WQCS00254_Compliance Evaluation Inspection_20210928

ROY COOPER
SEArr
Governor
ELIZABETH S. BISER
SPCYefary
tea.
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S. DANIEL SMITH
NORTH CAROLINA
Director
Environmental Quality
Certified Mail # 7018 1830 0000 9681 6057
Return Receipt Requested
September 28, 2021
Honorable Billy W Hammond
Town of Fair Bluff
PO Box 157
Fair Bluff, NC 28439-0157
SUBJECT: NOTICE OF DEFICIENCY
Tracking Number: NOD-2021-PC-0492
Permit No. WQCS00254
Fair Bluff Collection System
Columbus County
Dear Mayor Hammond:
The North Carolina Division of Water Resources conducted an inspection of the Fair Bluff Collection System on
September 15, 2021. This inspection was conducted to verify that the facility is operating in compliance with the
conditions and limitations specified in Collection System Permit No. WQCS00254. A summary of the findings and
comments noted during the inspection are provided in the enclosed copy of the inspection report.
The Collection System inspection was conducted by Division of Water Resources staff from the Wilmington
Regional Office. The following deficiency(s) was noted during the inspection:
Inspection Area Description of Deficiency
Reporting Requirements Last Annual Wastewater Performance report received by Division was for Calendar Year 2018.
This report is required to be mailed to the Division within 60 days of the end of the applicable
reporting year — either calendar or fiscal year are the options.
Pump Stations None of the stations have complete signage. Please see the signage requirements listed in
the report.
Sunset PS needs to have a louder audible alarm & relocation of float tree or use of pressure
bell w/back-up alarm float due to influence of the incoming flow.
Dead End PS needs alarms repaired and keep an eye on DIP force mains in wetwell due to
observed corrosion.
Elm Street PS needs alarms repaired and appears it could use periodic flushing of wetwell for
debris accumulation based on an assumed low flow scenario.
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In addition, please provide the following information also summarized in the report:
1. Please provide a copy of the Town's I&I Study from 2002. In addition, please provide information on what
areas or items have been addressed and what the Town's plan is to address other critical items remaining.
2. Please provide an update on the Town's actions to date to access manholes that were buried, paved over, or
were surcharged when the Sewer Asset & Assessment field work was conducted.
3. The above mentioned Assessment prioritized areas/items that were able to be evaluated that needed repair
and extensive cleaning. What actions have been completed to date on any of the needed repairs? For the
areas needing extensive cleaning, have any of these areas been cleaned? Your contract operator indicated
that they cleaned about 15,000 feet of line in 2020, were the identified areas included in this activity and if not
please explain why?
Please provide a written response to this Notice within 30 days of receipt indicating what actions have been or
will be taken with a date of completion or planned completion to address the noted deficiencies. The response
should also include the information in the three (3) items above.
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,
Tom Tharrington, Assistant Regional Supervisor
Water Quality Regional Operations Section
Wilmington Regional Office
Division of Water Resources, NCDEQ
ATTACHMENT
Cc: WQS Wilmington Regional Office - Hunkele
Upload to Laserfiche
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Wilming[on Regional Office 13]Cardinal Drive Ex[ms�on Wilming[on. North Carolina 28405
910.796 ]315

