WQ0003299_NOV-2019-PC-0057_20190204

ROY COOPER
Governor
MICHAEL S.REGAN r.
r
Secretary 99l•!
LINDA CULPEPPER NORTH CAROLINA
Director Environmental Quality
February 4,2019
CERTIFIED MAIL 7017 0190 0000 9562 7336
RETURN RECEIPT REQUESTED
Geraldine Langford, Mayor
Town of Seaboard
PO BOX 327
Seaboard,NC 27876
Subject: NOV-2019-PC-0057
Compliance Evaluation Inspection
Town of Seaboard WWTF
Wastewater Irrigation System
Permit Number WQ0003299
Northampton County
Mayor,
On January 31,2019 Rick Trone 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 Joey Barnes, ORC, and Clifton Mason 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 July 28, 2017 and expires on June 30,2022.
The Town of Seaboard has been under a sewer flow moratorium since 2007 that prohibits future
connections to the collection system that would add flow to the Town's wastewater treatment facility.
Among the reasons for the moratorium included excessive wastewater influent beyond permitted limits
and excessive flooding in the spray fields.
A E Q�� North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office 1 3800 Barrett Drive I Raleigh.North Carolina 27609
�� 919.791.4200

The Town submitted a sewer extension application to DWR in late 2017 for the West Fraser Sanitary
Sewer Extension requesting 20,000 gallons of additional flow per day to enter the Town's wastewater
treatment facility.Because the Town is under a sewer flow moratorium, additional flow to the collection
system and treatment facility is prevented.It was recommended the Town enter into a Special Order of
Consent(SOC)that would detail improvements to the collection system and treatment facility and
alleviate the Town from notices of violations and penalties while these improvements take place.An
application for a SOC was received by DWR on April 6,2018 and is currently in review. The Town has
received various grants to address issues in the collection system and treatment facility. The town
continues to pursue funds currently. On or about July 2017, reported flow into the system saw a
significant reduction.This trend continued through 2018 with reported flow below permit limits.
Meters monitoring influent flow and irrigation were last calibrated on October 18,2018 by FC"Services.
A representative soil analyses has not been performed on the spray fields in at least three years.This
office issued a Notice of Violation(NOV-2017-PC-0172)for failure to conduct a soil analysis in 2016.
Ensure a soil analysis is conducted as soon as possible. (see deficiency below).
NDMR records for 2017-2018 were reviewed. Throughout most of 2018,the facility did not report a
value on NDMR for Residual Chlorine.During all of 2017 the facility reported Residual Chlorine as zero.
Currently,the facility is utilizing a small electric pump(Pulsatron)to dose the system with hypochlorite.
Ensure this setup is dosing the system correctly and that residual chlorine is properly measured.
Additionally,the Town must ensure enough hypochlorite is available on site. Overall it appears the
Town is monitoring the wastewater effluent as required in the current permit.
A review of NDAR records for 2017-2018 were reviewed. For event spray event,the facility reports
58,333 gallons of water irrigated for 240 minutes.Please indicate clearly,in writing, how these values
are calculated.The facility is indicating on form NDAR that the permitted yearly rate for each field
is 109.211,however,the current permit lists this rate as 61".Please correct this value on form
NDAR.
GW-59 reports for 2017-2018 were reviewed. As specified on form GW-59, the facility should report the
results of annual VOC testing and attach lab reports.The facility sampled for VOC's in 2017 and 2018
but did not report the results on form GW-59. Overall it appears the Town is monitoring the wells as
required in the current permit.
Components of the wastewater 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
should be placed into an appropriate container,and not on the ground. Water in the storage lagoons
was clear and free of solids and plenty of freeboard was available. Gauges to monitor freeboard levels
in ponds 1 and 3 were missing at the time of the inspection.Replace these gauges as soon as possible
(see deficiency below).The storage lagoon continues to experience a large bubble in the liner reducing
capacity. This bubble is one issue the Town hopes to address with grant money.
The facility maintains three irrigation spray fields totaling 3 5.10 acres planted with sycamore trees.These
trees appeared to be healthy and the Town keeps other vegetation to a minimum.The spray heads appear
to be accessible for maintenance. Public access to the spray fields is restricted.A function check was
performed during this inspection but due to the very low temperatures most of the spray heads had ice
accumulation making it difficult to ascertain their condition.During this inspection,standing water was

noted in many areas of the fields as well as water coursing across the ground in at least one
location. Mr. Bames indicated the Town owns additional land near the existing spray fields which at
some point in the future may possibly be used for irrigation of the Town's treated wastewater.
The following permit condition deficiencies were noted during the December 28,2018 compliance
inspection and records review:
III.Operation and Maintenance Requirements
Condition 4,which states that, "adequate measures shall be taken to prevent effluent ponding in or runoff
from the irrigation sites..."During this inspection,standing water was noted in many areas of the
fields as well as water coursing across the ground in at least one location. Ensure all available
measures are taken to reduce these issues as much as possible.
Condition 13. which states that, "gauges to monitor waste levels in the two 1.5-acre stabilization lagoons,
the 1.5 million gallon holding basin,and the 7.425-million-gallon storage lagoon shall be provided...."
Gauges to monitor freeboard levels in ponds 1 and 3 were missing at the time of the inspection.
Replace these gauges as soon as possible.
IV.Monitorine and Reoortine Requirements
Condition 12,which states that, "An annual representative soil analysis shall be conducted on each
irrigation site listed in Attachment B..."A representative soil analyses has not been performed on the
spray fields in at least three years. Ensure a soil analysis is conducted as soon as possible.
If you have any questions about this inspection or this letter,please contact Rick Trone at
rick.trone(cdi ncdenr. oovv or 919-7914257.
Sincerely,
Wicolich.,L.G.
Assistant Regional Supervisor
Water Quality Regional Operations
Raleigh Regional Office
Attachments: EPA Water Compliance Inspection Report
cc:
Central Files
RRO Files