WQCS00217_Compliance Evaluation Inspection_20240904

Docusign Envelope ID: 15989A11-6F97-46E2-9C45-6280180CDBE0
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ROY COOPER ' f �
Governor �_. �;} •' 1
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR. *`$`Qtmm
Director NORTH CAROLINA
Environmental Quality
September 4,2024
Carolina Trace Collection System
Carolina Trace Utilities,Inc.
Attention: Tony Konsul
P.O. Box 240908
Charlotte,NC 28224-908
Subject: System-wide Collection System Permit
Carolina Trace Utilities,Inc.
Permit No.: WQCS00217
Lee County
Mr.Konsul:
On August 21, 2024,Danny Smith,Tanvir Pasha, and Myles Parker from the Raleigh Regional Office of the
Division of Water Resources conducted a Compliance Evaluation Inspection(CEI)of the Wastewater
Collection System for the Carolina Trace Utilities,Inc. The purpose of this visit was to review the facility's
compliance with the subject System-wide Collection System Permit. During the inspection,the presence and
cooperation of Christopher Godfrey Operator in Responsible Charge(ORC),Dean Miller Lead Operator, and
Ronnie Dickens, Operator were greatly appreciated and very helpful to this review process.
This compliance evaluation inspection addressed the following:
• Review of the owner/facility information.
• Review of June 30,2021-July 31,2024 Sewer System Overflow compliance history.
• On-site inspection of the system records.
• On-site inspection of select pump stations,high-priority lines, and easements/ROWs.
• Requested additional information/written response(see items#6,8-Country Club PS, and 11).
Findings during the pre-inspection file review and the site visit were as follows:
1. Permit renewal. The current Collection System Permit(WQCS00217)was issued effective January 23,
2024 and will expire December 31,2031.
2. Collection system description. The collection system consists of 39.7 miles of gravity sewer line and 5.3
miles of force main.
Pump stations totals:
-Simplex pump stations serving single building n=0(Note: the previously listed seven(7) simplex pumps
are now privately owned.)
-Simplex pump stations serving multiple building n=0
-Duplex pump stations n=5 (note: The 6t'pumpstation located at Carolina Trace is not a part of the
collection systems. This pump station is located at the wastewater treatment plant and is part of the
WWTP's influent.)
3. Sewer System Overflows. A DWR BasinWide Information Management System(BIMS) database review
of the reported Sewer System Overflows from Carolina Trace for June 30, 2021,through July 31,2024,
revealed twelve(12)reported sewer system overflows. The volume reported for the twelve(12) SSO
events totaled 23,040 gallons. For the twelve SSO events that occurred during this review period,the
North Carolina Department of Environmental Quality I Division of Water Resources
D_E 512 North Salisbury Street 1 1617 Mail Service Center I Raleigh,North Carolina 27699-1617
919,707.9000

Docusign Envelope ID: 15989A11-6F97-46E2-9C45-6280180CDBE0
Carolina Trace Collection System
System-wide Collection System Permit
Compliance Evaluation Inspection-Permit No. WQCS00217
Page 2 of 5
reported total amount estimated to have reached surfaced waters was 21,680 gallons. Roots were identified
as the cause for 66%of the SSOs events during this period.
4. Collection System Operators. The Carolina Trace Collection System is classified as a CS-2. Carolina Trace
Utilities, Inc.has designated Stephen Boyd Harrell as the facility's ORC and Dean Ray Miller as the backup
ORC (bORC). Stephen Boyd Harrell has a Grade CS-4(Cert#995549)and Dean Ray Miller has Grade CS-
1(Cert#997978)operator designation. The certification status is"Active"for each of the above listed
operators.
During the inspection Mr. Godfrey explained he is currently performing the ORC role for the Carolina Trace
collection system and Mr. Stephen Harrell is now the Area Manager.
Please update the designation(s) and request removal of ORCs as appropriate to reflect current system
operations.
For your reference operator designation and removal forms can be found at the DWR's Operator
Certification web site.
htttp://www.deq.nc.gov/about/divisions/water-resources/operator-certification
or
https://www.deq.nc.gov/about/divisions/water-resources/operator-certification/wastewater-
operator/downloads-links#ORCFormsOperatorDesignationResignation-9234
5. Fees. The required Annual Administering and Compliance Monitoring Fee for the current billing period has
been paid. There are no overdue fees.
6. Annual Report [143-215.1C]. Permittees who own or operate facilities that collector treat municipal or
domestic waste are required to provide an annual report to its users/customers summarizing the performance
of the collection or treatment system. The report shall be provided no later than sixty days after the end of
the calendar or fiscal year.
A copy of Carolina Trace Utilities'Annual Report was not available for review) during the onsite
inspection. Please provide this office a copy of the 2023 annual report for Carolina Trace Utilities within
60 days of receipt of this letter.
7. Pump stations. Five(5)pump stations were visited during the inspection(South Landing,Harbor Creek,
Woodfield, Country Club and Laurel Thicket Landing). Inspection logs are maintained for all lift station
visitations and data for each station is kept electronically.
South Landing,Harbor Creek and Woodfield Pumpstations. These stations had identification signage,
secured access,appeared in good condition and was free of excess debris. The audible and visual
alarms functioned and notification/call back for high wet-well levels were received when high water
level floats were tested.
Laurel Thicket PS. This station had identification signage, secured access, appeared in good condition.
The audible alarms functioned, standby power, and notification/call back for high wet-well levels were
received when high water level floats were tested. This station was observed to have some
accumulations of grease. The visual alarm for this pumpstation did not work during the system test.