Compliance Inspection Report
Permit: WQCS00254 Effective: 08/07/13 Expiration: 05/31/21 Owner : Town of Fair Bluff
SOC: Effective: Expiration: Facility: Fair Bluff Collection System
County: Columbus
Region: Wilmington
Contact Person: Al J Leonard Title: Town Manager Phone: [phone]
Directions to Facility:
System Classifications: CS1,
Primary ORC: Ronnie Eugene Seals
Secondary ORC(s):
Kevin H Taylor
On -Site Representative(s):
On -site representative
Certification: 987420
i111111B1 M
Kevin H Taylor
Phone: [phone]
910-734-7301
910-272-0833
Related Permits:
NC0086550 Town of Fairmont - Fairmont Regional WWTP
WQCS00097 Town of Fairmont - Fairmont Collection System
WQCS00373 Town of Boardman - Boardman -Cerro Gordo Deemed Municipal Collection
System
Inspection Date: 09/15/2021 Entry Time 09:40AM Exit Time: 01:OOPM
Primary Inspector: Dean Hunkele Phone: [phone]
Secondary Inspector(s):
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: WQCS00254 Owner - Facility: Town of Fair Bluff
Inspection Date: 09/15/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Inspection Summary:
This was the first compliance inspection of the system since 8-2016 prior to the devastating flooding from Hurricanes
Matthew & Florence as the Division was providing time for the Town to make emergency repairs and work towards overall
recovery.
Following a Division inspection in 10-2014 which found numerous compliance issues and concerns about the lack of O&M
and oversight of the sewer system, the Town began working with a consultant to obtain funding to begin determining the
needs of the Town which the regional office provided written support in 4-2016. The Town was able to secure a grant to
perform a Sewer Asset Inventory & Assessment which was initiated in 2017 following damage & flooding from Hurricane
Matthew in 10-2016 and completed in 2018 prior to more flooding from Hurricane Florence in September. The Assessment
Report was completed in 1-2019 for areas outside of system area covered by a 2002 1&1 Report which the Division doesn't
have copy.
The assessment found several manholes (-28) that were unaccessible due to being buried under soil/pavement or were
found to be excessively surcharged which prevented an analysis. The assessment also made prioritized recommendations
for manhole and sewer line repairs and/or cleaning based on likelihood to fail or cause issues. The assessment along with
recovery funding allowed the Town to replace and/or upgrade 4 of its 6 pump stations in 2019/2020. No information on
raising the buried manholes and assessment of them or surcharged manholes has been made available to the regional office
nor any repairs to sewer lines identified as the highest priority. Consequently, this office is requesting an update on these
activities and future plans to address them. In addition, please provide our office a copy of the 2002 1&1 study and
information on remediation of issues it found or plans to do that which encompasses about 79 manholes.
The contract operator indicated that their crews cleaned approximately 15,000 feet of lines during calendar year 2020.
Please advise if the areas noted as needing to be cleaned in the Inventory & Assessment were included in the 2020 cleaning
activity and why if they were not.
Page 2 of 7

Permit: WQCS00254 Owner - Facility: Town of Fair Bluff
Inspection Date: 09/15/2021 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 for pump
stations
# 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? 0 ❑ ❑ ❑
Does the permittee have a copy of their permit? ❑ ❑ ❑
# Is permit expiring within the next 6 months? ❑ ❑ 0 ❑
If Yes, has the Permittee applied for renewal? 0 ❑ ❑ ❑
Comment: Svstem still has numerous known issues and update beinq requested by this report - See
Summary. Expired at end of 5-2021 and renewal application was received in early 2-2021.
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? ❑ ❑ ❑
What is the standard grease trap cleaning requirement in the FOG ordinance?
Is Grease Control Program enforced via periodic inspections/records review?
Is action taken against violators?
# Have satellite systems adopted an equivalent or more stringent ordinance?
Is grease/sewer education program documented with req'd customer distribution?
# Are other types of education tools used like websites, booths, special meetings, etc?
If Yes, what are they? (This can reduce mailing to annual.)
Town does one mailing with the Annual Water Report and usually sets up booth at Annual NC Watermelon
Festival, but its been canceled last 2 years due to pandemic.
Comment:
Capital Improvement Plan
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?
❑❑■❑
❑❑■❑
❑❑■❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Yes No NA NE
❑■❑❑
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
Page 3 of 7

Permit: WQCS00254 Owner - Facility: Town of Fair Bluff
Inspection Date: 09/15/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Comment: Anticipated that anew CIP is either underdevelopment or will be soon using the Sewer Asset &
Assessment report as its basis.
Map
Is there a overall sewer system map?
Does the map include:
■❑❑❑
Pipe Type (GS/FM)
0
❑ ❑ ❑
Pipe sizes
❑
❑ ❑
Pipe materials (PVC, DIP, etc)
❑
❑ ❑
Pipe location
0
❑ ❑ ❑
Flow direction
0
❑ ❑ ❑
Approximate pipe age
0
❑ ❑ ❑
Pump station ID, location and capacity
0
❑ ❑ ❑
# Force main air release valve location & type
❑
❑ ❑
# Location of satellite connections
❑
❑ 0 ❑
Is the map being updated for changes/additions within 1 year of activation?
❑
❑ 0 ❑
Comment: Maps within the Assessment report has a lot of the information and assumed more info may
be
in other data/info collected.
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? mailed with FOG &
water report
Comment: Last report received by Division was for CY 2018
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? ❑ ❑ 0 ❑
Comment: Town has one known HPL - an aerial line adjacent to the Causey Road PS
Page 4 of 7

