_WQ0003299_Town of Seaboard_Inspection_NOV-2022-PC-0574_20220927

North Carolina Department of Environmental Quality  Division of Water Resources  Raleigh Regional Office
3800 Barrett Drive  1628 Mail Service Center  Raleigh, North Carolina 27699-1628
919.791.4200

September 27, 2022
The Honorable Geraldine Langford, Mayor
Town of Seaboard
P. O. Box 327
Seaboard, NC 27876

Certified Mail # 7020 3160 0000 4115 4859
Return Receipt Requested
Subject: Notice of Violation & Intent to Assess Civil Penalty
Tracking Number: NOV-2022-PC-0574
Wastewater Surface Irrigation System
Permit Number: WQ0003299
Northampton County

Mayor Langford,
On September 20, 2022 Chris Smith of the Raleigh Regional Office conducted a compliance evaluation
inspection of the wastewater irrigation system for the town of Seaboard. The purpose of this inspection
was to ensure compliance with the subject permit. During the inspection, the cooperation and
assistance of Jeff Long (ORC), Christine Bass, and Joseph Simonowich 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 effective July 15, 2021 and expired on June 30, 2022. This permit states
“the Permittee shall submit a renewal application no later than January 1, 2022.” The Division received
the Town’s permit renewal application for the Town of Seaboard on June 7, 2022. The Division is in the
process of renewing this non-discharge permit.
The Town of Seaboard Wastewater Treatment Facility (WWTF) is permitted for the following treatment
system: continued operation and subsequent abandonment of: the existing bar screen; the existing flow
meter; the existing high-density polyethylene (HDPE) liner system in the 7.425 million gallon (MG)
effluent storage pond; the existing 293 irrigation risers, riser piping, and sprinkler heads from the
irrigation mains; and all associated piping, valves, controls, and appurtenances.
DocuSign Envelope ID: E56369EE-DE65-4FF4-A7FF-DC8D8B13224E
WQ0003299
Northampton
September 27, 2022
Page 2 of 4

North Carolina Department of Environmental Quality  Division of Water Resources  Raleigh Regional Office
3800 Barrett Drive  1628 Mail Service Center  Raleigh, North Carolina 27699-1628
919.791.4200

The replacement of the 293 existing irrigation risers, riser piping, and sprinkler heads from the irrigation
mains to be replaced with identical sprinkler heads and risers; and all associated piping, valves, controls,
and appurtenances.
The construction and operation of: a new mechanical bar screen with a manually cleaned bar screen
bypass; a new flow measuring manhole with a Parshall flume and an ultrasonic flowmeter; a new
backup transfer pump station connecting the two stabilization lagoons consisting of a 400 gallon per
minute (GPM) dry prime pump mounted on a trailer and 300 linear feet (LF) of 4-inch force main; a new
60 mil HDPE liner system for the 7.425 million gallon (MG) effluent storage pond with a leak detection
and vent system; a new 125 kilowatt (kW) standby power generator; and all associated piping, valves,
controls, and appurtenances.
The continued operation of: 2,825 LF of 10-inch sewer line; two 1.5 acre stabilization lagoons in series;
chlorination facilities; a 1.5 MG holding basin with two 200 GPM vertical turbine transfer pumps; a 7.245
MG effluent storage pond; an irrigation pumping system with three 235 GPM centrifugal pumps; a 35.1
acre spray irrigation area with three fields and 91 nozzles per field; and all associated piping, valves,
controls, and appurtenances.
At the time of this inspection the above-mentioned original equipment permitted for abandonment and
replacement was still in use.
The following conditions were noted during the inspection:
1. 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. [15A NCAC 02T .0108(b)(l)(A)].”
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 II. 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 .0108].” Facility staff were advised to repair the damaged well
structures as soon as possible.
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,
DocuSign Envelope ID: E56369EE-DE65-4FF4-A7FF-DC8D8B13224E
WQ0003299
Northampton
September 27, 2022
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North Carolina Department of Environmental Quality  Division of Water Resources  Raleigh Regional Office
3800 Barrett Drive  1628 Mail Service Center  Raleigh, North Carolina 27699-1628
919.791.4200

