WQCSD0074_NOD-2022-PC-0035_20220401

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
April lst, 2022
The Honorable W.T. "Tommy" Barrett, Jr., Mayor
Attn: Ms. Nancy Jenkins, Town Manager
Town of Conway
PO Box 365
Conway, NC 27820
Subject: Notice of Deficiency
NOD-2022-PC-003 5
Compliance Evaluation Inspection
T15A NCAC 02T .0403 — Permitting by Regulation
Deemed Collection System Permit WQCSDO074
Facility Name: Conway Town Collection System
Northhampton County
Dear Mayor Barrett:
On March 18, 2022, Josh Brigham of the Raleigh Regional Office conducted a compliance evaluation
inspection of the Town of Conway Collection System. The purpose of this inspection was to ensure
compliance with the subject regulation. During the inspection, the guidance of Roger Coffield and Tim
Turner, was greatly appreciated.
This Deemed Collection System inspection consisted of the following:
• Review of the 15A NCAC 02T .0403 permit requirements;
• Review of the owner/facility information;
• Review of records; and
• On -site inspection of the collection system and pump station units.
Findings during the pre -inspection file review were as follows:
1. The subject facility is classified as CS-1. The facility currently does not have designated operators.
Please fill out the attached Operator Designation Form and return to the address listed.
2. The Town of Conway has had no Sanitary Sewer Overflows since the last inspection on August 15,
2018.
Findings during the inspection were as follows:
3. The Conway collection system has 10 pump stations all of which are equipped with SCADA. 4 of the
pump stations were visited during this inspection. Comments regarding the pump stations can be
found below:
a. PS2: Pump station was functioning properly.
North Carolina Department of Environmental Quality I Division of Water Resources
e::ro:of Raleigh Regional Office 1 3800 Barrett Drive I Raleigh, North Carolina 27609
DW 919.791.4200
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b. PS8: The wet well was full of sewage and the alarms were not functioning at the time
of inspection. Please provide an update on the status of the pump station.
c. PS9: Pump station was functioning properly
d. PSI 0: Pump station was functioning properly except for the audible alarm. Please
provide an update on the audible alarm.
4. Pump station weekly inspections and logbooks are being maintained as required.
5. A map of the sewer system was available and appeared to contain all required information.
6. The Conway collection system has a Fats, Oils, and Grease Program.
7. The Conway collection system has three high -priority lines. All three lines were visited during the
inspection and no issues were noted.
8. A Spill Response Action Plan was not available for review during the inspection. Please provide a
copy of the Spill Response Action Plan to this department.
9. Right-of-way and sewer system maintenance records were not available for review during the
inspection. Any maintenance performed should be documented and maintained.
This inspection letter is being sent as a Notice of Deficiency because of the bolded items listed in
points 1, 3, 8 and 9. Within 30 day of receiving this letter, please submit a written response
addressing how the town has or will resolve the noted deficiencies.
If you have questions concerning this report please contact Josh Brigham at 919-791-4251 or
[e-mail].
Sincerely,
Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS: Compliance Inspection Report
Operator Designation Form
Cc: RRO Files
Laserfiche
North Carolina Department of Environmental Quality 1 Division of Water Resources
D E Q�� 512 North Salisbury Street 1 1611 Mail Service Center E Raleigh, North Carolina 27699-1611
919.707.9000
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Compliance Inspection Report
Permit: WQCSD0074 Effective: 03/01/00 Expiration: Owner: Town of Conway
SOC: Effective: Expiration: Facility: Conway Town Collection System
County: Northampton
Region: Raleigh
Contact Person: W Thomas Barrett Title: Mayor Phone: [phone]
Directions to Facility:
System Classifications: CS1,
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 03/17/2022 Entry Time 09:30AM
Primary Inspector: Joshua S Brigham
Secondary Inspector(s): -J _ -�— (-I/1 / Z Z
Certification: Phone:
Exit Time: 11:30AM
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Collection System Inspect Non Sampling
Permit Inspection Type: Deemed permitted collection system management and operation
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Miscellaneous Questions General Grease Control
Spills/Response Plan Inspections Lines
Manholes Pump Stations
(See attachment summary)
Page 1 of 6

Permit: WQCSD0074 Owner - Facility: Town of Conway
Inspection Date: 03/17/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Inspection Summary:
See attached inspection report.
Page 2 of 6

