WQCS00177_Response to Notice_20180829

Town of Newport
Dennis Barber, Mayor
Charles Shinn, Mayor Pro Trot
Connell Members
David Heath
Mark Eadie
Danny Fomes
Bob Benedict
T. O. BoX1869
X,,por4 9VC 28570
August 22, 2018
NC DEQ/Division of Water Resources
Attn: Morelia Sanchez -King
127 Cardinal Drive Ext.
Wilmington, NC 28405
Subject: NOV Response
NOV-2018-PC-0304
Newport Collection System
WQCS00177
Carteret County
Dear Ms. Sanchez -King:
Angela Christian
Town Manager
Taylor & Taylor
Town Attorney
Maryellen Brown
Town Cterkll. Collector
[phone]
[phone] faX
The Town of Newport has received the NOV and Intent To Assess Civil Penalties dated August 2, 2018. We
acknowledge that there were some deficiencies on the Town's part, but we do not feel that the severity of
the violations warrant civil penalties.
Over the course of the permit period, the staff has always tried to maintain compliance with all conditions.
Unfortunately, over the past couple of years, there has been many stressors on the staff. These challenges
include relocating to a new work area and turnover in four of the utility staff positions. Hiring and training
new staff has meant that there were times when we were understaffed and the training process takes a good
amount of time from other work efforts.
We would like to offer the following comments regarding the violations noted in the NOV:
The noted deficiency states that "Overall recordkeeping/documentation needs improvement or kept
in any manner." As stated earlier, in relocating from one administrative building to another,
paperwork became disorganized. Of the records required by the permit conditions, the specific one(s)
that were deficient were not noted in the NOV. The Town is working to locate all required
documentation in a central area. In addition, the Town will be looking at optional methods of
recordkeeping, including the logs on the NC PERCS website.
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• The noted deficiency is a failure to clean 10% of collection system. Since the implementation of the
collection system permit, the Town has met this condition, with the exception of calendar year 2017.
During 2017 the sewer letter was inoperable for a significant amount of time. The Town spend
approximately $4000.00 for repairs in 2017. Also, 2017 was when the Town had significant turnover
in the utility department. Due to the staff shortages and training requirements, there were not staff
qualified to operate the letter and complete all other necessary duties. The sewer jetter was also out
of service in early 2018, requiring an additional $3000.00 for repairs. Approximately 3,000 feet of
sewer line has been cleaned in calendar year and our goal is to clean approximately 4,000 feet per
month until our required cleaning is accomplished.
• The noted deficiency was that Town did not have "a complete map of its system .. " The Town does
have a collection system map which shows the location of the sewer lines, manholes and pump
stations, but not the other items listed in the requirements. The as -built plans for the collection
system are available and these plans show the depth and size of pipes. The collection system map
was on the Town's GIS system. The server became corrupted and the data was lost. The Town has
purchased GIS location equipment and mapping software and will be mapping the collection system
per permit requirements. The Town may also work with an engineering firm as necessary to complete
the map.
In our most recent Collection System Permit renewal package, dated February 20, 2018, we included a copy
of the map and stated that we would be working on an updated map.
The Town staff has worked hard to maintain compliance not only with the collection system permit but also
with NPDES permit and drinking water requirements. They have overcome several challenges and will
continue working to maintain compliance. The Town has spent over $7,000 in repairs to the sewer jetter. We
feel that incurring civil penalties can impact the any future repairs or expenditures needed for compliance and
again request that civil penalties not be assessed for the NOVs.
Sincerely, ��Q�
Vefi•�"�' JIl 6
Bernie Hall
Town of Newport
Deputy Utility Director
bhallPtownofnewnort com
Office [phone]
Cell [phone]
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