WQCS00146_Compliance Evaluation Inspection - NOV-2023-PC-0471_20230918

DocuSign Envelope ID: DAAC215C-lC54-44D8-BE58-B5503BA88742
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
Certified Mail # 7017 2680 0000 2237 3178
Return Receipt Requested
September 18, 2023
Kent Jackson, Assistant Town Manager/Engineering Director
Town of Pittsboro
PO Box 759
Pittsboro, North Carolina 27312-0759
Subject: Notice of Violation and Compliance Evaluation Inspection
Case No.: NOV-2023-PC-0471
Town of Pittsboro Sewer Collection System
Collection System Permit No: WQCS00146
Chatham County
Dear Mr. Jackson:
On September 6, 2023, Cheng Zhang and Kevin Fowler of the Raleigh Regional (RRO) Office Division
of Water Quality conducted a Compliance Evaluation Inspection of the subject facility. The assistance
and cooperation of you, Mr. Ken Green, and Mr. Mark Wright, during the inspection, were very helpful
and appreciated. A checklist of items is enclosed with this letter. During the inspection the following
items were noted:
1.) The Town's Collection System is classified as a CS-2 system. Current permit became effective on
February 20, 2023, and will expire on January 31, 2031. The Town has not designated an
Operators in Responsible Charge (ORC). Jamie McLaurin is listed as the backup ORC. 15A
NCAC 8G.0201 requires the Permittee shall designate and employ a certified operator to be in
responsible charge (ORC) and one or more certified operator(s) to be back-up ORC(s) of the
facilities. The Town must designate an ORC by October 6, 2023.
2.) The Town has developed and implemented a Capital Improvement Plan covering a period from 2022
through 2036.
3.) The Town has maintained a map of the collection system, the following required elements need to
be added to the map: approximate pipe age, pipe materials for gravity lines and force mains,
and force main air release valve location/type.
4.) The system has 8 duplex pump stations. All stations were equipped with telemetry system and six
pump stations are equipped with standby generators. Four pump stations (Christian Village,
Northwood High School, Powell Place, Norwood Landings) were visited during this inspection.
These pump stations were inspected and maintained as required by the permit. Pump station
logbooks only documented dates of visits, pump hour meter readings, and generator fuel level.
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office I 3800 BarrettDrive I Raleigh, North Carolina 27609
NORTH CAROLINA ^ �/ 919.791.4200
n-o ,Mo E-Nmnm W10--I V

DocuSign Envelope ID: DAAC215C-1C54-44D8-BE58-B5503BA88742
Documentation of pump station inspections shall include the following items: 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, as required by 15A NCAC 02T.0108(b) and Section II.3. of the Collection System
Permit.
5.) The Town has a Sewer Use Ordinance, which requires users who operate establishments that
prepare, process, or serve food and/or food products to install and maintain grease and oil traps or
other interceptors. It was noted that the Town had not inspected grease traps/interceptors on a
regular basis and take enforcement actions against violators. The Town must develop a
program to inspect grease traps/interceptors at least annually. Distribution of grease
educational material had not been conducted and documented. 15A NCAC 02T.0108(b)
requires bi-annual distribution of educational materials for both commercial and residential
users, distribution of grease/sewer educational material must be documented.
6.) The Town has developed and implemented a spill response action plan; the plan was adequate.
7.) A review of records and logbooks indicates the following:
a) High priority line inspections and easement maintenance were not documented as required
by Section II.6. and V. 4.. Line cleaning was marked on sewer map, however, footage of
gravity line cleaning was not documented. The Town must document gravity line cleaning,
high priority line inspections, and easement maintenance in details.
b) No Sanitary Sewer Overflows (SSOs) were discovered or reported in the past three years.
8.) The Town has three designated high priority/aerial lines; two high priority lines were observed
during the inspection, the aerial line at MLK Blvd.@ Fairground/Roberts Street was in good
condition, the aerial line at 15-501 South had overgrowing vegetation that needs to be removed.
The right-of-way to these high priority lines were maintained and accessible.
9.) Annual wastewater performance reports were not filed with the Division and not available to all
sewer customers. The Town must submit annual wastewater performance reports to the
Division and make the reports available to all customers (by mailing or posting on the Town's
website), as required by North Carolina General Statute §143-215.1C.
This inspection letter is being issued as a Notice of Violation due to the conditions noted above.
Please respond in writing to RRO within 30 days of receipt of this letter regarding Items 1, 3, 4,
5,7,8,and 9.
D � ��� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CAROLINA ��` 919.707.9000
nnpn .mo EnWromm�nfal nual

