WQCSD0420_PC-2019-0582_20190816

ROY COOPER . —)
Cowtror .
MICI-}AEL S.REGAN _,= RECEIVED/NCDE61/DWR
Secretary � ""`
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LINDA CULPEPPER NORTH CAROLINA AUG 2 3 2019
Director Environmental Quality
Water Quality
Permitting Section
Certified Mail # 7018 0040 0000 4771 7202
Return Receipt Requested
August 16, 2019
Ulysses Barrett, Mayor
Town of Taylortown
PO Box 1274
Pinehurst, NC 28374
SUBJECT: NOTICE OF VIOLATION
Tracking Number: NOV-2019-PC-0582
Permit No. WQCSD0420
Taylortown Collection System
Moore County
Dear Permittee:
The North Carolina Division of Water Resources conducted an inspection of the Taylortown Collection System on
August 14, 2019. This inspection was conducted to verify that the facility is operating in compliance with the
conditions and limitations specified in Collection System Permit No. WQCSD0420. A summary of the findings and
comments noted during the inspection are provided in the enclosed copy of the inspection report.
The Collection System Non-sampling inspection was conducted by Division of Water Resources staff from the
Fayetteville Regional Office. The following violation(s) were noted during the inspection:
Inspection Area Description of Violation
Pump Stations 24-hour emergency notification sign was posted but there is no pump station identifier
present on the sign. This issue was noted in previous inspection reports and has not
been corrected. Pump station identifier sign shall be posted. Audible and visual alarms
at the Main St. pump station were not functional. Repairs to the alarms shall be made
immediately. Documentation of pump station visitation, inspection and maintenance
was not available. Permittee shall immediately begin keeping required documentation.
Grease Control Documentation of grease trap inspections should be kept.
General Records of system maintenance were not available. All maintenance activities should be
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documented. i
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Inspection Area Description of Violation
Lines/Right-of-Ways/Aerial ROW's observed duringinspection appeared to be accessible, but were beginning to grow
P PP9 9
Lines up with vegetation. Documentation of ROW clearing shall be maintained. _
Inspections Written documentation of maintenance was not available. Please be reminded that
documentation of any and all maintenance activities is required. No documentation of
pump stations visitation was available. Inspector was told during inspection that pump
stations were visited 6 days per week. Non-telemetry pump stations shall be visited 7 days
per week, 365 days per year. Documentation of inspection of high priority lines should be
kept.
In addition, the issues below must also be addressed:
Compliance Issue(s):
1. Permittee shall immediately begin maintaining written documentation of all maintenance
activities related to the operation of this collection system.
2. The garbage cans present at the pump stations containing grease and debris removed from the
pump stations shall be removed and properly disposed of within 30 days of the receipt of this
letter. This was noted in a previous inspection but has not been properly addressed.
3. No documentation of pump station visitation was available, but it was the understanding of the
inspector that pump stations were being visited 5-6 days per week. Pump stations that only
have audible/visual alarms shall be visited 7 days per week, 365 days per year.
4. Emergency notification signage shall be provided that includes a pump station identifier at both
pump stations.
5. Audible and visual alarms were not functional at the Main Street pump station. Immediate
repairs shall be made.
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, please respond in writing to this office within 10 days upon your receipt of this Notice
of Violation regarding your plans or measures to be taken to address the indicated violations and other identified
issues, if applicable.
If you should have any questions, please do not hesitate to contact Chad Turlington with the Water Quality
Regional Operations Section in the Fayetteville Regional Office at 910-433-3300.
