WQCSD0644_Response to Notice NOV-2018-2T-001_20181211

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December 11, 2018
S Daniel Smith
Water Quality Regional Supervisor
Raleigh Regional Office
1628 Mal Service Center
Raleigh, NC 27699-1628
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Subject: Notice of Violation- Intent to Enforce
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NOV-2018-2T-001
Indian Creek Overlook Wastewater Collection System
Permit No. WQCSD0644
Dear Mr. Smith:
Thank you for the opportunity to respond to Notice of Violation NOV-2018-2T-001
issued on November 8, 2013 and received by Envirolink on November 13, 2018. This letter shall
serve as a formal response to the same on behalf of Envirolink and the owner, Indian Creek
MHP, LLC. At the outset, I would like to note that no SSO occurred at the Indian Creek Overlook
facility. Substantial investigation by Envirolink staff confirmed there was no SSO.
Envirolink offers the following response to the questions posed in the November 8 NOV:
1. Who owns this collection system?
Response: Indian Creek MHP, LLC owns the collection system.
2• Who is responsible for operating and maintaining the collection system?
Response: Envirolink, Inc. contracted with the owner to operate and maintain the collection
system and Envirolink employee, Chris Peele, is the Operator in Responsible Charge.
3. Please explain the collection system situation/status in detail:
a• What happened to cause this failure in the collection system. (i.e.
clogged/broken line, broken pumps, etc.)
Response: On September 12, 2018, Indian Creek Overlook ORC, Chris Peele, noticed a problem
with the lift station in question during his weekly inspection. Once the lift station pumps were
cleared and checked, it was determined that the sanitary sewer force main connecting the lift
station to the City of Raleigh collection system was not operating as designed. Mr. Peele began
to pump and haul immediately to prevent an SSO. It was determined that the force main that
connects the lift station to the City of Raleigh collection system was not operating correctly. The
City of Raleigh and Envirolink staff were both onsite and worked collectively to pump and haul
Envirolink, Inc.
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47M Homewood Court, Raleigh, [north Carolina 27609
252-2354900 (phone) 252-235-2132 (fax)

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preventing an overflow situation. Once it was established that the issue was the responsibility of
Indian Creek, Envirolink staff took the lead.
The Indian Creek Overlook system is privately owned and discharges to the City of Raleigh
gravity collection system. On the evening of September 12, 2018, after pumping and hauling the
lift station down to a safe level, it was agreed with the City of Raleigh staff that an Envirolink
technician, Jeff Cincinnati, would remain onsite until the bypass pump was installed. Mr.
Cincinnati was there to monitor the lift station level and be in position to put resources to work,
if needed, to prevent an SSO. Envirolink staff provided 24-hour per day onsite monitoring until
the bypass pump was installed. The bypass diesel pump included an automatic control system,
operating floats and a control panel. Due to the automatic pumping capability and continued
telemetry monitoring, the 24-hour per day monitoring was reduced to daily inspections. The
bypass pump and controls were supplied and installed by Charles R. Underwood, Inc., an
established water and wastewater utility contractor. The bypass pipe length was approximately
700 feet in length through the woods and hilly terrain. The bypass was inspected daily while in
operation from September 13 to October 10, 2018. Final repairs were completed on or around
October 10, 2018 the lift station was put back in service. The force main from the lift station to
the gravity discharge had to be taken apart in sections for inspection by ccty and jetting to clear
the blockage. The force main was reassembled and put back into service on October 10, 2018.
b. What length of the collection system was bypassed?
Response: Approximately 700 feet.
C. When was the issue first discovered? Please clearly detail the duration of
the collection system failures.
Response: The issue was first discovered on September 12, 2018 and was corrected on October
10, 2018. Please see the above response to question 3a for further detail
d. How was the issue discovered?
Response: The issued was discovered during a regularly scheduled weekly inspection by ORC
Chris Peele. Mr. Peele determined during the inspection that lift station level was too high.
Further inspection revealed the lift station was not operating properly. The pumps were pulled
cleared and reinstalled. After checking and reinstalling the pumps the lift Station level continued
to rise. Both the City of Raleigh and Envirolink staff were onsite until it was determined which
system was not working properly and who was responsible. Please see the above response to
question 3a for further detail
e. Specifically, detail the activities/repair efforts that were conducted to
temporarily remedy the inoperable collection system?
Response: Please refer to the above response to question 3a.
f. How was the collection system ultimately repaired?
Envirolink, Inc.
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PO Box 670, Bailey, North Carolina 27807
252-2354900(phone) 252-235-2132(fax)

