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HomeMy WebLinkAboutWQCS00372_CEI Letter and Report 2024_20240718 Docusign Envelope ID:2E3F77BE-EF66-4695-9FOA-89282C20054F r „ STA72 , _y ROY COOPER `y > GnrtvMx �`.�, � t„ 2 MICHAEL S.REGAN f -1 a a ccurr LINDA CULPEPPER NOR' I .-A-4(;NA Uirecfor Environmental Quality July 18,2024 Mr. John McDonald Old North State Water Company, LLC Briar Chapel Collection System PO Box 10127 Birmingham AL, 35202 Subject: Compliance Evaluation Inspection Briar Chapel Collection System WWCS Permit WQCS00372 Chatham County Dear Mr. McDonald: On July 16, 2024, Donald Smith from the NC Division of Water Resources - Raleigh Regional Office (RRO)conducted an inspection of the Briar Chapel Wastewater Collection System to evaluate compliance with the operation and maintenance of the subject wastewater collection system permit. The cooperation and assistance of Chip White and Jeremy Nordan during the inspection was greatly appreciated. Records indicate the wastewater collection system consists of approximately 19.l3 miles of gravity sewer, approximately 7.31 miles of force main, 15 simplex pump stations, 13 duplex pump stations and 4 high priority lines. The subject permit is effective from August 1, 2018, until July 31, 2026, and is subject to specific conditions and limitations. The items below show what conditions were noted during the inspection: 1. Reported Sanitary Sewer Overflows. During the period of January 1, 2022, to July 15, 2024, there were 2 SSOs from the Briar Chapel collection system with a combined estimated volume of 90,200 gallons. The SSOs during this period, resulted in this office issuing the following notices. No fish kills were reported because of the SSO events. Reported Sanitary Sewer Overflows Notice Issued by Division of Water Resources-RRO September 5,2023 Notice of Violation June 25,2024 TBD D E` Q�� AxthGr taUr�arimci uiCuvuun'nrtwlQuality Uivisionotl�aterRetiuurces Ra eigh Regional Office moo Barrett Drive t Ralriah.North Carolina 176011 u.:.rr.�a.+n� 9Nt,iNIALItU Docusign Envelope ID:2E3F77BE-EF66-4B95-9FOA-892B2C2D054F Permittee,WQCS00372 July 18,2024 2. Fats, Oils and Grease Program. Old North State, hereinafter referred to as PERMITTEE, has developed and implements an educational fats,oils and grease program that includes at least bi-annual distribution of educational material targeted at both residential and non-residential users. The PERMITTEE has also developed and implements a FOG program for non-residential users. 3. Capital Improvement Plan. The PERMITTEE establishes and manages funding for wastewater collection system infrastructure maintenance and repair through annual budgeting. Funds are determined and based in accordance with the regulatory oversight of the NC Utilities Commission. 4. Contingency Plan for Pump Failure. The PERMITTEE maintains a general contingency plan for collection system and pump failure for the duplex pump stations and pipelines. Contracted services are available to assist with pumping and hauling if needed. Some pump stations(ie: Pump Station A and Pump Station H) have bypass pump connections for mobile pumps. Some duplex pump stations have generator connections for emergency backup power. Mr. White indicated that one mobile generator is available to serve the pump stations(located in Jacksonville, NC) that do not have a permanent onsite emergency generator. According to Mr. White, 480-volt pump stations that do not have quick connections or appropriate external connection for mobile generators would require contracted services to safely wire in portable generators. Pump stations currently listed in the Briar Chapel wastewater collection system permit do not match the number and naming convention of the duplex pump stations in operation. The permit lists only 8 of 13 pump stations in operation. Provide this office with a current and updated list of all duplex pump stations and include the following information: pump station name/identification, physical address, firm capacity, onsite emergency backup power/pump,type of station monitoring (telemetry/SCADA). The contingency plan for pump failure is a general contingency plan combined with a spill response plan that does not specifically list steps that will be taken to address pump station failures or how mobile generators, or mobile pumps will be deployed in the event of a failure or multiple pump station failures. Please update your contingency plan to provide more specificity on how response/deployment will take place in the event of a pump station or multiple pump station failures. Mr. White indicated that only one mobile generator is available and is located in Jacksonville NC which is approximately 150 miles or 2.5 hours from Briar Chapel. 