DocuSign Envelope ID: DAAC215C-1C54-44D8-BE58-B5503BA88742
If you have any questions regarding the attached report or any of the findings, please contact Cheng
Zhang at: [phone] (or email: Cheng [e-mail]. og_v).
Sincerely,
DocuSigned by:
f.
Vaun t,SSa
62916E6AB32144F...
Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources
Attachments: Compliance Inspection Report
Cc: Laserfiche
D � ��� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CAROLINA ��` 919.707.9000
nnpn .mo EnWromm�nfal nual

DocuSign Envelope ID: 6EA5767C-A189-48E6-A027-5F9E8833A769
Compliance Inspection Report
Permit: WQCS00146 Effective: 02/20/23 Expiration: 01/31/31 Owner : Town of Pittsboro
SOC: Effective: Expiration: Facility: Pittsboro Collection System
County: Chatham PO Box 759
Region: Raleigh
Pittsboro NC 273120759
Contact Person: Jonathan Franklin Title: Town Manager Phone: [phone] Ext.1105
Directions to Facility:
System Classifications: CS2,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s): Kent Jackson, Ken Green, Mark Wright, and Gerald Cox (City of Sanford)
Related Permits:
NCO020354 Town of Pittsboro - Pittsboro WWTP
Inspection Date: 09/06/2023 Entry Time 09:30AM Exit Time: 12:45PM
Primary Inspector: Cheng Zhang DocuSigned by: Phone: [phone]
Secondary Inspector(s): Kevin Fowler
D6171508E1EC41F.-
DocuSigned by:
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Reason for Inspection: Routine 5DCE14CC... 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

DocuSign Envelope ID: 6EA5767C-A189-48E6-A027-5F9E8833A769
Permit: WQCS00146 Owner - Facility: Town of Pittsboro
Inspection Date: 09/06/2023 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Inspection Summary:
Current permit became effective on February 20, 2023 and will expire on January 31, 2031. No designated ORC. Logs are
not reviewed on a regular basis because vacant ORC/supervisor position. The Town has a merger agreement with City of
Sanford, effective on June 30, 2024. City of Sanford will take over the Town's collection system after the merger, current
permit might need to be rescinded.
The Town has developed and implemented a Capital Improvement Plan covering a period from 2022 through 2036.
The Spill Response Action Plan was adequate.
The Town has a Sewer Use Ordinance, which requires users operate establishment preparing, processing, or serving food
and/or food products to install and maintain grease and oil traps or other interceptors. It was noted that the Town had not
inspected grease traps/interceptors on a regular basis and take enforcement actions against violators. Distribution of
grease educational material had not been conducted and documented.
The Town maintains a map of the sewer system, the following components need to be added to the map: pipe materials for
gravity lines and force mains, approximate pipe age, and force main air release valve location/type.
Pump stations were inspected weekly, and documented on logbooks. Documentation of pump station inspections shall
include the following items: 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.
High priority line inspections and easement maintenance were not documented. Line cleaning was marked on sewer map,
footage of gravity line cleaning was not documented.
Page 2 of 7