Permit: WQCSD0074 Owner - Facility: Town of Conway
Inspection Date: 03/17/2022 Inspection Type : Collection System Inspect Non Sampling
Reason for Visit: Routine
General
Yes No NA NE
# Is this system a satellite system?
❑ M ❑ ❑
# If Yes, what is system name or permit number?
Is there a overall sewer system map?
0 ❑ ❑ ❑
Does the map include:
Pipe sizes
0 ❑ ❑ ❑
Pipe materials (PVC, DIP, etc)
0 ❑ ❑ ❑
Pipe location
E ❑ ❑ ❑
# 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
❑ ❑ M ❑
Are system maintenance records maintained?
❑ M ❑ ❑
Comment: Inspection records kept for pump stations.
Grease Control
Yes No NA NE
Is grease/sewer education program documented with req'd customer distribution? 0 ❑ ❑ ❑
# Are other types of education tools used like websites, booths, special meetings, etc? ❑ ❑ ❑
If Yes, what are they? (This can reduce mailing to annual.)
For public systems, is there a Grease Control Program via an ordinance/agreement? ❑ ❑ ❑
If Yes, does it require grease control devices at applicable locations? ❑ ❑ ❑
Is the Grease Control Program enforced via periodic inspections/records review? ❑ ❑ ❑
Is action taken against violators? ❑ ❑ ❑
Comment:
Spills and Response Action Plan
Yes No NA NE
# Is system free of known points of bypass?
M ❑ ❑ ❑
If No, describe type of bypass and location
# Have there been any sewer spills in the past 3 years?
❑ M ❑ ❑
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?
❑ ❑ ❑
Are all spills or sewer related issues/complaints documented?
❑ ❑ ❑
# Are there repeated overflows/problems (2 or more in 12 months) at same location?
❑ ❑ 0 ❑
# If Yes, is there a corrective action plan?
❑ ❑ ❑
Is a Spill Response Action Plan available?
❑ ❑ ❑
Is a Spill Response Action Plan available for all personnel?
❑ ❑ 0 ❑
Page 3 of 6

Permit: WOCSD0074 Owner - Facility: Town of Conway
Inspection Date: 03/17/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Does the plan include:
# 24-hour contact numbers
# Response time ❑ El 0 ❑
# Equipment list and spare parts inventory ❑ 0 E El
# Access to cleaning equipment ❑ 11 0 ❑
# Access to construction crews, contractors, and/or engineers ❑ ❑
# Source of emergency funds 11❑ E ❑
# Site sanitation and cleanup materials ❑ ❑ 0 ❑
# Post-overflow/spill assessment ❑ El 0 ❑
Comment: No spill response action plan available for review.
Inspections Yes No NA NE
Are adequate maintenance records maintained? ❑ ❑
Are pump stations being inspected at the required frequency? 0 ❑ ❑
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? ❑ El
Is the annual inspection documented? ❑ ❑
# Does the system have any high -priority lines/locations? ❑ ❑ ❑
Are inspections of HPL documented at least every 6 months? 0 ❑
Are new lines being added to the HPL list when found or created? ❑ 0 ❑
Comment: Inspections of HPLs not documented.
Lines/Right-of-Ways/Aerial Lines Yes No NA NE
Please list the Lines/Right of Ways/Aerial Lines Inspected:
Three lines at pump station 8.
Are right-of-ways and easements maintained for the full width for access? 0 ❑ El
If No, give details on temporary access:
Is maintenance documented? 110 ❑ ❑
Were all areas/lines inspected free of issues? E ❑ ❑
El
Comment: Maintenance not documented.
Manholes
Yes No NA NE
Please list the Manholes Inspected:
Upstream of PS 8 and 9,
Are manholes accessible? 0❑ ❑
# Are manhole covers/vents above grade? E❑ ❑ ❑
Are manholes free of visible signs of overflow? 0❑ ❑ ❑
Are manholes free of sinkholes and depressions? 0❑ ❑ ❑
Are manhole covers present? 0❑ ❑ ❑
Page 4 of 6

Permit: WQCSDO074 Owner - Facility: Town of Conway
Inspection Date: 03/17/2022 Inspection Type : Collection System Inspect Non Sampling
Reason for Visit: Routine
# Are manholes properly seated?
■ ❑ El
# Are manholes in good condition?
■ ❑ ❑
# Are inverts in good condition?
1:1■
Is flow unrestricted in manholes?
❑ El
Are manholes free of excessive amounts of grease?
Are manholes free of excessive roots?
Are manholes free of excessive sand?
.
Are manhole vents screened?
❑ El El ■
Are vents free of submergence?
❑ ■
Are manholes free of bypass structures or pipes?
0❑ ❑ ❑
Comment:
Puma Stations
Yes No NA NE
Please list the Pump Stations Inspected:
#2, 8, 9, 10
# Number of duplex or larger pump stations in system
10
# 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?
10
# A simple one-way telemetry/communication system (auto -dialer) installed?
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?
❑ M El ❑
# Do they all have telemetry installed?
■ ❑ El ❑
Is the telemetry system functional?
0
Is a 24-hour notification sign posted ?
0
Does the sign include:
Owner Name?
■
Pump station identifier?
■
# Address?
■ ❑ ❑
Instructions for notification?
■ ❑ ❑ ❑
24-hour emergency contact numbers?
❑
Are audio and visual alarms present?
. l El ❑
Are audio and visual alarms operable?
El M F1❑
Page 5 of 6

