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HomeMy WebLinkAboutWQCS00187_Renewal (Application)_20201201 RECEIVED November 17, 2020 DEC 01 2020 NCDEQ/DWR/NPDES NCDEQ-DWR Attn: PERCS Unit Supervisor 1617 Mail Service Center Raleigh,NC 26799-1617 Subject: Collection System Permit Renewal Town of St. Pauls St. Pauls Collection System WQCS00187 Robeson County Dear PERCS Unit: The Town of St. Pauls holds permit #WQCS00187 for the operation and maintenance of the sewer collection system. The permit expiration date is March 31, 2021. The Town is submitting a permit renewal application package. The renewal package includes one original and one copy of: - Cover letter - Completed Application Form CSA 04-16 - Pump station list - High priority lines list - Annual Budget for Collection System(Wastewater) - Capital Improvement Plan - Response action plan - Contingency Plan - Sewer collection map. Comments related to the permit application include: • The number of duplex pump stations has increased to eleven(11). There is still just one simplex pump station. • One high priority line has been rerouted and is no longer high priority. If you have any questions,please call Tim Lyde at: 910-885-8780. Sincerely, ert Gi son, Mayor Town of St. Pauls A State of North Carolina DWR Department of Environmental Quality Division of Water Resources 15A NCAC 02T.0400—SYSTEM-WIDE WASTERWATER COLLECTION SYSTEMS Division of Water Resources INSTRUCTIONS FOR FORM CSA 04-16&SUPPORTING DOCUMENTATION Documents shall be prepared in accordance with 15A NCAC 02T .0100, 15A NCAC 02T .0400, and all relevant Division Policies. Failure to submit all required items will necessitate additional processing and review time. For more information, visit the System-wide Collection System Permitting website: General — When submitting an application to the Pretreatment, Emergency Response, & Collection Systems (PERCS) Unit,please use the following instructions as a checklist in order to ensure all required items are submitted. Adherence to these instructions and checking the provided boxes will help produce a quicker review time and reduce the amount of requested additional information. The Applicant shall submit one original and one copy of the application and supporting documentation. A. Cover Letter El Submit a cover letter listing all items and attachments included in the permit application package B. No Application Fee Required > No application fee is necessary. The permittee will be billed an annual fee upon issuance of the permit > The appropriate annual fee for systemwide wastewater collection system permits may be found at: > Annual Non-Discharge Fees C. System-Wide Wastewater Collection System(FORM:CSA 04-16)Application: El Submit the completed and appropriately executed System-wide Wastewater Collection System(FORM: CSA 04- 16) application. Any unauthorized content changes to this form shall result in the application package being returned. If necessary for clarity or due to space restrictions,attachments to the application may be made, as long as the attachments are numbered to correspond to the section and item to which they refer. ❑ If the Applicant Type in Section I.3 is a Privately-Owned Public Utility, provide the Certificate of Public Convenience and Necessity (CPCN) from the North Carolina Utilities Commission demonstrating the Applicant is authorized to hold the utility franchise for the area to be served by the wastewater collection system,or ❑ Provide a letter from the North Carolina Utilities Commission's Water and Sewer Division Public Staff stating an application for a franchise has been received and that the service area is contiguous to an existing franchised area or that franchise approval is expected. ❑ If the Applicant Type in Section I.3 is a corporation or company, provide documentation if it is registered for business with the North Carolina Secretary of State. D. General Information: > The Authorized signing official listed in Section 1.4 should match with that of the Applicant certification page in accordance with 15A NCAC 02T .0106(b). Per 15A NCAC 02T .0106(c), an alternate person may be designated as the signing official if a delegation letter is provided from a person who meets the criteria in 15A NCAC 02T .0106(b). > NOTE - Public Works Director's are not authorized to sign this permit application according to the rule unless they are delegated. INSTRUCTIONS FOR APPLICATION CSA 04-16&SUPPORTING DOCUMENTATION Page 1 of 5 E. Summary of Attachments Required: El Instruction A: Cover Letter ❑ Instruction C: Application ❑ Instruction C: Ownership Documentation(i.e.CPCN)(If necessary) ❑ Instruction D: Delegation Letter(If necessary for signing official) • Section IV.3 Pump Station List ® Section IV.4 High Priority Lines List ® Section V.4 Annual Budget for Collection System(Updated and Approved) • Section V.6 Capital Improvement Plan(Updated and Approved) RECEIVED • Section VI.2 Response Action Plan DEC 01 2020 ® Section VI.4 Contingency Plan NCDEQ/DWRINPDES Section VI.6 Comprehensive Collection System Map ❑ Section VH Note Any Potential Compliance Issues THE COMPLETED APPLICATION PACKAGE INCLDING ALL SUPPORTING INFORMATION AND MATERIALS,SHOULD BE SENT TO: NCDEQ-DWR Water Quality Permitting Section PERCS UNIT By U.S.Postal Service: By Courier/Special Delivery: Attn: PERCS Unit Supervisor 512 N.SALISBURY ST. Suite 925 1617 MAIL SERVICE CENTER RALEIGH,NORTH CAROLINA 27604 RALEIGH,NORTH CAROLINA 27699-1617 TELEPHONE NUMBER: (919)807-6300 INSTRUCTIONS FOR APPLICATION CSA 04-16&SUPPORTING DOCUMENTATION Page 2 of 5 I. APPLICANT INFORMATION: 1. Applicant's name(Municipality,Public Utility,etc):Town of St.Pauls 2. Facility Information: Name: St.Pauls Collection System Permit No.:WQCS00187 3. Applicant type: ®Municipal ❑State ❑Privately-Owned Public Utility ❑County ❑Other: 4. Signature authority's name:Elbert Gibson per 15A NCAC 02T.0106(b) Title:Mayor 5. Applicant's mailing address: PO Box 364 City:St.Pauls State:NC Zip:28384-0364 6. Applicant's contact information: Phone number:(910)865-5164 Fax number: (910)865-3849 Email address:debra@stpaulsnc.gov II. CONTACT/CONSULTANT INFORMATION: 1. Contact Name:Timothy Lyde 2. Title/Affiliation:CS Operator in Responsible Charge/Town of St.Pauls 3. Contact's mailing address:PO Box 364 4. City: St Pauls State:NC Zip:28384-0364 5. Contact's information: Phone number:(901)885-8780 Fax number:(910)865-3849 Email address:wwtp(a,ncrrbiz.com III. GENERAL REQUIREMENTS: 1. New Permit or Premit Renewal? ❑New ® Renewal 2. County System is located in: Robeson County 3. Owner&Name of Wastewater Treatment Facility(ies)receiving wastewater from this collection system: Owner(s)&Name(s):Town of St Pauls WWTP 4. WWTF Permit Number(s): NC0020095 5. What is the wastewater type? 100%Domestic or %Industrial(See 15A NCAC 02T.0103(20)) Is there a Pretreatment Program in effect?