WQCS00015_Inspection_20220316

DocuSign Envelope ID: 80DDC7D6-B962-407C-8FE7-1174A17F8A13
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
March 16, 2022
Steven J Whited
Commanding Officer Marine Corps Base Camp Lejeune
P S C Box 20004
Camp Lejeune, NC 28542-0004
SUBJECT: Compliance Inspection Report
Camp Lejeune Collection System
Collection System Permit No. WQCS00015
Onslow County
Dear Permittee:
The North Carolina Division of Water Resources conducted an inspection of the Camp Lejeune Collection
System on 3/01/2022 and 3/02/2022. This inspection was conducted to verify that the facility is operating in
compliance with the conditions and limitations specified in Collection System Permit No. WQCS00015.
The findings and comments noted during this inspection are provided in the enclosed copy of the
inspection report entitled "Compliance Inspection Report".
There were no significant issues or findings noted during the inspection and therefore, a response to this
inspection report is not required. If you should have any questions, please do not hesitate to contact Bryan
Lievre with the Water Quality Regional Operations Section in the Wilmington Regional Office at 910-796-7215
or via email at [e-mail].
ATTACHMENT
Cc: Laserfiche
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Sincerely,
DocuSigned by:
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Morella Sanchez -King, Regional Supervisor
Water Quality Regional Operations Section
Wilmington Regional Office
Division of Water Resources, NCDEQ
North Carolina Department of Environmental Quality I Division of Water Resources
Wilmington Regional Office 1127 Cardinal Drive Extension I Wilmington, North Carolina 28405
910.796,7215

DocuSign Envelope ID: 80DDC7D6-B962-407C-8FE7-1174A17F8A13
Compliance Inspection Report
Permit: WQCS00015 Effective: 12/01/15 Expiration: 11/30/23
SOC: Effective: Expiration:
County: Onslow
Region: Wilmington
Contact Person: Steven J Whited Title: Utilities Director
Directions to Facility:
System Classifications: CS4,
Primary ORC: Randy Allen Meeks
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
NC0063029
Owner : Commanding Officer Marine Corps Base
Camp Lejeune
Facility: Camp Lejeune Collection System
Phone: [phone] Ext.223
Certification: 1009948 Phone: [phone]
Commanding Officer Marine Corps Base Camp Lejeune - Frenchs Creek
Advanced WWTP
Inspection Date: 03/01/2022
Primary Inspector: Bryan Lievre
Secondary Inspector(s):
Reason for Inspection: Routine
Entry Time 08:OOAM
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Exit Time: 03:OOPM
Phone: [phone]
Inspection Type: Collection System Inspect Non Sampling
Permit Inspection Type: Collection system management and operation
Facility Status: Compliant
Question Areas:
▪ Miscellaneous Questions
▪ Capital Improvement Plan
▪ Inspections
▪ Lines
(See attachment summary)
Not Compliant
▪ General
▪ Map
▪ Spill Response Plan
▪ Manholes
▪ Sewer & FOG Ordinances
▪ Reporting Requirements
▪ Spills
▪ Pump Stations
Page 1 of 8

DocuSign Envelope ID: 80DDC7D6-B962-407C-8FE7-1174A17F8A13
Permit: WQCS00015 Owner - Facility: Commanding Officer Marine Corps Base Camp Lejeune
Inspection Date: 03/01/2022
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Inspection Summary:
An inspection of the Marine Corps Base Camp Lejeune collection system, Permit Number WQCS00015, was performed
from March 1, 2022 and March 2, 2022 in order to verify compliance with the existing permit. Present during the procedures
were (at times) Randy Meeks (Collections Supervisor and ORC), Charles ("Sonny") Scozzari (Collections BORC and Land
Applications Supervisor), Curtis Sallis (Collections BORC & French Creek Advanced WWTF ORC), and Travis Vorhees and
Dan Straub (both with Environmental Management Division) for the base as well as Megan Faulkner and Bryan Lievre (both
with NCDEQ, DWR).
The existing permit provides for the operation of a wastewater collection system which serves the base and discharges into
the Frenchs Creek Advanced Wastewater Plant, Permit Number NC0063029. The collection system is currently permitted
for 116 miles of gravity sewer, approximately 102 miles of force mains, 185 simplex pump stations that discharge to a
pressure sewer and serve a single building, 154 duplex pump stations.
During the two-day inspection, inspectors were provided with all requested reports and logs which were reviewed and
discussed. The control room was shown with the older (to be phased out) and newer SCADA systems, GIS system and
associated database, as well as Maximo system. Field activities were performed, as noted within the attached report.
During the inspection, system staff demonstrated the use of a new truck to clean lines on Neville Cove and staff seemed
very knowledgeable of operations and procedures.
Significant advances have been made to organize the system and operations through the use of a Maximo database
platform and updated SCADA system. Although not specifically mentioned within the permit, there are four oil/water
separators included within the collection system which are maintained by a subcontractor. Closer scrutiny of these
structures is recommended since these structures can be a source of significant inflow during precipitation events which can
place a heavy burden on the wastewater treatment system or if not properly maintained. It is our understanding that
maintenance grease traps are also performed by a subcontractor. As these structures represent part of the collection
system, collection staff need to maintain control over these structures and/or control of the subcontractors who are
maintaining these structures, which does not currently seem to be the situation.
Based on discussions with system staff a recommendation was made to perform yearly inspections to focus on limited
areas. Four separate days of inspections were anticipated to cover Hadnot Point and Paradise Point on Day 1, Onslow
Beach, Courthouse Bay and Rifle Range on Day 2, Air Station, Camp Geiger and Sandy Run on Day 3, and Camp Johnson
and Tarawa Terrace on Day 4.
Although a few minor issues were noted during inspection activities, requests for repairs were issued prior to the completion
of field activities. Staff were very knowledgeable of system operations and required activities and their assistance with these
activities is greatly appreciated. Records were reviewed and found to be well organized and comprehensive. Please review
the comment sections of the inspection report for more details.
Page 2 of 8