Sincerely,
f--DocuSigned by:
'-5189C2D3DD5C42B
J. Trent Allen, Regional Supervisor
Water Quality Regional Operations Section
Fayetteville Regional Office
Division of Water Resources, NCDEQ f
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ATTACHMENTS
Cc: WQS Fayetteville Regional Office - Enforcement File
PERCS Compliance/Enforcement Unit - Enforcement Fille
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Compliance Inspection Report
Permit: WQCSD0420 Effective: 03/01/00 Expiration: Owner: Town of Taylortown
SOC: Effective: Expiration: Facility: Taylortown Collection System
County: Moore
Region: Fayetteville
Contact Person: Ulysses Barrett Title: Phone:
Directions to Facility: j
13
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
i
Inspection Date: 08/14/2019 Entry Time: 10 30AM Exit Time: 12 30PM
,—DocuSigned by
Primary Inspector: Chad Turlington Ativt--,sv Phone: [phone] Ext 720 I
Secondary Inspector(s): `—CCA0697813D247D
,—DocuSigned by
Trent Allen •^R 0--k&A,
Reason for Inspection: Routine Inspection Type: Collection System Inspect Non Sampling
5189C2D3DD5C42B
Permit Inspection Type: Deemed permitted collection system management and operation
Facility Status: ❑ Compliant II Not Compliant
Question Areas: 1
in Miscellaneous Questions I. General II Grease Control
• Spills/Response Plan El Inspections 11 Lines
I. Pump Stations
(See attachment summary)
)
Page 1 of 6

Permit: WQCSD0420 Owner-Facility:Town of Taylortown
Inspection Date: 08/14/2019 Inspection Type:Collection System Inspect Non Sampling Reason for Visit: Routine
Inspection Summary
A copy of the spill response plan and map of the system were available for review Inspector was told that grease education
materials were being distributed,but no documentation of the distribution was available Permittee shall begin keeping
documentation of bi-annual distribution of grease education materials No documentation of any maintenance,cleaining,
pump station visitation or emergency generator testing was avaible Please ensure that documentation of all activities
related to the operation-of this collection system are documented The right of ways observed during the inspection
appeared accesible, but there was considerable vegetation and small trees begining to grow up on the ROW
Documentation of ROW clearing was not available Please begin keeping written documentation of ROW clearing. 24-hour
notification signs were present at both pump stations,but pump station identifier information was not on the sign Permittee
shall provide pump station identifier signage at both pump stations This issue was documented on a previous Collection
Sytem inspection report from 9/7/2016, but has not been corrected as of the date of this inspection. The audible and visual
alarms at the Main St pump station were not functional at the time of this inspection Corrective actions shall be
immediately undertaken Grease accumulation and debris being removed from the wet wells at both pump stations and
being stored in household trash cans at the stations Some of the trash cans were split open allowing the contents to spill
out Some of the cans had no lids and were allowing rain water to enter and then overflow out onto the ground. Another
method for pump station debris removal cleaning should be developed that does not involve storage of the removed material
in the current manner Trash cans of debris present at the pump stations shall be removed and disposed of properly. This
issue was also noted in the previous inspection report,but has not been corrected
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Permit: WQCSD0420 Owner-Facility:Town of Taylortown
Inspection Date- 08/14/2019 Inspection Type:Collection System Inspect Non Sampling Reason for Visit: Routine
General Yes No NA NE
#Is this system a satellite system? El ❑ • El
#If Yes,what is system name or permit number?
Is there a overall sewer system map? III ❑ El ❑ i
I
Does the map include
Pipe sizes • ❑ ❑ 0 ;
Pipe matenals(PVC,DIP,etc) ❑ ❑ ❑
IN i
Pipe location • 0 ❑ ❑ 1
# Flow direction • 0 El El
# Approximate pipe age El ❑ 0
# Pump station ID,location and capacity • 0 0 El i
# Force main air release valve location&type ❑ El 0 •
# Location of satellite connections 0 0 IN 0 i
Are system maintenance records maintained? ❑ • 0 ❑ I
Comment. Records of system maintenance were not available All maintenance activities should be
documented I
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Grease Control Yes No NA NE I
Is grease/sewer education program documented with req'd customer distribution'? El • ❑ ❑
#Are other types of education tools used like websites,booths,special meetings,etc'? ❑ ❑ III ❑ • 1
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If Yes,what are they'?(This can reduce mailing to annual) 1
Documentation of the required grease education matenals distnbution should be maintained 1
For public systems,is there a Grease Control Program via an ordinance/agreement? • ❑ ❑ ❑ 1
If Yes,does it require grease control devices at applicable locations'? • ❑ El El I
Is the Grease Control Program enforced via periodic inspections/records review'? ❑ El 0 ■
Is action taken against violators'? El 0 ❑
III I
Comment: Documentation of grease trap inspections should be kept
Spills and Response Action Plan Yes No NA NE
#Is system free of known points of bypass'? • El ❑ El
If No,descnbe type of bypass and location
#Have there been any sewer spills in the past 3 years'? • ❑ ❑ El 4
4
If Yes,were they reported to the Division if meeting the reportable criteria'? • ❑ ❑ El 1
If applicable,is there documentation of press releases and public notices issued'? ❑ El • ❑
I
Are all spills or sewer related issues/complaints documented'? 1 ❑ ❑ ❑ i
#Are there repeated overflows/problems(2 or more in 12 months)at same location'? ❑ ❑ MI ❑
#If Yes,is there a corrective action plan'? El El U ❑ 1