Permit: WQCSDO074 Owner - Facility: Town of Conway
Inspection Date: 03/17/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
# Is there a backup generator or bypass pump connected? M ❑ ❑ ❑
If tested during inspection, did it function properly? 0 ❑ ❑ ❑
Is the back-up system tested at least bi-annually under normal operating conditions? ❑ ❑ ❑ M
# 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/StaffNehicles/etc) are included in Plan?
# 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: Pump station 8 had a full wet well Audible alarm was not working at PS10.
❑ ❑ ❑
M ❑ ❑ ❑
■❑❑❑
❑ ❑ ❑
Page 6 of 6

WATER POLLUTION CONTROL SYSTEM OPERATOR DESIGNATION FORM
NCAC 15A 8G .0201
TAB to Navigate Form
Facility Name: Permit #
Facility Type: Select Facility Grade: Select SUBMITA SEPARATE FORM FOR EACH CLASSWICATION
Permittee Owner/Officer Name:
Email Address:
Permittee Signature: Date:
ORC
Operator in Responsible Charge
Full Name: Work Phone:
Email Address:
Certificate Type: Select Certificate Grade: Select Certificate #:
Signature: Effective Date:
"i certify that / agree to my designation as the Operator in Responsible Charge for the facility noted. I understand and will
abide by the rules and regulations pertaining to the responsibilities of the ORC as set forth in 15A NCAC 08G .0204 and
failing to do so can result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission."
Backup ORC
Full Name: Work Phone:
Certificate Type: Select Certificate Grade: Select Certificate #:
Signature: Effective Date:
"l certify that I agree to my designation as a Back-up Operator in Responsible Charge for the facility noted. I understand and will
abide by the rules and regulations pertaining to the responsibilities of the ORC as set forth in 15A NCAC 08G .0204 and failing to
do so can result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission."
Backup ORC
Full Name: Work Phone:
Certificate Type: Select Certificate Grade: Select Certificate #:
Signature: Effective Date:
"I certify that I agree to my designation as a Back-up Operator in Responsible Charge for the facility noted. I understand and will
abide by the rules and regulations pertaining to the responsibilities of the ORC as set forth in 15A NCAC 08G .0204 and failing to do
so can result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission."
Mail, fax or email ORIGINAL to: WPCSOCC, 1618 Mail Service Center, Raleigh, NC 27699-1618 1 FAX: [phone] [e-mail]
Mail or fax a COPY to: Choose DWR Regional Office that has coverage of this facility.
Revised 312019

Facility Name:
Backup ORC
Permit M
Page 2
Full Name:
Work Phone:
Certificate Type:
Select Certificate Grade: Select Certificate #:
Signature:
Effective Date:
"I certify that/ agree to my designation as a Back-up Operator in Responsible Charge for the facility noted. I understand and will
abide by the rules and regulations pertaining to the responsibilities of the ORC as set forth in 15A NCAC 08G .0204 and failing to
do so can result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission."
Backup ORC
Full Name:
Work Phone:
Certificate Type:
Select Certificate Grade: Select Certificate #:
Signature:
Effective Date:
"I certify that/ agree to my designation as a Back-up Operator in Responsible Charge for the facility noted. 1 understand and will
abide by the rules and regulations pertaining to the responsibilities of the ORC as set forth in 15A NCAC 08G .0204 and failing to
do so can result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission."
Backup ORC
Full Name:
Work Phone:
Certificate Type:
Select Certificate Grade: Select Certificate #:
Signature:
Effective Date:
"/ certify that I agree to my designation as a Back-up Operator in Responsible Charge for the facility noted. I understand and will
abide by the rules and regulations pertaining to the responsibilities of the ORC as set forth in 15A NCAC 08G .0204 and failing to
do so can result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission."
Backup ORC
Full Name:
Work Phone:
Certificate Type:
Select Certificate Grade: Select Certificate #:
Signature:
Effective Date:
"I certify that/ agree to my designation as a Back-up Operator in Responsible Charge for the facility noted. I understand and will
abide by the rules and regulations pertaining to the responsibilities of the ORC asset forth in 15A NCAC 08G .0204 and failing to
do so can result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission."