WQCS00173_Response to Compliance Inspection_20220926

DocuSign Envelope ID: 8A090D57-BD6D-460E-945A-41E94614029A
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
September 8, 2022
Ms. Justine Jones, Town Manager
Town of Kenly
P.O. Box 220
Tarboro, NC 27886 207 West Second Street
Kenly, North Carolina, 27542
Subject: Compliance Evaluation Inspection
Town of Kenly Sewer Collection System
Collection System Permit No: WQCS00173
Johnston County
Dear Ms. Jones:
On June 23, 2022, Cheng Zhang of the Raleigh Regional (RRO) Office Division of Water Quality
conducted a Compliance Evaluation Inspection of the subject facility. The assistance and cooperation of
Mr. John Pitts, the Town's Public Works Director, during the inspection, were very helpful and
appreciated. A checklist of items is enclosed with this letter. During the inspection the following items
were noted:
1.) The Town's collection system is classified as a Class 2 collection system. It has approximately 2.5
miles of gravity sewer mains, 2.8 miles of force main (length of gravity sewer and force mail
listed on the permit appears in accurate), and 9 pump stations. Kenneth Kopp is the ORC. Adam
Stuckey is listed as the backup ORC in BIMS, the inspector was told that Adam Stuckey no
longer served as the backup ORC, the Town needs to designate a backup ORC.
2.) The Town has a map of the collection system map which does not include the entire system and
connection of satellite system, the map lacks some key required elements, such as flow direction,
pipe sizes, pipe materials, approximate pipe age, pump station ID and capacity, and location of
satellite system connection. The inspector was told that an engineer firm was developing a GIS-
based sewer map.
3.) The Town has developed and implemented a Capital Improvement Plan (CIP) for the sewer system.
Current CIP covers a ten-year period (from 2013 to 2023), the Town is in the process to develop a
new CIP.
4.) The system has 9 pump stations. All stations were equipped with telemetry system. Five pump
stations were visited during this inspection. These pump stations were inspected and maintained as
required by the permit, with exception that the visual alarm at Big Boy Pump Station was not
operable at the time of inspection.
D_E Q 1
NORTH CAROLINA
DeperhneM of Environmental Oual�
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office I 3800 Barrett Drive I Raleigh, North Carolina 27609
919.791.4200

DocuSign Envelope ID: 8A090D57-BD6D-460E-945A-41E94614029A
5.) The Town has a grease control program. Grease traps/interceptors at restaurants and other food
services are inspected once per year. Grease/sewer educational material has not been distributed
at least twice per year as required by the permit (only available documented distribution was
in June 2022).
6.) A review of records and logbooks indicates the following
a) Records are maintained adequately for sewer line maintenance, cleaning, high priority line
inspection, and right of way maintenance. It was noted that 6854 feet of gravity line was
cleaned in 2021, 3618 feet in 2020, which did not meet the annual minimum 10% target (the
Town has about 15.5 mile of gravity sewer, the Town needs to verify the length of gravity
sewer and force main through GIS mapping).
b) Six Sanitary Sewer Overflows (SSOs) were discovered or reported since the last inspection.
7.) The Town has designated 4 high priority/aerial lines; these lines are inspected quarterly. Two high
priority lines were observed during the inspection, these lines were in good condition, the right-of-
way to these high priority lines were maintained and accessible.
Please respond in writing to RRO within 30 days of receipt of this letter regarding Items 1, 4, 5
and 6. If you have any questions regarding the attached report or any of the findings, please contact
Cheng Zhang at: [phone] (or email: [e-mail]).
Sincerely,
DocuSigned by:
Scott l/iA,setA,
BCDA9D825D4A46D...
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources
Attachments: Compliance Inspection Report
Cc: Laserfiche
John Pitts, Town of Kenly (electronic copy only)
D_E
NORTH CARCLINA
gaparhnanl of Environmental quality
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11611 Mail Service Center I Raleigh, North Carolina 27699-1611
919.707.9000

