WQCSD0014_Notice of Violation_20220523

ROY COOPER
Governor
EL"ETH S. B1SER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Enviromnental Quality
May 23", 2022
Certified Mail # 7020 3160 0000 4115 4019
Return Receipt Requested
John Godfrey, Town Manager
P.O. Box 130
Broadway, NC 27505
Subject: Notice of Violation
NOV-2022-PC-0282
Compliance Evaluation Inspection
NPDES Permit WQCSDO014
Facility Name: Town of Broadway Collection System
Lee County
Dear Mr. Godfrey:
On May 11, 2022, Josh Brigham of the Raleigh Regional Office conducted a compliance evaluation
inspection of the Town of Broadway Collection System. The purpose of this inspection was to ensure
compliance with the subject NPDES permit. During the inspection, the guidance of yourself, Craig
Buchanan, ORC, and Jacob Melvin was greatly appreciated.
This NPDES compliance evaluation 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 designated Operator in Responsible Charge (ORC),
Craig Buchanan, is classified as CS-1.
2. The Town of Broadway has had no reported Sanitary Sewer Overflows since the last inspection on
July 25, 2019.
Findings during the inspection were as follows:
3. The Broadway collection system has 4 pump stations. All of the pump stations were visited during
this inspection. All pump stations had secured access, and exhibited very little to no waste build-up.
Pump stations are monitored daily. Inspection records were available at each pump station. The high-
water float was used to trigger audio and visual alarms at each station and each generator was tested.
The Knowledge Street generator would not start, but Mr. Buchanan stated that new batteries would be
installed. No issues were noted at any of the other the pump stations.
North Carolina Department of Environmental Quality I Division of Water Resources
D E Q�� Raleigh Regional Office 1 3800 Barrett Drive 1 Raleigh, North Carolina 27609
NORTH CAPOUNA �/
ao.mu.�iav \ r 919.791.4200

4. A map of the sewer system was available and contained all required information except for pump
station location, id, and capacity.
5. The Broadway collection system has a Fats, Oils, and Grease Program. Materials are distributed with
utility bills and restaurants are inspected but not documented. Please keep documentation of
inspections in the future.
6. The Broadway collection system has one high -priority line. It is inspected regularly, and inspections
are documented.
7. A Spill Response Action Plan was available for review during the inspection. It contained contact
information and response time. Please continue to develop and provide a copy of a Spill Response
Action Plan to this department within 60 days. It should include an 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, and post
overflow/spill assessment. This deficiency was also noted during the inspection on July 25, 2019.
8. An operation and maintenance plan was not available for review. Per 15A NCAC 02% .0403(3) and
operation and maintenance plan including pump station inspection frequency, preventative
maintenance schedule, spare parts inventory, and overflow response shall have been developed
and implemented. This deficiency was also noted during the inspection on July 25, 2019.
9. Right-of-way maintenance records were available for review during the inspection and were
complete.
This inspection letter is being sent as a Notice of Violation because of the bolded items listed in
points 5, 7, and 8. Within 60 days of receiving this letter, please provide this office with a written
response indicating how these issues have been resolved.
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: EPA Water Compliance Inspection Report
Cc: RRO Files
Laserfiche
DNorth
EQ Carolina Department of Environmental Quality I Division of Water Resources
.�. 512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CAAOLINA
�zlsle� 919.707.9000

Compliance Inspection Resort
Permit: WQCSD0014 Effective: 03/01/00 Expiration: Owner: Town of Broadway
SOC: Effective: Expiration: Facility: Broadway Collection System
County: Lee
Region: Raleigh
Contact Person: John M Godfrey Title: Town Manager Phone: [phone]
Directions to Facility:
System Classifications: CS1,
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 05/11/2022 Entry Time 08:40AM
Primary Inspector: Joshua S Brigham 2,
Secondary Inspector(s): y
Certification
Phone:
Exit Time: 10:OOAM
9 z 2 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: WQCSD0014 Owner - Facility: Town of Broadway
Inspection Date: 05/11/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Inspection Summary:
See attached inspection report.
Page 2 of 6

Permit: WQCSD0014 Owner - Facility: Town of Broadway
Inspection Date: 05/11/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
General Yes No NA NE
# Is this system a satellite system? ❑ 0 ❑ ❑
# 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 0 ❑ ❑ ❑
# Flow direction 0 ❑ ❑ ❑
# Approximate pipe age 0 ❑ ❑ ❑
# Pump station ID, location and capacity ❑ 0 ❑ ❑
# Force main air release valve location & type 0 ❑ ❑ ❑
# Location of satellite connections 0 ❑ ❑ ❑
Are system maintenance records maintained? 0 ❑ ❑ ❑
Comment: Discussed adding pump station ID, location, and capacity.
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.)
Inspection of restaurants.
For public systems, is there a Grease Control Program via an ordinance/agreement? M ❑ ❑ ❑
If Yes, does it require grease control devices at applicable locations? 0 ❑ ❑ ❑
Is the Grease Control Program enforced via periodic inspections/records review? M ❑ ❑ ❑
Is action taken against violators? ❑ ❑ ❑
Comment:
Spills and Response Action Plan
Yes No NA NE
# 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?
❑ ❑ M ❑
Are all spills or sewer related issues/complaints documented?
0 ❑ ❑ ❑
# Are there repeated overflows/problems (2 or more in 12 months) at same location?
❑ ❑ ❑
# If Yes, is there a corrective action plan?
❑ ❑ ❑
Is a Spill Response Action Plan available?
M ❑ ❑ ❑
Page 3 of 6

