WQCS00233_Compliance Evaluation Inspection_20191028

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
NORTH CAROLINA
Environmental Quality
October 28, 2019
CERTIFIED MAIL #7015 1520 0002 8376 2876
RETURN RECEIPT REQUESTED
Mr. Tony Konsul, Regional Manager
Carolina Water Service Inc. of NC
PO Box 24098
Charlotte, North Carolina 28217
Subject: Notice of Violation
Compliance Evaluation Inspection
Case # NOV-2019-PC-0713
Permittee: Hemby Acres
Permit No. WQCS00233
Union County, NC
Dear Mr. Konsul:
Wastewater Collection System
Mr. Tony Parker and of the Mooresville Regional Office of the NC Division of Water Resources
(DWR or the Division) conducted a compliance evaluation inspection (CEI) of the subject
wastewater collection system (WWCS) on October 24, 2019. The assistance of Mr. Larry Henry
and Mr. Kylend Mullis during the inspection was greatly appreciated.
Violations were noted for failure to perform weekly visits to pump stations as required and failure
to have proper signage at some pump stations which do not list an address. A copy of the
inspection report is attached for your records and other inspection findings are summarized below.
Site/System Review
The following system components were inspected:
a. Four pump stations were inspected. Issues noted. Please see report for details.
b. Various manholes were inspected. No issues noted.
C. One right of way was inspected. Issues noted. See report.
��� North Carolina Department of Environmental Quality I Division of Water Resources
�Mooresville Regional Office 1 610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115
NOHiH GAROLINA i J
WMftW or Emimnn Wawory 704.663.1699

2. As you are aware, owners of permitted collection systems must comply with their permit
and all rules listed under NC Administrative Code 15A NCAC 02T .0400, et seq. Your
compliance status with each of these rules is summarized below:
15A NCAC 02T .0403(a)(1): Requires that the system be effectively maintained
and operated at all times to prevent discharge to land or surface waters and any
contravention of ground or surface water standards.
Observations: No reportable spills for the review period.
Compliance Status: Compliant
b. 15A NCAC 02T .0403(a)(2): Requires that a map of the wastewater collection
system be developed and actively maintained.
Observations: Maps were available for this inspection.
Compliance Status: Compliant
C. 15A NCAC 02T .0403(a)(3): Requires that an operation and maintenance (O&M)
plan be developed and implemented, which includes pump station inspection
frequency, preventative maintenance schedule, spare parts inventory and overflow
response.
Observations: Protocol has been set up to address these needs. Pump station logs
were available documenting inspections of pump stations. However, instances
were noted at each pump station which indicated some weekly visitations were not
performed as required and therefore are in violation of reporting requirements.
Compliance Status: Not Compliant
d. 15A NCAC 02T .0403(a)(4): Requires that the permittee or its representative
inspect pump stations that are not connected to a telemetry system (i.e., remote
alarm system) every day (i.e., 365 days per year) and pump stations that are
connected to a telemetry system at least once per week.
Observations: The pump station inspection logs indicate that the pump stations
were not visited weekly as required.
Compliance Status: Not Compliant
15A NCAC 02T .0403(a)(5): Requires that the permittee or its representative
inspect high -priority sewers (UPS - as defined in 15A NCAC 02T .0402(2)) at least
once every six months and document the inspections.
Observations: Documentation provided.

Compliance Status: Compliant
f. 15A NCAC 02T .0403(a)(6): Requires that the permittee or its representative
conduct a general observation of the entire wastewater collection system at least
once per year.
Observations: This requirement may have been met through line cleaning by
others and other observations. Line cleaning requirements were exceeded.
Compliance Status: Compliant.
g. 15A NCAC 02T .0403(a)(7): Requires that overflows and bypasses from the
system be reported to the Division's Mooresville Regional Office in accordance
with 15A NCAC 02B .0506(a), and that public notice must be provided as required
by G.S. 143-215.1C.
Observations: No SSO's have been reported for this review period. The NC
regulations and statutes, which cover the reporting requirements for SSOs, are
found in NC Administrative Code 15A NCAC 02B .0506(a) and NC General
Statute 143-215.1 C, respectively. You may access the NC regulations online at the
NC Office of Administrative Hearings (OAH) website at:
http://www.oah.state.nc.us/rules/ and the NC General Statutes online at the NC
General Assembly's website at:
http://www.ncga.state.nc.us/gascripts/Statutes/StatutesTOC.Pl. You may wish to
review them to ensure you are fully familiar with all requirements.
When reporting SSOs to DWQ, you must call the Mooresville Regional Office
(MRO) at 704-663-1699 during normal business hours. If outside normal business
hours, you must report the spill to the NC Division of Emergency Management at
1-800-858-0368. Please note that all reportable SSOs must be reported within 24
hours of the occurrence, or first knowledge, of the SSO. Please also note that voice
mail or faxed messages are not considered as the initial verbal report. You must
talk to and report the spill to a live person.
Compliance Status: Compliant
h. 15A NCAC 02T .0403(a)(8): Requires that a grease control program be developed
and implemented as follows:
For privately owned collection systems, the Grease Control Program shall
include at least bi-annual distribution of grease education materials to users
and the legal means to require grease interceptors. The Program shall also
include legal means for inspections, enforcement, and legal means to
control grease entering the system from other public and private satellite
sewer systems.
2. Grease education materials shall be distributed more often than required
above if necessary to prevent grease -related sanitary sewer overflows.