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Response: The full length of force main was jetted and cleaned to clear the blockage.
g. Are their ongoing repairs/structural or mechanical repairs remaining to
address?
Response: No, all repairs to address the issue are complete.
4. How many pump stations are present at Indian Creek Overlook?
Response: Two pump stations are present at Indian Creek Overlook.
S. Are floats and alarms present at all of the pump station(s)? Are the connected to a
telemetry system? Are all lift stations equipped with operational duel pumps?
Response: Floats and alarms are present at both pump stations. Both pump stations are
connected to telemetry. All lift stations are equipped with operational duel pumps.
6. How often is (are) the pump station(s) inspected? Are records kept of these
inspections?
Response: The pump stations are inspected weekly and records are kept of the inspections.
7. Was any wastewater discharged to the surface?
Response: No wastewater was discharged to the surface.
8. Based on DWR observations, conversations with the City of Raleigh staff and a
neighborhood resident, it appeared that the issue(s) and the bypass pumping lasted
several weeks. The bypass pumping required roads to be inaccessible due to
piping/hose in the roadway during this time. Please explain how long the bypass
Pumping took place and why it took so long to repair the system.
Response: The bypass pumping occurred from September 13, 2018 until October 10, 2018. The
hilly terrain and distance of the force main made jetting and cleaning the force main difficult.
period which caused delays in completing the work. The work was completed
Further, Hurricane Florence and Hurricane Michael produced substantial rain during this tas quickly as
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possible given conditions present, including terrain, distance to the force main and torrential
rains.
9. It was observed by City of Raleigh staff and DWR staff during site visits that no one
was present operating and maintaining the portable pump and pump around. Please
explain why no one was onsite operating the portable pump and observing the bypass
pumping.
Response: The bypass pump was inspected daily during the period it was operated from
September 13, 2018 until October 10, 2018. The system included floats and a control panel for
Envirolink, Inc.
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PO Box 670, Bailey, North Carolina 27807
252-235-4900(phone) 252-235-2132(fax)

automatic operation. Telemetry was active to monitor and provide the lift station with a high-
level alarm.
10. See the ten (10) requirements of 15A NCAC 2T ,0403(a)(1) (attached). These are the
requirements of deemed permitted systems such as Indian Creek Overlook. Please go
through each of the 10 requirements and explain if these requirements are being met
for the Indian Creek Overlook Wastewater Collection System.
Response:
15 NCAC 02T .0403 Permitting By Regulation
(a) Collection systems having an actual, permitted or Division -approved average daily flow less
than 200,000 gallons per day shall be deemed permitted, pursuant to Rule .0113 of this
Subchapter if the system meets the criteria in Rule .0113 of this Subchapter and all criteria
required in this Rule:
1. The collection system shall be effectively maintained and operated at all times to
prevent discharge to land or surface waters and to prevent any contravention of
groundwater standards or surface water standards.
Response: Envirolink operates the collection system pursuant to all applicable regulations.
Routine inspection identified the clogged force main and quick response by Mr. Peele prevented
any discharge to land or surface waters.
2. A map of the collection system shall have been developed and shall be maintained.
Response: A map of the collection system is on file, maintained onsite by the owner.
3. An operation and maintenance plan, including pump station inspection frequency,
preventative maintenance schedule, spare parts inventory, and overflow response shall
have been developed and implemented.
Response: Envirolink has developed and implemented an operation and maintenance plan,
including pump station inspection frequency, preventative maintenance schedule, spare parts
inventory, and overflow response. This plan is contained in Envirolink's wastewater standard
SOP. Mr. Peele and Envirolink technicians have been trained on the SOP.
4. Pump stations that are not connected to a telemetry system shall be inspected by
the permittee or its representative every day, 365 days per year, unless the permittee
demonstrates that daily inspections are not necessary because the pump station has
sufficient storage capacity, above the elevation at which the pump activates, to justify a
longer inspection interval. In no case shall the inspection interval exceed seven days.
Pump stations that are connected to a telemetry system shall be inspected once per
week.
Envirolink, Inc.
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PO Box 670, Bailey, North Carolina 27807
252-235-4900(phone) 252-235-2132 (fax)