Permit: WQCSD0014 Owner - Facility: Town of Broadway
Inspection Date: 05/11/2022 Inspection Type : Collection System Inspect Non Sampling
Reason for Visit: Routine
Is a Spill Response Action Plan available for all personnel?
E❑ ❑ ❑
Does the plan include:
# 24-hour contact numbers
0 ❑ 0 ❑
# Response time
0 ❑ ❑
# Equipment list and spare parts inventory
❑ 0 11 ❑
# Access to cleaning equipment
El 0 ❑ ❑
# Access to construction crews, contractors, and/or engineers
El 0 ❑ ❑
# Source of emergency funds
❑ ❑
# Site sanitation and cleanup materials
❑ 0 El ❑
# Post-overflow/spill assessment
❑ 0 ❑ El
Comment: Spill response plan needs to be further developed.
Inspections
Yes No NA NE
Are adequate maintenance records maintained? ❑
0 El
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? 0❑ ❑ ❑
Are new lines being added to the HPL list when found or created? ❑ ❑
Comment:
Lines/Right-of-Ways/Aerial Lines
Yes No NA NE
Please list the Lines/Right of Ways/Aerial Lines Inspected:
Knowledge St.
Are right-of-ways and easements maintained for the full width for access? E El ❑ ❑
If No, give details on temporary access:
Is maintenance documented? E❑ ❑ El
Were all areas/lines inspected free of issues? 0 ❑ El ❑
Comment:
Manholes
Yes No NA NE
Please list the Manholes Inspected:
Above Knowledge St. and Colonial St pump stations.
Are manholes accessible?
# Are manhole covers/vents above grade?
Are manholes free of visible signs of overflow? E❑ ❑ ❑
Are manholes free of sinkholes and depressions? 0 El n ❑
Page 4 of 6

Permit: WQCSDO014 Owner - Facility: Town of Broadway
Inspection Date: 05/11/2022 Inspection Type :Collection System Inspect Non Sampling
Reason for Visit: Routine
Are manhole covers present?
M ❑ ❑ ❑
# Are manholes properly seated?
0 ❑ ❑ ❑
# Are manholes in good condition?
0 ❑ ❑ ❑
# Are inverts in good condition?
0 ❑ ❑ ❑
Is flow unrestricted in manholes?
0 ❑ ❑ ❑
Are manholes free of excessive amounts of grease?
0 ❑ ❑ ❑
Are manholes free of excessive roots?
0 ❑ ❑ ❑
Are manholes free of excessive sand?
0 ❑ ❑ ❑
Are manhole vents screened?
0 ❑ ❑ ❑
Are vents free of submergence?
0 ❑ ❑ ❑
Are manholes free of bypass structures or pipes?
0 ❑ ❑ ❑
Comment:
Pump Stations
Yes No NA NE
Please list the Pump Stations Inspected:
Knowledge St., Colonial St., Gilbert Lett Dr., Underwood.
# Number of duplex or larger pump stations in system
4
# Number of vacuum stations in system
0
# Number of simplex pump stations in system
0
# Number of simplex pump stations in system serving more than one building
0
How many pump/vacuum stations have:
# A two-way "auto polling" communication system (SCADA) installed?
0
# A simple one-way telemetry/communication system (auto -dialer) installed?
0
For pump stations inspected:
Are they secure with restricted access?
0 ❑ ❑ ❑
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 telemetry system functional?
❑ ❑ 0 ❑
Is a 24-hour notification sign posted ?
0 ❑ ❑ ❑
Does the sign include:
Owner Name?
0 ❑ ❑ ❑
Pump station identifier?
0 ❑ ❑ ❑
# Address?
❑ ❑ ❑
Instructions for notification?
❑ ❑ ❑
24-hour emergency contact numbers?
❑ ❑ ❑
Are audio and visual alarms present?
0 ❑ ❑ ❑
Page 5 of 6

Permit: WQCSD0014 Owner - Facility: Town of Broadway
Inspection Date: 05/11/2022 Inspection Type :Collection System Inspect Non Sampling Reason for Visit: Routine
Are audio and visual alarms operable? ❑ ❑ ❑
# Is there a backup generator or bypass pump connected? ❑ ❑ ❑
If tested during inspection, did it function properly? 0❑ ❑ ❑
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/StaffNehicles/etc) are included in Plan?
No telemetry. Inspected daily.
# 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:
❑❑[IN
M ❑ ❑ ❑
■❑❑❑
•❑❑❑
• El Ell]
■❑❑❑
Page 6 of 6