❑Yes or®No 6. Wastewater flow:0.35 MGD(Current average flow of wastewater generated by collection system) 7. Combined permitted flow of all treatment plants: 0.50 MGD 8. Explain how the wastewater flow was determined: ❑ 15A NCAC 02T.0114 or®Representative Data 9. Population served by the collection system:2332 IV. COLLECTION SYSTEM INFORMATION: 1. Line Lengths for Collection System: Sewer Line Description Length Gravity Sewer 17(miles) Force Main 6(miles) Vacuum Sewer NA(miles) Pressure Sewer NA(miles) APPLICATION CSA 04-16 Page 3 of 5 2. Pump Stations for Collection System: Pump Station Type Number Simplex Pump Stations(Serving Single Building) 1 Simplex Pump Stations(Serving Multiple Buildings) NA Duplex Pump Stations 11 3. Submit a list of all major(i.e.not simplex pump station serving a single family home)pump stations. Include the following information: ➢ Pump Station Name > Physical Location ➢ Alarm Type(i.e.audible,visual,telemetry, SCADA) ➢ Pump Reliability(Can convey peak hourly wastewater flow with largest single pump out of service) ➢ Reliability Source(permanent/portable generator,portable pumps) ➢ Capacity of Station(Pump Station Capacity in GPM) 4. Submit a list of all high priority lines according per 15A NCAC 02T.0402(2)known to exist in the collection system. Head the list with"Attachment A for Condition V(4)"and include the system name. > Use the same line identification regularly used by the applicant ➢ Indicate type of high priority line(i.e.aerial),material and general location V. COLLECTION SYSTEM ADMINISTRATION: 1. Provide a brief description of the organizational structure that is responsible for management, operation and maintenance of the collection system. Mayor—Town Manager—Public Works Director—CS/WWTP ORC 2. Indicate the current designated collection system operators for the collection system per 15A NCAC 08G.0201 Main ORC Name: Timothy Lyde Certification Number: 1001621 Back-Up ORC Name: Danny Holloman Certification Number: 1004886 See the"WQCS Contacts and ORC Report"for a current listing of the ORC(s)the Division has on file for WQCS permit 3. Approximate annual budget for collection system only: $ 145,000.00 4. Submit a copy of your current annual budget. 5. Approximate capital improvement budge for the collection system only: $46,100.00 6. Submit a copy of your current capital improvement plan. 7. Is this collection system currently a satellite system❑Yes or®No 8. Do any satellite systems discharge to this collection system❑Yes or®No(If yes complete table below) Satellite System Contact Information(Name,Address,Phone Number) Complete for Satellite Systems that have a flow or capacity greater than 200,000 GPD(Average daily flow) 9. List any agreements or ordinances currently in place to address flows from satellite systems: NA APPLICATION CSA 04-16 Page 4 of 5 VI. COLLECTION SYSTEM COMPLIANCE: 1. Is a Response Action Plan currently in place®Yes or❑No 2. If Yes,submit a copy of the Response Action Plan or see table 6 below. 3. Is a pump station contingency plan currently in place?®Yes or❑No 4. If Yes,submit a copy of the pump station contingency plan or see table 6 below. 5. Is a comprehensive collection system map currently in place? ®Yes or❑No 6. Submit a submit a copy of the collection system map(CD or hardcopy)or indicate a schedule for completion 7. Thoroughly read and review the System-Wide Collection System Permit Conditions. Typically compliance schedules are only offered to NEW permit applicants and NOT permit renewals. Any compliance dates must be included within the permit prior to issuance or the permit holder will be found in violation upon inspection. Current If no,Indicate a Typical Permit Condition Compliance Compliance Compliance? Date Schedule I(4)—Grease ordinance with legal authority to inspect/enforce ®Yes ❑No 12—18 mo. I(5)— Grease inspection and enforcement program ®Yes ❑No 12—18 mo. I(6)—Three to five year current Capital Improvement Plan. ®Yes ❑No 12—18 mo. I(8)—Pump station contingency plan // Yes ❑No 3 mo. I(9)—Pump station identification signs. ®Yes ❑No 3 mo. I(11)—Functional and conspicuous audible and visual alarms. ®Yes ❑No 3—6 mo. II(5)—Spare pumps for any station where one pump cannot handle peak flows alone(in a duplex station,the 2nd pump is ®Yes ❑No 6—9 mo. the spare if pump reliability is met). II(7)—Accessible right-of-ways and easements. ®Yes ❑No 6— 12 mo. II(9)—Response action plan with Items 9(a—h). ®Yes ❑No 3 mo. III(3)—Comprehensive collection system map ®Yes ❑No 10%per year For conditions not listed,compliance dates are not typically offered. List any permit conditions that may be difficult for the applicant to meet(attach clarification if needed): NA VII. APPLICANT'S CERTIFICATION per 15A NCAC 02T.0106(b): I,Elbert Gibson,Mayor attest that this application for St Pauls Collection System (Signature Authority's Name&Title from Item I.4) (Facility name from Item I.1) has been reviewed by me and is accurate and complete to the best of my knowledge. I understand that if all required parts of this application are not completed and that if all required supporting information and attachments are not included, this application package will be returned to me as incomplete. Note: In accordance with NC General Statutes 143-215.6A and 143-215.6B, any person who knowingly makes any false statement, representation, or certification in any application shall be guilty of a Class 2 misdemeanor which may include a fine not to exceed $10,000 as well as civil penalties up to$25, per violation.Signature: �'��"'"�~ Date: //—.L.2107C APPLICATION CSA 04-16 Page 5 of 5 Town of Saint Pauls Collection System Permit Renewal Part IV - 3 WQCS00187 Pump Station List Name Location Alarm Pump