WQ0003299_Special Order By Consent_20180618

1.•;, , x ROY COOPER
.. Governor
I.
! ( °x {- MICHAEL S.REGAN
SeCretary
Water Resources LLVDA CULPEPPER
ENVIRONMENTAL OUALUVY Interim D reC!DT
June 18, 2018
Geraldine Langford, Mayor
Town of Seaboard
PO Box 327
Seaboard NC, 27876
Subject: Town of Seaboard special Order of Consent
WQCSD0111 (Collection System); WQ0003299 (WWTP—Spray Irrigation)
Town of Seaboard
Northampton County
Dear Ms. Langford:
The Town of Seaboard has been under a sewer flow moratorium since February 26, 2007 that prohibits
future connections to the collection system that would add flow to the Town's treatment facility. The
reason for the Moratorium is that the Division determined that the Town of Seaboard was unable to
consistently store,treat and spray wastewater at the Town's wastewater treatment plant as required in
Permit No. WQ0003299. Violations noted at the facility included: 1) excessive influent beyond the
permitted limitations, 2) improper freeboard levels, 3) bypassing of treatment components,4) excessive
flooding in all areas of the sprayfield, and 5)wastewater runoff impacting the waters of the state. The
reason for the excessive flows at the plant include inflow and infiltration in the Town's collection
system.
The Town submitted a sewer extension application to the Division of Water Resources on September 19,
2017 for the West Fraser Sanitary Sewer Extension that included a request for 20,000 gallons per day to
Seaboard's wastewater treatment facility. However,the Town's moratorium prevents the addition of
flow to the collection system and treatment plant. Division of Water Resources(DWR)staff and
Seaboard staff and representatives met in November 2017 to discuss this request for a sewer extension
and the Town's moratorium. As discussed in this meeting, as well as in a follow-up letter that was
mailed to the Town on October 31, 2017,the Town was recommended to enter into a Special Order of
Consent(SOC)that would detail improvements that would be accomplished to the collection system,
and alleviate the town from notice of violations and civil penalties while these improvements are
completed.
An application for an SOC from the Town was received on April 6, 2018. The application was prepared
by Mark A. Russel, PE of Mack Gay Associates, P.A. on March 30, 2018.
State of North Carolina I Environmental Quality I Water Resources
1628 Mail Service Center,Raleigh,NC 27699-1628
919-791-4200

DWR has reviewed the application and has the following comments/questions that need to be
addressed.
1. Section III of the SOC application instructions requires the following:
a. Provide a detailed description of the proposed allocation for additional flow, with an
explanation of how flow quantities were estimated.
b. If the flow is Non-domestic, the facility must be able to demonstrate the ability to
effectively treat the waste and dispose of residuals.
i. Provide a detailed analysis of the constituents in the proposed non-domestic
wastewater.
ii. Will pretreatment be required?
iii. Identify the 40 CFR Industrial category and subpart(s) applicable to the process
wastewater being produced
2. Please provide an analysis of the wastewater from Carolina Bark's non-domestic wastewater
after it leaves the holding pond and enters Seaboard's Collection System. Please note where the
samples are taken from (Attachment A contains a list of analytes to use with your analysis of the
mulch leachate analysis).
3. The SOC application states that the upcoming CDBG l&I project that was awarded on May 8,
2017 should achieve a 30% reduction in flow.
a. Please explain what this 30% reduction is relative to (e.g. daily flow average, monthly
flow averages,winter flow averages)
b. Please explain how was this 30% reduction was estimated.
4. Below is the facility's reported flow from January 2017 to December 2017. There appears to
be a significant drop in flows starting in July 2017 that continues through the end of the year.
Also,there are extremely high flows in January and June 2017. Please explain what caused this
significant decrease in flow starting in July, and the extremely large flows in January and June of
2017.
Reported
Month Year Monthly
Average
(MCD)
1 2017 0.177
2 2017 0.084
3 2017 0 07
4 2017 0.134
5 2017 0.131
6 2017 0 152
7 2017 0 055
8 2017 0 034
9 2017 0.048
10 2017 0 023
11 2017 0.027
12 2017 0.027
State of North Carolina I Environmental Quality I Water Resources
1628 Mail Service Center,Raleigh,NC 27699-1628
919-791-4200

.. , .
5. Seaboard staff stated in a meeting that they own additional land around their existing spray
fields that could be used for new spray fields. Please describe the land (e.g. land uses, soils,
cover crop,wells, buildings etc.)that is owned and the acreage. Has this option, additional
spray fields, been further explored in past?
6. The SOC application states that funding has been obtained for improvements to the wastewater
treatment plant, including the repair of the floating liner in one of the lagoons.
a. Please provide a description of how this lagoon will be taken off line and how this repair will
be conducted.
b. Does the WWTP plant have the capacity to take this lagoon off-line while it is repaired?
c. Where and how will the removed solids be deposited?
7. Flow Monitoring
a. Where is the flow recorded (influent or effluent)?
b. What is the Monitoring Frequency?
c. When was the flow meter last calibrated? Please provide the dates and the firms that
have performed calibrations over the last 3 years.
d. Is a chart recorder also used?
8. Would the proposed additional 20,000 gallons of wastewater flow be instantaneously realized at
the treatment plant, or will flow gradually built-up to this volume? Please explain.
9. The SOC application states that plans and specifications for the current CDBG-funded project to
address I&I will be submitted to NCDEQ by April 30, 2018. Has this been done? Have all
other CDBG milestones been met to date?
Please respond as soon as possible to this letter addressing all the items above. Upon receiving a
response, DWR staff would like to schedule a site visit of the wastewater treatment plant and will
contact you regarding this.
If you have any questions, please contact Jason Robinson at(919) 791-4200 or via e-mail at
[e-mail].
Sincerely,
/2 I-6::
(.--):
S. Daniel Smith, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
cc: Mark Russell
Raleigh Regional Office Files
Water Resources Central Files
State of North Carolina I Environmental Quality I Water Resources
1628 Mail Service Center,Raleigh,NC 27699-1628
919-791-4200

. ,
Attachment A— List of Analytes to be Analyzed in Carolina Bark's wastewater
Physical Parameters:
1. DO (mg/L)
2. Conductivity (spc us/cm)
3. pH (s.u.)
Chemical Parameters (mq!L):
1 BOD-5 Day
2 NO2+ NO3 asN
3 TKN as N
4 TP
5. Hardness (mg/L CaCO3)
Total Metals (ug/L).
1 Aluminum (Al)
2. Arsenic (As)
3 Barium (Ba)
4. Chromium (cr), Total
5 Copper(Cu)
6. Iron (Fe)
7 Lead (Pb)
8. Manganese (Mn)
9. Potassium (K)
10. Sodium (Na)
State of North Carolina I Environmental Quality I Water Resources
1628 Mail Service Center,Raleigh,NC 27699-1628
919-791-4200