DocuSign Envelope ID: 80DDC7D6-B962-407C-8FE7-1174A17F8A13
Permit: WQCS00015 Owner - Facility: Commanding Officer Marine Corps Base Camp Lejeune
Inspection Date: 03/01/2022
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
General
Is there a properly designated primary ORC and at least one back-up of proper grade?
Are logs being reviewed by the system management or owner on a regular basis?
# What is that frequency?
# Are there any issues being addressed currently or any in the planning stages?
Is there a specific pump failure plan available for all pump stations?
Does plan indicate if pump parts/new pumps are in spare parts/equipment inventory?
Are new/significantly upgraded pump stations equipped with anti -corrosion materials?
Does the permittee have a copy of their permit?
# Is permit expiring within the next 6 months?
If Yes, has the Permittee applied for renewal?
Yes No NA NE
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Monthly, typ. but
able to review
daily
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Comment: Work activities are performed through the issuance of work orders through a newly adopted
Maximo database management and operating platform. The system has emergency withdrawal
connections at about 95% of pump stations to enable the connection of a portable pump or
pump truck to connect in the event of power outage.
Current issues planned to be addressed include the need to replacement of pump stations
(PS230 & 606) and converting other pump stations with gravity line systems. The current
permit was issued 6/24/15, became effective 12/1/15 and expires 11/30/23.
Sewer and FOG Ordinances
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.)
Distribution of monthly newsletter, maintains information on website, sets up booths at events and places
door hangers in problematic residential areas
Comment: The system has a base order (Grease Control Base Order, dated 3/16/2021) which states how
FOGs are to be handled. The order is enforced through Community Services if it cannot be
resolved otherwise. The base is exploring establishing drop off locations for oils, especially
after holidays (e.g. Thanksgiving, etc.).
Capital Improvement Plan
Yes No NA NE
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every 3 weeks,
every month or 3
X's/yr
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Yes No NA NE
Page 3 of 8

DocuSign Envelope ID: 80DDC7D6-B962-407C-8FE7-1174A17F8A13
Permit: WOCS00015 Owner - Facility: Commanding Officer Marine Corps Base Camp Lejeune
Inspection Date: 03/01/2022
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
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?
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Comment: The base has many reports to cover the requirements cited above, including Capital
Improvement Plan for 2011-2014, Wastewater Collection Master Plan Update (10/2003),
Water/Wastewater Master Plan Update, Phase I, II & III (6/2007) and Water/Wastewater Master
Plan Update (10/2000). Please note that the CIP Report should be updated yearly with results
of recommended needed repairs/upgrades (at a minimum). However since the base does not
have user fees to offset costs and relies on federal appropriations, the system has limited
control over spending for future needs.
Map
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?
Yes No NA NE
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Comment: The map has been placed in a GIS system and is cross -linked to a database that contains
specific information on structures, whereas pipe age can be determined by contract date and
detailed pump station information can be cross-referenced. The GIS system is being updated
regularly as information is obtained. Map books are also printed out and distributed for field
staff.
Reporting Requirements
# 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?
Yes No NA NE
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Page 4 of 8

