WQCS00202_Compliance Evaluation Inspection_20200901

DocuSign Envelope ID: CF40FDF7-6AOD-4DB6-AB85-E286CE6D3C3B
ROY COOPER
Governor
MICHAEL 5. REGAN
se—t"y
S. DANIEL SMITH
Da-w
NORTH CAROLINA
Environmental Qaality
October 05, 2020
Robert Walker
Brunswick Regional Water and Sewer H2GO
PO Box 2230
Leland, NC 28451-2230
SUBJECT: NOTICE OF DEFICIENCY
Tracking Number: NOD-2020-PC-0476
Permit No. WQCS00202
Brunswick Regional W&S Collection System
Brunswick County
Dear Permittee:
The North Carolina Division of Water Resources conducted an inspection of the Brunswick Regional W&S
Collection System on September 1, 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. WQCS00202. 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 deficiency was noted during the inspection:
Inspection Area Description of Deficiency
Pump Stations Some stations inspected had visual alarms screened from view and other that needed louder
Audible alarms to attract attention. All stations should be evaluated for these issues.
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. To prevent further action, carefully review these deficiencies and address the causes of
non-compliance to prevent the recurrence of similar situations.
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:
Onti �Aa2'c'InJ(�On,
71141F73B6F3456...
Tom Tharrington, Asst. Regional Supervisor
Water Quality Regional Operations Section
Wilmington Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS
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W.im:ngw Fegaoel Dfiic 1127 CardimiDnve Eztensoa I Wlmirg[ , North Carole 2.3405
919-796-7215

Compliance Inspection Report
Permit: WQCS00202 Effective: 11/01/13 Expiration: 10/31/21 Owner: Brunswick Regional Water and Sewer H2go
SOC: Effective: Expiration: Facility: Brunswick Regional W&S Collection System
County: Brunswick
Region: Wilmington
Leland NC 284512230
Contact Person: Russ Lane
Directions to Facility:
System Classifications: CS2,
Primary ORC: Keith Dwayne Gore
Secondary ORC(s):
Jared Eugene Glick
On -Site Representative(s):
On -site representative
Title: Assistant Director
Certification: 996710
1004239
Keith D Gore
Phone: [phone] Ext.111
Phone: [phone]
910-279-4571
910-279-9568
Related Permits:
WQCS00284 Brunswick County - Brunswick County Collection System
NC0086819 Brunswick County - Northeast Brunswick Regional WWTP
NC0075540 Brunswick Regional Water and Sewer H2go - Belville WWTP
Inspection Date: 09/01/2020 Entry Time 09:45AM Exit Time: 02:45PM
Primary Inspector: Dean Hunkele Do�� Phone: [phone]
10/5/2020
Secondary Inspectors):
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: WQCS00202 Owner - Facility: Brunswick Regional Water and Sewer 1-12go
Inspection Date: 09/01/2020 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Inspection Summary:
Overall the system seems to be well operated and maintained. Please review the comments within the report to address
items noted.
Only somewhat significant issue detected during inspection was that some pump stations had their visual alarms screened
by fencing/vegetation and others had aubible alarms were insufficient to attract attention. All stations need to be evaluated
for these issues and corrected.
A Notice of Deficiency will be issued for the above issue.
Page 2 of 7

Permit: WQCS00202 Owner - Facility: Brunswick Regional Water and Sewer H2go
Inspection Date: 09/01/2020 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? 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?
❑
❑ ❑
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:
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? 60 days
Is Grease Control Program enforced via periodic inspections/records review? 0 ❑ ❑ ❑
Is action taken against violators? ❑ ❑ ❑
# 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.)
Comment:
Capital Improvement Plan Yes No NA NE
Has a Capital (CIP) or System Improvement Plan been developed and adopted? ❑ ❑ ❑
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? ❑ ❑ ❑
Does CIP include description of existing facilities? ❑ ❑ ❑
Does CIP include known deficiencies? ❑ ❑ ❑
Does CIP include forecasted future needs? 0 ❑ ❑ ❑
Comment: Fulll CIP requested post inspection but only a line item & budget provided. Need to ensure a full
CIP is developed, implemented, and available.
Map Yes No NA NE
Page 3 of 7

Permit: WQCS00202 Owner - Facility: Brunswick Regional Water and Sewer H2go
Inspection Date: 09/01/2020 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
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?
■❑❑❑
Comment: Electronic map provided lacks some of the detail above, but likley information is available but ius
not in that output/format. If not, then the information needs to be compiled and added.
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? website
Comment:
Inspections
Yes No NA NE
Are adequate maintenance records maintained?
❑ ❑ ❑
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?
❑
❑ ❑
# 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?
❑
❑ ❑
Comment: Nearlv all of the District's system is within or beside roadways. thus likelv seen over the course
of a year by staff or customers. and remote areas checked biannually.
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? ❑ ❑ ❑
Page 4 of 7

Permit: WQCS00202 Owner - Facility: Brunswick Regional Water and Sewer 1-12go
Inspection Date: 09/01/2020 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
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?
❑
❑ ❑
Comment
$pills 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:
Lines/Right-of-Ways/Aerial Lines Yes No NA NE
Please list the Lines/Right of Ways/Aerial Lines Inspected:
Mallory Creek/Westport Force Main
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? ❑ ❑ ❑
Has at least 10% of lines older than 5 yrs been cleaned annually? ❑ ❑ ❑
Were all areas/lines inspected free of issues? 0 ❑ ❑ ❑
Comment: Cleaned over 100% of cleaning requirement for CY 2019 and have cleaned 38% of requirement
thus far for 2020.
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? ❑ ❑ ❑
Page 5 of 7

Permit: WQCS00202 Owner - Facility: Brunswick Regional Water and Sewer 1­12go
Inspection Date: 09/01/2020 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?
❑
❑ ❑
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?
❑
❑ ❑
Comment:
Pump Stations
Yes No NA NE
Please list the Pump Stations Inspected:
27, 28, 32, 37, 38, 39, 53
# Number of duplex or larger pump stations in system
54
# Number of vacuum stations in system
0
# Number of simplex pump stations in system
700
# 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?
54
# 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?
❑
❑ ❑
Page 6 of 7

Permit: WQCS00202 Owner - Facility: Brunswick Regional Water and Sewer H2go
Inspection Date: 09/01/2020 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
# 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? ❑ ❑ ❑
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: A few of the stations visited had the visual alarm obscurred by high fencing or vegetation
supposedly maintained by POAs. Those behind fencing need to be elevated or relocated to be
visible and District needs to force maintenance of vegetation as often as necessary to keep no
taller than any fencing or to maintain alarm visibility otherwise remove it. Several audible alarms
(mainly newer) are not loud enough to alert nearby residences or businesses, thus these need tc
be upgraded. Consequently all stations need to be evaluated for these issues. Only other issue
noted was the vent at #39 needed reDair.
Page 7 of 7