wqcs00065_Compliance Evaluation Inspection_20200413

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
Tonya Mann, Utilities Director
City of Graham
PO Drawer 357
Graham, NC 27253-0357
NORTH CAROLINA
Environmental Quality
April 7, 2020
Subject: Compliance Evaluation Inspection Report
Wastewater Collection System Permit WQCS00065
Graham Wastewater Collection System
Dear Ms. Mann:
On March 10, 2020, Gary Hudson of the Division of Water Resources (Division),
Winston-Salem Regional Office met with Ladd Nall, Operator in Responsible Charge (ORC), to
conduct a Compliance Evaluation Inspection of the above referenced Wastewater Collection
System.
This inspection consists of (1) a review of the permit and accompanying documentation
to determine compliance with permit conditions, and (2) an on -site inspection of collection
system components. The attached inspection form notes the areas that were evaluated for the
inspection, with notable findings outlined as follows.
Site Inspections
1. Pump Stations — The Haw River Pump Station was inspected, and no issues were
noted.
2. High Priority Lines — The East Gilbreath Aerial Crossing was inspected, and no issues
were noted.
The inspection was considered satisfactory. If you should have any questions, please do
not hesitate to contact Gary Hudson or our office at [phone].
Sincerely,
D-ocuSiTgned<by:
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_.49E225C94EA...
Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
Enclosures — Inspection Report
CC: WQS Winston-Salem Regional Office
PERCS Unit
D � North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office [ 450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105
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Compliance Inspection Report
Permit: WQCS00065 Effective: 02/01/15 Expiration: 01/31/23 Owner: City of Graham
SOC: Effective: Expiration: Facility: Graham Collection System
County: Alamance PO Drawer 357
Region: Winston-Salem
Graham NC 272530357
Contact Person: Victor Ray Quick Title: Phone: [phone]
Directions to Facility:
System Classifications: CS2,
Primary ORC: Jonathan Ladd Nall
Secondary ORC(s):
On -Site Representative(s):
Certification: 989250 Phone: [phone]
Related Permits:
NC0021211 City of Graham - Graham WWTP
NC0023876 City of Burlington - Southside WWTP
Inspection Date: 03/10/2020 Entry Time 10:OOAM
Primary Inspector: Gary Hudson
Secondary Inspector(s):
Exit Time: 12:OOPM
Phone: [phone]
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 Reporting Requirements
Inspections Spill Response Plan Lines
Pump Stations
(See attachment summary)
Page 1 of 6

Permit: WQCS00065 Owner - Facility: City of Graham
Inspection Date: 03/10/2020 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Inspection Summary:
*The City of Graham uses "Utility Cloud" an advaned computer based record keeping system.
*There are 57 food establishments in the City of graham. The city has a quarterly news letter that has an article on FOG
control and information is posted on the City of Graham's website. All grease traps are inspected yearly.
*The City of Graham has an adequate Capital Improvement Plan that covers out to the end of 2025.
*The collection system maping system is GIS and incorperated into Utility Cloud.
*There are a total of 38 high -priority lines in the system and they are checked at the proper frequency with the inspections
logged.
*The required response time for all spills is 30 minutes or less.
*The East Gilbreath Aerial Crossing, the Haw River Pump Station Outfall, and the Haw River Pump Station was inspected.
*Over 90,000 feet of gravity mains have been cleaned which is well over the required 10%.
*6 f the 7 pump stations have a stationary generator.
Page 2 of 6

Permit: WQCS00065 Owner - Facility: City of Graham
Inspection Date: 03/10/2020 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? ❑ ❑ ❑
Are logs being reviewed by the system management or owner on a regular basis? ❑ ❑ ❑
# What is that frequency? Daily
# 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? ❑ ❑ 0 ❑
Comment: The Citv of Graham uses "Utility Cloud" an advaned computer based record keeping system.
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?
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.)
There are 57 food establishments in the City of graham. The city has a quarterly news letter that has an
article on FOG control and information is posted on the City of Graham's website. All grease traps are
inspected yearly.
Comment:
Capital Improvement Plan
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?
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Page 3 of 6

