WQCS00065_Graham_Collection_System_CEI_Letter_20230404

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
City of Graham
Attn: Frankie Maness, City Manager
P.O. Drawer 357
27253-0357
NORTH CAROLINA
Environmental Quality
April 4, 2023
SUBJECT: Compliance Evaluation Inspection
City of Graham Wastewater Collection System
Wastewater Collection System Permit #: WQCS00065
Alamance County
Ron Boone of the Winston-Salem Regional Office (WSRO) of the NC Division of Water Resources (DWR
or the Division), conducted a compliance evaluation inspection of the City of Graham's wastewater
collection system on March 20th, 2023. Mr. Boone met with Kenneth Hill and Shelby Smith, for the
inspection. Inspection findings are summarized below and detailed in the attached compliance inspection
report.
Mr. Boone noted no violations during the inspection. There were minor documentation issues that Mr. Hill
was able to correct before Mr. Boone completed the inspection report such as documentation of the review
of all logs and records, and documentation of the annual general observation of the entire system. Mr.
Boone reviewed the corrective actions and found them to be sufficient and in compliance with permit
requirements.
No further action is required, however, you are reminded that in accordance with NC General Statute 143-
215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000) may be assessed by the
Secretary of the Division of Water Resources against any person who is required but fails to apply for or to
secure a permit required by NCGS 143-215.1, or who violates or fails to act in accordance with the terms,
conditions, or requirements of such permit.
If you have any questions or concerns, please contact Mr. Boone by phone at 336.776.9690 or by email at
[e-mail]. Thank you for your time and immediate attention to these issues.
Sincerely,
DocuS�ig{<
ned by: /
145B49E225C94EA...
Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
Attachments:
Compliance Inspection Report
DffNorth Carolina Department of Environmental Quality I Division of Water Resources
oan caaouNn
Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105
M336.776.9800
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Compliance Inspection Report
Permit: WQCS00065 Effective: 02/01/15 Expiration: 01/31/23 Owner: City of Graham
SOC: Effective: Expiration: Facility: Graham Collection System
County: Alamance 105 W Parker St
Region: Winston-Salem
Graham NC 272530357
Contact Person: Victor Ray Quick Title: Phone: [phone]
Directions to Facility:
System Classifications: CS2,
Primary ORC: Kenneth Lee Hill
Secondary ORC(s):
On -Site Representative(s):
Certification: 1012312 Phone: [phone]
Related Permits:
NC0021211 City of Graham - Graham WWTP
NC0023876 City of Burlington - Southside WWTP
Inspection Date: 03/20/2023 Entry Time 09:OOAM
Primary Inspector: Ron Boone DocuSigned by:
onaecl Boom 4/3/2023
Secondary Inspectors):
EB20F8DD5F2A3460...
Exit Time: 01:OOPM
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Collection System Inspect Non Sampling
Permit Inspection Type: Collection system management and operation
Facility Status: Compliant Not Compliant
Question Areas:
Miscellaneous Questions General Sewer & FOG Ordinances
Capital Improvement Plan Map Reporting Requirements
Inspections Spill Response Plan Spills
Lines Manholes Pump Stations
(See attachment summary)
Page 1 of 7

Permit: WQCS00065 Owner - Facility: City of Graham
Inspection Date: 03/20/2023 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Inspection Summary:
Ron Boone of the Winston-Salem Regional Office (WSRO) of the NC Division of Water Resources (DWR or the Division),
conducted a compliance evaluation inspection of the City of Graham's wastewater collection system on March 20th, 2023.
Mr. Boone met with Kennith Hill and Shelby Smith, for the inspection. Inspection findings are summarized below and
detailed in the attached compliance inspection report.
Mr. Boone noted no violations during the inspection. There were minor documentation issues that Mr. Hill was able to
correct before Mr. Boone completed the inspection report such as documentation of the review of all logs and records and
documentation of the annual general observation of the entire system. Mr. Boone reviewed the corrective actions and found
them to be sufficient and in compliance with permit requirements.
No further action is required, however, you are reminded that in accordance with NC General Statute 143-215.6A, a civil
penalty of not more than twenty-five thousand dollars ($25,000) may be assessed by the Secretary of the Division of Water
Resources against any person who is required but fails to apply for or to secure a permit required by NCGS 143-215.1, or
who violates or fails to act in accordance with the terms, conditions, or requirements of such permit.
If you have any questions or concerns, please contact Mr. Boone by phone at 336.776.9690 or by email at
[e-mail]. Thank you for your time and immediate attention to these issues.
Page 2 of 7