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Response: The Indian Creek Overlook pump stations are connected to a telemetry system and
are inspected once per week. The bypass pump and line were inspected daily while in service.
5. Nigh -priority sewers shall be inspected by the permittee or its representative once
every six months, and inspections shall be documented.
Response: Indian Creek Overlook collection system is not a high priority sewer.
6. A general observation by the permittee or its representative of the entire collection
system shall be conducted once per year.
Response: Envirolink inspects the entire Indian Creek Overlook collection system on annual
basis.
7. Overflows and bypasses shall be reported to the appropriate Division regional office
in accordance with 15A NCAC 02B .0506(a), and public notice shall be provided as
required by G.S.143- 215.1C.
Response: The bypass was not reported because it only occurred in the collection system and
did not impact treatment of the wastewater, thus 15A NCAC 02B .0506(a) was not triggered.
No public notice was required as there was no spill.
8. A Grease Control Program shall be in place as follows: (A) For publicly owned
collection systems, the Grease Control Program shall include biannual distribution of
educational materials for both commercial and residential users and the legal means to
require grease interceptors for new construction and retrofit and if necessary, of grease
interceptors at existing establishments. The plan shall also include legal means for
inspections of the grease interceptors, enforcement for violators and the legal means to
control grease entering the system from other public and private satellite collection
systems. (B) For privately owned collection systems, the Grease Control Program shall
include biannual distribution of grease education materials to users of the collection
system by the permittee or its representative. (C) Grease education materials shall be
distributed more often than required in Parts (A) and (8) of this Subparagraph if
necessary to prevent grease -related sanitary sewer overflows.
Response: The Indian Creek Overlook collection system is privately owned. Envirolink is in the
Process of establishing a FOG program that will include the education materials required.
9. Right-of-ways and easements shall be maintained in the full easement width for
personnel and equipment accessibility.
Response: The owner maintains pathways for the collection system. There are no known
easements.
Envirolink, Inc.
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PO Box 670, Bailey, North Carolina 27807
252-235..1900 (phone) 252-235-2132 (fax)

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10. Documentation of compliance with Subparagraphs (a)(1) through (a)(9) of this Rule
shall be maintained by the collection system owner for three years with the exception of
the map, which shall be maintained for the life of the system.
Envirolink has documented compliance with subparagraphs (a)(1) through (a)(9) for this Rule
through its SOP and logbooks. A map of the collection system is on file, maintained onsite by
the owner.
Reporting requirements: Sanitary Sewer Overflows (SSO)
Did waste reach surface water?
Response: No waste was discharged on the surface, as such no waste reached surface water.
2. Is the spill 1000 gallons or more?
Response: There was no spill.
3. NCGS 143-215.1C.(c) (1) and (2)
Response: There was no spill so NCGS 143-215.1C.(c) (1) and (2) was not triggered.
Based on the swift remedial action taken by Mr. Peele and Mr. Cincinnati to prevent a spill,
Envirolink and the owner respectfully request that no further action be taken with respect to
NOV-2018-2T-001. Please contact me with any questions or if you need additional information.
Thank you for your time in considering this request.
Sin relPy,
J. Carr McLamb, Jr.
General Counsel
Envirolink, Inc.
cc: Elizabeth Yurgens via electronic mail
Envirolink, Inc.
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PO Box 670, Bailey, North Carolina 27807
252-235-4900 (Phone) 252-235-2132 (fax)