5. Pump Stations Inspected. The following pump stations were visited and inspected. a) Woods Charter Pump Station • (2) submersible pumps • At the time of the inspection, the wet well and float controls were clean and clear of excessive grease and debris. • High-Level Alarm (audible.`visual) was tested and was functional during the inspection. Mission telemetry was operational and high-level alarm testing was received Page 2 of 6 Docusign Envelope 10:2E3F776E-EF66-4695-9FOA-892B2C20054F Permittee,WQCS00372 July 18,2024 through a smart phone by text and a phone call. • Pump station will facilitate the connection of a portable generator. b) Pump Station A • (2) 100 hp submersible pumps • Variable frequency drive starters • At the time of the inspection, the wet well and float controls were clean and clear of excessive grease and debris. • High-Level Alarm (audibleivisual) was tested and was functional during the inspection. • Misson telemetry was operational and high-level alarm testing was received through a smart phone by text and a phone call. • Permanent onsite generator • Bypass pumping connection. • Bioxide (Calcium Nitrate)odor control chemical feed • A generator functionality test was performed during the inspection by turning off the main power to the pump station. The generator automatically started and transferred power from the generator to the station. No alarm was received through Mission Telemetry for the loss of power or generator running. Mr. White indicated that he would check and correct all the pump station telemetry as a loss of power alarn should have been received. • A Pump#1 temperature alann was received from the Mission telemetry. Mr. White indicated that he would check the cause and correct the alarm condition. • Significant coupling bolt and ARV corrosion was noted in the valve vault. Please monitor the condition and take necessary corrective action prior to component failure. c) Pump Station H • (2) submersible pumps • Variable frequency drive starters • At the time of the inspection, the wet well and float controls were clean and clear of excessive grease and debris. • High-Level Alarm (audible/visual) was tested and was functional during the inspection. • Mission telemetry was operational and high-level alarm testing was received through a smart phone by text and a phone call. • Permanent onsite generator • Bypass pumping connection. • A generator functionality test was performed during the inspection by turning off the main power to the pump station. The generator automatically started and transferred power from the generator to the station. No alarm was received through Mission Telemetry for the loss of power or generator running. Mr. White indicated that he would check and correct all the pump station telemetry as a loss of power alarm should have been received. Page 3 of 6 Docusign Envelope ID:2E3F77BE-EF66-4B95-9FOA-89282C2D054F Permittee,WQCS00372 July 18,2024 d) SD East Pump Station • (2) 164 hp submersible pumps • At the time of the inspection, the wet well and float controls were clean and clear of excessive grease and debris. • High-Level Alarm (audible.'visual) was tested and was functional during the inspection. • VT SCADA was operational and high-level alarm testing was received through a smart phone. • Portable diesel driven pump is in place and connected to bypass pumping connection. Level floats automatically operate the bypass pump when the wet well level is high. e) 341 Monteith Drive Simplex Pump Station • (1)submersible grinder pumps • Wet-well and control cabinet are located beside the house and was accessible. • Simplex system included a high level audibleivisual alarm. PERMITTEE is responsible for maintenance and repair of 15 simplex pump systems. • Homeowners have appropriate contact information to report system problems or alarm conditions. Force Main Air Release Valve (ARV) — Pump Station A and SD East • Three