WQCS00311_Compliance Evaluation Inspection_20240620

DocuSign Envelope ID:814F49A8-34FB-46DA-97BB-F85EC76C45EB
SrAIZ
GOY COOPER _
Governor
ELIZABETH S.BISER
Secretary
RICHARD E.ROGERS,JR. NORTH CAROLINA
Director Environmental Quality
June 28, 2024
Tim Owens, Town Manager
Town of Wrightsville Beach
321 Causeway Drive
Wrightsville Beach, NC 28480
SUBJECT: Compliance Inspection Report
Wrightsville Beach Collection System
Collection System Permit No. WQCS00311
New Hanover County
Dear Permittee:
The North Carolina Division of Water Resources conducted an inspection of the Wrightsville Beach
Collection System on 6/20/2024. This inspection was conducted to verify that the facility is operating in
compliance with the conditions and limitations specified in Collection System Permit No. WQCS00311.
The findings and comments noted during this inspection are provided in the enclosed copy of the
inspection report entitled "Compliance Inspection Report".
Please respond in writing to this office within 30 days of your receipt of this letter regarding your plans
or measures to be taken to address the fact that the system does not have a properly certified operator in
responsible charge nor a back-up operator in responsible charge, as required by Item II. 1 of Permit
WQCS00311 as well as 15A NCAC 08G .0200.
If you should have any questions, please do not hesitate to contact Bryan Lievre with the Water
Quality Regional Operations Section in the Wilmington Regional Office at 910-796-7215 or via email at
[e-mail].
Sincerel
DocuSigned by:
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Tom Tharrington, Assistant Regional Supervisor
Water Quality Regional Operations Section
Wilmington Regional Office
Division of Water Resources, NCDEQ
ATTACHMENT
Cc: Bill Fay (via email)
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Wilmington Regional Office 127 Cardinal Drive Enlenslon WllmingloR North Carolina 28005
910.79,7215

DocuSign Envelope ID:814F49A8-34FB-46DA-97BB-F85EC76C45EB
Compliance Inspection Report
Permit:WQCS00311 Effective: 04/13/18 Expiration: 04/01/26 Owner: Town of Wrightsville Beach
SOC: Effective: Expiration: Facility: Wrightsville Beach Collection System
County: New Hanover Public Works Department 200 Parmele Blvd
Region: Wilmington
Writsvlle Bch NC 28480
Contact Person:Bill E Fay Title: Asst Public Works Director Phone: [phone]
Directions to Facility:
System Classifications: CS2,
Primary ORC: William E Fay Certification: 992841 Phone: [phone]
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
WQCS00012 Cape Fear Public Utility Authority-CFPUA Collection System
NC0023973 Cape Fear Public Utility Authority-Wilmington Southside WWTP
Inspection Date: 06/20/2024 Entry Time 09:OOAM Exit Time: 11:30AM
Primary Inspector:Bryan Lievre Doausigned by: Phone: [phone]
Secondary Inspector(s): $ "'u
BAF550231BDD428...
Reason for Inspection: Routine Inspection Type: Collection System Inspect Non Sampling
Permit Inspection Type: Collection system management and operation
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Miscellaneous Questions General Sewer& FOG Ordinances
Capital Improvement Plan Map Reporting Requirements
Inspections Spill Response Plan Spills
Lines Pump Stations
(See attachment summary)
Page 1 of 7

DocuSign Envelope ID:814F49A8-34FB-46DA-97BB-F85EC76C45EB
Permit: WQCS00311 Owner-Facility:Town of Wrightsville Beach
Inspection Date: 06/20/2024 Inspection Type:Collection System Inspect Non Sampling Reason for Visit: Routine
Inspection Summary:
A routine compliance inspection of the Wrightsville Beach Collection System was performed on June 20, 2024. The purpose
of the inspection was to verify that the system is operating in compliance with the terms of Permit WQCS00311. Present
during the inspection were Bill Fay(Public Works Director), Steven Avant(Water and Wastewater Supervisor), and Luke
Hahn, all with the Town of Wrightsville Beach, as well as Bryan Lievre and Jordan Cocanower with NCDEQ.
