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Home My WebLink AboutWQCSD0526_Compliance Evaluation Inspection_20210916DocuSign Envelope ID: AB208C1A-889D-4FED-B92B-4C61 D5C21 CC4 ROY COOPER Governor - ,� sw ELIZABETHS.BISERr ? Secretary �a S. DANIEL SMITH NORTH CARouNA Direcmr Ennrunmentaf Quality September 30, 2021 Tim Tilma, Utility Manager 904 Georgetown Treatment Plant LLC 800 Sandpiper Club Dr Sunset Beach, NC 28468 SUBJECT: NOTICE OF DEFICIENCY Tracking Number: NOD-2021-PC-0494 Permit No. WQCSD0526 Sandpiper Bay Deemed Collection System Brunswick County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Sandpiper Bay Deemed Collection System on September 16, 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. WQCSD0526. 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 Pump Stations Balmore PS - need to fix gate so it can be locked, fix area light Maintenance PS - need to repair audible alarm and replace lock that had been cut off Wyndfall PS - need to keep locked 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. Please provide the inspector with a response once the above items have been addressed. 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. ATTACHMENT Cc: Upload to Laserfiche Sincerely, EDocuSigned by: Toµ "T�nacc� uti 7F141E73136F3456... Tom Tharrington, Asst. Regional Supervisor Water Quality Regional Operations Section Wilmington Regional Office Division of Water Resources, NCDEQ O}/ xann arou�a>kv..naF�am,:�ui 3.�.mrlon�Imoruv t.�v..sau.��: m«.. „D 1�P wIWrngte 9Io 0 IIX C, rne10-IN—Im IMII NntnC 1W 2W5 910. 720 DocuSign Envelope ID: AB208C1A-889D-4FED-B92B-4C61 D5C21 CC4 Compliance Inspection Report Permit: WQCSD0526 Effective: 06/22/10 Expiration: SOC: Effective: Expiration: County: Brunswick Region: Wilmington Contact Person: Timothy P Tilma Title: Utility Manager Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): Certification: Owner : 904 Georgetown Treatment Plant LLC Facility: Sandpiper Bay Deemed Collection System Phone: 910-579-9120 Phone: On -Site Representative(s): On -site representative Timothy P Tilma 910-579-9120 Related Permits: WQ0013398 904 Georgetown Treatment Plant LLC - Sandpiper Bay WWTP Inspection Date: 09/16/2021 Entry Time 01:OOPM Exit Time: 03:OOPM Primary Inspector: Dean Hunkele Docusigned by: Phone: 910-796-7215 EE 101112021 Secondary Inspector(s): E1 D9294C4D3746E... Docusigned by: Reason for Inspection: Routine 0_�^Inspection Type: Collection System Inspect Non Sampling QcoeC Inspection Type: Deemed F 49 E73B6F M..Permit permitted ion sys em management and operation Facility Status: ❑ Compliant Not Compliant Question Areas: Miscellaneous Questions General Grease Control Spills/Response Plan Inspections Lines Manholes Pump Stations (See attachment summary) Page 1 of 6 DocuSign Envelope ID: AB208C1A-889D-4FED-B92B-4C61 D5C21 CC4 Permit: WQCSD0526 Owner - Facility:904 Georgetown Treatment Plant LLC Inspection Date: 09/16/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Inspection Summary: The Utility has made some progress in managing its collections system, most importantly getting most of it mapped with the exception of force mains. The force mains need to be located and pump station designs either located or generated based on wetwell size and installed equipment which is discussed in the report as well and was previously noted in the 2019 report. All pump stations were found to be unsecured with one with a damaged & unlockable gate which also had an damaged/inoperable area light and another had a disconnected audible alarm. The WWTF operator feels that the treatment facility is stressed at times to operate with current flows which may be in part due to O&M issues with it, but unusual debris (rocks) were observed on the barscreen once again during its inspection on this same day. This is a clear indication that the sewer system has a compromised area(s) that need to be located as this type of debris will damage the impellors in pump station pumps and such areas are also likely adding inflow of stormwater or infiltration of groundwater into the sewer system which can cause hydraulic issues with the treatment facility if significant. Flows to pump stations should be monitored during dry times to ascertain a normal flow range which can be compared to flow rates following significant rainfall events to determine which basin(s) are contributing this debris and non -sewage flow so it can be located and repaired. Cleaning of the sewer system by someone with CCTV capability could also find such damage and generally sewer lines should be cleaned every 10 years as a preventative action to reduce likelihood of a blockage and/or spill. The Utility needs to continue seeking improvments to its O&M of the sewer system and ensure compliance with the requirements for operating it to avoid being required by our Division to obtain an individual permit with many more requirements including certified operator designations and an annual fee rather than operating under its current no -fee deemed status. Page 2 of 6 DocuSign Envelope ID: AB208C1A-889D-4FED-B92B-4C61 D5C21 CC4 Permit: WQCSD0526 Owner - Facility:904 Georgetown Treatment Plant LLC Inspection Date: 09/16/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine General Yes No NA NE # Is this system a satellite system? ❑ ❑ 0 ❑ # If Yes, what is system name or permit number? Is