WQCSD0010_Notice of Deficiency_20220610

ROY COOPER
Governor
EL"ETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
June 10'", 2022
The Honorable Ralph "Mack" Smith, Jr., Mayor
Town of Black Creek
P.O. Box 8
Black Creek, NC 27813
Subject: Notice of Deficiency
NOD-2022-PC-0086
Compliance Evaluation Inspection
NPDES Permit WQCSDO010
Facility Name: Town of Black Creek Collection System
Lee County
Dear Mayor Smith:
On May 26, 2022, Josh Brigham of the Raleigh Regional Office conducted a compliance evaluation
inspection of the Town of Black Creek Collection System. The purpose of this inspection was to ensure
compliance with the subject NPDES permit. During the inspection, the guidance of Greg Gates, ORC,
and Ty Davis, bORC, 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),
Greg Gates, is classified as CS-1. The bORC is listed as Richard J. Lucas, who is no longer with the
town. Please fill out the attached operator designation form, designating Ty Davis as the new
bORC.
2. The Town of Black Creek has had no reported Sanitary Sewer Overflows since the last inspection on
July 29, 2019.
Findings during the inspection were as follows:
3. The Black Creek collection system has 6 pump stations. Four 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 electronically. The
high-water float was used to trigger audio and visual alarms at each station and each generator was
tested. The River Road station had faded signage. The town will need to replace or refurbish the
sign to meet the permit requirements. This deficiency was also noted during the inspection on
July 29, 2019. No issues were noted at any of the other pump stations.
DKQXZA North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office { 3800 Barrett Drive I Raleigh, North Carolina 27609
o�,1 ,./ 919.791.4200

4. A map of the sewer system was available and contained all required information.
5. The Black Creek collection system has a Fats, Oils, and Grease Program. Materials are distributed
with utility bills and posted at city hall.
6. The Black Creek collection system has one high -priority line. It is inspected regularly, but inspections
are not documented. Please maintain documentation of inspections in the future.
7. A Spill Response Action Plan was available for review during the inspection. It contained all required
information.
8. An operation and maintenance plan was available for review. It contained all required information.
This inspection letter is being sent as a Notice of Deficiency because of the bolded items listed in
points 1, 3, and 6. 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
j oshua.brighamgncdenr.gov.
Sincerely, s
v
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
Operator Designation Form
Cc: RRO Files
Laserfiche
North Carolina Department of Environmental Quality I Division of Water Resources
�D 512 North Salisbury Street i 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CHAR INA 919.707.9000
Oe�0�1 ei EnNannrW OWMr�

Compliance Inspection Report
Permit: WQCSD0010 Effective: 03/01/00 Expiration: 01/01/23 Owner: Town of Black Creek
SOC: Effective: Expiration: Facility: Black Creek Collection System
County: Wilson
Region: Raleigh
Contact Person: Ralph M Smith Title: Mayor Phone: [phone]
Directions to Facility:
System Classifications: CS1,
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 05/26/2022 Entry Time 08:40AM
Primary Inspector: Joshua S Brigham
Secondary Inspectors):
-
Certification
Phone:
Exit Time: 10:10AM
Phone: [phone]
LAV/zvZ2
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: WQCSD0010 Owner - Facility: Town of Black Creek
Inspection Date: 05/26/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Inspection Summary:
See attached inspection report.
Page 2 of 6

Permit: WOCSD0010 Owner - Facility: Town of Black Creek
Inspection Date: 05/26/2022 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?
Wilson WWTP
NC0023906
Is there a overall sewer system map?
0 ❑ ❑ ❑
Does the map include:
Pipe sizes
0 ❑ ❑ ❑
Pipe materials (PVC, DIP, etc)
0 ❑ ❑ ❑
Pipe location
M ❑ ❑ ❑
# Flow direction
0 ❑ ❑ ❑
# Approximate pipe age
M ❑ ❑ ❑
# Pump station ID, location and capacity
0 ❑ ❑ ❑
# Force main air release valve location & type
0 ❑ ❑ ❑
# Location of satellite connections
M ❑ ❑ ❑
Are system maintenance records maintained?
0 ❑ ❑ ❑
Comment:
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.)
Flyers at town hall
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? ❑ ❑ ❑
Is the Grease Control Program enforced via periodic inspections/records review? ❑ ❑ 0 ❑
Is action taken against violators? ❑ ❑ M❑
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? ❑ 0 ❑ ❑
If Yes, were they reported to the Division if meeting the reportable criteria? ❑ ❑ 0 ❑
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? ❑ ❑ 0 ❑
# If Yes, is there a corrective action plan? ❑ ❑ 0 ❑
Page 3 of 6