ARVs were inspected and found to be operational and the isolation valve in the open position. No evidence of leaks was found during the inspection. Two ARVs inspected on 12-inch HDPE force main for Pump Station A, and one ARV inspected on HDPE force main for SD East pump station. g) Manholes Inspected — Wild Indigo Way, Saxapahaw'Great Ridge, and inlet to Pump Station H. • Wild Indigo Way was downstream of Margret Pollard Middle School. The manhole invert contained accumulated debris and grease. Wastewater was impacted but still flowing. Accumulations in the manhole and associated sewer lines should be inspected and cleaned to prevent a sewer backup and overflow. • Saxapahaw!Great Ridge and inlet to Pump Station H were clear of debris, defects, and were free flowing. 6. Pump Station Signage. Most pump stations had signage clearly and conspicuously posted that identifies the station,provides an emergency 24-hour contact telephone number(s), and provides instructions for notification if the visual alarm illuminates andr'or the audible alarm sounds, or if an emergency is apparent. Pump station A identification and emergency contact sign was not posted at the pump station. Part 1(8.) of your permit requires that"Each pump station shall be clearly and conspicuously posted with a pump station identifier and an emergency contact telephone number...". Post a pump station Page 4 of 6 Docusign Envelope ID:2E3F77BE-EF66-4B95-9FOA-892B2C2DO54F Permittee,WQCS00372 hily 18,2024 identification and emergency contact sign at Pump Station A or any other pump station without a sign as soon as possible. 7. Pump Station Restricted Access. The pump station sites, equipment and components were observed to have restricted access. All pump stations were secured with a perimeter fence and locked gate. 8. Pump Stations Automatic Polling Feature. The pump stations are equipped with Mission telemetry or VT SCADA that allow the PERMITTEE routine contact with the pump station from an electronic device(laptop;phone) to check the operational status of the communication system. During the inspection, the Mission telemetry and VT SCADA acknowledged the alarms when the high-water float was activated. 9. Pump Station High Water Alarms. The pump stations are equipped with audible and visual high-water alarms. During the inspection, these alarms functioned properly. The operator received the high-water alann remotely to their smart phone. 10. Pump Station Inspection Program. The PERMITTEE has developed and implements a weekly routine inspection of each pump station that includes the following maintenance activities: cleaning and removing debris from the pump station area and wet well; inspecting all valves; inspecting pumps and other mechanical equipment; and verifying the proper operation of the alarms, telemetry system and auxiliary equipment. The inspector reviewed the inspection logs of the pump stations visited and observed adequate entries of the date and time of the operator's inspection, observations made, and any maintenance, repairs, or corrective actions taken. Service Link work order system is utilized for managing and recording system operation and maintenance tasks. 11. Designated Operators. The PERMITTEE wastewater collection system is classified as a Class 2 system, and the designated certified Operator in Responsible Charge (ORC) and back-up ORC on record are Robert Charles (Chip)White and Backup ORC Carley Marie White. The certification status for each operator is reflected as active in the Division's data system. 12. Cleaning Sewer Lines. The PERMITTEE has developed and implements a program for cleaning the sewer lines. As required by Section 11.8 of the subject permit, at least 100 o of the wastewater collection system should be cleaned each year. Preventative cleaning is not required for sewer lines less than five years old, unless an inspection reveals the need for cleaning. Mr. White provided a record during the inspection that approximately 12-percent of sewer line were cleaned in calendar year 2023. 13. Spill Response Action Plan.The PERMITTEE has developed and maintains a general Spill Response Action Plan that includes 24-hour contact numbers, response time (within 35 minutes), equipment list and spare parts inventory, access to cleaning equipment, access to construction crews, sources of emergency funds, site sanitation and cleanup materials, and post-SSO assessment. The Permittee may utilize contracted services to assist in sewer spill cleanup and major infrastructure repair. 