Docusign Envelope ID: 15989A11-6F97-46E2-9C45-6280180CDBE0
Carolina Trace Collection System
System-wide Collection System Permit
Compliance Evaluation Inspection-Permit No. WQCS00217
Page 3 of 5
Please make replace or repair visual alarm for the Laurel Thicket Pump Station.
Country Club PS. During the inspection the Mr. Godfrey explained that one of the pumps for the
Country Club PS had been removed/sent out for repairs. Later during the inspection,Mr. Godfrey
received a highwater notification for Country Club PS. [Note: It was observed that the ORC was
immediately responsive to the highwater notification, including contacting a contractor to respond
onsite to initiate pump station repairs. Mr. Godfrey explained to the inspectors that a contractor was in
route and was anticipating the contractor to be onsite later in the afternoon(within a couple of hours).
In addition,the ORCs were able to clear(or partially clear)the pump at the Country Club PS,enabling
draw down to start.]
The Country Club PS was observed to have identification signage,the notification/call back in response
to an"in process"high water level event functioned properly. The audible and visual alarms functioned
when tested. This station was observed to have accumulations of grease and the pump station did not
have secure access and was operating on one(1)pump(the other had been removed for servicing)
Please address the following items in your written response:
1)Please explain when the pump was removed for repair and when the pump was reinstalled/put
back into service. Please detail what repairs were performed to the pumpstation's 2nd pump and what
measures were used fix highwater concerns for this lift station.
2) This pump station does not have "secure access"as required by the permit. Please explain how
and when the secure access for this pumpstation will be achieved.
3)Please address in your response, ifparts are readily available for this pumpstation,given the
system's age.
4) Corrosion causing structural debris(mortar, brick and corroded metal etc.)to fall into the wet well
possibly causing damage to system operations. Please discuss/assess the wiring,panel, and
structural integrity of this pumpstation with respect reliable/sustainable operational status and any
plans to overhaul or replace this pumpstation.
5)Concerns include age and corrosion of this pump station. In your response,specifically address
the brick-and-mortar integrity of the wet well. Please address/ensure wastewater is contained in the
wet well such that infiltration or wastewater seepage through the wet well wall is not occurring.
Note: This office recognizes that the system operators received highwater notification, sought out a
contractor to address repairs, and performed measure(s)to help address pump blockage,while continuing to
be responsive and actively assisting the inspectors with this inspection. This office recognizes this and
appreciates their responsiveness/professionalism regarding these matters.
8. Pump Station Contingency Plan. A Pump Sation Contingency Plan was not available for review or located
as required by the permit for each respective pumpstation.
Part I,Item 7. "The Permittee shall maintain a contingency_plan for pump failure at each pump station. If
one of the pumps in a pump station containing multiple pumps fails,the process of repairing or replacing the
pump shall be initiated immediately and the new parts or pump shall be installed as soon as possible. The
permittee shall provide justification for delay in initiating the process for repair or replacement at the
Division's request. If the pump in a simplex pump station serving more than a single building or pump
stations not capable of pumping at a rate of 2.5 times the average daily flow rate with the largest pump out
of service fails, it shall be replaced immediately. [15A NCAC 02T .0305(h)(1)]"