The collection system is classified a CS-2 and has approximately 3 linear miles of force mains, 18 linear miles of gravity
sewer, one (1)triplex pump station (LS#1), four(4)duplex pump stations (LS#2 through LS#5)and two (2) simplex pump
stations (LS#6 & LS#7-which both serve at least two buildings), at least 353 of manholes, as well as associated
appurtenances. It should be noted that the system had another simplex pump station (LS#8)which served the Wrightsville
Beach Parks Building, but this pump station was abandoned and the lines reportedly capped. The collection system
discharges into a manhole, north of Pump Station#35,located south of Bradley Creek on Military Cutoff Rd., for the Cape
Fear Public Utility Authority(CFPUA) collection system, Permit Number WQCS00012. Once in the CFPUA collection
system, the flow discharges into CFPUA's Wilmington Southside WWTP, Permit Number NC0023973.
The current permit only contains one high-priority line which is a 14-inch diameter DIP aerial line which travels under the
bottom of the eastbound lanes and is attached to the superstructure of the Causeway Bridge over Banks Channel. The
system also has four subaqueous (all suspected 16" HDPE) lines installed as part of the Northeast Interceptor Segment 1.
The subaqueous segments include two along West Salisbury Street, one under the Intracoastal Waterway(ICW) and one
under Bradley Creek, adjacent to Oleander Drive.
It should be noted that in a Technical Memorandum, provided by Highfill Infrastructure Engineering, P.C., dated June 14,
2017, the segment of line under the ICW was determined to be present at a depth of only four to five inches below the
bottom of the navigation channel with small portions without any cover for protection. In addition, the memo states that pier
pilings have been driven within three inches of the pipe. The insufficient vertical depth of burial does not provide adequate
protection of the pipe from damage from anchors or other items that could strike the channel bottom and the proximity to the
piers represents threats in the event replacement piers are installed or in the event of damage to existing piers. For these
reasons, it is recommended that this segment of line be considered as a High-Priority line, in accordance with 15A NCAC 2T
.0305 (f) and .0402 (2) as well as Sections 1.04 A.1. &4.06 B.1. of the Minimum Design Criteria for Pump Stations and
Force Mains. As such, this segment should continue to be performed every six (6) months, per Item V. 4 of the existing
collection system permit.
An agreement has been prepared and approved by CFPUA to take over the Wrightsville Beach Collection System, with the
exception of the two simplex pump stations (i.e., LS#6 & LS#7). According to system staff the agreement has been
approved by both CFPUA and town personnel, with anticipated take-over sometime in September 2024.
Available information indicates that the average daily flow in 2023 was approximately 609,000 gpd with a maximum of
approximately 1,294,000 gpd. Since the date of the last permit was issued (4/13/2018), the system has not had any
reportable sanitary sewer overflows (SSOs) and was issued one violation, as a result of the prior compliance inspection,
which was performed on June 10, 2021. It should be noted that the system resolved all the cited in the prior inspection
report, with documentation provided on July 14, 2021.
The town's staff's knowledge of the system was impressive and very helpful during the inspection. The existing staff have a
great understanding of the system and potential sources of inflow and infiltration which daunts the system and it is hoped
that this knowledge is not lost. Please review the comments sections of the inspection reports for more details.