DocuSign Envelope ID: 8A090D57-BD6D-460E-945A-41 E94614029A
Compliance Inspection Report
Permit: WQCS00173 Effective: 11/08/18
SOC: Effective:
County: Johnston
Region: Raleigh
Contact Person: John Raymond Pitts
Directions to Facility:
System Classifications: CS2,
Primary ORC: Kenneth Eugene Kopp
Secondary ORC(s):
On -Site Representative(s):
On -site representative
Related Permits:
Expiration: 10/31/26
Expiration:
Owner : Town of Kenly
Facility: Kenly Collection System
PO Box 519
Title: Public Works Director
Certification: 992411
John Raymond Pitts
NC0064891 Town of Kenly - Kenly Regional WWTP
Inspection Date: 06/23/2022
Primary Inspector: Cheng Zhang
Secondary Inspector(s):
Reason for Inspection: Routine
Permit Inspection Type: Collection
Facility Status: ❑ Compliant
Question Areas:
▪ Miscellaneous Questions
II Capital Improvement Plan
▪ Inspections
▪ Lines
Entry Time 09:30AM
1- DocuSigned by:
D6171508E1 EC41 F...
DocuSigned by:
Scott UVt,seln,
BCDA9D825D4A46D_.
system management and
Not Compliant
(See attachment summary)
Kenly NC 27542
Exit Time: 12:30PM
Phone: [phone]
Phone: [phone]
919-284-9207
Phone: [phone]
9/8/2022
9/8/2022
Inspection Type: Collection System Inspect Non Sampling
operation
▪ General
▪ Map
▪ Spill Response Plan
▪ Manholes
▪ Sewer & FOG Ordinances
▪ Reporting Requirements
▪ Spills
▪ Pump Stations
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DocuSign Envelope ID: 8A090D57-BD6D-460E-945A-41 E94614029A
Permit: WQCS00173 Owner - Facility:Town of Kenly
Inspection Date: 06/23/2022
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Inspection Summary:
See inspection report.
Page 2 of 7

DocuSign Envelope ID: 8A090D57-BD6D-460E-945A-41 E94614029A
Permit: WQCS00173 Owner - Facility:Town of Kenly
Inspection Date: 06/23/2022
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: Contigency plan and spill plan are kept at each pump station.
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.)
Posted on the Town's website and at Town Hall.
Comment: Only documented distribution of grease/sewer educational material was in June, 2022.
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: The CIP covers from 2013 to 2023. New CIP is being developed.
Map
Yes No NA NE
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Monthly
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Yes No NA NE
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As needed
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Yes No NA NE
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DocuSign Envelope ID: 8A090D57-BD6D-460E-945A-41 E94614029A
Permit: WQCS00173 Owner - Facility:Town of Kenly
Inspection Date: 06/23/2022
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: An engineer firm is developing a GIS-based map of the collection system. Town of Micro is the
satellite system.
Reporting Requirements Yes No NA NE
# 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? on the Town's
website
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:
Spill Response Action Plan
Is a Spill Response Action Plan available?
Is a Spill Response Action Plan available for all personnel?
Yes No NA NE
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Yes No NA NE
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DocuSign Envelope ID: 8A090D57-BD6D-460E-945A-41 E94614029A
Permit: WQCS00173 Owner - Facility:Town of Kenly
Inspection Date: 06/23/2022
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
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
Does the Permittee appear to respond within 2 hours of first knowledge of a spill?
Comment: Response time was not specified in the plan.
Spills
Is system free of known points of bypass?
If No, describe type of bypass and location
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:
Lines/Right-of-Ways/Aerial Lines
Please list the Lines/Right of Ways/Aerial Lines Inspected:
Truck Stop Road A and B.
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?
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Yes No NA NE
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Comment: 6854 feet of gravity line was cleaned in 2021, 3618 feet in 2020. The System has about 15.5
miles of gravity line (number on permit was not accurate).
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?
Yes No NA NE
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DocuSign Envelope ID: 8A090D57-BD6D-460E-945A-41 E94614029A
Permit: WQCS00173 Owner - Facility:Town of Kenly
Inspection Date: 06/23/2022
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
# Are manholes properly seated?
# Are manholes in good condition?
# 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:
Public Works; Cottenfield; Little River; Big Boy; Goldsboro St
# 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?
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Yes No NA NE
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DocuSign Envelope ID: 8A090D57-BD6D-460E-945A-41 E94614029A
Permit: WQCS00173 Owner - Facility:Town of Kenly
Inspection Date: 06/23/2022
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
# 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: Visual alarm at Big Boy Lift Station was not operable. Cotten Field Lift station has standby
generator, others has dedicated connections for portable generators.
Page 7 of 7