WQ0003299_Request to lift moratorium_20190122

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NC Dept of Environmental Quality
FEB 14 2019
Raleigh Regional Office
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TOWN OF SEABOARD
P.O. BOX 327
SEABOARD, NC 27876
PHONE:[phone]
FAX:[phone]
January 22, 2019 •
Linda M. Culpepper Via Certified Mail
DWR Director Return Receipt Requested
1611 Mail Service Center 70180360000217049615
Raleigh, NC 27699-1611
Re: Town of Seaboard Permit#WQ0003299 Moratorium
Dear Director Culpepper,
I am writing to you in my capacity as Mayor of the Town of Seaboard, requesting that you consider lifting
the existing Sewer Moratorium imposed upon the Town of Seaboard effective Feb. 26, 2007.A review of
the Notice of Moratorium, the Notice of Amendment to Sewers Moratorium; dated March 4, 2013, and
%the Notice of Deficiency, dated Sept. 23, 2014 (NOD-2014-PC-0184), all reflect that the Moratorium was
imposed as the result of sewer-overflows occurring in 2007,of which there has been no reoccurrence.The
sewer overflow was proximately caused by heavy rains over a.Two-Day period.causing Lagoon #1 to
overflow(14 inches of rainfall).There has been no subsequent overflow which has been corroborated, in
part by both the Notice of Amendment to Sewer Moratorium dated March 4, 2013 referenced above,
which authorized the inclusion of additional flows from the Carolina Bar Co. into the Town's Wastewater
Treatment and Surface Irrigation System, because the influent flow into the plant had decreased from an
excess of the permitted limit approximately 81%of the permitted Influent Flow Rate.
The Town.of Seaboard has both proximate to the Moratorium and subsequent to the-Moratorium
undertaken to abate the causes mentioned in the Moratorium by undertaking a progressive grant policy
to curtail the causes of same. More particularly,the Town has sought and procured a CDBG Water Hookup
Grant,a CDBG Water Treatment Plant Grant,a CDBG-I Localized Sewer Improvement and Extension Grant,
a Localized CDBG-I Water Improvement and Extension Grant, a DWSRF Water Grant impacting
approximately 25%of the Town, and a CWSRF Grant impacting 35%±of the sewer collection system, all
of which, to some degree, address the Town's infiltration and inflow, water flow into the sanitary sewer
system, run-offs into sanitary sewer system,etc.Additionally, municipal records reflect that the Town has
been compliant with permitted influent rates for 18 of the last 19 months, including November and
December of 2018. Additionally, the Town has capped numerous old sewer lateral lines, commensurate
with the flow from the sewer line-extension mentioned above.The Town has also replaced approximately
Two-Thirds of its water meters and eliminated drainage from an abandoned school facility where the
gutter system drained approximately 15,000 sq. ft. of roof which would-could possibly dump
approximately 27,000 Gallons of additional water into the sewer system in a 2-Inch rainfall event.

possibly dump approximately 27,000 Gallons of additional water into the sewer system in a 2-Inch
rainfall event.
Our Town, in the recent past, sought assistance and funding from the US EDA to help finance
• repairs/replacement to the leaking liner in Lagoon #1. The EDA, although receptive to the funding, has
trepidations regarding funding a project that will not address an economic employment need as long as
the Moratorium is in place. Since the root cause of the Moratorium was the overflow of Lagoon #1,
which has not overflowed now an excess of 10 years, it is respectfully requested that the Moratorium be
lifted so as to enable the Town to procure the EDA Funding to resolve the ever-present leaky liner.
As a corollary to this request, the Town does have pending, a Special Order of Consent application,
which it intends to perfect, as said application addresses the tying in of the West Fraser Lumber Co. into
the Town's Sanitary Sewer Treatment System.
Currently,the Town has applications pending with the State of North Carolina DEQ seeking funding for
drinking water improvements in areas not previously nor pending improvement to further address,the
Town's I & I problems. The Town also has a CDBG-NR Drainage/Housing Rehabilitation Application
pending with the NC DOC. Finally,the Town has under discussion, pending further infrastructure grants
both in the Spring 2019 NC DEQ Cycle and the Fall CDBG-I Cycle. It is evident that since the Moratorium
was imposed, the Town has been compliant with State Regulations, been a good neighbor with
assistance to both the State and to Carolina Bark and has sought and procured, not less than Six Grants
to abate, in part, the Town's I & I Problems and Lagoon Issues. Therefore, it is respectfully requested
that, upon review of the within correspondence, and based upon the Town's Capacity Compliance '
Record,that the existing Moratorium be lifted.
Respectfully,
/Lac;
Mayor Geraldine Lang ord
Cc: Christine Bass(Town Clerk)
Joe Dooley(Consultant, Upper Coastal Plain Council of Government)
ick Bolich,lG(Assistant Supervisor, NCDEQ Raleigh Regional Office)]
Jeff Poupart(Chief, NCDEQ, Div. of Water Resources, Water Quality Permitting Section)
Mike Tolson, P.E. (Engineer, Mack Gay Associates)
Stuart Bass(Planner, Upper Coastal Plain Council of Government)