WQCS00363_NOI_NOV2021PC0493_Response_20211108

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Mr. Lon T. Snider, Regional Supervisor
C/O North Carolina Department of Environmental Quality
450 West Hanes Mill Road, Suite 300
Winston Salem, NC 27105-7407
Re: Response to Notice of Violation
Tracking Number: NOV-2021-PC-0493
Permit No: WQCS00363
Trinity Collection System/Randolph County
Mr. Snider,
This letter is in reference to the Notice of Violations found during the Annual Audit of the City of Trinity
Collections System.
The items listed as non -compliant in your letter have been addressed as follows
FOG Program: The city has created a FOG Inspections form to be used when inspections are done for accounts
requiring this inspection (copy attached). We have added FOG information to our website with a clear link to that
information. Listings of identified FOG uses have been created for inspections. We are currently seeking/exploring
any options that are available for FOG. We have contacted a neighboring municipality for pointers and to view their
procedures used during inspections for FOG. If you have any information concerning where the City may attend a
class, please share the information with me. In discussing this with the Public Works Supervisor he advised me this
was not something that a lot of time was spent on during their classes. A system has been created to document and
file all future inspections.
Pump Station Contingency Plan: We are working with Abbotts Creek Engineering to develop a separate
Contingency Plan for pump failure. We will review the draft again on 10/26/2021 for any final edits and will post
final plan at all lift stations as well as make sure copies are available on -hand for the operators.
Collection System Inspections: Confirmation document has been created to confirm inspections for Annual
Collection Systems. The sewer map will be used to document ROW Easement as completed. All documentation
will be signed off by the Public Works Supervisor.
High Priority Lines: These lines are being identified and marked using sewer maps and GIS software. This will be
completed by January 01, 2022. We were not aware that most of our lines are considered High Priority Lines. This
was not brought to our attention until this inspection. The High Priority Lines are inspected by default even though
not identified as HP lines at the time of inspection.
5978 NC Highway 62 • P.O. Box 50 • Trinity, NC 27370 • Phone [phone] • Fax [phone]

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The City did not deliberately ignore the requirements of our permit and as indicated most of the violations were
record keeping that had not been questioned in the past inspections. Since Mr. Baker's retirement we have replaced
our Public Works supervisor 2 times.
Our current Public Works Supervisor is working diligently with our engineer as well as a neighboring municipality
to make sure the issues addressed in this letter are identified and corrected to meet the requirements set by the North
Carolina Department of Environmental Quality. All requirements have been addressed concerning paper record
acknowledgements. The Pump Station Contingency Plan will be completed by the end of the month (October).
The High Priority Lines will be identified by the end of the year.
I would like to respectfully request that you take all of this into consideration when considering the next steps to this
process.
Sincerely,
Debbie Hinson, City Manager
City of Trinity
Cc: Rodney Johnson
5978 NC Highway 62 • P.O. Box 50 • Trinity, NC 27370 • Phone [phone] • Fax [phone]

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System
Inspection
Documentation

Date:
I certify that City of Trinity operators have observed the entire collection system over the course
of the previous year.
Signature/Title
5978 NC Highway 62 • P.O. Box 50 • Trinity, NC 27370 • Phone [phone] • Fax [phone]

FOG
Inspection
Form and Documentation

FOG INSPECTION FORM
GENERAL INFORMATION
Inspector_
Date/Time of
Facility Name
Facility Address
Facility Contact Name & Til
Facility Telephone Number
GREASE TRAP/INTERCEPTOR INFORMATION
Does the facility have (circle one): Outside Grease Interceptor - Inside Grease Trap
Location of Trap/Interceptor
Condition of Trap/Interceptor
Measurement of Grease Layer (in inches)
Are lids to trap/interceptor accessible? YES -- NO
Pumping Company and Contact #
BMP/INTERVIEW INFORMATION
Are appropriate BMPs being follow? YES — NO
Is a maintenance log on site of inspections/cleanings? YES — NO
If YES, is unit inspected at least every two (2) months? YES — NO
Does establishment keep load tickets of pumping activities? YES — NO
Is a company employee present to observe grease interceptor pumping? YES —NO
Is the grease interceptor left empty upon completion of pumping? YES — NO
Is the trap/interceptor being cleaned based on the 25% rule? YES — NO
Are fryer vats present? YES — NO
If YES, are waste grease and oil storage containers present? YES — NO
Is a garbage grinder present? YES — NO
If NO, are drain screens used? YES— NO
Is an automatic dishwasher present? YES — NO

COMMENTS:
Corrections and Deadline

Date:
I certify that City of Trinity operators have observed the entire collection system over the course
of the previous year.
5978 NC Highway 62 • P.O. Box 50 • Trinity, NC 27370 • Phone [phone] • Fax [phone]