Reliability Reliable Source Capacity GPM Lift Station#1 W. Broad St. (behind 101 S. Wilkinson Dr.) Audible,Visual,Telemetry Yes Generator 400 Lift Station#2 Butler St(end of) Audible,Visual,Telemetry Yes Portable Generator 140 Lift Station#3 N. 2nd St at McColl Page Plaza Audible, Visual,Telemetry Yes Portable Generator 150 Lift Station#4 W. McLean St at Lumbee Bank Audible, Visual,Telemetry Yes Portable Generator 140 Lift Station#5 Evans Rd at apartments Audible,Visual,Telemetry Yes Portable Generator 150 Lift Station#6 Veterans Rd at Foodlion Audible,Visual,Telemetry Yes Generator 250 Lift Station#7 W. Hwy 20 at Muller Steam Audible,Visual,Telemetry Yes Generator 150 Lift Station#8 N. Maple& E. Armfield Audible,Visual,Telemetry Yes Simplex,Storage and Pump 50 Lift Station#9 Gracie St. Audible,Visual,Telemetry Yes Generator 140 Lift Station# 10 N. Chapel St Audible,Visual,Telemetry Yes Generator 140 Lift Station#11 Hwy 20 at Sanderson Farm Rd Audible,Visual,Telemetry Yes Generator 140 Lift Station#12 Broad St at Pepsi Rd. Audible,Visual,Telemetry Yes Generator 186 Attachment A Town of Saint Pauls Saint Pauls Collection System WQCS00187 Part IV.4 High Priority Lines Number Type Location Pipe Type Creek Bore 101 S. Wilkinson Drive Ductile 4" 2 Aerial 104 N. Wilkinson Drive Ductile 4" 3 Aerial Between 110 N. Wilkinson Dr and 126 N. Ductile 8" Wilkinson Dr. 4 Aerial Church on S. Lafayette St. going east in front Ductile 8" of 116 S. Lafayette St. 5 Aerial Ditch at 104 S. Wilkinson Drive Ductile 4" Departmental Budget vs Actual Town of St. Pauls 11/2/2020 9:23:18 AM Page 1 Of 1 Period Ending 6/30/2021 Department: 710 Sewer Expenditures Description Budget MTD YTD Variance Percent 60-710-0200 SALARIES 64,552 0.00 26,041.61 38,510.39 40% 60-710-0500 FICA TAXES 5,300 0.00 1,992.17 3,307.83 38% 60-710-0600 GROUP INSURANCE 13,000 0.00 4,152.98 8,847.02 32% 60-710-0700 RETIREMENT 9,700 0.00 2,330.71 7,369.29 24% 60-710-0701 RETIREMENT-401(K) 2,700 0.00 525.06 2,174.94 19% 60-710-1100 COMMUNICATIONS 8,500 0.00 7,660.52 839.48 90% 60-710-1200 OFFICE SUPPLIES& 500 0.00 0.00 500.00 PRINTING 60-710-1300 UTILITIES 38,000 0.00 14,712.30 23,287.70 39% 60-710-1400 TRAVEL 1,000 0.00 0.00 1,000.00 60-710-1450 TRAINING 3,000 0.00 85.00 2,915.00 3% 60-710-1500 MAINT& REPAIR- 4,000 0.00 109.01 3,890.99 3% BUILDINGS 60-710-1600 MAINT& REPAIR- 40,000 0.00 11,085.34 28,914.66 28% EQUIPMENT 60-710-1700 MAINT& REPAIR- 10,000 0.00 1,334.39 8,665.61 13% VEHICLES 60-710-2600 ADVERTISING 500 0.00 0.00 500.00 60-710-3100 FUEL 5,500 0.00 1,405.52 4,094.48 26% 60-710-3300 DEPARTMENT SUPPLIES 45,273 0.00 18,889.79 26,383.21 42% 60-710-3600 UNIFORMS 2,200 0.00 242.67 1,957.33 11% 60-710-4500 CONTRACTED SERVICES 70,000 0.00 16,953.33 53,046.67 24% 60-710-5300 DUES& FEES 10,000 0.00 2,326.15 7,673.85 23% 60-710-5400 INSURANCE& BONDS 16,500 0.00 8,200.70 8,299.30 50% 60-710-5500 TESTING (SAMPLING) 21,000 0.00 5,543.00 15,457.00 26% 60-710-7300 CAPITAL OUTLAY- 46,100 0.00 11,680.00 34,420.00 25% EQUIPMENT 60-710-8500 DEBT SERVICE 34,000 0.00 6,304.39 27,695.61 19% 60-710-8806 TANK REPAIR RESERVE 5,000 0.00 0.00 5,000.00 60-710-9900 CONTINGENCY 8,595 0.00 0.00 8,595.00 Total Expenditures for Department 464,920 0.00 141,574.64 323,345.36 30% TOWN OF ST.PAULS WASTEWATER ASSET MANAGEMENT PLAN 8.0 Capital Improvements Plan for Wastewater Services This section details the Capital Improvement Plan (CIP) that is an outgrowth of this Asset Management Plan process. While the Town currently has previously had a CIP, the breadth and depth of the asset inventory and assessment completed in 2017 and updated in 2020 better informs the Town of its capital needs. This Capital Improvement Plan (CIP) provides for the scheduling, financing, and implementing of future capital projects over a 10-year horizon. It allows the Town decision makers- the Town Board of Commissioners —to think over a longer, multi-year period, allowing costs to be spread over a number of years so the no one budget year is overburdened. For the purposes of this CIP, the first five (5) years address capital improvements for sewer assets determined to be in either "Poor" condition or having reached the end of their useful life. Specific cost estimates are provided for capital project within this time frame. 8.1 Introduction The Town of St. Pauls is located in Robeson County in the northern part of the county. Robeson County is located in southeastern portion of the State along the South Carolina line. (See Figure 26) The Town is easily accessed on U.S. Highways 95 and NC 20. Neighboring counties include Scotland, Hoke, Cumberland, Bladen and Columbus in North Carolina and Dillon County in South Carolina. Figure 26. County Location Maps I E Off+ lirreir o� • N ger P.0 Ir,� UM.,SPRINGS .. ';, ;s MOORS xmmNs ==1 I ENN9t F SON sane STi+m s 9r SAMP COMBER�N f . "OB . O rowEusr<IE WCRMDND wtta PENT, -AMR r Imo°"• (tAs,snte fi /J N ROgESO a Zk:v warm 41 NOWT R4,D2. stnntr OkE1D Ap ORMS 0.1-014 COLOMBOS ° 00-1NGTON MAR10N ' C s ' N,ea►ssA RORENCE NORM w.w I M 11 _� .FY-�_� MI Tr M1Y1' Source: US Census The Town has historically been a textile hub. Significant industrial growth in textiles and warehouse infrastructure investment took place over the 20th century. Like most communities in this region, St. Pauls is adjusting to the loss of much of this traditional industry and is seeking investments by newer 1 manufacturing. 