Observations: The operator indicated educational information is mailed out 2/year.
Compliance Status: Compliant.
15A NCAC 02T .0403(a)(9): Requires that right-of-ways (ROW) and easements
be maintained in the full easement width for personnel and equipment accessibility.
Observations: Records were available documenting ROW maintenance.
Compliance Status: Compliant.
15A NCAC 02T .0403(a)(10): Requires that documentation be kept for all
activities you undertake to comply with the requirements of 15A NCAC 02T .0403,
subparagraphs (a)(1) through (a)(9), for a minimum of three years, with the
exception of the map, which shall be maintained for the life of the system.
Observations: Records were available for the activities listed above.
Compliance Status: Compliant
In accordance with NC General Statute 143-215.6A, these violations are subject to civil penalty
assessments not to exceed $25,000 per day, per violation. Your written response and the actions
that you take to address these violations listed herein and on the attached report will be considered
in deciding whether or not such penalties are necessary to compel compliance.
It is imperative that immediate actions be taken for all the above violations noted.
It is requested that a written response be submitted to this Office within fifteen (15) days of receipt
of this Notice regarding the above noted violations.
Also, please take note of the comments in the inspection report for all issues that need to be
addressed. The inspection report should be self-explanatory; however, if you have any questions
regarding the inspection report or this correspondence, please contact either Tony Parker at 704-
663-1699 (email at tony_parker(2ncdenr.gov) or me at 704-235-2194 (email at
corey.basinger2ncdenr. gov).
Sincerely,
DocuSigned by:
for
F161FB69A2D84A3...
W. Corey Basinger, Regional Supervisor
Mooresville Regional Office
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
Attachments: BIMS Inspection Report
CC: MRO, Central Files, PERCS Unit (LaserFiche)

Compliance Inspection Report
Permit: WQCS00233
SOC:
County: Union
Region: Mooresville
Contact Person: Dana Hill
Directions to Facility:
Effective: 10/10/13 Expiration: 11/30/21 Owner : Carolina Water Service Inc of North Carolina
Effective: Expiration: Facility: Hemby Acres Collection System
PO Box 240908
System Classifications: CS2,
Primary ORC: Larry Darnell Henry
Secondary ORC(s):
On -Site Representative(s):
Title: Director of Operations
Certification: 1004209
Charlotte NC 282240908
Phone: [phone]
Phone: [phone]
Related Permits:
NC0035041 Carolina Water Service Inc of North Carolina - Hemby Acres WWTP
Inspection Date: 10/24/2019 EntryTime: 10:OOAM Exit Time: 01:30PM
Primary Inspector: Tony Parker Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Collection System Inspect Non Sampling
Permit Inspection Type: Collection system management and operation
Facility Status: ❑ Compliant 0 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

Permit: WQCS00233 Owner - Facility: Carolina Water Service Inc of North Carolina
Inspection Date: 10/24/2019 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Inspection Summary:
Numerous issues observed that need to be corrected. Monitoring/visitation violations noted. Corrective actions need to
undertaken immediately to rectify and abate these issues and violations.
A response is requested within 15 days of receipt of this report.
Page 2 of 7

Permit: WQCS00233 Owner - Facility: Carolina Water Service Inc of North Carolina
Inspection Date: 10/24/2019 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?
0
❑ ❑ ❑
Are logs being reviewed by the system management or owner on a regular basis?
0
❑ ❑ ❑
# What is that frequency?
weekly
# Are there any issues being addressed currently or any in the planning stages?
❑ ❑ ❑
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?
❑
❑ ❑
Comment: The existing collection system permit expires 11/30/2021
Sewer and FOG Ordinances
Yes No NA NE
Is Sewer Use Ordinance (SUO) or other Legal Authority available?
❑
❑ ❑
Does it appear that the Sewer Use Ordinance is enforced?
❑
❑ ❑
Is there a Grease Control Program that legally requires grease control devices?
❑
❑ ❑
What is the standard grease trap cleaning requirement in the FOG ordinance?
as needed per the
operator
Is Grease Control Program enforced via periodic inspections/records review?
❑
❑ ❑
Is action taken against violators?
❑
❑ ❑
# Have satellite systems adopted an equivalent or more stringent ordinance?
❑
❑ ❑
Is grease/sewer education program documented with req'd customer distribution?
❑ ❑ ❑
# Are other types of education tools used like websites, booths, special meetings, etc?
❑ ❑ ❑
If Yes, what are they? (This can reduce mailing to annual.)
Flyers and website.
Comment:
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?
❑
❑ ❑
Does CIP include forecasted future needs?
❑ ❑ ❑
Comment
Page 3 of 7

