WQCS00124_NOV-2022-PC-0440_20220901

ROY COOPER
Governor
ELIZABETH S. RISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
Certified Mail # 7001 2510 0006 9499 0582
Return Receipt Requested
August 17, 2022
Clint Mack, Manager Town
Town of Robbins
PO Box 296
Robbins, NC 27325
SUBJECT: NOTICE OF VIOLATION
Tracking Number: NOV-2022-PC-0440
Permit No. WQCS00124
Robbins Collection System
Moore County
Dear Permittee:
The North Carolina Division of Water Resources conducted an inspection of the Robbins Collection System on
May 17, 2022. This inspection was conducted to verify that the facility is operating in compliance with the
conditions and limitations specified in Collection System Permit No. WQCS00124. A summary of the findings and
comments noted during the inspection are provided in the enclosed copy of the inspection report.
The Collection System Non -sampling inspection was conducted by Division of Water Resources staff from the
Fayetteville Regional Office. The following violation(s) were noted during the inspection:
Inspection Area Description of Violation
Capital Improvement Plan
"The Permittee shall adopt and implement a Capital Improvement Plan (CIP) to designate
funding for reinvestment into the wastewater collection system infrastructure. The CIP
should address the short-term and long-term "master plan" concepts. The CIP should
typically cover a three to five year period and include a goal statement, description of
project area, description of existing facilities, known deficiencies (over a reasonable
period) and forecasted future needs. Cost analysis is integral to the CIP.
[G.S. 143-215.9B]rr
Compliance Issue(s):
Remedial actions should have already been taken to correct this problem and prevent further occurrences in the
future. The Division of Water Resources may pursue enforcement action for this and any additional violations of
State law.
North Carolina Deportment of Environmental Quality I Division of Water Resources
Fayetteville Regional ice 1225 Green Street Suite 714 I Fayetteville. North Carolina 25301
910.4333300

To prevent further action, please respond in writing to this office within 30 days upon your receipt of this Notice
of Violation regarding your plans or measures to be taken to address the indicated violations and other identified
issues, if applicable.
If you should have any questions, please do not hesitate to contact Danielle Simpson with the Water Quality
Regional Operations Section in the Fayetteville Regional Office at 910-433-3300.
Sincerely,
Do�c�uS,iggnnedd by: Q
5189C2D3DD5C42B...
J. Trent Allen, Regional Supervisor
Water Quality Regional Operations Section
Fayetteville Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS
Cc: WQS Fayetteville Regional Office - Enforcement File (Laserfiche)
D_ Q
North Carolina Deportment of Environmental Quality I Division of Water Resources
Fayetteville Regional ice 1225 Green Street Shire 714 I Fayetteville. Worth Carolina 25201
910.4333300

Compliance Inspection Report
Permit: WQCS00124
SOC:
County: Moore
Region: Fayetteville
Effective: 11/08/16 Expiration: 10/31/23
Effective: Expiration:
Contact Person: Daniel Gray
Directions to Facility:
System Classifications: CS1,
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
NC0062855
Title:
Town of Robbins - Robbins WWTP
Inspection Date: 05/17/2022
Primary Inspector: Danielle Simpson
Secondary Inspector(s):
Reason for Inspection: Routine
Certification:
Owner : Town of Robbins
Facility: Robbins Collection System
PO Box 296
Robbins NC 27325
Phone: [phone] Ext.8
Phone:
Entry Time 09:OOAM Exit Time: 12:OOPM
DocuSigned by:
4�,�t,�e.11� -(s�ovl, 8/2/2022 Phone: [phone]
-8C7638281 DAB46D...
DocuS,iggnnedd by: Q
5189C2D3DD5C42B...
8/19/2022
Inspection Type: Collection System Inspect Non Sampling
Permit Inspection Type: Collection system management and operation
Facility Status: ❑ Compliant
Question Areas:
▪ Miscellaneous Questions
II Capital Improvement Plan
▪ Inspections
▪ Lines
(See attachment summary)
Not Compliant
▪ General
▪ Map
▪ Spill Response Plan
▪ Manholes
▪ Sewer & FOG Ordinances
▪ Reporting Requirements
▪ Spills
▪ Pump Stations
Page 1 of 7

Permit: WQCS00124 Owner - Facility:Town of Robbins
Inspection Date: 05/17/2022
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Inspection Summary:
The Robbins Collection System oversees three pump stations, all of which were visited during the inspection; HWY 705,
Talc Mine Road, and Candor Sunset Drive. Currently there is a bypass in use at the HWY 705 station. Portable generators
are used in the event of a power outage.
Logs track maintenance and a running tally is kept of line cleaning. The Sewer Use/FOG Ordinance was available. This
should be updated to include grease trap details such as cleaning requirements. Grease education is distributed via mail,
flyers, and more frequently following problems. The CIP is kept at Town Hall but was not available at the time of inspection.
This needs to be developed if one is not in place, and kept on hand.
Page 2 of 7