31 TOWN OF ST.PAULS WASTEWATER ASSET MANAGEMENT PLAN The Town's original collection system was constructed in the late 1890's and consisted of the lines in the downtown district and adjacent neighborhoods. These pipes were, and many still are, of vitrified clay material with brick manholes. Additions and alterations to the collection system appear to have begun in the 1950's and extend until present day. 8.2 What is a Capital Improvement Project vs.a Rehab Project? As defined by the CUPSS software, a capital improvement project creates a new asset that previously did not exist. It can also provide an upgrade or improvement of an existing asset's capacity. Projects can result from environmental,growth, or regulatory requirements, including the following: - Installation of a new asset or improvements to an existing asset to meet federal and/or state regulatory mandates (i.e., increased/tightened NPDES limits) • Installation of a new asset or improvements to an existing asset that increases the original design capacity - Upgrades that increase the capacity of an asset - Construction designed to produce an improvement in the standard operation of an asset beyond present capacity Capital improvement projects are not exclusive to the creation of a new asset. This CIP identifies capital projects that involve the rehabilitation or replacement of an existing asset. Rehabilitation/replacement planning provides the best opportunities for capital cost savings. By rehabilitating or replacing sewer assets, the Town can automatically avoid costs such as emergency contractor fees, staff overtime, unplanned repairs, and cleanup costs. Additional cost savings can be achieved through the coordination of sewer projects with other construction projects, replacing longer segments, and phasing improvements over a period of years. Rehabilitation/replacement expenditures are directed towards capital projects that do not increase an existing sewer asset's design capacity, but restores or enhances its original design capacity and/or function. Sewer improvements that require more than simply restoring a sewer asset to its original capacity are classified as a replacement project. Such projects include the following: - improvements/upgrades that enhance an asset's performance, but do not increase its capacity such as the installation of a SCADA system; • Improvements that replace and/or realign/relocate an existing asset, restoring it to a "Like new" condition such as the replacement of old gravity sewer lines. 8.3 Total Capital Need at 5 and 10-Year Marks If the Town were to grapple with all suggested capital projects noted in the first five years of the CIP, the Town would need to invest $11,724,875. In years 6-10, that total is $180,880 for a total 10-year need of$11,905,755 as shown in the figure below. 32 TOWN OF ST.PAULS WASTEWATER ASSET MANAGEMENT PLAN Figure 27. Five and Ten-Year Capital Improvement Needs Amount Years 1-5 Amount Years 6-10 Total 2021-2026 2026-2031 Capital Need $11,724,875 $180,880 $11,905,755 Please note that any asset which has aged beyond its estimated useful life or service life shows to be completed in 2021 to 2026 capital improvement year. Based upon the significant number of assets in service beyond their expected useful life, the total for the first five years is significant. The Town is currently seeking funding for the WWTP Improvements project and the ability to complete additional work will depend on funding availability for that project. The Collection System Rehabilitation project has been funded through Division of Water Infrastructure and includes a loan of approximately 1.1 million which will impact the availability of funds for additional capital improvements also. Priority projects for the Town include: 8.4 Collection System CIP Priority Needs Priority projects for the Town's collection system include the rehab or replacement of the priority lift stations, manhole rehab and rehab or replacement of the collection lines. The fact that the Town operates with such a significant amount of clay pipe (56 percent of the gravity line inventory) is likely a major cause of the Town's ongoing Inflow and Infiltration problems. Based on the evaluation of the collection system assets, a listing of priority projects follows. I. Wastewater Collection System Rehabilitation: The Town is currently in the bid phase of a wastewater collection system rehabilitation project. The project includes the rehabilitation and replacement of existing gravity sewer lines, manholes, wet wells and appurtenances within the Town of St. Pauls' wastewater collection system. Gravity sewer construction includes approximately, 3,500 LF of 8" gravity sewer, 10,000 LF of CIPP lining in existing 8" and 10" sewer lines, precast concrete manholes, manhole rehabilitation and related appurtenances. 2. Lift Station Rehab or Replacement: The Town should conduct further evaluations on the lift stations. The result of these evaluations should be both a short-term and a long-term program for lift station component replacements or wholesale replacement of the stations. Further evaluation is needed on the electrical panels and pumps and these evaluations need to be completed by a licensed electrician. The Town completed a significant line rehab project which includes the upgrades of lift stations#1 and#6 in 2016.These two lift stations are integral to the delivery of wastewater from the industrial park located on Highway 20 to the Town's treatment facility. The project through which they were being treated was funded through the Golden Leaf Foundation ($820,000) and the State CDBG Program ($1,000,000). The Capital Improvement Plan includes projects to address "Critical Needs" for eight of the ten other lift stations as shown below: a. Lift Station #2—South Butler Street: Pumps/wet well/ Miscellaneous Fixtures b. Lift Station #3—North 2nd Street/McColl Plaza: Electrical Controls and Motors/Pumps 33 TOWN OF ST.PAULS WASTEWATER ASSET MANAGEMENT PLAN C. Lift Station #4—West McLean at Lumbee Bank: Electrical Controls and Motors d. Lift Station #5—Evans Road: Electrical Controls and Motors/Pumps e. Lift Station #7—Hwy 20/Broad St: Pumps f. Lift Station #8—East Armfield Dr.: Electrical Controls and Motors/Pumps/Wet well/ Miscellaneous Fixtures including guiderails, lift chains,hoist(if applicable), hood for control panel, etc. g. Lift Station#9—Grayce Street: Electrical Controls and Motors/Pumps/Permanent Generator h. Lift Station #10—North Chapel Street: Electrical Controls and Motors/Pumps/Permanent Generator Note: Lift Station#11 at the Industrial Park and Lift Station#12 at the Pepsi plant are new and in generally very good condition.Lift Stations#1,#2,#3,#4,#6,#8 and#9 will need wet well improvements in the future. 