DocuSign Envelope ID: 6EA5767C-A189-48E6-A027-5F9E8833A769
Permit: WQCS00146 Owner - Facility: Town of Pittsboro
Inspection Date: 09/06/2023 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? ❑ ❑ ❑
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? 0 ❑ ❑ ❑
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? ❑ ❑ 0 ❑
Comment: Current permit became effective on February 20, 2023 and will expire on ianuary 31, 2031. No
designated ORC. Logs are not reviewed on a regular basis because vacant ORC/supervisor
position. The Town has a merger agreement with City of Sanford, effective on June 30, 2024.
City of Sanford will take over the Town's collection system after the merger, current permit
might need to be rescinded.
Sewer and FOG Ordinances Yes No NA NE
Is Sewer Use Ordinance (SUO) or other Legal Authority available? 0 ❑ ❑ ❑
Does it appear that the Sewer Use Ordinance is enforced? ❑ 0 ❑ ❑
Is there a Grease Control Program that legally requires grease control devices? M ❑ ❑ ❑
What is the standard grease trap cleaning requirement in the FOG ordinance? every 30 days
Is Grease Control Program enforced via periodic inspections/records review? ❑ 0 ❑ ❑
Is action taken against violators? ❑ ❑ 0 ❑
# Have satellite systems adopted an equivalent or more stringent ordinance? ❑ ❑ 0 ❑
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? ❑ 0 ❑ ❑
If Yes, what are they? (This can reduce mailing to annual.)
Comment: Grease traps/interceptors are not inspected on a regular basis. Grease educational material
has not been mailed as required.
Capital Improvement Plan Yes No NA NE
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? ❑ ❑ ❑
Page 3 of 7

DocuSign Envelope ID: 6EA5767C-A189-48E6-A027-5F9E8833A769
Permit: WQCS00146 Owner - Facility: Town of Pittsboro
Inspection Date: 09/06/2023 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Does CIP include forecasted future needs? 0 ❑ ❑ ❑
Comment: Dedicated section in the Town's overall CIP.
Map Yes No NA NE
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? 0 ❑ ❑ ❑
Comment: Pipe materials only available for high priority lines. Approximate pipe age and force main air
release valve location/type were not available.
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?
Comment: No reportable SSOs in past three years. Annual wastewater performance reports were not
filed with the Division and not available to all sewer customers.
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?
❑ ❑ ❑
Page 4 of 7

DocuSign Envelope ID: 6EA5767C-A189-48E6-A027-5F9E8833A769
Permit: WQCS00146 Owner - Facility: Town of Pittsboro
Inspection Date: 09/06/2023 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Comment: Pump station inspection logbooks are kept at each pump station. High priority line inspections
and easement maintenance were not documented. Line cleaning was marked on sewer map,
cleaning footage was not documented.
Spill Response Action Plan Yes No NA NE
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
❑ ❑ ❑
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?
M
❑ ❑ ❑
Comment:
Spills 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? 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 ❑
Comment:
Lines/Right-of-Ways/Aerial Lines Yes No NA NE
Please list the Lines/Right of Ways/Aerial Lines Inspected:
15-501 South near Bridge and MILK Blvd.(@_ Fairground/Roberts Street.
Are right-of-ways/easements maintained for full width for access by staff/equipment? 0 ❑ ❑ ❑
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? ❑ 0 ❑ ❑
Comment: Brush growth around 15-501 South HPL was observed.
Manholes Yes No NA NE
Page 5 of 7

DocuSign Envelope ID: 6EA5767C-A189-48E6-A027-5F9E8833A769
Permit: WQCS00146 Owner - Facility: Town of Pittsboro
Inspection Date: 09/06/2023 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Please list the Manholes Inspected:
Manhole at Thompson Street Outfall line
Manhole outsied Christian Village pump station
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:
Pump Stations
Please list the Pump Stations Inspected:
Christian Village, Northwood High School, Powell Place, Norwood
Landings
# 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?
FcArr84isStg Rpesv��treeACrted 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:
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
❑❑■❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Yes No NA NE
8
0
0
0
0
8
Page 6 of 7

DocuSign Envelope ID: 6EA5767C-A189-48E6-A027-5F9E8833A769
Permit: WQCS00146 Owner - Facility: Town of Pittsboro
Inspection Date: 09/06/2023 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
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?
# Does Permittee have the approved percentage of replacement simplex pumps?
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? ❑ 0 ❑ ❑
Inspecting and exercising all valves? ❑ 0 ❑ ❑
Inspecting and lubricating pumps and other equipment? ❑ 0 ❑ ❑
Inspecting alarms, telemetry and auxiliary equipment? ❑ 0 ❑ ❑
Comment: Pump station logbooks only documented dates of visits, pump hour meter readings, and
generator fuel level. For pump stations without standby generator, the Town uses a portable
diesel pump during power outrage.
Page 7 of 7