WQCSD0016_NOV-2022-PC-0249_20220506

DocuSign Envelope ID: 7B690965-8BE0-4A3B-9740-2CD48187D172
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
Certified Mail # 7020 3160 0000 4115 3555
Return Receipt Requested
Emily Turner, Mayor
203 W. Green Street
P.O. Box 185
Macclesfield, NC 27557
Subject:
Dear Mayor Turner:
May 6, 2022
NOTICE OF VIOLATION: NOV-2022-PC-0249
Compliance Evaluation Inspection
Macclesfield Collection System
Deemed Permitted Collection System No. WQCSD0016
Edgecombe County
This letter serves as a Notice of Violation (NOV) for the Town of Macclesfield's (Town's)
wastewater collection system, which is a Deemed Permitted System under permit number
WQCSD0016. The Town has not created or retained the required records and plans which must
be associated with the collection system, as required by 15A North Carolina Administrative
Code Section 02T.0400 (15A NCAC 02T.0403).
On April 20, 2022, Alys Hannum and Jason Robinson of the Division of Water Resources
conducted an inspection of the Town Collection System to evaluate compliance with the
operation and maintenance of the subject deemed wastewater collection system permit. The
cooperation and assistance of Benjy Lassiter, Operator in Responsible Charge (ORC) was greatly
appreciated.
Findings during the inspection were as follows:
1. The wastewater collection system has 2 pump stations. Both pump stations are connected
to a communication system (SCADA) and have connections for portable generators.
2. The Town provided a map of the collection system, but the map was for proposed
additions to the system in 1999. The Town's current map is NOT a map of current
collection system assets. Within 60 days of receipt of this letter, please create an updated
map which reflects current collection system assets or submit a plan to create one. This
map should include: pipe location, material, approximate age, and size; flow direction;
pump station locations, names, and capacity; and force main release valves.
NORTH CAROLINA
Department of Environmental Quality
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office 13800 Barrett Drive I Raleigh, North Carolina 27609
919.791.4200

DocuSign Envelope ID: 7B690965-8BE0-4A3B-9740-2CD48187D172
Notice of Violation: NOV-2022-PC-0249
Macclesfield Collection System
Permit No. WQCSD0016
Page 2 of 3
3. No sanitary sewer overflows to State Waters were discovered during the most recent 3-
year period ending March 2022.
4. The Town did not have an Operations and Maintenance plan. Within 60 days of receipt
of this letter, please submit to this office a draft Operations and Maintenance Plan for
review - or a schedule for creating one - which includes at minimum the following:
1. Pump Station Inspection Frequency
2. Preventative Maintenance Schedule
3. Spare Parts Inventory
4. Overflow Response Plan
5. The Town did not have Grease Control Program. Within 60 days of receipt of this letter,
please submit to this office a draft Grease Control Program for review - or a schedule
for creating one - which includes at minimum the following:
1. The schedule of the bi-annual distribution of educational materials for both
commercial and residential users;
2. The legal means to require grease interceptors for new construction and
retrofit if necessary, of grease interceptors at existing establishments;
3. The legal means for inspections of grease interceptors, enforcement for
violators; and
4. The legal means to control grease entering the collection system from other
public and private satellite collection systems.
6. The Town's two pump stations were inspected. Both had identification signs, secured
access, appeared in good condition and were free of excess debris. All audible and visual
alarms functioned when tested. The pump stations inspected were as follows:
a. Wilson Street Pump Station (#1)
b. North Railroad Pump Station (#2)
7. A logbook for each pump station was available to view during the inspection. According
to Town staff, pump station logs do not accurately reflect the frequency of inspections. The
logbooks show approximately one inspection per month. Pump stations that are connected
to a telemetry system, like the Town's, are required to be inspected at least once per week.
Within 60 days of receipt of this letter, please ensure collection system staff are trained
on the frequency of inspections required and remind them to record every pump station
visit in the logbooks.
Within 60 days of receipt of this letter, please submit a written response to this office and indicate
the actions the Town will take, or has taken, to comply with the requirements for Deemed
Permitted Collection Systems. The response should address items 2, 4, 5, and 7 above, as well
as include the requested O&M and Grease Control Program Plans or a schedule for their
NORTH CAROLINAD_E
Department of Environmental Quality
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office 13800 Barrett Drive I Raleigh, North Carolina 27609
919.791.4200