3. Replacement of Vitrified Clay Collection Lines: Due to the amount of line inventory in vitrified clay (56% of the gravity inventory), the Town will need to develop a long-term strategy for replacement of this inventory. This entire pipe inventory is in poor condition and is aged well beyond its useful service life. A planned strategy for treatment through CIPP or replacement is being developed. Specific areas of concern based on work orders, video inspection and staff knowledge include: a. Wilkinson Drive (Britt Street South to Lift Station#1) -8"VC pipe A b. Lafayette Drive-8"VC pipe. A c. Stack Street—8"VC pipe. A d. Clark Street_8", 10" and 12"VC pipe. A e. Outfall Line to Plant- 12"VC pipe. A f. Ross Street—8"VC pipe. A g. Old Stage Road-8", 10" and 12"VC pipe. A h. Elizabeth Street—8", 10" and 12"VC pipe. A i. Shaw Street—8"VC pipe. A j. Britt Street—8"VC pipe. A k. Ballance Street—8"VC pipe. A I. Cutlar Street—8"VC pipe. A m. Wilkinson Drive (Britt Street North to Pool Street)-8"VC pipe e n. North Railroad Street—6"and 8"VC pipe. 8 0. 2nd 3rd and 4th Streets—6",8" and 10"VC pipe. A p. Bay Street—8"VC pipe. e q. Blue Street—6" and 8"VC pipe. e r. Broad Street—6" and 8"VC pipe. e s. East Armfield Street_8"VC pipe. 0 t. Eure Street—6"and 8" VC pipe. 8 u. Powers Street_8"VC pipe. e v. Brannon Street-8"VC pipe. 0 w. Seawell Street-8"VC pipe. 0 x. Butler Street—8"VC pipe. 0 Streets marked with a above have sections were rehabilitated or replaced in the Sewer Rehabilitation in North Wilkinson Street Area project designed by McGill Associates in 2016 34 r TOWN OF ST.PAGES WASTEWATER ASSET MANAGEMENT PLAN and constructed in 2017. Streets marked with a e are included in a rehabilitation project designed by McGill Associates that is in the bidding phase as mentioned above. 4. Replacement of Brick and Block Manholes: The Town estimates an inventory of 207 brick manholes co-located with VC pipe which are in poor condition. Manholes in the areas targeted above require further evaluation to confirm replacement or rehab need. 5. Replacement of 2" and 4" force mains: There is an estimated 12,656 linear feet of 2" and 4" force mains in the systems in poor condition which need to be upgraded to the appropriate force main diameter. 6. Replacement of 4" gravity lines: There is an estimated 1,599 linear feet of 4" gravity line which is undersized, in poor condition and should be replaced. 8.5 Wastewater Treatment CIP Priority Needs The Town's wastewater treatment plant located southwest of Town on Elizabeth Street. The plant dates to 1963 and is an oxidation ditch type treatment process which utilizes long solids retention times to remove the organics. The system is fixed with dual aeration rotors that provide aeration and circulation. Most of the plant assets are original to this date and have been in operation beyond their useful service lives. The plant was constructed to handle 0.500 million gallons per day. Average daily flow in the last 12 months averages 0.388 MGD or about 78 percent of rated plant capacity. However, following periods of heavy rain, flows have reached 1.2 MGD and during the recent hurricane (Matthew) the plant was submerged. 1 I Photo: Flooded influent ' r _ screen channel at the WWTP. f� ' _ _ --... ..._ -,, �1 '� 1 ....,` Managing the biological process at the plant is a continual challenge and has resulted in numerous permit violations. Priority projects for the Town's wastewater treatment plant include: 35 TOWN OF ST.PAULS WASTEWATER ASSET MANAGEMENT PLAN 1. Oxidation Ditch: Ditch is original to the plant (circa 1963). One set of paddle cylinders, motors and gears have been recently replaced;the other is original to the plant. (below left) 41, • "y i *�llp' Of ,, ' 2. Bar Rake Basin/Electrical Control/Motor: Is aged beyond its useful life and should be replaced. (above right) 3. Clarifier #1 Basin: Replacement of clarifier basin #1 is needed. It has exceeded its useful life period and is an essential component to meeting the NDPES limits. (below left) ' #, , i 44:. iwzr • :.... tau. .. f. _ • - .. t .i 42111141 4. Digester Basin/Electrical Controls/Motors: Rehab or replacement of the existing basin is needed. It has exceeded its useful life period and is an essential component to meeting the NDPES limits. (Above right) 5. Chlorine Contact Chamber and Equipment: While recently coated through a project by APWA, the chamber has served beyond its useful life period. (below left) 36 TOWN OF ST.PAULS —_.____ WASTEWATER ASSET MANAGEMENT PLAN 4 1,. %" ,w N ..$ , F. a. >�< � a• „ t`,.i•-, ,` 4. ' , - jil 4. e , ..A.11,1-","'. PP.."' Akigsktaie ,A...„- iso'w" ,.., p''�i14��� `fir -,1-- 6. Influent and Effluent Pumps and Motors: While "workhorse" pumps, all six of these pumps have now served beyond their useful life periods. The check and gate valves and motor controls are aged and failing. (above right) Within the last year, the motors have been raised to a point where they appear to be above the flood level experienced in Hurricane Matthew. (below left) . + ® <<; an i i ti , 4�� r it'` 1 =� e, s�Y?*Iii, i 'T�w ` 4/111i • _ aON C \p f•p 7. WWTP Operations Building/Storage Buildings/Chemical Feed Building: These structures are aged and have experienced frequent flooding. The Operations Building (above right) houses equipment essential to the operation of the plant- including the electrical panels for all pumps) and cannot be at risk of failure. The Chemical Feed Building (below left) is essential to the quality of effluent produced by the plant. The pump storage trailer (below right) houses spare parts for the influent and effluent pumps. 37 TOWN OF ST.PAULS WASTEWATER ASSET MANAGEMENT PLAN a 1 , , , c il' 4 , * war:':..*,: 8. Wastewater Treatment Plant Relocation: In order to address these issues outlined in 1-7 the Town proposes to abandon the existing wastewater treatment plant located within the 100-year floodplain of the Big Marsh Swamp, construct a new pump station and force main to an alternative site and construct a new wastewater treatment plant at the new site. The WWTP is anticipated to be a field erect type plant with flow equalization, extended aeration, clarifiers, sludge holding, tertiary filtration, and UV disinfection. A new lab and administration building are also proposed to replace the existing facility that has been flooded multiple times. Effluent from the WWTP would be returned to a discharge point within the Big Marsh Swamp closer to the new plant site. 38 TOWN OE ST.PAULS WASTEWATER ASSET MANAGEMENT PLAN Figure 28.St. Pauls Wastewater Treatment Plant Upgrades Cost Estimate Item Description Quantity Unit Unit Price TOTAL I No. 1 Mobilization(3%of total construction) 1 LS $144,800.00 $144,800 2 12"PVC Sanitary Sewer 250 LF $75.00 $18,750 1 3 4'Dia SS Manhole with Watertight Lid and Vent 1 EA $5,000.00 $5,000 4 12"PVC Sewer Force Main 1400 LF $50.00 $70,000 5 18"PVC Effluent Sewer 1000 LF $140.00 $140,000 Submersible Sewer Pump Station Complete w/ 6 Sitework,fencing,pumps,piping,electrical and 1 LS $450,000.00 $450,000 emergency generator 7 Mechanical Bar Screen and Channel 1 LS $150,000.00 $150,000 8 0.5 MGD Packaged Treatment Plant with Flow EQ. 1 LS $1,900,000.00 $1,900,000 Aeration,Clarifiers and Sludge Storage 9 Blowers and Piping 1 LS $140,000.00 $140,000 10 Concrete Foundations for Treatment Units 1 LS $250,000.00 $250,000 11 Tertiary Disc Filters 1 LS $400,000.00 $400,000 12 UV Disinfection System 1 LS $250,000.00 $250,000 13 New Operations Bldg w/Space for Future 1 LS $225,000.00 $225,000 Dewatering 14 Sitework,including Access Road 1 LS $150,000.00 $150,000 15 Yard Piping 1 LS $175,000.00 $175,000 16 Electrical 1 LS $475,000.00 $475,000 17 Erosion Control 1 LS $30,000.00 $30,000 39 TOWN OF ST.PAULS WASTEWATER ASSET MANAGEMENT PLAN Figure 29. (Continued)St. Pauls Wastewater Treatment Plant Upgrades Cost Estimate CONSTRUCTION SUBTOTAL $4,973,550 CONTINGENCY $497,400 GRANT ADMINISTRATION $25,000 ER/ED $40,000 SURVEYING $20,000 PLANNING AND ENGINEERING DESIGN $315,000 PERMITTING $2,500 BID AND AWARD $8,000 CONSTRUCTION ADMINISTRATION $157,000 EASEMENT PREPARATION $5,000 PROPERTY ACQUISITION $50,000 TOTAL PROJECT COST $6,093,450 8.6 Summary of All Wastewater CIP Needs A summary of the known capital needs for the sewer system for the next 10 years are presented in Figures 29 and 30 below. Due the high aggregate dollar amount of capital improvements needed — approximately $12 million in a ten-year period — several of the critical assets have been selected for further assessment to refine needs and the associated capital costs. Therefore, there are two figures — one for assessments needed and one for estimated capital needs. 40 TOWN OF ST.PAULS WASTEWATER ASSET MANAGEMENT PLAN Figure 30.St. Pauls Wastewater System Assessments Type of Capital Capital Improvement Project Total Cost Improvement Year to Conduct Project Assess potential for developing a regional Support of wastewater treatment facility in partnership Preventive 1 with Roberson County Landfill and Parkton. $50,000 Maintenance 2021 Assess clay lines for replacement or slip lining through updated flow monitoring and CCTV as needed. The quantity and poor condition of these lines continues to present operational challenges at the plant and threat to the environment. Develop a Support of planned multi-year program of addressing Preventive 2 the collection system line needs. $50,000 Maintenance 2017-2021 TOTAL FOR ASSESSMENTS $133,500 Figure 31.St. Pauls Wastewater System Capital Improvement Needs Years 0-10 Type of Capital 5-and 10- Year to Count Capital Improvement Project Total Cost Improvement Conduct Total by Year Year CIP Project Totals Wastewater Treatment Plant 1 Relocation $6,093,450 Rehab/Replace 2021 Wastewater Collection System 2 Rehabilitation $1,600,000 Rehab/Replace 2021 Lift Station#3(North 2nd St/McColl Plaza)-Duplex $20,000 Rehab/Replace 2021 3 Pumps Lift Station#7(Hwy 20/Broad 4 St.) Duplex Pumps $25,000 Rehab/Replace 2021 5 Ductile Iron 4"-Fair Condition $10,075 Rehab/Replace 2021 6 PVC 4"-Poor Condition $63,960 Rehab/Replace 2021 7 PVC 6"-Fair Condition $66,280 Rehab/Replace 2021 Lift Station#4(West McLean at Lumbee Bank)-Electrical $20,000 Rehab/Replace 2021 8 Wiring/Motor/Motor Controls Lift Station#10(North Chapel St.) Duplex Pumps $10,000 Rehab/Replace 2021 9 Lift Station#5(Evans Road)- Electrical Wiring/Motor/Motor $20,000 Rehab/Replace 2021 10 Controls Lift Station#5(Evans Road)- 11 Duplex Pumps $20,000 Rehab/Replace 2021 Lift Station#8(East Armfield 12 Dr.) Duplex Pumps $10,000 Rehab/Replace 2021 41 TOWN OF ST.PAULS WASTEWATER ASSET MANAGEMENT PLAN Lift Station#9(Grayce St.)- 13 Duplex Pumps $25,000 Rehab/Replace 2021 Lift Station#8(East Armfieid Dr.)-Electrical $10,000 Rehab/Replace 2021 14 Wiring/Motor/Motor Controls _ 15 Clay 12"-Poor Condition $189,480 Rehab/Replace 2021 16 Clay 10"-Poor Condition $152,130 Rehab/Replace 2021 17 Clay 8"-Poor Condition $1,746,760 Rehab/Replace 2021 18 Clay 6"-Poor Condition $567,240 Rehab/Replace 2021 Manholes-Poor 19 Condition/Brick $724,500 Rehab/Replace 2021 Lift Station#3(North 2nd St/McColl Plaza)-Electrical $20,000 Rehab/Replace 2021 20 Wiring/Motor/Motor Controls Lift Station#10(North Chapel St.)-Electrical $10,000 Rehab/Replace 2021 $11,403,875 21 Wiring/Motor/Motor Controls Lift Station#9(Grayce St.)- Electrical Wiring/Motor/Motor $10,000 Rehab/Replace 2022 $10,000 22 Controls Lift Station#10(North Chapel St.) Permanent Generator $25,000 Rehab/Replace 2023 $25,000 23 Manholes-Fair Condition/Block and Precast $266,000 Rehab/Replace 2025 24 Lift Station#2(South Butler $20,000 Rehab/Replace 2025 $286,000 $11,724,875 25 St.)-Duplex Pumps Lift Station#9(Grayce St.)- Permanent Generator $25,000 Rehab/Replace 2027 $25,000 26 Lift Station#8(East Armfield Dr.) Wet Well $45,000 Rehab/Replace 2028 27 Lift Station#8(East Armfield Dr.) Misc Fixtures(Valve, $30,000 Rehab/Replace 2028 $75,000 valve vault,rails,piping,hoist if 28 present) Lift Station#2(South Butler 29 St.) Wet Well $50,000 Rehab/Replace 2030 Ductile Iron 4"FM Poor $880 Rehab/Replace 2030 Condition 30 Lift Station#2(South Butler St.)