WQCSD0043_Inspection_20220427

April 27, 2022
Certified Mail # 7014 3490 0001 8820 9563
Return Receipt Requested
Mr. Reginald White, Mayor
Town of Rich Square
PO Box 336
Rich Square, NC 27869
Subject: NOTICE OF DEFICIENCY
Tracking No.: NOD-2022-PC-0056
Compliance Evaluation Inspection
Town of Rich Square Collection System
Deemed Permit # WQCSD0043
Northampton County
Permittee:
On Wednesday, April 6, Jason Robinson, Cassidy Kurtz, Dorothy Robson and Chris Smith of the NC Division
of Water Resource’s Raleigh Regional Office (RRO) conducted an inspection of Rich Square’s Wastewater
Collection System (not the wastewater treatment plant). Yours and Mr. Jeffrey Long (Operator in
Responsible Charge) presence and cooperation was appreciated
The Compliance Evaluation Inspection of the Town’s Collection System consisted of the following:
x Review of relevant documentation required by 15A NCAC 02T .0405
x Visual Inspection of the collection system.
Findings during the pre-inspection file review were as follows:
1)The Town of Rich Square’s Wastewater Collection System has a flow of less than 200,000 gallons per
day, and therefore does not require an individual state-issued permit for its collection system.
Instead, the system is “Permitted by Regulation” and must meet the requirements of North Carolina
Administrative Coded 15A NCAC 02T, particularly Section .0405. These regulations are attached to
this inspection report.
2)DWR last inspected this Collection System for compliance on August 1, 2018. A Notice of Violation
was sent as a result of that inspection (NOV-2018-PC-0308).




 


Prior to that, the system was inspected on August 17, 2017. A notice of Violation was sent as a result
of that inspection (NOV-2017-PC-0558).

3) No Sanitary Sewer Overflows (SSOs) have been reported since 2003. Please be reminded that any
SSOs that reaches surface water (regardless of volume) or any spill to land that is greater than 1,000
gallons should be reported to this office.

4) This system is classified as a CS-1. Classified systems require an Operator in Responsible Charge
(ORC). Please designate an ORC for this system by completing an Operator Designation Form
(attached).

Below are the different sections of 15A NCAC 02T .0405, followed by NCWR’s finding during the
inspection:

5) 15A NCAC 02T .0405(1):

NCDWR’s Comments: Rich Square staff stated that no Sanitary Sewer Overflows (SSOs) have occurred
recently, and none have been reported to the Division since 2003. Staff are not aware of any violations of
groundwater or surface water standards from the Collection System.

6) 15A NCAC 02T .0405(2):

NCDWR’s Comments: A map was available during the inspection that showed sewer lines, manholes and
pump stations. This map should be updated to include pump station names and capacities, flow
directions, and pipes sizes (and material, if known).

7) 15A NCAC 02T .0405(3):

NCDWR’s Comments: An operations and maintenance plan was not available for review. The Town
should develop an Operation & Maintenance (O&M) Plan that includes all of the listed components.
This O&M Plan should be made available to all staff that works with the Collection System and
wastewater treatment plant. It should be kept in the Town vehicles, town hall, at the storage facility,
and at the pump stations.

8) 15A NCAC 02T .0405(4):

NCDWR’s comments: The system has nine (9) pump stations. SCADA nor telemetry are available at any
of the stations, and staff stated that the pump stations are inspected at least once daily, and that each




 


pump station is equipped with quick power hookup. A portable generator on a trailer was observed at
the Town’s storage shed. Pump Stations #1, #2, #3, #4 and #8 were observed during the inspection. Log
books were present at all stations verifying at least daily inspections. Rich Square staff should document
more in the pump station log books, including when issues are found or maintenance is performed at
the Pump Stations. The alarms worked at all the stations observed, except the audible alarm at Station
#1. Please make sure that audible and visual alarms work at all pump stations. Signs were observed at
all stations except Station #1’s sign did not include an emergency phone number. Pump station names
and emergency contact numbers should be displayed at all pump stations.

Rich Square staff stated that the Town had recently acquired a sewer jetter on a trailer that will be used
to clean the system. They also stated that several of the pump stations will be upgraded. Please
update this office when upgrades are made.

