WQCS00055_NOV-2020-PC-0145_20200310

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quaiity
March 10, 2020
CERTIFIED MAIL# 7012 0470 0001 3841 4396
RETURN RECEIPT REQUESTED
Edward Blackmon, City Manager
PO Box 1434
Henderson, NC 27536-1434
Subject: Notice of Violation — NOV-2020-PC-0145
Compliance Evaluation Inspection
Henderson Collection System
Permit WQCS00055
Vance County
Dear Mr. Blackmon,
On Wednesday, March 4th, 2020, Zach Thomas and Chris Smith from the Raleigh Regional
Office of the Division of Water Resources, conducted a compliance evaluation inspection of the
collection system for the City of Henderson. The purpose of this inspection was to ensure
compliance with the subject permit. During the inspection, the presence and cooperation of Mr.
Joey Long (CS ORC), Mr. Seth Davidson (Supervisor — Lift Stations), Mr. Troy Gooch (Crew
Leader), Mr. Lamont Allen (WWTP Director), and other staff was helpful and appreciated.
This compliance evaluation inspection consisted of the following:
• Review of the permit;
• Review of the owner,"facility information;
• Review of records;
• On -site inspection of the collection system and lift station units
Findings during the inspection and file review were as follows:
1. The permit (WQCS00055) was issued effective on May I, 2018, and will expire on April 30,
2026.
2. Many permit affiliations have changed since the last inspection. Please compile an updated
list and provide them to DWR, to ensue ive have accurate and lip to date contacts for the
subject permit.
North Carolina Department of Environmental Quality ! Division of Water Resources
_ Raleigh Regional Office ! 3800 Barrett Drive I Raleigh, North Carolina 27609
919191,4200

NOV-2020-PC-0145
City of Henderson Collection System
Permit: WQCS00055
3. The system is classified CS-3. The subject permit states the system contains approximately
147 miles of gravity sewer, 15 miles of force main, and 13 duplex pump stations. All
wastewater is received into the Henderson CS before treatment at the Henderson WRF
(NC0020559). Staff stated that there are currently 12 lift stations, as the 1311 station was
demolished and replaced with a gravity line (approximately two years ago), due to frequent
issues at the station. Please ensure during the permit renewal process that your application
reflects any additional modificationslextensions that have occurred, as well as any changes to
the system are kept up to date on any maps (Condition 111(4)).
4. The City implements a Fats, Oil and Grease (FOG) program and Sewer Use Ordinance. It is
enforced by staff at the WRF. Materials are mailed out with the utility bills and are posted
to the Town's website. Grease Traps are inspected frequently and many are sampled by
WRF staff. Enforcements are on a tiered system and all records are maintained on -site at the
WRF.
5. The Capital Improvement Plan detailed projects through 2020. The ORC stated a new CIP is
currently being developed and that new vac -trucks are a priority for CS staff. Per Condition 1
(5) of the subject permit, the capital improvement plan (CIP) should contain short/long term
needs, cover a five-year period, and include a goal statement, description of project area,
existing facilities, known deficiencies and forecasted future needs incorporating the cost
analysis accordingly. As part ofyour permit requirements, please provide an updated CIP to
this office, or an estimated reasonable timeframe far tivhen an updated CIP will be
completed.
6. An annual report was not available for review. Mr. Joey Long informed DWR staff on
3.+9i2020 that an annual report for 2018,2019 has not been created. As part of your permit
requirements (Condition IV (3)), please provide a copy of the completed Annual Report to
this office.
7. Maintenance, inspection, and system records are compliant and are reviewed by the ORC.
Citizen complaints are handled through the department via work tickets and are recorded in
the City's internal tracking system.
8. Of the 12 lift stations, 7 have permanent generators. The remaining rely on a portable
generator that connect to on -site hookups; the City currently has 1 portable generator.
Generators are tested monthly.
9. A map of the system is kept both in paper form and digital form. The digital map is
approximately 98% complete. New additions or changes will be tracked through the internal
system and updated.

NOV-2020-PC-0145
City of Henderson Collection System
Permit: WQCS00055
10. Right of way and high priority line inspections were in compliance with the permit
requirements. Right of ways are cut once per year and are inspected frequently. High
priority line inspections are performed every week, along with the manhole (-62)
inspections. The system contains 21 high priority lines. See 13c for observations.
11.Of the approximate 147 miles (776,160 feet) of gravity line listed in the permit,
approximately 79,379 feet were cleaned in 2019. Staff stated they are allotted approximately
$25,000 per year for root control treatment. Approximately 13,000 if were treated for roots
in 20I9.
12. SSO records are kept with the ORC and BIMs shows there have been over 45 incidents since
the last inspection. Many of these were reported to be due to I&I issues during storm events
or debris/grease in the line. Any correspondence regarding these incidents was sent
separately from this letter. If applicable, staff indicated press releases and notices are sent
out via the Daily Dispatch paper. The Spill Response Plan contained all required aspects, but
needs updated individuals for emergency contact. As part of your permit requirements
(Condition II (9)), please enstire the plan is updated and provide a copy to our office via
email.
13. Several lift stations. manholes and high griority lines were inspected:
a) 4 of the 12 lift stations were inspected (Stations: Zeb-Robinson Rd., Red Bud, Sandy
Creek, Wortham Ct.). Red Bud and Sandy Creek stations contain SCADA. All others
have telemetry with text message, email, and phone call alerts. Stations are inspected M,
W, F of each week. The following observations were noted:
i) Zeb-Robinson Rd. Pump Station: There was an excessive amount of grease inside of
the wet well and should be cleaned as soon as possible to ensure proper capacity.
This was an issue noted in the previous inspection. Staff indicated that the "peanut
roaster facility" feeds into this station. Please notify this office when the grease has
been cleaned and describe what action you will take to prevent grease build lip in the
future (Condition II (-la)).
ii) Red Bud, Sandy Creek, and Wortham Court all appeared to be in good working order
and met all requirements.
b) All inspected manholes were found to be in good condition, free of excessive debris and
signs of overflow.
c) The 2 high priority lines inspected were Southern Vance & Shank Street. The following
observations were noted:
i) Southern Vance: The flow was unobstructed and supports appeared in good
condition. Trees and large branches were noted to be growing in very close
proximity to the line. Staff indicated the trees would be maintained soon to ensure
they do not compromise the integrity of the line. Please note this office when this
action has been performed (Condition V (l)).
ii) Shank Street: The flow was unobstructed and supports appeared in good condition.
One junction point showed a small amount of damage along with a broken bolt. Staff

NOV-2020-PC-0145
City of Henderson Collection System
Permit: WQCS00055
indicated that it was possibly struck by a mower and that they would have it evaluated
to ensure structural integrity. Please notes this office of the evaluation outcome and
when this action was performed (Condition V (4)).
Please respond in writing to this office within 30 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. Please include in your response all corrective actions
already taken and a schedule for completion of any corrective actions for the followingitems:
ems:
2, 5, 6,12,13ai, Be
This office requires that the violations, as detailed above, be abated immediately and
properly resolved. Environmental damage and violations of North Carolina Administrative
Codes have been documented for the subject site as stated above. Your efforts to undertake
activities to bring the subject site back into compliance is not an admission, rather it is an action
that must be taken in order to begin to resolve ongoing environmental issues.
These violations and any future violations are subject to a civil penalty assessment of up to
$25,000.00 per day for each violation. Your response to this letter will be considered with
any Enforcement Action recommendation or Civil Penalty Assessment.
If you have questions or comments about the inspection, this report or the requirements to take
corrective action (if applicable), please contact:
Zach Thomas at 919-791-4247 or via email at zachary.thomasCamcdenngov.
Sincerely,
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Attachments: Compliance Inspection Report
Cc: Joey Long, ORC (via email: jlongCu.ci.henderson.nc.us)
RRO Files
Laserfiche

Compliance Inspection Report
Permit: WOCS00055 Effective: 05/01/18 Expiration: 04/30/26 Owner: City of Henderson
SOC: S07005 Effective: 09/01/08 Expiration: 02/01/10 Facility: Henderson Collection System
County: Vance PO Box 1434
Region: Raleigh
Henderson NC 275361434
Contact Person: Harry Lamont Allen Title: Phone: [phone]
Directions to Facility:
System Classifications: CS3,
Primary ORC: Joey Giambra Long
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Certification:990227 Phone: [phone]
NC0020559 - City of Henderson - Henderson WRF
Inspection Date: 03104/2020 Entry Time 10,OOAM Exit Time: 01:30PM
Primary Inspector: Zachary Thomas Phone: [phone]
Secondary Inspector(s):
Chris Smith
Reason for Inspection: Routine 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 n Reporting Requirements
inspections Spill Response Plan Spills
Lines Manholes Pump Stations
(See attachment summary)
Pagel of 7

