WQCS00333_Compliance Evaluation Inspection_20200827

DocuSign Envelope ID: 772F4F51-693A-4986-AOA8-78DO7B12E4E9
ROY CooPEA
Governor
MICHAEL S. PEGAN
Sep t—y
S. DANIEL SMITH
Drrermr
,.,srnreq
NOR7W CAROLINA
Environmental Qaality
October 05, 2020
David A Hollis
Town of Leland
102 Town Hall Dr
Leland, NC 28451
SUBJECT: NOTICE OF VIOLATION
Tracking Number: NOV-2020-PC-0438
Permit No. WQCS00333
Leland Collection System
Brunswick County
Dear Permittee:
The North Carolina Division of Water Resources conducted an inspection of the Leland Collection System on
August 27, 2020. This inspection was conducted to verify that the facility is operating in compliance with the
conditions and limitations specified in Collection System Permit No. WQCS00333. A summary of the findings and
comments noted during the inspection are provided in the enclosed copy of the inspection report.
The compliance evaluation inspection was conducted by Division of Water Resources staff from the
Wilmington Regional Office. The following violation(s) were noted during the inspection:
Inspection Area Description of Violation
Pump Stations Several pump stations were noted to have visual alarms screened by fencing and/or
vegetation and some whereby the audible alarm was insufficient to attract attention.
Each station needs to be evaluated for these issues and corrections made. This issue
was pointed out during the 2016 inspection as well.
Sewer and FOG Ordinances The Town's FOG inspection & enforcement program has taken a backseat in recent years
and needs to become a priority again
Remedial actions should have already been taken to correct this problem and prevent further occurrences in the
future. The Division of Water Resources may pursue enforcement action for this and any additional violations of
State law.
�rw North Ca—,ms Department of Environmental Qualrtv 6!vsvn of Water Resources
lVf ) Wdrn:ngw eg+�neiaff;ce 1127 Ca NimlDnve Eztensan N5lmirg-, North :ara-na7S40.5
910-796-7215

DocuSign Envelope ID: 772F4F51-693A-4986-AOA8-78DO7B12E4E9
If you should have any questions, please do not hesitate to contact Dean Hunkele with the Water Quality
Regional Operations Section in the Wilmington Regional Office at 910-796-7215.
Sincerely,
EDocuSigned by:
Cow 'llnarriuA,
7F141E7366F3456...
Tom Tharrington, Asst. Regional Supervisor
Water Quality Regional Operations Section
Wilmington Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS
Cc: Upload to Laserfiche
�E North Caro G ma Department of Environmental Quality I Dioision of Water Resources
W lmingon Reg—] office I 127 Cardinal Dave Exteason I Wilmington, North Carof ma 23405
91D-796-7215

Compliance Inspection Report
Permit: WQCS00333 Effective: 09/01/17 Expiration: 08/31/25 Owner : Town of Leland
SOC: Effective: Expiration: Facility: Leland Collection System
County: Brunswick
Region: Wilmington
Contact Person: Brandon W Faircloth Title: Utilities Supervisor Phone: [phone]
Directions to Facility:
System Classifications: CS2,
Primary ORC: Brandon Warren Faircloth Certification: 999561 Phone: [phone]
Secondary ORC(s):
Michael Wayne Flynn 1007736 910-409-6388
On -Site Representative(s):
24 hour contact name Brandon W Faircloth 910-508-4076
On -site representative Brandon W Faircloth 910-508-4076
Related Permits:
WQCS00284 Brunswick County - Brunswick County Collection System
NC0086819 Brunswick County - Northeast Brunswick Regional WWTP
Inspection Date: 08/27/2020 Entry Time 09:30AM Exit Time: 03:30PM
Primary Inspector: Dean Hunkele Docusigned by: Phone: [phone]
Secondary Inspector(s): EE 10/5/2020
E1 D9294C4D3746E...
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 Manholes Pump Stations
(See attachment summary)
Page 1 of 7

