WQ0000948_NOD-2019-PC-0187_20190823

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
Jason S. Morris, Mayor
Town of Jackson
PO BOX 614
Jackson, NC 27845
Mayor Morris,
NORTH CAROLINA
Environmental Quality
August 23, 2019
Subject: NOTICE OF DEFICIENCY
NOD-2019-PC-0187
Compliance Evaluation Inspection
Town of Jackson
Wastewater Irrigation System
Permit Number W00000948
Northampton County
On August 20, 2019, Rick Trone of the Raleigh Regional Office conducted a compliance evaluation
inspection of the wastewater irrigation system for the Town of Jackson. The purpose of this inspection
was to ensure compliance with the subject permit. During the inspection, the excellent cooperation and
assistance of Mr. Johnny Young and staff 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 September 28, 2016 and expires on December 31, 2021. Currently, Mr.
Young is designated ORC with Christopher Wheeler as backup ORC.
Components of the wastewater system appeared to be overall well -maintained and operational. A copy of
the 2018 Annual Report was reviewed and appears compliant with the permit. Please ensure a copy of
the Annual Report is sent to the Division at the address listed in the permit. Water in the
stabilization/storage lagoon was free of floating solids and plenty of freeboard was available. The influent
D_E QJ� North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office 1 3800 Barrett Drive I Raleigh. North Carolina 27609
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flowmeter was last calibrated February 2019 by ISI. The irrigation fields appeared to be in good condition
with no evidence of ponding or runoff. Portions of the spray system were activated and appeared to have
good spray patterns and coverage. Mr. Young explained there was a leak on Field 3 that staff was actively
addressing. A small portion of the activated system near the road was not activated due to issues with
minor ponding of water that have occurred in the past. The chlorination equipment appeared to be in good
condition. At the time of the inspection, the facility had plenty of liquid hypochlorite available.
NDMR records for 2018-2019 were reviewed and some months were compared against lab bench sheets.
No errors were noted. The facility is monitoring the effluent as required but is having the contract lab
(Environment 1) analyze some parameters monthly when they are only required three times per year (e.g.,
Chlorides, Total Dissolved Solids) resulting in additional cost to the Town. NDMR forms are complete
and signed where required. The Town has many exceedances of their flow limit. For the years 2018 and
2019, the Town had 11 exceedances for flow (see deficiency below). These exceedances of flow
correspond with large rain events. Mr. Young explained a couple satellite communities (Eastside and
Moore Subdivision) are possibly a major contributor to excess flow during heavy rains. Mr. Young is
proactive when flow exceedances occur and always informs this office.
Monitoring wells 1, 2, 9, and 10 were observed and appeared to be in good condition. At the time of the
inspection all wells were locked except for well 2. Well 2 requires a large wrench to access and has no
provision for a traditional lock. GW-59 reports for 2018-2019 were reviewed and compared against the
lab data. The current permit requires wells to be sampled for Total Phosphorous (TP). The facility is
currently not having the wells sampled for this parameter. Please ensure well samples are analyzed for
TP (see deficiency below). Lastly, Monitoring Well 2 has had exceedances for Ammonia in February and
June 2019. Exceedances of Ammonia have been noted on previous inspections.
NDAR forms for 2018-2019 were reviewed. NDAR reports appeared to be accurate and were signed as
appropriate.
The following permit condition deficiencies were noted during the August 20, 2019 compliance
inspection and records review:
IV. Monitorine and Reuortine Requirements
Condition 3, which states that, "The Permittee shall monitor effluent from the subject facilities at the
frequencies and locations for the parameters specified in Attachment A." For the months of January 2018-
June 2019, the facility has exceeded the permitted monthly average flow of 203,000 gallons per day for
11 months. Please explain what the Town is currently doing to address the ongoing flow exceedances
and what the Town believes to be the cause.
Condition 11, which states that, "Monitoring wells shall be sampled at the frequencies and for the
parameters specified in Attachment C. " The current permit requires wells to be sampled for Total
Phosphorous (TP). The facility is currently not having the wells sampled for this parameter. Please
ensure all monitoring well samples are analyzed for TP.
To prevent further action, please respond in writing to this office within 30 days upon your receipt
of this Notice of Deficiency regarding your plans or measures to be taken to address the indicated

deficiencies and other identified issues, if applicable. Please include in your response all corrective
actions already taken and a schedule for completion of any corrective actions not addressed.
If you have any questions about this inspection or this letter, please contact Rick Trone at
rick.troneAncdenr.gov or 919-791-4200.
Sincer,W,
ickick BG.
Assistant Regional Supervisor
Water Quality Regional Operations
Raleigh Regional Office
Attachments: EPA Water Compliance Inspection Report
cc:
Central Files
RRO Files