DocuSign Envelope ID: 7B690965-8BE0-4A3B-9740-2CD48187D172
Notice of Violation: NOV-2022-PC-0249
Macclesfield Collection System
Permit No. WQCSD0016
Page 3 of 3
creation. This office will review this information and any additional information you provide to
determine whether to take further action.
If you have any questions concerning this NOV or the required submissions, please contact Alys
Hannum at [e-mail] or by phone at [phone].
Sincerely,
—DocuSigned by:
Vatiuussa t. D'ttatiuwL
B2916E6AB32144F...
Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Attachment: EPA Water Compliance Inspection Report
cc: RRO Files // Laserfiche
Benjy Lassiter, ORC ([e-mail])
GD_E
NORTH CofEn NA
Deparbnent iR of Environmental Quality
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office 13800 Barrett Drive I Raleigh, North Carolina 27609
919.791.4200

DocuSign Envelope ID: 7B690965-8BE0-4A3B-9740-2CD48187D172
Compliance Inspection Report
Permit: WQCSD0016 Effective: 03/01/00 Expiration:
SOC: Effective: Expiration:
County: Edgecombe
Region: Raleigh
Contact Person: Eric Johnson
Directions to Facility:
Owner : Town of Macclesfield
Facility: Macclesfield Collection System
Title: Mayor Phone: [phone]
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 04/20/2022
Primary Inspector: Alys K Hannum
Secondary Inspector(s):
Entry Time 10:OOAM
1- DocuSigned by:
"-4C22170C5AA04F3...
Exit Time: 12:OOPM
5/2/2022
Phone: [phone]
Jason T Robinson
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
II Spills/Response Plan Inspections Pump Stations
(See attachment summary)
Page 1 of 5

DocuSign Envelope ID: 7B690965-8BE0-4A3B-9740-2CD48187D172
Permit: WQCSD0016 Owner - Facility:Town of Macclesfield
Inspection Date: 04/20/2022
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Inspection Summary:
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DocuSign Envelope ID: 7B690965-8BE0-4A3B-9740-2CD48187D172
Permit: WQCSD0016 Owner - Facility:Town of Macclesfield
Inspection Date: 04/20/2022
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
General
# Is this system a satellite system?
# If Yes, what is system name or permit number?
Is there a overall sewer system map?
Does the map include:
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
Are system maintenance records maintained?
Yes No NA NE
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Comment: The map provided was for proposed additions to the system back in 1999 and is NOT a map of
current collection system assets as they stand on the ground now. Needs to be updated to
reflect current collection system status.
Grease Control
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.)
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?
Yes No NA NE
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Comment: Municipality does not have a written grease ordinance or program. Previously sent out FOG
flyers 2x per year, but due to staff turnover flyers have not been retained or sent out this year
yet.
Spills and Response Action Plan
# Is system free of known points of bypass?
If No, describe type of bypass and location
# 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?
Are all spills or sewer related issues/complaints documented?
# Are there repeated overflows/problems (2 or more in 12 months) at same location?
Yes No NA NE
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DocuSign Envelope ID: 7B690965-8BE0-4A3B-9740-2CD48187D172
Permit: WQCSD0016 Owner - Facility:Town of Macclesfield
Inspection Date: 04/20/2022
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
# 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?
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
Comment: Town does not have a Spill Response Action Plan.
Inspections
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?
Comment: Not all inspections to pump stations are recorded. Official
one visit per month.
Pump Stations
Please list the Pump Stations Inspected:
#1 - Wilson Street // #2 - North Railroad
# 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?
Were they free of by-pass structures/pipes?
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Yes No NA NE
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records at the pump stations show
Yes No NA NE
2
0
0
0
2
0
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DocuSign Envelope ID: 7B690965-8BE0-4A3B-9740-2CD48187D172
Permit: WQCSD0016 Owner - Facility:Town of Macclesfield
Inspection Date: 04/20/2022
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Were wet wells free of excessive grease/debris?
# Do they all have telemetry installed?
Is the telemetry system functional?
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 (Units/Staff/Vehicles/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?
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Comment: Town staff stated during the inspection that one of the emergency contact numbers on the
contact sign was for an ex -employee's personal cell number. Please update the signage with
the correct contact numbers.
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