9) 15A NCAC 02T .0405(5):

NCDWR’s comments: Town staff stated there are no High-Priority sewer in the system (aerial sewers,
sewer contacting surface waters, siphon, sewer positioned parallel to streambanks that are subject to
erosion that undermines or deteriorates the sewer, or sewer designated high priority due to not meeting
minimum design requirements).

10) 15A NCAC 02T .0405(6):

NCDWR’s comments: The entire system is visually inspected frequently.

11) 15A NCAC 02T .0405(7):

NCDWR’s comments: No Sanitary Sewer Overflows (SSOs) have been reported since 2003. Please be
reminded that any SSOs that reach surface water (regardless of volume) or any spill to land that is greater
than 1,000 gallons should be reported to this office within 24 hours.

12) 15A NCAC 02T .0405(8):





 


NCDWR’s comments: The Town does not have a Grease Control Program. The Town should create and
distribute education material to both its residential and commercials users at least bi-annually (can be
done with water bills).

13) 15A NCAC 02T .0405(9):

NCDWR’s comments: A right-of-way was observed at one of the pump stations. The right-of-way was
well maintained.

14) 15A NCAC 02T .0405(10):

NCDWR’s comments: Please develop the appropriate documentation as described in this inspection
report. Document all activities that are done as part of the operation and maintenance of the
Collection system including pump station visits, cleaning, repairs, mowing, mailing of grease
educational materials, etc. Make sure to keep all documents for at least three years.

Please respond in writing to the portions of this letter that are bolded (Items 4, 6, 7, 8, 12 and 14)
within 30 days of receipt of this report. The response should be mailed to the following:

NCDEQ – DWR – Raleigh Regional Office
Attn: Jason Robinson
3800 Barrett Dr.
Raleigh, NC 27609

The Town is commended to trying to improve the operation and maintenance of their collection system,
and addressing some of the issues cited in previous inspection reports. Please continue to strive to meet
all requirements of 15A NCAC 02T .0405. If you have any questions regarding the attached reports or
any of the findings, please contact Jason Robinson at [e-mail].

Sincerely,

by Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ

ATTACHMENTS
x 15A NCAC 02T .0405
x Operator Designation Form
x Compliance Inspection Checklist

Cc: Raleigh Regional Office and Laserfiche
[e-mail]




 

15A NCAC 02T .0403 PERMITTING BY REGULATION
(a) Collection systems having an actual, permitted or Division-approved average daily flow less than 200,000
gallons per day shall be deemed permitted, pursuant to Rule .0113 of this Subchapter if the system meets the criteria
in Rule .0113 of this Subchapter and all criteria required in this Rule:
(1) The collection system shall be effectively maintained and operated at all times to prevent
discharge to land or surface waters and to prevent any contravention of groundwater standards or
surface water standards.
(2) A map of the collection system shall have been developed and shall be maintained.
(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.
(4) Pump stations that are not connected to a telemetry system shall be inspected by the permittee or
its representative every day, 365 days per year, unless the permittee demonstrates that daily
inspections are not necessary because the pump station has sufficient storage capacity, above the
elevation at which the pump activates, to justify a longer inspection interval. In no case shall the
inspection interval exceed seven days. Pump stations that are connected to a telemetry system
shall be inspected once per week.
(5) High-priority sewers shall be inspected by the permittee or its representative once every six-
months, and inspections shall be documented.
(6) A general observation by the permittee or its representative of the entire collection system shall be
conducted once per year.
(7) Overflows and bypasses shall be reported to the appropriate Division regional office in accordance
with 15A NCAC 02B .0506(a), and public notice shall be provided as required by G.S. 143 -
215.1C.
(8) A Grease Control Program shall be in place as follows:
(A) For publicly owned collection systems, the Grease Control Program shall include bi-
annual distribution of educational materials for both commercial and residential users and
the legal means to require grease interceptors for new construction and retrofit and if
necessary, of grease interceptors at existing establishme nts. The plan shall also include
legal means for inspections of the grease interceptors, enforcement for violators and the
legal means to control grease entering the system from other public and private satellite
collection systems.
(B) For privately owned collection systems, the Grease Control Program shall include bi-
annual distribution of grease education materials to users of the collection system by the
permittee or its representative.
(C) Grease education materials shall be distributed more often than required in Parts (A) and
(B) of this Subparagraph if necessary to prevent grease -related sanitary sewer overflows.
(9) Right-of-ways and easements shall be maintained in the full easement width for personnel and
equipment accessibility.
(10) Documentation of compliance with Subparagraphs (a)(1) through (a)(9) of this Rule shall be
maintained by the collection system owner for three years with the exception of the map, which
shall be maintained for the life of the system.
(b) Private collection systems on a single property serving an industrial facility from which the domestic wastewater
contribution is less than 200,000 gallons per day shall be deemed permitted.
(c) The Director may determine that a collection system shall not be deemed to be permitted i n accordance with this
Rule and Rule .0113 of this Subchapter. This determination shall be made in accordance with Rule .0113(e) of this
Subchapter.