Permit: WQCS00055 owner - Facility: City of Henderson
Inspection Date: 03/04/2020 Inspection Type : Collect on System Inspect Non Sampling Reason for Visit: Routine
Inspection Summary:
Please see report.
Page 2 of 7

Permit: WOCS00055 Owner -Facility: City of Henderson
Inspection Date: 03/04/2020 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?
so ❑ ❑
Are logs being reviewed by the system management or owner on a regular basis?
E 0 ❑ ❑
# What is that frequency?
Monthly
# 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?
E0 El 0
Does plan indicate if pump parts/new pumps are in spare parts/equipment inventory?
E 0 ❑ 0
Are new/significantly upgraded pump stations equipped with anti -corrosion materials?
0❑ 0 0
Does the permittee have a copy of their permit?
0❑ 0 El
# Is permit expiring within the next 6 months?
C10
If Yes, has the Permittee applied for renewal?
Comment:
Sewer and FOG Ordinances
Yes No NA NE
Is Sewer Use Ordinance (SUO) or other Legal Authority available? 0000
Does it appear that the Sewer Use Ordinance is enforced? E0
Is there a Grease Control Program that legally requires grease control devices?
What is the standard grease trap cleaning requirement in the FOG ordinance?
Is Grease Control Program enforced via periodic inspections/records review?
Is action taken against violators? m
# Have satellite systems adopted an equivalent or more stringent ordinance? 0 El
Is grease/sewer education program documented with req'd customer distribution?
# Are other types of education tools used like websites, booths, special meetings, etc? 0❑ 0
If Yes, what are they? (This can reduce mailing to annual.)
Website
Comment: The CitV implements a Fats Oil and Grease FOG program and Sewer Use Ordinance. It is
enforced by staff at the WRF. Materials are mailed out with the utility bills and are Posted to the
Town's website. Grease Traps are insl2ected frequently and many are sampled by WRF staff.
Enforcements are on a tiered system and all records are maintained on -site at the WRF.
Capital lm rovement Plan
Yes No NA NE
Has a Capital (GIP) or System Improvement Plan been developed and adopted? ❑
Is it designated for wastewater only or does it have a dedicated section? 0El ❑ ❑
Does CIP cover three to five year period of earmarked improvements? E ❑
El
Does CIP include description of project area?
Does CIP include description of existing facilities? 00 ❑
CD
Does CIP include known deficiencies? ❑ ❑ ❑
Does CIP include forecasted future needs? ■ ❑ ❑
Page 3 of 7

Permit: WQCS00055 Owner - Facility: Cdy of Henderson
Inspection Date: 03/04/2020 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Rout ne
Comment: The Capital Improvement Plan detailed projects through 2020. The ORC stated a new CIP is
currently being developed and that new vac -trucks area priority for CS staff.
As part of your permit requirements, lease provide an updated CIP to this office or an
estimated reasonable timeframe for when an updated CIP will be completed.
map Yes No NA NE
Is there a overall sewer system map? M ❑ ❑ ❑
Does the map include:
Pipe Type (GSIFM)
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 aclivati3-�?
Comment: A map of the system is kept both in pager form and digital form. The digital maR is approximatel�
98% complete. New additions or changes will be tracked through the internals stem and
updated.
Reporting Requirements Yes No NA NE
# Have there been any sewer spills in the past 3 years? 0 ❑ ❑ ❑
If Yes, were they reported to the Division if meeting the reportable criteria? 0 ❑ ❑ ❑
If applicable, is there documentation of press releases and public notices issued? M ❑ ❑ ❑
Is an Annual Wastewater Performance Report being filed with the Division, if required? ❑ M ❑ ❑
Is the report being made available to all its sewer customers? ❑ 0 ❑ ❑
# How is it being made available? NA
Comment: SSO records are kept with the ORC.
If applicable, staff indicated Press releases and notices are sent out via the Daily Dispatch Paper
An annual report was not available for review. Mr. Joey Long informed DWR staff on 3/9/2020
that an annual report for 2018/2019 has not been created. As part of your permit requirements
Condition IV 3 lease provide a copy of the completed Annual Report to this office.
Inspections Yes No NA NE
Are adequate maintenance records maintained? M ❑ ❑ ❑
Are pump stations being inspected at the required frequency? M ❑ ❑ ❑
# Is at least one complete functionality test conducted weekly per pump station? 0 ❑ ❑ ❑
Is there a system or plan in place to observe the entire system annually? MOOO
Page 4 of 7