Permit: WQCS00333 Owner - Facility: Town of Leland
Inspection Date: 08/27/2020 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Inspection Summary:
Overall, the Town is making great strides in improving its management and oversight of the collection system, Staff should
review comments in the report and make changes as needed and applicable.
The following items were noted that need to be addressed:
1. Several pump stations were noted to have visual alarms screened by fencing and/or vegetation and some whereby the
audible alarm was insufficient to attract attention. Each station needs to be evaluated for these issues and corrections
made. This issue was pointed out during the 2016 inspection as well.
2. The Town's FOG inspection & enforcement program has taken a backseat in recent years and needs to become a
priority again.
A Notice of Violation for items above is being issued.
Page 2 of 7

Permit: WQCS00333
Inspection Date: 08/27/2020
Owner - Facility: Town of Leland
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
General
Is there a properly designated primary ORC and at least one back-up of proper grade?
Are logs being reviewed by the system management or owner on a regular basis?
# What is that frequency?
# Are there any issues being addressed currently or any in the planning stages?
Is there a specific pump failure plan available for all pump stations?
Does plan indicate if pump parts/new pumps are in spare parts/equipment inventory?
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?
If Yes, has the Permittee applied for renewal?
Yes No NA NE
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weekly
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Comment: One project to correct an issue is the planned extension of the FM from LS #17 along Pine
Harvest Dr to a deeper manhhole. The Town has a general plan for pump station pump fail
but it could use more formality.
Sewer and FOG Ordinances
Yes No NA NE
Is Sewer Use Ordinance (SUO) or other Legal Authority available?
❑
❑ ❑
Does it appear that the Sewer Use Ordinance is enforced?
❑
❑ ❑
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?
staff said 90 days,
but SUO
says 30
days
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.)
On website and included with the annual wastewater report to customers
Comment: Town reauires arease trap cleanina records to be submitted to the Town. The Town needs to
resurrect its periodic commercial FOG control inspection program and take action for
non-compliance. Issuance of low-cost annual grease control permits were discussed as option
to fund its inspection and education program.
Capital Improvement Plan Yes No NA NE
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? ❑ ❑ ❑
Does CIP cover three to five year period of earmarked improvements? ❑ ❑ ❑
Does CIP include description of project area? ❑ ❑ ❑
Page 3 of 7

Permit: WQCS00333 Owner - Facility: Town of Leland
Inspection Date: 08/27/2020 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Does CIP include description of existing facilities?
Does CIP include known deficiencies?
Does CIP include forecasted future needs?
Comment: Full CIP requested but not provided - just a line item and budget. Need to ensure more formal
CIP is developed, implemented, and available.
Map Yes No NA NE
Is there a overall sewer system map? 0 ❑ ❑ ❑
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?
❑ ❑ ❑
❑ ❑ ❑
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Comment: The Town has its system mapped electronically and is working on implementing a complete GIS
system. Maps observed and provided previously have some of the information above, but lacks
some which should be added in some manner. Need to ensure newly certified & activated
sewer is added to the map within 1 year.
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? 0 ❑ ❑ ❑
# How is it being made available? on website
Comment: Were mailing report to generic DWR address and were not being shown as received by Raleigh;
provided better address to staff.
Inspections Yes No NA NE
Are adequate maintenance records maintained? 0 ❑ ❑ ❑
Are pump stations being inspected at the required frequency? ❑ ❑ ❑
# Is at least one complete functionality test conducted weekly per pump station? ❑ ❑ ❑
Is there a system or plan in place to observe the entire system annually? ❑ ❑ ❑
Is the annual inspection documented? ❑ ❑ ❑
Page 4 of 7

