WQCSD0003_NOV-2019-PC-0666 Response_20191014

THE TOWN OF BAILEY
PO BOX 40
BAILEY, NC 27807
[phone]
COMMISIONERS
SHELLY nUI.LARD
ALLEN DANIELS
DWAN FINCH
JOEL KILLION
ERVIN POWELL
October 14, 2019
Rick Bolich, L.G.
NCDEQ Division of Water Resources
Ra;eigh Regional Office
3800 Barrett Dr.
Raleigh, NC 27609
Town of Bailey Collection System
Compliance Evaluation Inspection
NOV-2019-PC-0666
Wastewater Irrigation System
Permit No. WQCSDO003
Nash County
Dear Mr. Bolich:
THOMAS RICHARDS. 11AVOR
KELLIE GLOVER, TOWN CLERK
DEBBIE RAKER, FINANCIAL OFFICER
SfEVEN BORASKI, CHIEF OF POLICE
NC Dept of Environmental Quality
OCT 2 5 2019
Raleigh Regional Office
The Town of Bailey appreciates the opportunity to respond to NOV-2019-PC-0666 dated October 2,
2019. This letter shall serve as the Town's response and it is our hope that the additional information
provided will result in no further action by the Division.

On July 18, 2019 the state conducted a compliance evaluation inspection of the collection system for the
Town of Bailey. Conditions and issues of NOD-2019-PC-0170 were found are as follows:
1. Envirolink, Inc. operates and maintains the collection system for the Town of Bailey.
2. A review of Records indicated the following
a. There is no map of the system available. Per 15A NCAC 02T.040312) a map of the system
must be developed and actively maintained.
b. An operation and maintenance plan were not available for review. Per 15A NCAC
02T.0403(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.
c. There are three high priority lines for the system. No documentation of the high priority line
inspections was available at the time of the Inspection. Per 15A NCAC 02T.0403 (5), the lines
must be Inspected at least once evely six -months and inspections documented.
d. No documentation was found that a general observation of the entire system was
conducted In the past year, which is required by 15A NCAC 02T.0403(6).
e. Documentation of a Grease Control Program was not available. Grease education materials
are distributed to users were not available for review. Per 15A NCAC 02T.403(a)(8) (A)(C),
grease education material is to be distributed at least biannually, an ordinance and
documentation of grease Interceptor inspections were not available.
3. There are three pump station in the collection system, none are equipped with telemetry and
are Inspected daily. The pump station logbook should contain greater detail in regard to
station maintenance and repair. As the time of the inspection, the visual alarm at the main
stream pump station was not working. The audible alarm at the Reid street was not working.
Item 2 (a), (b), (c) and (d) were addressed and corrected by Envirolink, Inc. and details provided In
email correspondence with Erin Deck. Item 3 has been corrected and the visual alarm at Main Street
and the audible alarm at Reid Street are working properly. Envirolink has provided a more detailed
logbook for the operator to use.
In the NOV dated October 2, 2019 it states: As of the date of this letter, a complete response has not
been received by this office. The outstanding items that were required to be addressed are as follows:
(1) Documentation of the high priority line inspections (ISA NCAC 02T,0403(5)),
Submitted by email per Erin Deck and attached to this response.

(2) Documentation of the general observation of the entire system has been conducted in the past
year (1SA NCAC 02T0403(6)),
Submitted by email per Erin Deck and attached to this response.
(3) Documentation that the deficiencies noted at the pump stations during the inspection have been
corrected,
Audio and Visual alarms are working properly
(4) Please address how the Town plans to meet the required bi-annual distribution of grease
education materials (15A NCAC 02T, 403 (a)(8) (A)(C)),
Grease education materials are posted on the Town of Bailey website and available at Town
Hall. Informational materials are attached to this response.
We trust that this letter addresses all your concerns outlined in the NOV. We understand the reason for
the notice of violation, but respectfully request that Division not seek any action against the Town of
Bailey. We believe the WWTP's history of compliance demonstrates the Towns commitment to
operating this facility in a responsible manner. Therefore, we respectfully request that the Division
considers these efforts and take no further action. If we can be of any further assistance or additional
information Is needed, please contact me at
If we can be of any further assistance or additional information is needed, please contact me at (252)
235-4977.
Sincerely,
Thomas Richards
Mayor
Town of Bailey
cc' Dave Strum, Envirolink, Inc.
Rebecca Manning, Envirolink, Inc.
Glynn Whitley, Envirolink, Inc.