Permit: WQCS00233 Owner - Facility: Carolina Water Service Inc of North Carolina
Inspection Date: 10/24/2019 Inspection Type : Collection System Inspect Non Sampling
Reason for Visit: Routine
Map
Yes No NA NE
Is there a overall sewer system map?
0
❑ ❑ ❑
Does the map include:
Pipe Type (GS/FM)
0
❑ ❑ ❑
Pipe sizes
0
❑ ❑ ❑
Pipe materials (PVC, DIP, etc)
0
❑ ❑ ❑
Pipe location
0
❑ ❑ ❑
Flow direction
0
❑ ❑ ❑
Approximate pipe age
0
❑ ❑ ❑
Pump station ID, location and capacity
0
❑ ❑ ❑
# 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
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: With flows less than 200,000 GPD the Permittee does not wish to file an Annual Report at this
time.
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? ❑ ❑ 0 ❑
Comment: Log books indicate the ORC is Not inspecting the pump stations as required. Some weekly
visits were not conducted at each of the 4 pump stations inspected. The ORC had no clear
explanation for these discrepancies.
Spill Response Action Plan Yes No NA NE
Page 4 of 7

Permit: WQCS00233 Owner - Facility: Carolina Water Service Inc of North Carolina
Inspection Date: 10/24/2019 Inspection Type : Collection System Inspect Non Sampling
Reason for Visit: Routine
Is a Spill Response Action Plan available?
0
❑ ❑ ❑
Is a Spill Response Action Plan available for all personnel?
0
❑ ❑ ❑
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?
❑ ❑ ❑
Comment: The system is not free of spills but are reporting as required
Spllls Yes No NA NE
Is system free of known points of bypass? ❑ ❑ ❑
If No, describe type of bypass and location
Are all spills or sewer related issues/complaints documented? ❑ ❑ ❑
# Are there repeated overflows/problems (2 or more in 12 months) at same location? ❑ ❑ ❑
# If Yes, is there a corrective action plan? ❑ ❑ 0 ❑
Comment: All spills or complaints are documented via a work order.
Lines/Right-of-Ways/Aerial Lines Yes No NA NE
Please list the Lines/Right of Ways/Aerial Lines Inspected:
The Oak Grove US #3 R/W outfalls. This is a 2 line outfall/ R/W and both were overgrown and needs clearing.
Are right-of-ways/easements maintained for full width for access by staff/equipment? ❑ 0 ❑ ❑
If No, give details on temporary access
See above comments.
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: Above ground vents were not screened. Missing vent screens need to be replaced.
Manholes Yes No NA NE
Please list the Manholes Inspected:
Various manholes were inspected and the only issues noted were above ground vent screens were missing.
Again these need to be replaced.
Are manholes accessible? ❑0 ❑ ❑
# Are manhole covers/vents above grade? ❑ ❑ ❑
Page 5 of 7

Permit: WQCS00233 Owner - Facility: Carolina Water Service Inc of North Carolina
Inspection Date: 10/24/2019 Inspection Type : Collection System Inspect Non Sampling
Reason for Visit: Routine
Are manholes free of visible signs of overflow?
0
❑ ❑ ❑
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: All vent pipes visited need the screens replaced
Pump Stations
Yes No NA NE
Please list the Pump Stations Inspected:
Main US at the WWTP, Oak Grove US #3, Hemby Acres #2 US and Hemby Acres#1 US. The signage at
each pump station visited lacked an address location identifier.
# Number of duplex or larger pump stations in system
4
# Number of vacuum stations in system
0
# Number of simplex pump stations in system
0
# Number of simplex pump stations in system serving more than one building
0
How many pump/vacuum stations have:
# A two-way "auto polling" communication system (SCADA) installed?
4
# A simple one-way telemetry/communication system (auto -dialer) installed?
0
For pump stations inspected:
Are they secure with restricted 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:
Owner Name?
❑ ❑ ❑
Pump station identifier?
❑ ❑ ❑
# Address?
❑
❑ ❑
Instructions for notification?
❑ ❑ ❑
Page 6 of 7

Permit: WQCS00233 Owner - Facility: Carolina Water Service Inc of North Carolina
Inspection Date: 10/24/2019 Inspection Type : Collection System Inspect Non Sampling
Reason for Visit: Routine
24-hour emergency contact numbers?
0
❑ ❑ ❑
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?
The Permittee has a fleet of generators all across NC. Excessive grease noted at the Oak Grove US #3 and
needs to be cleaned out and the floats cleaned. Address markers need to be added at each P/S.
# 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?
❑ ❑ ❑
Inspecting and exercising all valves?
❑ ❑ ❑
Inspecting and lubricating pumps and other equipment?
❑ ❑ ❑
Inspecting alarms, telemetry and auxiliary equipment?
❑ ❑ ❑
Comment: All deficiencies previously mentioned
Page 7 of 7