Page 2 of 7

DocuSign Envelope ID:814F49A8-34FB-46DA-97BB-F85EC76C45EB
Permit: WQCS00311 Owner-Facility:Town of Wrightsville Beach
Inspection Date: 06/20/2024 Inspection Type:Collection System Inspect Non Sampling Reason for Visit: Routine
General Yes No NA NE
Is there a properly designated primary ORC and at least one back-up of proper grade? ❑ 0 ❑ ❑
Are logs being reviewed by the system management or owner on a regular basis? 0 ❑ ❑ ❑
#What is that frequency? A couple of times a
week
#Are there any issues being addressed currently or any in the planning stages? 0 ❑ ❑ ❑
Is there a specific pump failure plan available for all pump stations? 0 ❑ ❑ ❑
Does plan indicate if pump parts/new pumps are in spare parts/equipment inventory? 0 ❑ ❑ ❑
Are new/significantly upgraded pump stations equipped with anti-corrosion materials? 0 ❑ ❑ ❑
Does the permittee have a copy of their permit? 0 ❑ ❑ ❑
# Is permit expiring within the next 6 months? ❑ 0 ❑ ❑
If Yes, has the Permittee applied for renewal? ❑ ❑ 0 ❑
Comment: The current permit was issued 4/13/2018 and expires 4/1/2026. The system does not have
any properly certified operators. Based on the estimated population in the area, the system
has a Grade II Classification. According to the NCDEQ, Wastewater Operator Certification,
William (Bill) Fay is the ORC, however his certification is not valid and the system does not
have a backup operator. The town maintains two portable generators as well as a diesel
powered bypass pump for emergencies. The use and arrangement of this equipment is
documented within their Standard operating Procedures Manual.
Sewer and FOG Ordinances Yes No NA NE
Is Sewer Use Ordinance(SUO)or other Legal Authority available? 0 ❑ ❑ ❑
Does it appear that the Sewer Use Ordinance is enforced? 0 ❑ ❑ ❑
Is there a Grease Control Program that legally requires grease control devices? 0 ❑ ❑ ❑
What is the standard grease trap cleaning requirement in the FOG ordinance? monthly
Is Grease Control Program enforced via periodic inspections/records review? 0 ❑ ❑ ❑
Is action taken against violators? ❑ ❑ 0 ❑
#Have satellite systems adopted an equivalent or more stringent ordinance? ❑ ❑ 0 ❑
Is grease/sewer education program documented with req'd customer distribution? 0 ❑ ❑ ❑
#Are other types of education tools used like websites, booths, special meetings, etc? 0 ❑ ❑ ❑
If Yes,what are they?(This can reduce mailing to annual.)
FOG information is available on the Town of Wrightsville Beach website. Also, the town has saet up
information booths at the Town's Floatilla event in the past.
Comment: Information is available on the intranet regarding the Town's Sewer Use Ordinance (SUO),
which is under their Sewer Use Regulations within Chapter 50 of their Code of Ordinances.
The town maintains information on their website on their FOG program and educational
information. They also provide FOG statements in October and February bills. CFPUA
Compliance Department inspects that town's FOG program annually since the wastewater is
treated at CFPUA's Southside WWTP.
Capital Improvement Plan Yes No NA NE
Page 3 of 7

DocuSign Envelope ID:814F49A8-34FB-46DA-97BB-F85EC76C45EB
Permit: WQCS00311 Owner-Facility:Town of Wrightsville Beach
Inspection Date: 06/20/2024 Inspection Type:Collection System Inspect Non Sampling Reason for Visit: Routine
Has a Capital (CIP)or System Improvement Plan been developed and adopted? 0 ❑ ❑ ❑
Is it designated for wastewater only or does it have a dedicated section? 0 ❑ ❑ ❑
Does CIP cover three to five year period of earmarked improvements? ❑ 0 ❑ ❑
Does CIP include description of project area? 0 ❑ ❑ ❑
Does CIP include description of existing facilities? 0 ❑ ❑ ❑
Does CIP include known deficiencies? 0 ❑ ❑ ❑
Does CIP include forecasted future needs? 0 ❑ ❑ ❑
Comment: Although the existing Capital Improvement Plan only projects out until 2024, the system has a
detailed estimate of future needs gathered as part of engineerinq reports in association with
the anticipated take over of the system by CFPUA.
Map Yes No NA NE
Is there a overall sewer system map? ❑ ❑ ❑
Does the map include:
Pipe Type(GS/FM) ❑ ❑ ❑
Pipe sizes ❑ ❑ ❑
Pipe materials(PVC, DIP, etc) ❑ ❑ ❑
Pipe location ❑ ❑ ❑
Flow direction ❑ ❑ ❑
Approximate pipe age ❑ ❑ ❑
Pump station ID, location and capacity ❑ ❑ ❑
# Force main air release valve location &type ❑ ❑ ❑
# Location of satellite connections ❑ ❑ ❑
Is the map being updated for changes/additions within 1 year of activation? 0 ❑ ❑ ❑
Comment: A complete collection system GIS map was available for review as well as detailed paper maps.