there a overall sewer system map? ❑ ❑ ❑ Does the map include: 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 ❑ ❑ ❑ Are system maintenance records maintained? ❑ ❑ ❑ Comment: Utility recently had its sewer system surveyed; the map reviewed has the gravity sewer lines manholes, & pump stations located, but not the force mains from the stations to their discharge point nor any air release valves (ARVs) along it. All lines are of similar age and PVC except possible areas of DIP which should be shown on it along with pipe size or at least record drawings of the construction. Also, the low point in each pump station's sewer basin should be identified to determine where to check for spill if station goes down. Lastly, if the utility does not have its pump staton designs then they should have an engineeer analyze & create them based on current DumDs in use. Grease Control Yes No NA NE 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? ❑ ❑ ❑ If Yes, what are they? (This can reduce mailing to annual.) They place some info in a newsletter. Need to make sure info gets mailed out to each owner in some manner once usually with billing and can use website, general newsletter, etc for the other mechanism. For public systems, is there a Grease Control Program via an ordinance/agreement? ❑ ❑ ❑ If Yes, does it require grease control devices at applicable locations? ❑ ❑ ❑ ❑ Is the Grease Control Program enforced via periodic inspections/records review? ❑ ❑ ❑ ❑ Is action taken against violators? ❑ ❑ ❑ ❑ Comment: Need to make sure info gets mailed out to each owner in some manner once usually with billin and can use website, general newsletter, etc for the other mechanism. While pump station wetwells had acceptable grease levels, considerable grease was observed floating on the aeration basins which the treatment plant is not designed to treat. Spills and Response Action Plan Yes No NA NE # Is system free of known points of bypass? 0 ❑ ❑ ❑ If No, describe type of bypass and location Page 3 of 6 DocuSign Envelope ID: AB208C1A-889D-4FED-B92B-4C61 D5C21 CC4 Permit: WQCSD0526 Owner - Facility:904 Georgetown Treatment Plant LLC Inspection Date: 09/16/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine # Have there been any sewer spills in the past 3 years? ❑ ❑ 0 ❑ If Yes, were they reported to the Division if meeting the reportable criteria? ❑ ❑ 0 ❑ If applicable, is there documentation of press releases and public notices issued? ❑ ❑ 0 ❑ Are all spills or sewer related issues/complaints documented? 0 ❑ ❑ ❑ # Are there repeated overflows/problems (2 or more in 12 months) at same location? ❑ ❑ 0 ❑ # If Yes, is there a corrective action plan? ❑ ❑ 0 ❑ Is a Spill Response Action Plan available? 0 ❑ ❑ ❑ Is a Spill Response Action Plan available for all personnel? ❑ ❑ ❑ Does the plan include # 24-hour contact numbers ❑ 0 ❑ ❑ # Response time ❑ 0 ❑ ❑ # Equipment list and spare parts inventory ❑ 0 ❑ ❑ # Access to cleaning equipment ❑ 0 ❑ ❑ # Access to construction crews, contractors, and/or engineers ❑ 0 ❑ ❑ # Source of emergency funds ❑ 0 ❑ ❑ # Site sanitation and cleanup materials ❑ 0 ❑ ❑ # Post-overflow/spill assessment ❑ ❑ ❑ ❑ Comment: The Utility has a very generic or simplistic spill response plan and its geared more toward pump station issues. The Plan needs to be amended to include more information like above. 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? ❑ ❑ ❑ # 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: All gravity sewer located within or alonq roadways, thus easily observable by Utility and residents. Force main routes are unknown, thus may be area that requires at least yearly observation if "cross country" and would be documented as an easement/right-of-way maintenance activitv. Lines/Right-of-Ways/Aerial Lines Yes No NA NE Please list the Lines/Right of Ways/Aerial Lines Inspected: Are right-of-ways and easements maintained for the full width for access? ❑ ❑ ❑ If No, give details on temporary access: Is maintenance documented? ❑ ❑ ❑ Page 4 of 6 DocuSign Envelope ID: AB208C1A-889D-4FED-B92B-4C61 D5C21 CC4 Permit: WQCSD0526 Owner - Facility:904 Georgetown Treatment Plant LLC Inspection Date: 09/16/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Were all areas/lines inspected free of issues? ❑ ❑ ❑ Comment: It appears that only force main routes may need to be maintained & inspected if traversing "cross country". 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? ❑ ❑ ❑ Comment: Manholes receiving force main discharges need to be inspected annually for corrosive damage so it can be remediated prior to failure. Pump Stations Yes No NA NE Please list the Pump Stations Inspected: Balmore, Maintenance, Wyndfall # Number of duplex or larger pump stations in system 3 # 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? 3 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? ❑ ❑ ❑ Page 5 of 6 DocuSign Envelope ID: AB208C1A-889D-4FED-B92B-4C61 D5C21 CC4 Permit: WQCSD0526 Owner - Facility:904 Georgetown Treatment Plant LLC Inspection Date: 09/16/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Is the telemetry system functional? ❑ ❑ ❑ 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: Balmore PS - need to fix pate so it can be locked, fix area light Maintenance PS - need to repair audible alarm and replace lock that had been cut off Wyndfall PS - need to keep locked Page 6 of 6