Permit: WQCS00124 Owner - Facility:Town of Robbins
Inspection Date: 05/17/2022
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
General
Is there a properly designated primary ORC and at least one back-up of proper grade?
Are logs being reviewed by the system management or owner on a regular basis?
# What is that frequency?
# Are there any issues being addressed currently or any in the planning stages?
Is there a specific pump failure plan available for all pump stations?
Does plan indicate if pump parts/new pumps are in spare parts/equipment inventory?
Are new/significantly upgraded pump stations equipped with anti -corrosion materials?
Does the permittee have a copy of their permit?
# Is permit expiring within the next 6 months?
If Yes, has the Permittee applied for renewal?
Comment:
Sewer and FOG Ordinances
Is Sewer Use Ordinance (SUO) or other Legal Authority available?
Does it appear that the Sewer Use Ordinance is enforced?
Is there a Grease Control Program that legally requires grease control devices?
What is the standard grease trap cleaning requirement in the FOG ordinance?
Is Grease Control Program enforced via periodic inspections/records review?
Is action taken against violators?
# Have satellite systems adopted an equivalent or more stringent ordinance?
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.)
Flyers, Mailed with Bills, and Following Problems.
Comment: Grease trap cleaning requirements not included with the ordinance.
Capital Improvement Plan
Has a Capital (CIP) or System Improvement Plan been developed and adopted?
Is it designated for wastewater only or does it have a dedicated section?
Does CIP cover three to five year period of earmarked improvements?
Does CIP include description of project area?
Does CIP include description of existing facilities?
Does CIP include known deficiencies?
Does CIP include forecasted future needs?
Comment: Kept at Town Hall, please have handy for future inspections.
Map
Yes No NA NE
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Not Seen
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Page 3 of 7

Permit: WQCS00124 Owner - Facility:Town of Robbins
Inspection Date: 05/17/2022
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Is there a overall sewer system map?
Does the map include:
Pipe Type (GS/FM)
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
Is the map being updated for changes/additions within 1 year of activation?
Comment: Infraforce app used for mapping.
Reporting Requirements
# 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?
Is an Annual Wastewater Performance Report being filed with the Division, if required?
Is the report being made available to all its sewer customers?
# How is it being made available?
Comment:
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: No HPLs in the system.
Spill Response Action Plan
Is a Spill Response Action Plan available?
Is a Spill Response Action Plan available for all personnel?
Does the plan include:
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Town Hall, Website
Yes No NA NE
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Page4of7

Permit: WQCS00124 Owner - Facility:Town of Robbins
Inspection Date: 05/17/2022
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
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
Does the Permittee appear to respond within 2 hours of first knowledge of a spill?
Comment:
Spills
Is system free of known points of bypass?
If No, describe type of bypass and location
HWY 705
Are all spills or sewer related issues/complaints documented?
# Are there repeated overflows/problems (2 or more in 12 months) at same location?
# If Yes, is there a corrective action plan?
Comment: Bypass pump at HWY 705 pump station
Lines/Right-of-Ways/Aerial Lines
Please list the Lines/Right of Ways/Aerial Lines Inspected:
Are right-of-ways/easements maintained for full width for access by staff/equipment?
If No, give details on temporary access:
Is maintenance documented?
Are gravity sewer cleaning records available?
Has at least 10% of lines older than 5 yrs been cleaned annually?
Were all areas/lines inspected free of issues?
Comment: Log and running tally for line cleaning.
Manholes
Please list the Manholes Inspected:
Are manholes accessible?
# Are manhole covers/vents above grade?
Are manholes free of visible signs of overflow?
Are manholes free of sinkholes and depressions?
Are manhole covers present?
# Are manholes properly seated?
# Are manholes in good condition?
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Page5of7

Permit: WQCS00124 Owner - Facility:Town of Robbins
Inspection Date: 05/17/2022
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
# Are inverts in good condition?
Is flow unrestricted in manholes?
Are manholes free of excessive amounts of grease?
Are manholes free of excessive roots?
Are manholes free of excessive sand?
Are manhole vents screened?
Are vents free of submergence?
Are manholes free of bypass structures or pipes?
Comment:
Pump Stations
Please list the Pump Stations Inspected:
HWY 705, Talc Mine Road, Candor Sunset Drive
# 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?
Were wet wells free of excessive grease/debris?
# Do they all have telemetry installed?
Is the communication 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?
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Page6of7

Permit: WQCS00124 Owner - Facility:Town of Robbins
Inspection Date: 05/17/2022
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
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?
Portable Generators for use in event of power outage.
# 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 Bypass pump at pump station HWY 705.
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Page 7 of 7