WQCS00278_NOVNOI-2022-DV-0249 Response_20220906

Town of Surf City
Douglas C. Medlin, Mayor
William J. (Buddy) Fowler, Mayor Pro-Tem
John Koloski, Councilman
Donald R. Helms, Councilman
Teresa B. Batts, Councilwoman
Jeremy Shugarts, Councilman
September 2, 2022
Subject: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Tracking No.: NOV-2022-DV-0249
Sanitary Sewer Overflows —July 2022
Collections System Permit No. WQCS00278
Surf City Collection System
Pender County
Mrs. Helen Perez
Water Quality Regional Operations Section
Division of Water Resources
Department of Environmental Quality
Mrs. Perez,
The Town of Surf City would like to thank the NCDEQ for the opportunity to respond to the
mentioned Notice of Violation (NOV). Our two organizations have always had honest and open
communications concerning the geographical challenges of operating a utility so close to the water. I
would like this to continue in this matter as well.
During the month of July 2022, several storms blew through the area causing lighting damage to
multiple town facilities. The last of which occurred on July 31 at approximately 5 pm. During this storm
the Mainland Lift Station suffered a surge of electricity that incapacitated portions of the Programable
Logic Computer (PLC). This damage froze the inputs of the PLC to the values that were existing at the
time of the surge. The result is that there were no inputs telling the pumps to run. Also, audio/visual
alarms and telemetry notifications did not sound since all of this is controlled by the PLC. An operational
generator was in place but since there was no power loss it did not come on. The situation was not
discovered until 7:30 am on August 15t, when staff seen the flow coming into the wastewater plant was
less than normal. By 8:00 am of the same day staff had the pumpstation operational again and started
remediation efforts for the spill.
While the pumpstation was being worked on, staff located the SSO. This SSO occurred on the
back of a ditch. Therefore, staff dammed up the entire water conveyance system at the point it enters
the Intercoastal Waterway by Water's Bay. Once the pumpstation was repaired, staff pumped all water
back into the collections system to be sent to the WWTP. Once this was complete, the entire
conveyance system was treated with lime. The only visual evidence of a SSO was at the manhole at the
corner of Alston Blvd and Roland Ave. This was cleaned up and sanitized.
214 W Florence Way PO BOX 2475 PHONE [phone]
Hampstead, North Carolina 28443 Surf City, North Carolina 28445 FAX [phone]

The calculation for the amount of the SSO was determined by taking the average flow for the
time period and subtracting it from the storage capacity of this section of the collections system. This is
not an exact number, and the town is not sure any of the SSO reached the waterway. This was reported
as such out of an abundance of caution. The fecal test result of 8 MPN and TKN test results of .6mg/L
indicate that either the SSO did not reach the waterway, or the actions of staff greatly mitigated its
effect.
In order to prevent this occurrence in the future, the town had a data fail alarm installed on this
station and is in the process of installing them on every other station in the system. A data fail alarm will
send alarms through the telemetry system if new data stops being received by the SCADA main
computer for any reason. The Town also added a weekly test to all backup equipment at this station.
The collection system was in full compliance in terms of inspection and equipment when this
unpredictable natural event bypassed every redundancy we put into place. Town staff did everything
possible to prevent further ecological damage once the problem was discovered. The test results show
they were successful. There were no known fish kills or impact to public health. The recreational area
closures were closed out of caution but quickly reopened once the test results were revealed. The fact
that staff reported this incident before knowing quantity of SSO or if any reached the waterway shows
the town's commitment to ecological and public safety over personal or political convenience. With this
in mind the Town of Surf City respectfully asks that civil penalties to be waived in regard to this incident.
Should you need more information on this matter, please contact David Price, Director of Public
Utilities at 910-545-3059. Thank you for your consideration.
Regards,
Ky[e reuer, AICP
To n of Surf City
Town Manager
910-328-4131