Permit: WQCS00333 Owner - Facility: Town of Leland
Inspection Date: 08/27/2020 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
# Does the system have any high -priority lines/locations?
Are inspections of HPL documented at least every 6 months?
Are new lines being added to the HPL list when found or created?
• ❑ ❑ ❑
• ❑ ❑ ❑
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Comment: Town staff indicates that it observes system via normal visitation to Dump stations and cleanin
of lines.
Spill Response Action Plan Yes No NA NE
Is a Spill Response Action Plan available? ❑ ❑ ❑
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?
❑ ❑ ❑
❑ ❑ ❑
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❑ ❑ ❑
❑ ❑ ❑
❑0❑❑
❑ ❑ ❑
❑0❑❑
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Comment: The Dlan could use some uDdatina to include our aaencv's current name (Division of Water
Resources Water Quality Section), phone numbers for regional supervisors, correct or delete
this inspector's number, indicate sampling of surface water only required if press release will be
required, add ORCs post site visit/assessment activities, and add section about filing 5-Day
report with Division
Spills
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?
Comment:
Lines/Right-of-Ways/Aerial Lines
Please list the Lines/Right of Ways/Aerial Lines Inspected:
Most of the sewer lines are within or along paved streets, but there are a few not
Are right-of-ways/easements maintained for full width for access by staff/equipment?
If No, give details on temporary access:
Is maintenance documented?
Are gravity sewer cleaning records available?
Yes No NA NE
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Page 5 of 7

Permit: WQCS00333 Owner - Facility: Town of Leland
Inspection Date: 08/27/2020 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Has at least 10% of lines older than 5 yrs been cleaned annually? 0 ❑ ❑ ❑
Were all areas/lines inspected free of issues? ❑ 0 ❑ ❑
Comment: Town contracts out its routine cleaning of 45K feet annually and lines are videoed upon
completion. Defects are reported and if bad reported during camera work. Town recently
purchased its first Jet -Vac truck to compliment its jet trailer.
Manholes
Yes No NA NE
Please list the Manholes Inspected:
Are manholes accessible?
❑
❑ ❑
# Are manhole covers/vents above grade?
❑
❑ ❑
Are manholes free of visible signs of overflow?
❑
❑ ❑
Are manholes free of sinkholes and depressions?
❑
❑ ❑
Are manhole covers present?
❑
❑ ❑
# Are manholes properly seated?
❑
❑ ❑
# Are manholes in good condition?
❑
❑ ❑
# Are inverts in good condition?
❑
❑ ❑
Is flow unrestricted in manholes?
❑
❑ ❑
Are manholes free of excessive amounts of grease?
❑
❑ ❑
Are manholes free of excessive roots?
❑
❑ ❑
Are manholes free of excessive sand?
❑
❑ ❑
Are manhole vents screened?
❑
❑ ❑
Are vents free of submergence?
❑
❑ ❑
Are manholes free of bypass structures or pipes?
❑
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Comment:
Pump Stations
Yes No NA NE
Please list the Pump Stations Inspected:
10, 13, 18, 21, 28
# Number of duplex or larger pump stations in system
30
# Number of vacuum stations in system
0
# Number of simplex pump stations in system
0
# 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?
30
# 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?
0
❑ ❑ ❑
Were wet wells free of excessive grease/debris?
0
❑ ❑ ❑
Page 6 of 7

Permit: WQCS00333 Owner - Facility: Town of Leland
Inspection Date: 08/27/2020 Inspection Type : Collection System Inspect Non Sampling
Reason for Visit: Routine
# Do they all have telemetry installed?
0
❑ ❑ ❑
Is the communication system functional?
0
❑ ❑ ❑
Is a 24-hour notification sign posted ?
0
❑ ❑ ❑
Does the sign include:
Owner Name?
0
❑ ❑ ❑
Pump station identifier?
0
❑ ❑ ❑
# Address?
❑
❑ 0 ❑
Instructions for notification?
0
❑ ❑ ❑
24-hour emergency contact numbers?
0
❑ ❑ ❑
Are audio and visual alarms present?
0
❑ ❑ ❑
Are audio and visual alarms operable?
0
❑ ❑ ❑
# Is there a backup generator or bypass pump connected?
0
❑ ❑ ❑
If tested during inspection, did it function properly?
0
❑ ❑ ❑
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/Staff/Vehicles/etc) are included in Plan?
# 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: #28 needs to have its wetwell vent extended and alarm liaht placed where it can be observed.
Several of the stations were noted to have alarm lights below fence line that need adjusting for
visibility -- this item was mentioned for some stations inspected in 3-2016. #18 needs to have the
access way cleared of vegetation to maintain full 12-foot access width & visibility -- needs light
relocated and a louder alarm installed. All stations need to be evaluated for alarm light visibility
and ability of audible to attract attention of nearby buildings.
Page 7 of 7