Docusign Envelope ID: 15989A11-6F97-46E2-9C45-6280180CDBE0
Carolina Trace Collection System
System-wide Collection System Permit
Compliance Evaluation Inspection-Permit No. WQCS00217
Page 4 of 5
Please make the necessary changes to ensure the Pump Station Contingency Plan as well as document
storage is available to address pump failure at each pump station.
9. Sewer line cleanings,inspections, and easement maintenance. The Carolian Trace Utilities cleans and
documents/tracks the cleaning of their sewer lines. Carolian Trace Utilities uses logs to document and track
the maintenance of easements. The records indicate Carolina Trace Utilities' sewer line cleaning efforts
achieves the requisite of 10%per year. (All of the 39 miles of sewer line have been cleaned in last 7 years.)
10. Capital Improvement Plan, The Capital Improvement Plan was available for review. This document covered
1/1/2019 through 12/31/2024 with an approximately $50,000 available for point repairs and cleaning
(infiltration sewer main repairs), for each respective year.
Part I, condition 5 of the System-wide Collection System permit states the following:
"The Permittee shall adopt and implement a Capital Improvement Plan(CIP)to designate funding for
reinvestment into the wastewater collection system infrastructure. The CIP should address the short-term
needs and long-term"master plan" concepts. The CIP should typically cover a three to five year period and
include a goal statement, description of the project area, description of the existing facilities,known
deficiencies (over a reasonable period)and forecasted future needs. Cost analysis is integral to the CIP.
[G.S. 143-215.9B] "
This CIP document available for review indicated that planning coverage ends 1213112024. Please ensure
the CIP continues to be periodically updated and ensure that the CIP address the short-term needs and long-
term "master plan"concepts.
11. High Priority Lines(HPLs). During the site visit the following high priority sewer lines were
inspected/visited:
HPL-Dam, South Side of Lake—DIP 12": Aerial crossing A significant amount of bank erosion had
occurred due to a recent storm event(s). Erosion daylighted portions of the previously buried 12"pipe and
eroded streamside material(earthen)from portion of the manhole (the cone/riser). This is located on left
bank of the Upper Little River and will need to be stabilized and monitored to ensure structural stability is
not compromised. Also, a tree had fallen across the sewer easement near this location and is partially
obstructing or may inhibit truck traffic and manhole access at this location.
In your written response,please detail measures taken to address the stabilization of this HPL. (These
observations were primarily focused on the left bank of the Upper Little River. Please ensure the
opposite stream bank and easement is stable/secure.)
HPL 1A-Traceway North(manhole#1):During the inspection the manhole cover was removed revealing
that wastewater was backed up in the collection system due to ongoing pump failure(s) at the Country Club
Pumpstation.
HPL—5041 Bluebird Drive: two 4-inch laterals(from two separate Single family residences) converge into
one 4 inch and then into a 8 inch line. These connections were all above ground(on the left bank) and
formed an 8-inch line that crossed the creek. A small tree limb was observed on DIP with no signs of
damage. This DIP was supported by short(6-12") columns/poured concrete blocks. Please continue to
periodic review these supports to ensure overbankflow and/or age (weathering) does not eventually cause
the supports to erode, shift or otherwise fail.

Docusign Envelope ID: 15989A11-6F97-46E2-9C45-6280180CDBE0
Carolina Trace Collection System
System-wide Collection System Permit
Compliance Evaluation Inspection-Permit No. WQCS00217
Page 5 of 5
HPL—5055 Bluebird Drive: This DIP aerial line appeared to be strait/vertical. A nearby manhole located
landward of the stream bank exhibited what appeared to be signs of sloughing or a depression,
concentrically around the riser.
It appears that stormwater water is eroding soil from around the sewer line. The source(s) appear to be
both water coursing along the annular space(underground around the outside of the buried sewer pipe)
from the manhole riser to the creek as well as from episodic high stream flow events.
Please inspect this HPL to determine if sewer line repair(s) or other protective measures are necessary.
Please be sure to document this information and consider increased HPL visit/inspections in your
maintenance record(s) documentation.
12. Right-of-Way. Right-of-Ways observed during the inspection included those associated with or in near
proximately to pump stations and the abovementioned HPLs. Beyond the observations listed above,no
other issues of concern were noted, and all areas were observed to maintained, as appropriate.
13. Fates Oil and Grease Program(FOG). FOG education/information is distribution in billing invoice and
these material area also available on line.
Please continue to ensure that Fates Oil and Grease education material are distributed twice a year(bi-
annual) as required by your permit.
14. Collection System Map. An up-to-date map of the collection system is available.
Thank you for your attention to this matter. Please respond in writing to this correspondence within 60
days of receipt. Please address items 6,7(Country Club Pump Station), and 11 (HPL 12"DIP South side
Lake,Dam)in your response.
If you have questions or comments about the inspection,this report or the requirements to take corrective action
(if applicable),please contact Danny Smith at(919) 791-4248 (danny.smith&deq.nc.gov)or me at 919-791-
4232 or via email at Vanessa.Manuel(fdeq.nc.gov.
Sincerely,
Signed by:
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B2916HAB32144F...
Vanessa Manuel,Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources,NCDEQ
Cc: Laserfiche
Stephen Harrell- Stephen.Harrellknexusw
Christopher Godfrey-Christopher.Godfrey(a),nexuswg com