Permit: WQCSDO010 Owner - Facility: Town of Black Creek
Inspection Date: 05/26/2022 Inspection Type: Collection System Inspect Non Sampling Reason for Visit: Routine
Is a Spill Response Action Plan available? E ❑ ❑ ❑
Is a Spill Response Action Plan available for all personnel? 0 ❑ ❑ ❑
Does the plan include:
# 24-hour contact numbers 0 ❑ ❑ ❑
# Response time 0 ❑ ❑ ❑
# Equipment list and spare parts inventory 0 ❑ ❑ ❑
# Access to cleaning equipment 0 ❑ ❑ ❑
# Access to construction crews, contractors, and/or engineers 0 ❑ ❑ ❑
# Source of emergency funds 0 ❑ ❑ ❑
# Site sanitation and cleanup materials 0 ❑ ❑ ❑
# Post-overflow/spill assessment 0 ❑ ❑ ❑
Comment: NO SSOs reported.
Inspections Yes No NA NE
Are adequate maintenance records maintained? 0 ❑ ❑ ❑
Are pump stations being inspected at the required frequency? E ❑ ❑ ❑
Is at least one complete functionality test conducted weekly per pump station? 0 ❑ ❑ ❑
Is there a system or plan in place to observe the entire system annually? 0 ❑ ❑ ❑
Is the annual inspection documented? ❑ 0 ❑ ❑
# Does the system have any high -priority lines/locations? 0 ❑ ❑ ❑
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: Full functionality done monthly. HPL inspections not documented.
Lines/Right-of-Ways/Aerial Lines Yes No NA NE
Please list the Lines/Right of Ways/Aerial Lines Inspected:
River Road
Are right-of-ways and easements maintained for the full width for access? N ❑ ❑ ❑
If No, give details on temporary access:
Is maintenance documented? ❑ ❑ ❑
Were all areas/lines inspected free of issues? 0 ❑ ❑ ❑
Comment:
Manholes Yes No NA NE
Please list the Manholes Inspected:
Upstream of Evans and Mallard pump stations.
Are manholes accessible? 0 ❑ ❑ ❑
# Are manhole covers/vents above grade? N ❑ ❑ ❑
Are manholes free of visible signs of overflow? 0 ❑ ❑ ❑
Page 4 of 6

Permit: WQCSD0010 Owner - Facility: Town of Black Creek
Inspection Date: 05/26/2022 Inspection Type : Collection System Inspect Non Sampling
Reason for Visit: Routine
Are manholes free of sinkholes and depressions?
0 ❑ ❑ ❑
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?
E ❑ ❑ ❑
Are manholes free of excessive roots?
M ❑ ❑ ❑
Are manholes free of excessive sand?
0 ❑ ❑ ❑
Are manhole vents screened?
❑ ❑ ❑
Are vents free of submergence?
❑ ❑ ❑
Are manholes free of bypass structures or pipes?
❑ ❑ ❑
Comment:
Pump Stations
Yes No NA NE
Please list the Pump Stations Inspected:
# Number of duplex or larger pump stations in system
6
# 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?
6
# A simple one-way telemetry/communication system (auto -dialer) installed?
0
For pump stations inspected:
Are they secure with restricted access?
M ❑ ❑ ❑
Were they free of by-pass structures/pipes?
0 ❑ ❑ ❑
Were wet wells free of excessive grease/debris?
0 ❑ ❑ ❑
# Do they all have telemetry installed?
M ❑ ❑ ❑
Is the telemetry system functional?
M ❑ ❑ ❑
Is a 24-hour notification sign posted ?
0 ❑ ❑ ❑
Does the sign include:
Owner Name?
M ❑ ❑ ❑
Pump station identifier?
M ❑ ❑ ❑
# Address?
M ❑ ❑ ❑
Instructions for notification?
0 ❑ ❑ ❑
24-hour emergency contact numbers?
0 ❑ ❑ ❑
Are audio and visual alarms present?
0 ❑ ❑ ❑
Page 5 of 6

Permit: WQCSD0010 Owner - Facility: Town of Black Creek
Inspection Date: 05/26/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Are audio and visual alarms operable? 0 ❑ ❑ ❑
# 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? ❑ ❑ ❑
# 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?
# 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:
❑❑❑■
■❑❑❑
❑❑❑
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 CLASSIFICATION
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:
"l certify that 1 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:
"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:
"1 certify that I 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."
Mail, fax or email ORIGINAL to: WPCSOCC, 1618 Mail Service Center, Raleigh, NC 27699-1618 I FAX: [phone] [e-mail]
Mail or fax a COPY to: Choose DWR Regional Office that has coverage of this facility.
Revised 312019

Page 2
Facility Name:
Permit M
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."
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 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."
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 ISA 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:
"1 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."