Permit: WOCS00055 Owner - Facility: City of Henderson
Inspection Date: 03/04/2020 Inspection Type: Collection System Inspect Non Sampling Reason for Visit: Routine
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?
Comment: Stations are inspected M. W. F of each week.
Right of was are cut once per year and are inspected frequently.
High Priority line inspections are performed every week.
Spill Res onse Action Plan
Is a Spill Response Action Plan available?
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?
Yes No NA NE
■❑❑❑
■❑❑❑
Comment: The S ill Response Plan contained all re wired aspects, but needs undated individuals for
emergencyeme[gency contact. As gart of your vermit requirements Condition II 9 lease ensure the
Ian is updated and provide a copy to our office via email.
Spills
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? M000
# Are there repeated overflows/problems (2 or more in 12 months) at same location? 0000
# If Yes, is there a corrective action plan? 0000
Comment: Many of these were reported to be due to I&I issues during storm events or debris/grease in the
line. Staff is cleaning lines and performing root control each year.
Lines/Ri ht-of-Wa s/Aerial Lines
Yes No NA NE
Please list the Lines/Right of Ways/Aerial Lines Inspected:
Southern Vance & Shank 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? ■ ❑ ❑ ❑
Page 5 of 7

Permit: WOCS00055 owner - Facility: C ty of Henderson
inspection Date: 03/04/2020 Inspection Type . Collect on System Inspect Non Sampling Reason for Visit: Routine
Are gravity sewer cleaning records available? ■ ❑ ❑ ❑
Has at least 10% of lines older than 5 yrs been cleaned annually? 0000
Were all areastlines inspected free of issues? ❑ ❑
Comment: Southern Vance: Trees and large branches were noted to be growing in very close proximitY to
the tine.
Shank Street: One 'unction point showed a small amount of damage along with a broken bolt.
Manholes
Yes No NA NE
Please list the Manholes Inspected:
Are manholes accessible?
❑ ❑ ❑
# Are manhole covers/vents above grade?
M 0 ❑
Are manholes free of visible signs of overflow?
E ❑
Are manholes free of sinkholes and depressions?
0 ❑ ❑
Are manhole covers present?
0 Cl ❑ 11
# Are manholes properly seated?
0 1:1❑ El
# Are manholes in good condition?
0 ❑ ❑
# Are inverts in good condition?
E ❑ 013
Is flow unrestricted in manholes?
0 El ❑ ❑
Are manholes free of excessive amounts of grease?
U ❑ ❑ ❑
Are manholes free of excessive roots?
E ❑ 0 ❑
Are manholes free of excessive sand?
E ❑ El ❑
Are manhole vents screened?
N ❑ ❑
Are vents free of submergence?
■ ❑ ❑ ❑
Are manholes free of bypass structures or pipes?
E C1 ❑
Comment:
Pump Stations
Yes No NA NE
Please list the Pump Stations Inspected:
Zeb-Robinson Rd., Red Bud, Sandy Creek, Wortham Ct.
# Number of duplex or larger pump stations in system
12
# Number of vacuum stations in system
0
# Number of simplex pump stations in system
a
# Number of simplex pump stations in system serving more than one building
0
How many pumplvacuum stations have:
# A two-way "auto polling" communication system (SCACA) installed?
2
# A simple one-way telemetry/communication system (auto -dialer) installed?
10
For pump stations inspected:
Are they secure with restricted access?
E ❑ ❑ ❑
Were they free of by-pass structures/pipes?
0 ❑ 0 El
Page 6 of 7

Permit: WQCS00055 Owner - Facility: City of Henderson
Inspection Date: 03/04/2020 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Rcutine
Were wet wells free of excessive grease/debris? ❑ 0 ❑ ❑
# Do they all have telemetry installed? 0000
Is the communication system functional? MDOO
Is a 24-hour notification sign posted ?
Does the sign include:
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 (UnitslStaffNehicles/etc) are included in Plan?
Of the 12 lift stations, 7 have permanent generators. The remaining rely on a portable generator that connect
to on -site hookups; the City currently has 1 portable generator. Generators are tested monthly.
# 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?
■❑❑D
❑❑[IN
■❑❑❑
Comment: Zeb-Robinson Rd. Pum Station: There was an excessive amount of grease inside of the wet
well and should be cleaned as soon as possible to ensure proper capacity. This was an issue
noted in the Previous inspection. Staff indicated that the "12eanut roaster facility" feeds into this
station. Please notify this office when the grease has been cleaned and describe what action
you will take to Prevent grease build uD in the future Condition II 4a .
Page 7 of 7