Reporting Requirements Yes No NA NE
#Have there been any sewer spills in the past 3 years? ❑ ❑ ❑
If Yes,were they reported to the Division if meeting the reportable criteria? ❑ ❑ ❑
If applicable, is there documentation of press releases and public notices issued? ❑ ❑ ❑
Is an Annual Wastewater Performance Report being filed with the Division, if required? ❑ ❑ ❑
Is the report being made available to all its sewer customers? ❑ ❑ ❑
#How is it being made available? On their website
Comment: The last reported SSO was on 1/6/2018. A copy of the annual wastewater report is available
on-line. The system is reminded that a copy of this report is required to be submitted to the
Department annually, per NCGS 143-215.1 C.
Inspections
Yes No NA NE
Are adequate maintenance records maintained? 0 ❑ ❑ ❑
Are pump stations being inspected at the required frequency? 0 ❑ ❑ ❑
Page 4 of 7

DocuSign Envelope ID:814F49A8-34FB-46DA-97BB-F85EC76C45EB
Permit: WQCS00311 Owner-Facility:Town of Wrightsville Beach
Inspection Date: 06/20/2024 Inspection Type:Collection System Inspect Non Sampling Reason for Visit: Routine
# Is at least one complete functionality test conducted weekly per pump station? 0 ❑ ❑ ❑
Is there a system or plan in place to observe the entire system annually? 0 ❑ ❑ ❑
Is the annual inspection documented? 0 ❑ ❑ ❑
#Does the system have any high-priority lines/locations? 0 ❑ ❑ ❑
Are inspections of HPL documented at least every 6 months? 0 ❑ ❑ ❑
Are new lines being added to the HPL list when found or created? 0 ❑ ❑ ❑
Comment: Inspections are documented in an on-line software called PubWorks. All pump stations are
checked every Tuesday and Friday and Pump Stations LS#1 and LS#5 are checked daily.
The entire system is also inspected twice a year.
Spill Response Action Plan Yes No NA NE
Is a Spill Response Action Plan available? 0 ❑ ❑ ❑
Is a Spill Response Action Plan available for all personnel? ❑ ❑ ❑
Does the plan include:
24-hour contact numbers ❑ ❑ ❑
Response time ❑ ❑ ❑
Equipment list and spare parts inventory ❑ ❑ ❑
Access to cleaning equipment ❑ ❑ ❑
Access to construction crews, contractors, and/or engineers ❑ ❑ ❑
Source of emergency funds ❑ ❑ ❑
Site sanitation and cleanup materials ❑ ❑ ❑
Post-overflow/spill assessment ❑ ❑ ❑
Does the Permittee appear to respond within 2 hours of first knowledge of a spill? 0 ❑ ❑ ❑
Comment: The Town of Wrightsville Beach, Sanitary Sewer Overflow Response Action Plan, dated 2017
was reviewed prior to the inspection. The plan should be reviewed and updated to update list
of contacts to remove Dean Hunkele and include MR, WiRO contact of Helen Perez with
contact information email helen.perez(@deg.nc.gov, office 910-796-7306.
RR!S Yes No NA NE
Is system free of known points of bypass? ❑ ❑ ❑
If No, describe type of bypass and location
Are all spills or sewer related issues/complaints documented? ❑ ❑ ❑
#Are there repeated overflows/problems(2 or more in 12 months)at same location? ❑ ❑ ❑
# If Yes, is there a corrective action plan? ❑ ❑ 0 ❑
Comment: All sewer related issues/complaints can be tracked on the Town's work order system.