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Permit: WQCSD0420 Owner-Facility:Town of Taylortown
Inspection Date 08/14/2019 Inspection Type:Collection System Inspect Non Sampling Reason for Visit: Routine
Is a Spill Response Action Plan available? M ❑ 0 0 I
Is a Spill Response Action Plan available for all personnel? • 0 ❑ ❑ 1
1
Does the plan include i
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# 24-hour contact numbers • El El
# Response time • ❑ ❑ ❑ I
# Equipment list and spare parts inventory III 0 ❑ ❑ l
# Access to cleaning equipment • ❑ ❑ ❑ 1
# Access to construction crews,contractors,and/or engineers M ❑ ❑ 0 1
# Source of emergency funds • ❑ ❑ ❑
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# Site sanitation and cleanup matenals M ❑ ❑ ❑ I
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# Post-overflow/spill assessment U ❑ ❑ El
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Comment:
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Inspections Yes No NA NE
Are adequate maintenance records maintained? ❑ MI ❑ ❑ i
Are pump stations being inspected at the required frequency? 0 1 ❑ ❑ 1
I
Is at least one complete functionality test conducted weekly per pump station? • ❑ ❑ ❑ I
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Is there a system or plan in place to observe the entire system annually? II 0 0 ❑
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Is the annual inspection documented'? ❑ III ❑ ❑ 1
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#Does the system have any high-priority lines/locations? • ❑ ❑ ❑ 1
Are inspections of HPL documented at least every 6 months? • ❑ ❑ ❑ I
Are new lines being added to the HPL list when found or created'? ❑ ❑ NI ❑ i
I
Comment. Written documentation of maintenace was not availalble. Please be reminded that
documentation of any and all maintenace activites is required. No documentation of pump
stations was available Inspector was told during inspection that pump stations were visited 6
days per week Non-telemetry pump stations shall be visted 7 days per week, 365 days per I
year Documentation of inspection of high priority lines should be kept
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Lines/Right-of-Ways/Aerial Lines Yes No NA NE {i
Please list the Lines/Right of Ways/Aenal Lines Inspected 9
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Are nght-of-ways and easements maintained for the full width for access'? • ❑ ❑ 0 {
If No,give details on temporary access
Is maintenance documented'? _ ❑ II ❑ ❑
Were all areas/lines inspected free of issues'? ❑ ❑ ❑ 1
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Comment: ROWs observed during inspection appeared to be accessible, but were begining to grow up t
with vegetation Documentation of ROW clearing shall be maintained I
Pump Stations I
Yes No NA NE
Please list the Pump Stations Inspected
Main St,Lincoln St 3
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Permit: WQCSD0420 Owner-Facility:Town of Taylortown
Inspection Date: 08/14/2019 Inspection Type:Collection System Inspect Non Sampling Reason for Visit: Routine t
#Number of duplex or larger pump stations in system 2
#Number of vacuum stations in system
#Number of simplex pump stations in system 1
#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'? 0
# A simple one-way telemetry/communication system(auto-dialer)installed'? c 1
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For pump stations inspected
Are they secure with restricted access? • ❑ 0 0 1
Were they free of by-pass structures/pipes? U ❑ 0 0 1
Were wet wells free of excessive grease/debris? I ❑ ❑ ❑ 4
# Do they all have telemetry installed? ❑ ❑ MI ❑ 1
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Is the telemetry system functional? ❑ 0 • ❑ l
1
Is a 24-hour notification sign posted? II ❑ ❑ ❑ 1
3
Does the sign include I
Owner Name? • ❑ ❑ ❑
Pump station identifier? ❑ • ❑ ❑ !
# Address? ❑ MI 0 ❑ 4
Instructions for notification? • ❑ ❑ ❑
1
24-hour emergency contact numbers'? • ❑ 0 ❑ t
Are audio and visual alarms present? • 0 ❑ ❑ 1
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Are audio and visual alarms operable? ❑ • ❑ ❑
s
#Is there a backup generator or bypass pump connected'? ❑ ❑ • ❑
R
If tested during inspection,did it function properly? ❑ ❑ ❑ •
Is the back-up system tested at least bi-annually under normal operating conditions'? ❑ ❑ ❑ • 1
#Does it have a dedicated connection for a portable generator? MI ❑ ❑ ❑ 1
#Is the owner relying on portable units in the event of a power outage'? II ❑ ❑ ❑ I
#If Yes,is there a distribution plan'? • ❑ ❑ ❑ j
If Yes,what resources(Units/StaffNehicles/etc)are included in Plan'? 1
#Does Permittee have the approved percentage of replacement simplex pumps'? ❑ ❑ I ❑ 1
Is recordkeeping of pump station inspection and maintenance program adequate'? 0 • ❑ Eli
Do pump station logs include at a minimum
Inside and outside cleaning and debris removal'? ❑ • ❑ ❑ !
Inspecting and exercising all valves'? ❑ • ❑ ❑ j
Inspecting and lubricating pumps and other equipment? ❑ • ❑ ❑ i
Inspecting alarms,telemetry and auxiliary equipment'? ❑ • ❑ ❑
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Permit. WQCSD0420 Owner-Facility Town of Taylortown
Inspection Date: 08/14/2019 Inspection Type Collection System Inspect Non Sampling Reason for Visit: Routine
Comment: 24 hour emergency notification sign was posted but there is no pump station identifier present on
the sign This issue was noted in previous inspection reports and has not been corrected.
Pump station identifier sign shall be posted. Audible and visual alarms at the Main St pump
station were not functional Repairs to the alarms shall be made immediately Documentation
of pump station visitation, inspection and maintenance were not available. Permitte shall
immediately begin keeping required documentation.
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