-Misc Fixtures(Valve,valve vault,rails, < <n hoist if $30,000 Rehab/Replace 2030 $80,880 $180,880 pip g, 31 present) TOTAL $11,905,755 $11,905,755 42 Response Action Plan VIMPOTP sr,";* - ' w System Name: Town of St. Pauls Permit Number: WQCS00187 Address: PO Box 364 City/State/Zip: St. Pauls, NC 28384 1 4 Phone Number: 910/865-5 6 Fax: 910/865-3 849 Email: debra@ stpauls.gov CONTENTS SECTION I. Purpose II. Objectives III. Procedures A. Receipt of Information Regarding a Sanitary Sewer Overflow B. Dispatch of Sewer Maintenance Personnel to Site of Sewer Overflow C. Overflow Correction, Containment, and Clean Up D. Overflow Report E. Customer Satisfaction IV. SSO Response Plan Maintenance V. Appendices Appendix A — Contacts Appendix B — Spill/SSO Reporting Form I. Purpose This Response Action Plan has been prepared in accordance with Permit WQCS00187 Part II (9) Operation & Maintenance Requirements. The purpose of this Response Action Plan is to ensure proper sanitary sewer overflow (S SO) reporting and minimize the adverse effects that may be caused by a Sanitary Sewer Overflow. This plan was revised on November 2020 This plan will be reviewed and/or updated annually to incorporate any changes in contact information; system components; and/or personnel. II. Objectives The objectives of this plan are: ➢ To protect the public health and the environment > To meet regulatory and permit requirements > To develop and implement procedures to mitigate the effects of an SSO ➢ To protect the collection system and wastewater treatment personnel > To ensure the longevity of the collection system and wastewater treatment plant equipment > To protect both public and private property > To minimize regulatory enforcement and/or penalties, resulting from a spill/SSO ➢ To provide appropriate customer service III. Procedures A. Receipt of Information Regarding a Sanitary Sewer Overflow Sanitary Sewer Overflow's may be recognized and reported by system personnel or by others. The System is responsible to act, in a timely manner, to all reports of a possible SSO. Reports may be received via telephone, email, or by other means. 1. Typically reports received from the public will be received at Town Hall. Personnel collecting information regarding a possible SSO, please obtain the following: a. Time and date call was received b. Specific location c. Description of problem d. Time possible overflow was noticed e. Reporter's name and phone number f. Observations of the reporter g. Relevant information that will enable system personnel to quickly locate, assess and stop the overflow 2. Appropriate system personnel will be notified when a possible spill is reported. All reports of a SSO must be investigated by staff within two hours. System personnel must confirm the spill before it will be considered an SSO. Only after confirmation by system personnel will a spill be considered an SSO. 3. As soon as possible, but no later than 24 hours of the confirmation of a reportable Sanitary Sewer Overflow, the NC DWR Fayetteville Regional Office will be notified according to the rules of NC Division of Water Resources. The rule is: Sanitary Sewer Overflow (SSO) Reporting Requirements to the Division of Water Resources The Permittee shall verbally report to a Division of Water Resources staff member at the appropriate Regional Office, as soon as possible, but in no case more than 24 hours following first knowledge of the occurrence of either of the following: • Any SSO and/or spill over 1,000 gallons to the ground; or • Any SSO and/or spill, regardless of volume, that reaches surface water Voice mail messages or faxed information shall not be considered as the initial verbal report. SSOs (and other types of spills) occurring outside normal business hours may also be reported to the Division of Emergency Management at telephone number (800) 858-0368 or (919) 733-3300. 4. Spills that are fully contained and removed quickly and are less than one thousand gallons that do not reach surface waters are not required to be reported to NC DWR. However, a full spill report form will be filled out and kept on file. B. Dispatch of Sewer Maintenance Personnel to Site of Sewer Overflow Confirmation of a Spill / Sanitary Sewer Overflow will activate an immediate response to isolate and correct the problem. Personnel and equipment shall be available to respond to any and all SSO locations. 1. Dispatching Personnel Instructions ➢ When a spill/SSO is received by the system, Staff and equipment shall be dispatched to isolate and correct the problem in a timely manner ➢ Staff will be dispatched by telephone or radio ➢ Dispatching personnel must verify that all notified staff have received the message 2. Maintenance Personnel Instructions ➢ All dispatched staff should proceed immediately to the site of the spill/SSO. Any delays and/or conflicts should be promptly reported to the manager ➢ Upon arrival at the site of the spill/SSO, staff will report any and all findings to the appropriate supervisor. These findings should include damage to both public and private property 3. Supervisor Instructions ➢ The Supervisor will dispatch additional personnel, supplies, and equipment as needed or requested by dispatched staff ➢ The Supervisor will update the Public Works Director and/or Town Manager on a continuing basis if the SSO and/or repairs are not easily abated and fixed. 4. Initial Damage Assessment ➢ All dispatched staff must use discretionary action when responding to a spill/SSO. Dispatched personnel must be aware that the System may be responsible and/or liable for further damage to private property ➢ Dispatched personnel should not enter private property without authorization from the Supervisor > In order to thoroughly document the affected area, the dispatched staff will take appropriate photos and/or video. Any photos and/or video will be retained and filed with the spill/SSO report 5. Supervision and Inspection > The Supervisor will ensure that the guidelines outlined in this SSO Response Plan are properly implemented ➢ The Supervisor is responsible for properly notifying NC DWR Fayatteville Regional Office within the amount of time specified within the reporting requirement ➢ The Supervisor will coordinate with the Town Manager for the availability of funds. C. Spill/SSO Correction, Containment, and Clean-up The objectives of the actions taken by system personnel are: ➢ To protect public health, the environment, and property from a spill/SSO > To restore the surrounding area/property back to normal as quickly as possible > To establish an appropriate perimeter to contain the spill/SSO, using equipment (traffic cones, barricades), existing infrastructure (fencing, etc.), and/or natural boundaries(berm, ditch, stream, etc.) > To notify the appropriate regulatory agencies within permitted timeframe ➢ To protect surface water from contamination ➢ To minimize regulatory enforcement and/or penalties, resulting from a spill/SSO 1. Upon arrival at a spill/SSO, the dispatched system staff will perform the following: > Determine the cause of the spill/SSO (collection line blockage, lift station malfunction, line break, etc.). > Report findings to Supervisor and identify or request additional personnel and equipment to minimize the effects of the spill/SSO. > Should it be determined the cause of the spill/SSO is not the responsibility of the system, dispatched personnel will; o Take appropriate action to protect public health, property (public and private), and surface water bodies from immediate danger. 