which shall include operational functions, maintenance schedules, safety measures, and a spill
response plan. [15A NCAC 02T .0507(a)].” Within 30 days of receipt of this letter please provide
an Operation and Maintenance Plan to this office.
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 is
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)]” 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.
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.
6. The meter monitoring influent flow has been calibrated monthly for the past year and was last
calibrated on September 8, 2022 by FCx Services. Permit condition III. 16. States that “metering
equipment shall be tested and calibrated annually. [15A NCAC 02T .0507(d)]” Please continue
to ensure that the flow meter is calibrated annually.
7. A representative soil analysis was performed on the spray fields on November 30, 2021. Permit
condition IV. 12. states that “An annual representative soils analysis (i.e., Standard Soil
Fertility Analysis) shall be conducted on each irrigation site listed in Attachment B. [15A NCAC
02T .0108(c)].” Please continue to ensure that soil analysis for the irrigation areas is performed
annually.
8. NDMR records for the period beginning January 2021 and ending July 2022 were reviewed.
Multiple analysis parameters have been omitted during the 2021-2022 reporting period. These
reporting issues have been addressed through Notices of Violation and DWR staff are continuing
to work with the facility to resolve the issues. The most recent reporting (June - July 2022) has
adhered to the requirements set forth in the permit. Permit condition IV. 4. states “The
Permittee shall monitor the treated effluent at the frequencies and locations for the
parameters specified in Attachment A. [15A NCAC 02T .0108(c)].” Overall, it appears the Town
is monitoring the wastewater effluent as required in the current permit.
DocuSign Envelope ID: E56369EE-DE65-4FF4-A7FF-DC8D8B13224E
WQ0003299
Northampton
September 27, 2022
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North Carolina Department of Environmental Quality  Division of Water Resources  Raleigh Regional Office
3800 Barrett Drive  1628 Mail Service Center  Raleigh, North Carolina 27699-1628
919.791.4200

9. NDAR records for the period beginning January 2021 and ending July 2022 were reviewed.
Permit condition IV. 5. states “The Permittee shall maintain records tracking the amount of
effluent irrigated. These records shall include the following information for each irrigation site
listed in Attachment B… [15A NCAC 02T .0108(c)]” The spray irrigation events reviewed appear
to be in compliance with current permit conditions.
10. GW-59 reports for the period beginning January 2021 and ending July 2022 were reviewed.
Multiple wells have limit violations for Ammonia and Fecal Coliform. Permit condition IV. 10.
states “Monitoring wells MW-6, MW-7, MW-8, MW-9 and MW-10 shall be sampled at the
frequencies and for the parameters specified in Attachment C... [15A NCAC 02T .0105(m)].”
The GW-59 violations will be addressed under different cover.
11. Other components of the wastewater treatment system appeared to be operational. The
influent bar screen appeared to be doing an adequate job of screening the influent wastewater.
Screenings removed from the bar screen are placed into an appropriate container. Currently,
the facility is utilizing a small electric pump (Pulsatron) to dose the system with hypochlorite.
Water in the storage lagoons was clear and free of solids. The 1.5 MG holding basin had
approximately 4 feet of freeboard, stabilization lagoon 1 had approximately 34 inches of
freeboard, stabilization lagoon 2 had approximately 6 feet of freeboard, and the 7.245 MG
effluent storage pond had approximately 6 feet of freeboard. Gauges to monitor freeboard
levels were present in all storage structures at the time of the inspection. The gauge in lagoon 2
needs to be refastened at the top where a screw has broken. Please make this repair within 30
days of receipt of this letter and notify this office in writing that the repair has been completed.

This inspection report is being issued as a Notice od Violation due to the compliance issues cited in
items 1, 2, 3, 4, and 5 above. These violations and any future violations are subject to a civil penalty
assessment of up to $25,000 per day for each violation.
Please submit a written response to this office within 30 days of receipt of this letter indicating what
actions you have taken, or plan to take, to resolve the issues indicated above.
If you have any questions about this inspection or this letter, please contact Chris Smith at
[e-mail] or 919-791-4200.
Sincerely,

Vanessa Manuel
Assistant Regional Supervisor
Water Quality Regional Operations Raleigh Regional Office

Attachments: Compliance Inspection Report
cc: Laserfiche

DocuSign Envelope ID: E56369EE-DE65-4FF4-A7FF-DC8D8B13224E