DocuSign Envelope ID: 80DDC7D6-B962-407C-8FE7-1174A17F8A13
Permit: WQCS00015 Owner - Facility: Commanding Officer Marine Corps Base Camp Lejeune
Inspection Date: 03/01/2022
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Comment: The system has reported 9 spills to the Department since the last inspection, performed on
4/16/2019. Staff report all spills to the Environmental Management Division (EMD) and EMD
staff inform DEQ. When applicable, EMD informs base Communicatons Strategy staff
(COMMSTRAT) staff who prepares press releases and submits to news agencies (e.g. TV,
radio and/or newspaper). Reviewed Annual Performance Plan, dated 8/17/2021 and
requested staff to submit these reports to the Wilmington Regional Offiice annually.
Inspections
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: Pump station inspections are performed greater than the required frequency and this
information is initially logged in sheets located at each location. Information is also logged into
the Maximo management platform. Problematic pump stations are inspected two times per day
and non -problematic may be inspected three times per week. The system maintains an active
spreadsheet which lists all lines designated by permit or by themselves as high priority. The
system has approximately 38 locations designated as high -priority (either based on permit
requirements or their own evaluation) and these lines have typically been inspected three
times per year.
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:
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?
Yes No NA NE
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Comment: Most incidents and spills can be handled by system staff who are generally required to be able
to respond within 1 hour.
Spills
Is system free of known points of bypass?
Yes No NA NE
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DocuSign Envelope ID: 80DDC7D6-B962-407C-8FE7-1174A17F8A13
Permit: WOCS00015 Owner - Facility: Commanding Officer Marine Corps Base Camp Lejeune
Inspection Date: 03/01/2022
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
If No, describe type of bypass and location
Are all spills or sewer related issues/complaints documented?
# Are there repeated overflows/problems (2 or more in 12 months) at same location?
# If Yes, is there a corrective action plan?
Comment:
Lines/Right-of-Ways/Aerial Lines
Please list the Lines/Right of Ways/Aerial Lines Inspected:
Aerial line along west side of Seth Williams Blvd, crosssing Spring Branch, south of pump station S2643
(HPL #36)
Are right-of-ways/easements maintained for full width for access by staff/equipment?
If No, give details on temporary access:
The high priority line right-of-ways are cleared by subcontractors. Inspections are performed by system staff
to ensure work is performed adequately.
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?
Yes No NA NE
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Comment: Cleaning of gravity lines is well documented and these records were provided for review. The
system was unable to clean 10% of gravity lines during the 2020 calendar year due to staffing
issues associated with the Covid virus. However, the system has documented cleaning over
11 % of gravity lines for 2021 calendar year.
Manholes
Please list the Manholes Inspected:
Manholes in the vicinity of the pump stations and aerial line inspected were inspected at the surface.
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?
Yes No NA NE
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Page 6 of 8

DocuSign Envelope ID: 80DDC7D6-B962-407C-8FE7-1174A17F8A13
Permit: WQCS00015 Owner - Facility: Commanding Officer Marine Corps Base Camp Lejeune
Inspection Date: 03/01/2022
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Comment: The system has approximately 3,851 manholes. Manholes ranged from at grade to above
grade and all seemed to be properly constructed. Upon inquiry, the system uses rain guards
within some manholes which are at lower elevations.
Pump Stations
Please list the Pump Stations Inspected:
TT99, S2100, 590, S907, STT47, STT108, SM137 & S2643
# Number of duplex or larger pump stations in system
# Number of vacuum stations in system
# Number of simplex pump stations in system
# Number of simplex pump stations in system serving more than one building
How many pump/vacuum stations have:
# A two-way "auto polling" communication system (SCADA) installed?
# A simple one-way telemetry/communication system (auto -dialer) installed?
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?
# Is there a backup generator or bypass pump connected?
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?
# Is the owner relying on portable units in the event of a power outage?
# If Yes, is there a distribution plan?
If Yes, what resources (Units/Staff/Vehicles/etc) are included in Plan?
In addition to back-up emergency generators, the system has installed emergency withdrawal connections at
95% of the pump stations to enable connection of a portable pump or vacuum truck to prevent spills.
# Does Permittee have the approved percentage of replacement simplex pumps?
Yes No NA NE
161
0
23
0
135
0
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Page 7 of 8

DocuSign Envelope ID: 80DDC7D6-B962-407C-8FE7-1174A17F8A13
Permit: WOCS00015 Owner - Facility: Commanding Officer Marine Corps Base Camp Lejeune
Inspection Date: 03/01/2022
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Is recordkeeping of pump station inspection and maintenance program adequate?
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?
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Comment: Inspection log books were observed and inspected at each of the locations inspected. The
only location which did not have a book was the simplex station (S907), whereas the simplex
pump stations are serviced by a subcontractor (EMI). The audible alarm at pump stations
S907 and S2643 were inoperative. DEQ and base staff spoke to the assistant director of a
daycare which discharges into pump station STT108 regarding the excessive amount of female
hygene applicators being discharged into the system and assurnces were provided that these
practices would halt.
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