History Note: Authority G.S. 143-215.1(a); 143-215.3(a); 143-215.9B;
Eff. September 1, 2006;
Readopted Eff. September 1, 2018.

Revised 05-2015

Water Pollution Control System Operator Designation Form
WPCSOCC
NCAC 15A 8G .0201

Permittee Owner/Officer Name:

Mailing Address:

City: State: Zip: - Phone #:

Email address: _______________________________________________________________________________

Signature: Date:

Facility Name: Permit #:

County:

SUBMIT A SEPARATE FORM FOR EACH TYPE SYSTEM!
Facility Type/Grade (CHECK ONLY ONE):
Biological Collection Physical/Chemical Surface Irrigation Land Application

Operator in Responsible Charge (ORC)

Print Full Name: Email:

Certificate Type / Grade / Number: Work Phone #:

Signature: Date:

“I certify that I 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.”

Back-Up Operator in Responsible Charge (BU ORC)

Print Full Name: Email:

Certificate Type / Grade / Number: Work Phone #:

Signature: 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 BU ORC as set forth in 15A NCAC 08G .0205 and failing to do s o can result in
Disciplinary Actions by the Water Pollution Control System Opera tors Certification Commission.”

Mail, fax or email the
original to:
WPCSOCC, 1618 Mail Service Center, Raleigh, NC 27699-1618 Fax: [phone]
Email: [e-mail]
Mail or fax a copy to the
appropriate Regional Office:
Asheville
2090 US Hwy 70
Swannanoa 28778
Fax: [phone]
Phone: [phone]
Fayetteville
225 Green St
Suite 714
Fayetteville 28301-5043
Fax: [phone]
Phone: [phone]
Mooresville
610 E Center Ave
Suite 301
Mooresville 28115
Fax: [phone]
Phone: [phone]
Raleigh
3800 Barrett Dr
Raleigh 27609
Fax: [phone]
Phone:[phone]

Washington
943 Washington Sq Mall
Washington 27889
Fax: [phone]
Phone: [phone]
Wilmington
127 Cardinal Dr
Wilmington 28405-2845
Fax: [phone]
Phone: [phone]
Winston-Salem
450 W. Hanes Mall Rd
Winston-Salem 27105
Fax: [phone]
Phone: [phone]

WPCSOCC Operator Designation Form, cont.
Revised 05-2015

Facility Name: Permit #:

Back-Up Operator in Responsible Charge (BU ORC)

Print Full Name: Email:

Certificate Type / Grade / Number: Work Phone #:

Signature: 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 BU ORC as set forth in 15A NCAC 08G .0205 and failing to do so can result in
Disciplinary Actions by the Water Pollution Control System Operators Certification Commission.”

Back-Up Operator in Responsible Charge (BU ORC)

Print Full Name: Email:

Certificate Type / Grade / Number: Work Phone #:

Signature: 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 BU ORC as set forth in 15A NCAC 08G .0205 and failing to do s o can result in
Disciplinary Actions by the Water Pollution Control System Opera tors Certification Commission.”

Back-Up Operator in Responsible Charge (BU ORC)

Print Full Name: Email:

Certificate Type / Grade / Number: Work Phone #:

Signature: 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 BU ORC as set forth in 15A NCAC 08G .0205 and failing to do s o can result in
Disciplinary Actions by the Water Pollution Control System Operators Certification Commission.”

Back-Up Operator in Responsible Charge (BU ORC)

Print Full Name: Email:

Certificate Type / Grade / Number: Work Phone #:

Signature: 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 BU ORC as set forth in 15A NCAC 08G .0205 and failing to do so can result in
Disciplinary Actions by the Water Pollution Control System Operators Certification Commission.”