14. SSO Records. The PERMITTEE has maintained adequate records pertaining to SSOs and sewer complaints for the three-year period ending May 2024. The last reportable SSO occurred on June 25,2024. According to Mr. White, no non-reportable SSOs Page 5 of 6 Docusign Envelope ID:2E3F77BE-EF66-4B95-9FOA-89262C2DO54F Permittee,WQCS00372 July 18,2024 occurred for the last three years. The inspector reminded Mr. White that all SSOs whether reportable on non-reportable should be documented and recorded as required in Section III (2.) of the permit. 15. Comprehensive Sewer Map. The PERMITTEE maintains an up-to-date comprehensive GIS based map of its sewer collection system. The map includes pipe size, pipe material, pipe location, flow direction, approximate pipe age, number of active service taps, and each pump station identification, location and capacity. 16. Inspection of High Priority Lines. The PERMITTEE lists 4 high priority lines in the permit or have high priority lines associated with their system. According to Mr. White, one high priority line was added due to creek bank erosion and monitors the high priority lines at least semi-annually. Please provide this office with a written response to items 4 and 6 above no later than September 30, 2024. The overall condition of the collection system was compliant with the wastewater collection system permit requirements observed on the day of the inspection. If you have questions or comments about this inspection or the requirements to take corrective action if applicable, please contact Donald Smith at 919-791-4234. Sincerely, �Dotuftned by: �/AtA GSSdt. `�. A,atu,lIA 62916EBA632144F Vanessa E. Manuel, Assistant Regional Supervisor Water Quality Regional Operations Section Raleigh Regional Office Division of Water Resources, NCDEQ Altachment(s): Collcclion System Inspection Report Cc: Laserfiche Page 6 of 6 Docusign Envelope ID:2E3F77BE-EF66-4B95-9FOA-89282C2DO54F Compliance Inspection Report Permit:WQCS00372 Effective: 03/07/18 Expiration: 07/31/26 Owner: Pluris Hampstead LLC SOC: Effective: Expiration: Facility: Briar Chapel Collection System County: Chatham Region: Raleigh Contact Person:Sean McMillan Title: VP of Busines Development Phone:205-326-6858 Directions to Facility: System Classifications: CS2, Primary ORC: Robert Charles White Certification: 1008730 Phone:336-549-8990 Secondary ORC(s): On-Site Representative(s): Related Permits: W00028552 Pluris Hampstead LLC- Briar Chapel WWTP Inspection Date: 0711612024 Entry Time 09 30AM Exit Time: 02 00PM Primary Inspector:Donald Smith DucuSigneaoy 7/18/2024 Phone: 919-791-4234 Secondary Inspector(s): I �* C." 512EP5247FA847A Reason for Inspection: Routine Inspection Type: Collection System Inspect Non Sampling Permit Inspection Type: Collection system management and operation Facility Status: M Compliant Not Compliant Question Areas: Miscellaneous Questions General Sewer&FOG Ordinances Capital Improvement Plan Map Reporting Requirements Inspections Spill Response Plan Spills Lines Manholes Pump Stations (See attachment summary) Page 1 of 7 Docusign Envelope IO 2E3F77BE-EF66-4B95-9FOA-892B2C20054F Permit: WOCS00372 Owner-Facility:Pluris Hampstead LLC Inspection Date: 071612024 Inspection Type:Collection System Inspect Non Sampling Reason for Visit: Routine Inspection Summary: The overall condition of the collection system was compliant with the wastewater collection system permit requirements observed on the day of the inspection. Page 2 of 7 Docusign Envelope ID:2E3F77BE-EF66-4895-9FOA-892B2C2DO54F Permit: WQCS00372 Owner-Facility:Pluris Hampstead LLC Inspection Date: 07116/2024 Inspection Type:Collection System Inspect Non Sampl ng Reason for Visit: Routine General Yes No NA NE Is there a property designated primary ORC and at least one back-up of proper grade? No ❑ ❑ Are logs being reviewed by the system management or owner on a regular basis? M ❑ Cl ❑ #What is that frequency? Weekly #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? ❑ ❑ ❑ Does the permittee have a copy of their permit? ❑ ❑ ❑ #Is permit expiring within the next 6 months? ❑ 0 ❑ ❑ If Yes,has the Permittee applied for renewal? ❑ ❑ ❑ ❑ Comment: Pump failure plan is general and combined with their spill reponse plan. Plan needs updating with more specificity on how resoponse to failures will take place. Only mobile generator is located in Jascksonville NC. Sewer and FOG Ordinances Yes No NA NE Is Sewer Use Ordinance(SUO)or other Legal Authority available? ❑ M ❑ ❑ Does it appear that the Sewer Use Ordinance is enforced? M ❑ ❑ ❑ Is there a Grease Control Program that legally requires grease control devices? M ❑ ❑ ❑ What is the standard grease trap cleaning requirement in the FOG ordinance? Quarterly Is Grease Control Program enforced via periodic inspections/records review? M ❑ ❑ ❑ Is action taken against violators? M ❑ ❑ ❑ #Have satellite systems adopted an equivalent or more stringent ordinance? ❑ ❑ M ❑ Is grease/sewer education program documented with req'd customer distribution? MCI ❑ ❑ #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.) Comment: Sewer use is managed through customer account. Service cut-off if non-compliant. Capital Improvement Plan Yes No NA NE Has a Capital(CIP)or System Improvement Plan been developed and adopted? ❑ ❑ M ❑ 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? ❑ Cl 0 ❑ Does CIP include description of existing facilities? ❑ ❑ 0 ❑ Does CIP include known deficiencies? ❑ ❑ M ❑ Does CIP include forecasted future needs? ❑ ❑ 0 ❑ Comment: Maintenance and repair are managed through annual budget and as stipulated through NC Utilities Commission Page 3 of 7 Docusign Envelope ID:2E3F77BE-EF66-4B95-9FOA-892B2C2DO54F Permit: WOCS00372 Owner-Facility:Pluris Hampstead LLC Inspection Date: 0 7/1 612 0 24 Inspection Type:Collection System Inspect Non Sampling Reason for Visit: Routine Map Yes No NA NE Is there a overall sewer system map? 0 ❑ ❑ ❑ Does the map include: Pipe Type(GSIFM) 0 ❑ ❑ ❑ Pipe sizes 0000 Pipe materials(PVC,DIP,etc) 0 ❑ 1111 Pipe location 0 ❑ ❑ ❑ Flow direction 0 ❑ ❑ ❑ Approximate pipe age M ❑ ❑ Cl Pump station ID, location and capacity M ❑ ❑ Cl # Force main air release valve location&type 0 ❑ ❑ ❑ # Location of satellite connections ❑ ❑ M ❑ Is the map being updated for changes/additions within 1 year of activation? M ❑ ❑ ❑ Comment: No satellite connections Reporting Reauirements Yes No NA NE #Have there been any sewer spills in the past 3 years? M ❑ ❑ ❑ If Yes,were they reported to the Division if meeting the reportable criteria? 0 ❑ ❑ ❑ If applicable, is there documentation of press releases and public notices issued? ❑ ❑ M ❑ Is an Annual Wastewater Performance Report being filed with the Division,if required? 0 ❑ ❑ ❑ Is the report being made available to all its sewer customers? M ❑ ❑ ❑ #How is it being made available? Included in bill Comment: Inspections Yes No NA NE Are adequate maintenance records maintained? 0 ❑ ❑ ❑ Are pump stations being inspected at the required frequency? M ❑ ❑ ❑ # 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? M ❑ ❑ ❑ Is the annual inspection documented? M ❑ ❑ ❑ #Does the system have any high-priority lines/locations? M ❑ ❑ ❑ Are inspections of HPL documented at least every 6 months? M ❑ ❑ ❑ Are new lines being added to the HPL list when found or created? M ❑ ❑ ❑ Comment: ORC added a new HPL not currently listed in permit. Spill Response Action Plan Yes No NA NE Is a Spill Response Action Plan available? M ❑ ❑ ❑ Is a Spill Response Action Plan available for all personnel? M ❑ ❑ ❑ Page 4 of 7 Docusign Envelope ID:2E3F77BE-EF66-4895.9FOA-892B2C2DO54F Permit: WOCS00372 Owner-Facility:Pluris Hampstead LLC Inspection Date: 0711612024 Inspection Type:Collection System Inspect Non Sampling Reason for Visit: Routine Does the plan include: 24-hour contact numbers ❑ ❑ ❑ Response time N ❑ 110 Equipment list and spare parts inventory E ❑ ❑ ❑ Access to cleaning equipment 0 ❑ ❑ ❑ Access to construction crews,contractors, and/or engineers 0 ❑ ❑ ❑ Source of emergency funds 0 ❑ ❑ ❑ Site sanitation and cleanup materials E ❑ ❑ ❑ Post-overflow/spill assessment E ❑ ❑ ❑ Does the Permittee appear to respond within 2 hours of first knowledge of a spill? E ❑ ❑ ❑ Comment: ORC responds to all spiils, per ORC Spllls Yes No NA NE Is system free of known points of bypass? E ❑ ❑ ❑ If No, describe type of bypass and location Are all spills or sewer related issues/complaints documented? N ❑ ❑ ❑ #Are there repeated overflows/problems (2 or more in 12 months)at same location? ❑ N ❑ ❑ #If Yes, is there a corrective action plan? ❑ ❑ 0 ❑ Comment: Reminded ORC that all reportable and non-reportable spills must be recorded in accordance with germit re uirements. Lines/Right-of-Ways/Aerial Lines Yes No NA NE Please list the Lines/Right of Ways/Aerial Lines Inspected: Pump Station A-Force Main easement Are right-of-ways/easements maintained for full width for access by staff/equipment? 