2. Containment of a spill/SSO will be of utmost priority and will include, but are not limited to, the following measures: ➢ Determine the immediate destination of the spill/SSO (storm drain, water body, ditch, etc.) ➢ Identify and request the necessary personnel and equipment to contain and minimize the effects of the spill/SSO ➢ Take the appropriate, immediate action to contain the spill/SSO 3. Additional measures may be necessary to contain a prolonged spill/SSO. These measures will be determined and implemented by the Supervisor. 4. Clean up of a spill/SSO will be prompt and thorough. The necessary measures will be taken to eliminate any identifiable evidence of the spill/SSO. ➢ If possible, photos will be taken before and after clean up. Photos will be filed with the spill/SSO report P ➢ The affected area will be cleaned of any sewage and debris. All materials collected will be properly disposed of ➢ The area will be secured to prevent public contact, until the affected area has been thoroughly cleaned ➢ The spill/SSO site should be disinfected and deodorized, if appropriate ➢ If spill/SSO has affected a surface water body, the NC DWR Fayetteville Regional Office will be contacted for specific instructions. D. Overflow Reporting A written report to the NC DWR Fayetteville Regional Office is required within five days. The Supervisor will complete the required reports and submit them to the NC DWR Fayetteville Regional Office. Additional reporting requirements to the public may be required based upon volume discharged. For accurate reporting purposes, system personnel should gather the following information: > Determine if the spill/SSO has affected any surface water bodies ➢ Estimate the start time of the of the spill/SSO: o Date/time reported and confirmed by system personnel o Visual observations ➢ Estimate the stop time of the spill/SSO: o Date/time the blockage or equipment malfunction has been corrected o Date/time system personnel arrived onsite, if spill/SSO stopped before system personnel arrived > Visual Observations o Estimate the flow rate of the spill/SSO o Estimate the volume of the spill/SSO o Take photos for documentation o Assess damage to public and private property (System personnel will not enter private property to assess damage, unless authorized by the Supervisor) E. Customer Satisfaction To ensure good public relations and customer satisfaction, the appropriate system personnel will follow up with the reporting party. This follow up will include either a personal visit or telephone call. The Supervisor will determine the information to be disclosed to the reporting party. IV. SORP Maintenance This Sanitary Sewer Overflow Response Plan will reviewed annually. Amendments may include: ➢ Changes in procedure ➢ Changes in contact personnel ➢ Changes due to regulatory requirements V. Appendices Appendix A — Contact Phone Numbers Appendix B — Equipment List and Spare Parts Inventory Appendix A CONTACTS Division of Emergency Management 800-858-0368 Contact / Affiliation Phone Email Debra McNeill/Interim Town Manager- Clerk 910/865-5164 1 debra@stpaulsnc.gov Tim Lyde/CS ORC 910/885-8780 1 wwtp@ncrrbiz.com -4- Danny Holloman/Public Works Director 910/633-9432 danny@stpaulsnc.gov Benton Rogers/Asst. Public Works Director 910/633-1165 benton@stpaulsnc.gov Town of St. Pauls Police Department 910/865-5155 Fayetteville Regional Office 910/433-3300 McGill Assoc./David Honeycutt 910/690-2583 Fortiline 910/425-8100 Charles Underwood Associates/Russell 910/775-2462 Underwood Allen Townsend Electric 910/733-0388 Progress Energy 1-800-419-6356 Lumbee River Electric Cooperative 910/843/4131 Appendix B Equipment List and Materials Location and Materials WWTP 6" Portable Pump Discharge Hose/Suction Hose Portable Generator PS Spare Pumps Lime Dirt/Gravel PS Electrical Parts Public Works Bld. 6' Portable Pump Discharge Hose/Suction Hose 3"Mudhog Pump with Hoses Combination Truck Sewer Jetter Backhoe Mini Excavator Light Towers Barricades, Signs, Cones Dump Trucks Sewer Camera Pipe Pipe Fittings/Repair Clamps Valves Hand Tools Town of St. Pauls Pump Station Contingency Plan WQCS00187 The Town of St. Pauls operates and maintains eleven(11)duplex pump stations and one(1)simplex pump station serving a single building. In the case of pump station failure,the following steps will be taken: • Type of failure will be determined: Mechanical or Electrical • Electrical Failure ➢ Pump stations#1,#6,#7,#9,#10,#11,and#12 have permanent generators. ➢ Pumps stations#2,#3,#4,#8 and#5 have a hookup for a portable generator ➢ Spare parts—fuses,breakers,alternators,relays,etc.—are available for the more common failures. ➢ Electrical contractor will be called as needed. • Mechanical Failure > Pump will be inspected to check for blockages > Control floats will be checked ➢ Belts will be checked on belt-driven pumps > Bypass pumping connections are installed at all pumpstations. The Town has three YP P P g portable pumps. • Pump Failure > If pump cannot be made operational on-site: ■ Pumps will be sent to pump/motor repair shop or pump repair company will be contacted for on-site repair. • If both pumps in the pump station fail or if the remaining pump cannot maintain the water level: > The Town's vacuum truck will be utilized to pump the water level down. > A septage hauling company will be contacted to pump out the pump station wet well as needed. ➢ Bypass pumps are available as needed. V aw z, i ii -- \st L''''''' ' L�.�w\4+ r �. ♦ra s. Lip-f 1r N _��!�r . ka.„..1: .!Z ^� L s 1R"",..,p i r' r4 ) - -- .� we L I .1 ..... .,.. rr Dr. It t �n _ �-y• . Y" ♦ DI, C I Jf �4 ul rd DS Dli DE , ar* ir. III 1 ille -2, . rr L�4s rr/ I r.� r AL ..cLr". - i llt k I I '.4 it , ..„.,,,,,,,z.. „, r.,„.., .,...i, , ,.. . .., ......... . . .., . 1 t.,... .... . • \ , ......, ,".;41 -- • .-4•Iill.. E 3 L fir: "� Lis. ...z. `,. 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