Permit: WQCS00065 Owner - Facility: City of Graham
Inspection Date: 03/10/2020 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Comment: The City of Graham has an adequate Capital Improvement Plan that covers out to the end of
2025.
Map Yes No NA NE
Is there a overall sewer system map? 0 ❑ ❑ ❑
Does the map include:
Pipe Type (GS/FM) ❑ ❑ ❑
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 activation? 0 ❑ ❑ ❑
Comment: The collection system mailing system is GIS and incorperated into Utility Cloud.
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:
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: There are a total of 38 high -priority lines in the system and they are checked at the proper
frequency with the inspections lopped.
Spill Response Action Plan Yes No NA NE
Page 4 of 6

Permit: WQCS00065 Owner - Facility: City of Graham
Inspection Date: 03/10/2020 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?
0
❑ ❑ ❑
Comment: The required response time for all spills is 30 minutes or less.
Lines/Right-of-Ways/Aerial Lines Yes No NA NE
Please list the Lines/Right of Ways/Aerial Lines Inspected:
The East Gilbreath Aerial Crossing, the Haw River Pump Station Outfall, and the Haw River Pump Station was
inspected.
Are right-of-ways/easements maintained for full width for access by staff/equipment? ❑ ❑ ❑
If No, give details on temporary access
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: Over 90,000 feet of gravity mains have been cleaned which is well over the required 10%.
Pump Stations
Please list the Pump Stations Inspected:
The Haw River Pump Station.
# Number of duplex or larger pump stations in system
# Number of vacuum stations in system
# Number of simplex pump stations in system
# 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?
# A simple one-way telemetry/communication system (auto -dialer) installed?
For pump stations inspected:
Are they secure with restricted access?
Yes No NA NE
7
0
0
0
6
1
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Page 5 of 6

Permit: WQCS00065 Owner - Facility: City of Graham
Inspection Date: 03/10/2020 Inspection Type : Collection System Inspect Non Sampling
Reason for Visit: Routine
Were they free of by-pass structures/pipes?
0
❑ ❑ ❑
Were wet wells free of excessive grease/debris?
0
❑ ❑ ❑
# Do they all have telemetry installed?
0
❑ ❑ ❑
Is the communication system functional?
0
❑ ❑ ❑
Is a 24-hour notification sign posted ?
0
❑ ❑ ❑
Does the sign include:
Owner Name?
0
❑ ❑ ❑
Pump station identifier?
0
❑ ❑ ❑
# Address?
0
❑ ❑ ❑
Instructions for notification?
0
❑ ❑ ❑
24-hour emergency contact numbers?
0
❑ ❑ ❑
Are audio and visual alarms present?
0
❑ ❑ ❑
Are audio and visual alarms operable?
0
❑ ❑ ❑
# Is there a backup generator or bypass pump connected?
0
❑ ❑ ❑
If tested during inspection, did it function properly?
0
❑ ❑ ❑
Is the back-up system tested at least bi-annually under normal operating conditions?
0
❑ ❑ ❑
# Does it have a dedicated connection for a portable generator?
0
❑ ❑ ❑
# Is the owner relying on portable units in the event of a power outage?
0
❑ ❑ ❑
# If Yes, is there a distribution plan?
0
❑ ❑ ❑
If Yes, what resources (Units/Staff/Vehicles/etc) are included in Plan?
6 f the 7 pump stations have a stationary generator.
# Does Permittee have the approved percentage of replacement simplex pumps?
❑
❑ 0 ❑
Is recordkeeping of pump station inspection and maintenance program adequate?
0
❑ ❑ ❑
Do pump station logs include at a minimum:
Inside and outside cleaning and debris removal?
0
❑ ❑ ❑
Inspecting and exercising all valves?
0
❑ ❑ ❑
Inspecting and lubricating pumps and other equipment?
0
❑ ❑ ❑
Inspecting alarms, telemetry and auxiliary equipment?
0
❑ ❑ ❑
Comment:
Page 6 of 6