0 ❑ ❑ ❑ If No,give details on temporary access: Is maintenance documented? 001111 Are gravity sewer cleaning records available? N ❑ ❑ ❑ Has at least 10%of lines older than 5 yrs been cleaned annually? 0 ❑ ❑ ❑ Were all areas/lines inspected free of issues? 0 ❑ ❑ ❑ Comment: —12% sewer line cleaned in calendar year 2023 Manholes Yes No NA NE Please list the Manholes Inspected: Wild Indigo Way, Saxapahaw/Great Ridge, inlet manhole to Pump Station H. Are manholes accessible? E ❑ ❑ ❑ #Are manhole covers/vents above grade? E ❑ ❑ ❑ Are manholes free of visible signs of overflow? N ❑ ❑ ❑ Are manholes free of sinkholes and depressions? E ❑ ❑ ❑ Are manhole covers present? E ❑ ❑ ❑ Page 5 of 7 Docusign Envelope ID:2E3F77BE-EF66-4695-9FOA-892B2C2DC54F Permit: WQCS00372 Owner-Facility:Plur s Hampstead LLC Inspection Date: 07/16/2024 Inspection Type:Collection System Inspect Non Sampling Reason for Visit: Routine #Are manholes properly seated? #Are manholes in good condition? #Are inverts in good condition? 0 ❑ 11 ❑ Is Flow unrestricted in manholes? 0 ❑ ❑ El Are manholes free of excessive amounts of grease? ❑ M ❑ Are manholes free of excessive roots? 0 ❑ ❑ Are manholes free of excessive sand? Are manhole vents screened? Are vents free of submergence? Are manholes free of bypass structures or pipes? 0 0 El El Comment: Grease and debris noted in Wild Indigo manhole, Inspect and clean as necessary to prevent a backup and overflow Pump Stations Yes No NA NE Please list the Pump Stations Inspected: Pump Station A,Woods Charter Pump Station,Pump Station H, and SE East Pump Station #Number of duplex or larger pump stations in system 13 #Number of vacuum stations in system 0 #Number of simplex pump stations in system 15 #Number of simplex pump stations in system serving more than one building 0 How many pump/vacuum stations have: # A two-way"auto polling"communication system(SCADA)installed? 1 # A simple one-way telemetry/communication system(auto-dialer)installed? 12 For pump stations inspected: Are they secure with restricted access? 0 ❑ ❑ ❑ Were they free of by-pass structures/pipes? 0 ❑ ❑ ❑ Were wet wells free of excessive grease/debris? M ❑ Cl Cl # Do they all have telemetry installed? 0 ❑ ❑ ❑ Is the communication system functional? 0 ❑ ❑ 0 Is a 24-hour notification sign posted? 0 Does the sign include: Owner Name? Pump station identifier? MEl ❑ Cl # Address? 0 ❑ ❑ ❑ Instructions for notification? M ❑ 0 ❑ 24-hour emergency contact numbers? M 0 [l Are audio and visual alarms present? 00 Are audio and visual alarms operable? Page 6 of 7 Docusign Envelope ID:2E3F77SE-EF66.4B95.9FOA•89262C2D054F Permit: WQCS00372 Owner-Facility:Plur,s Hampstead LLC Inspection Date: 0716/2024 Inspection Type:Collection System nspe�t W:n Sampling Reason for Visit: Routine #Is there a backup generator or bypass pump connected? 0 ❑ ❑ ❑ If tested during inspection,did It function properly? M ❑ ❑ ❑ Is the back-up system tested at least bi-annually under normal operating conditions? 0 ❑ ❑ ❑ #Does it have a dedicated connection for a portable generator? 0 ❑ ❑ ❑ #Is the owner relying on portable units in the event of a power outage? 0 ❑ ❑ ❑ #If Yes,is there a distribution plan? ❑ 0 ❑ ❑ If Yes,what resources (Units/StaffNehicles/etc)are included in Plan? one mobile generator located in Jacksonville NC. Contractors leveraged for response and assistance. #Does Permittee have the approved percentage of replacement simplex pumps? M ❑ ❑ ❑ Is recordkeeping of pump station Inspection and maintenance program adequate? M ❑ ❑ ❑ Do pump station logs include at a minimum: Inside and outside cleaning and debris removal? 0 ❑ ❑ ❑ Inspecting and exercising all valves? ■ ❑ ❑ ❑ Inspecting and lubricating pumps and other equipment? 0 ❑ ❑ ❑ Inspecting alarms,telemetry and auxiliary equipment? 0 ❑ ❑ ❑ Comment: Pump station contingency plan needs more detailed information on how to response to failures Page 7 of 7