Permit: WQCS00254 Owner - Facility: Town of Fair Bluff
Inspection Date: 09/15/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Spill Response Action Plan
Is a Spill Response Action Plan available?
Is a Spill Response Action Plan available for all personnel?
Does the plan include:
Yes No NA NE
■❑❑❑
❑❑❑■
24-hour contact numbers 0 ❑ ❑ ❑
Response time ❑ 0 ❑ ❑
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: Reviewed plan included with renewal application. Agency info needs updating for name and
regional office number 910-796-7215 along with other items listed above.
Spllls Yes No NA NE
Is system free of known points of bypass? 0 ❑ ❑ ❑
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:
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? ❑ ❑ ❑
Comment: Most of the sewer system is within or along roadways; unknown if any system is located in open
areas or easements needing maintenance. If so, then these sewer lines should be inspected
annually and area maintained if necessary. Contract operator provided records indicating over
15K feet cleaned in CY 2020.
Manholes
Please list the Manholes Inspected:
Manholes adjacent to 76 West pump station
Yes No NA NE
Page 5 of 7

Permit: WQCS00254 Owner - Facility: Town of Fair Bluff
Inspection Date: 09/15/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Are manholes accessible?
0
❑ ❑ ❑
# Are manhole covers/vents above grade?
0
❑ ❑ ❑
Are manholes free of visible signs of overflow?
0
❑ ❑ ❑
Are manholes free of sinkholes and depressions?
0
❑ ❑ ❑
Are manhole covers present?
0
❑ ❑ ❑
# Are manholes properly seated?
0
❑ ❑ ❑
# Are manholes in good condition?
0
❑ ❑ ❑
# Are inverts in good condition?
0
❑ ❑ ❑
Is flow unrestricted in manholes?
0
❑ ❑ ❑
Are manholes free of excessive amounts of grease?
0
❑ ❑ ❑
Are manholes free of excessive roots?
0
❑ ❑ ❑
Are manholes free of excessive sand?
0
❑ ❑ ❑
Are manhole vents screened?
❑
❑ 0 ❑
Are vents free of submergence?
❑
❑ 0 ❑
Are manholes free of bypass structures or pipes?
0
❑ ❑ ❑
Comment: Inspection conducted to determine if pipe noted in photo taken during visit following
Hurricane
Matthew was an old bypass to creek. It was actually a force main damaged/separated from
flooding and was replaced by a bore directed into a new manhole.
Pump Stations
Yes No NA NE
Please list the Pump Stations Inspected:
All 6 - Main PS, Sunset PS, Dead End PS, Causey PS, Elm PS, 76 West PS
# Number of duplex or larger pump stations in system
6
# 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?
0
# A simple one-way telemetry/communication system (auto -dialer) installed?
6
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?
❑
❑ ❑
Page 6 of 7

Permit: WQCS00254 Owner - Facility: Town of Fair Bluff
Inspection Date: 09/15/2021 Inspection Type : Collection System Inspect Non Sampling
Reason for Visit: Routine
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?
❑
❑ ❑
Is the back-up system tested at least bi-annually under normal operating conditions?
❑
❑ ❑
# 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?
❑
❑ ❑
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?
❑
❑ ❑
Inspecting and exercising all valves?
❑
❑ ❑
Inspecting and lubricating pumps and other equipment?
❑
❑ ❑
Inspecting alarms, telemetry and auxiliary equipment?
0
❑ ❑ ❑
Comment: None of the stations have complete signage. All stations have connections for back-u
generator and/or bypass pump; only the triplex Main PS has an on -site generator. Sunset PS
needs to have a louder audible alarm & relocation of float tree or use of pressure bell
w/back-up alarm float due to influence of the incoming flow. Dead End PS needs alarms
repaired and keep an eve on DIP force mains in wetwell due to observed corrosion. Elm Street
PS needs alarms repaired and appears it could use periodic flushing of wetwell for debris
accumulation based on an assumed low flow scenario.
Page 7 of 7