Lines/Right-of-Ways/Aerial Lines Yes No NA NE
Please list the Lines/Right of Ways/Aerial Lines Inspected:
Aerial line over Banks Channel
Are right-of-ways/easements maintained for full width for access by staff/equipment? 0 ❑ ❑ ❑
If No, give details on temporary access:
Page 5 of 7

DocuSign Envelope ID:814F49A8-34FB-46DA-97BB-F85EC76C45EB
Permit: WQCS00311 Owner-Facility:Town of Wrightsville Beach
Inspection Date: 06/20/2024 Inspection Type:Collection System Inspect Non Sampling Reason for Visit: Routine
Is maintenance documented? 0 ❑ ❑ ❑
Are gravity sewer cleaning records available? 0 ❑ ❑ ❑
Has at least 10%of lines older than 5 yrs been cleaned annually? 0 ❑ ❑ ❑
Were all areas/lines inspected free of issues? 0 ❑ ❑ ❑
Comment: Maintenance is documented on the Town's work order system. Right-of-ways are maintained
by the Town's Parks and Recreation Department. The system has reportedly had
approximately 15,000 feet (or-16%) of sewer pipe cleaned by Pipe View Technologies.
Pump Stations Yes No NA NE
Please list the Pump Stations Inspected:
Pump Stations LS#'s 1, 2, 6&7
#Number of duplex or larger pump stations in system 5
#Number of vacuum stations in system 0
#Number of simplex pump stations in system 2
#Number of simplex pump stations in system serving more than one building 2
How many pump/vacuum stations have:
# A two-way"auto polling"communication system (SCADA)installed? 7
# A simple one-way telemetry/communication system (auto-dialer)installed? 0
For pump stations inspected:
Are they secure with restricted access? ❑ ❑ ❑
Were they free of by-pass structures/pipes? ❑ ❑ ❑
Were wet wells free of excessive grease/debris? ❑ ❑ ❑
# Do they all have telemetry installed? ❑ ❑ ❑
Is the communication system functional? ❑ ❑ ❑
Is a 24-hour notification sign posted ? ❑ ❑ ❑
Does the sign include:
Owner Name? ❑ ❑ ❑
Pump station identifier? ❑ ❑ ❑
# Address? ❑ ❑ ❑
Instructions for notification? ❑ ❑ ❑
24-hour emergency contact numbers? ❑ ❑ ❑
Are audio and visual alarms present? ❑ ❑ ❑
Are audio and visual alarms operable? ❑ ❑ ❑
# Is there a backup generator or bypass pump connected? ❑ ❑ ❑
If tested during inspection, did it function properly? ❑ ❑ ❑
Is the back-up system tested at least bi-annually under normal operating conditions? ❑ ❑ ❑
#Does it have a dedicated connection for a portable generator? ❑ ❑ ❑
# Is the owner relying on portable units in the event of a power outage? 0 ❑ ❑ ❑
Page 6 of 7

DocuSign Envelope ID:814F49A8-34FB-46DA-97BB-F85EC76C45EB
Permit: WQCS00311 Owner-Facility:Town of Wrightsville Beach
Inspection Date: 06/20/2024 Inspection Type:Collection System Inspect Non Sampling Reason for Visit: Routine
# If Yes, is there a distribution plan? 0 ❑ ❑ ❑
If Yes,what resources (Units/Staff/Vehicles/etc)are included in Plan?
Pump Station LS#1 has a permanent generator and LS#6 is connected to the Town's Administrative Building
generator. The town uses portable generators and a bhypass pump for the remaining purr stations and has
a plan regarding the use of the equipment within their SOP.
#Does Permittee have the approved percentage of replacement simplex pumps? 0 ❑ ❑ ❑
Is recordkeeping of pump station inspection and maintenance program adequate? 0 ❑ ❑ ❑
Do pump station logs include at a minimum:
Inside and outside cleaning and debris removal? 0 ❑ ❑ ❑
Inspecting and exercising all valves? 0 ❑ ❑ ❑
Inspecting and lubricating pumps and other equipment? 0 ❑ ❑ ❑
Inspecting alarms,telemetry and auxiliary equipment? 0 ❑ ❑ ❑
Comment: The Town has one or more replacement simplex pumps always available. Lewis Farms pump
and hauls grease, sand from the lift stations yearly or more if needed. Lift Stations#1-5 each
have a bypass pump connection.
Page 7 of 7