Permit: WQCS00065 Owner - Facility: City of Graham
Inspection Date: 03/20/2023 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
General Yes No NA NE
Is there a properly designated primary ORC and at least one back-up of proper grade? 0 ❑ ❑ ❑
Are logs being reviewed by the system management or owner on a regular basis? 0 ❑ ❑ ❑
# What is that frequency? As generated
# Are there any issues being addressed currently or any in the planning stages? 0 ❑ ❑ ❑
Is there a specific pump failure plan available for all pump stations? 0 ❑ ❑ ❑
Does plan indicate if pump parts/new pumps are in spare parts/equipment inventory? 0 ❑ ❑ ❑
Are new/significantly upgraded pump stations equipped with anti -corrosion materials? 0 ❑ ❑ ❑
Does the permittee have a copy of their permit? 0 ❑ ❑ ❑
# Is permit expiring within the next 6 months? 0 ❑ ❑ ❑
If Yes, has the Permittee applied for renewal? 0 ❑ ❑ ❑
Comment: None
Sewer and FOG Ordinances
Yes No NA NE
Is Sewer Use Ordinance (SUO) or other Legal Authority available?
0
❑ ❑ ❑
Does it appear that the Sewer Use Ordinance is enforced?
0
❑ ❑ ❑
Is there a Grease Control Program that legally requires grease control devices?
0
❑ ❑ ❑
What is the standard grease trap cleaning requirement in the FOG ordinance?
3 months for
exterior
traps,
monthly for interior
traps
Is Grease Control Program enforced via periodic inspections/records review?
0
❑ ❑ ❑
Is action taken against violators?
0
❑ ❑ ❑
# Have satellite systems adopted an equivalent or more stringent ordinance?
0
❑ ❑ ❑
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?
0
❑ ❑ ❑
If Yes, what are they? (This can reduce mailing to annual.)
Other distribution opportunities such as when new tenants move into apartment complexes they are given a
newsletter that educates them on the proper disposal of oil and grease.
Comment: None
Capital Improvement Plan Yes No NA NE
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? ❑ ❑ ❑
Page 3 of 7

Permit: WQCS00065 Owner - Facility: City of Graham
Inspection Date: 03/20/2023 Inspection Type : Collection System Inspect Non Sampling
Reason for Visit: Routine
Comment: 2022-2027: $29.855 million
Map
Yes No NA NE
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
0
❑ ❑ ❑
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: None
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? Website
Comment: None
Inspections
Yes No NA NE
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?
0
❑ ❑ ❑
# 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: None
Spill Response Action Plan Yes No NA NE
Is a Spill Response Action Plan available? 0 ❑ ❑ ❑
Page 4 of 7

Permit: WQCS00065 Owner - Facility: City of Graham
Inspection Date: 03/20/2023 Inspection Type : Collection System Inspect Non Sampling
Reason for Visit: Routine
Is a Spill Response Action Plan available for all personnel?
0
❑ ❑ ❑
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: None
$pills Yes No NA NE
Is system free of known points of bypass? 0 ❑ ❑ ❑
If No, describe type of bypass and location
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 ❑
Comment: None
Lines/Right-of-Ways/Aerial Lines Yes No NA NE
Please list the Lines/Right of Ways/Aerial Lines Inspected:
36.048145,-79.3755 (aerial, —220' of 8" ductile iron pipe); 36.058611,-79.414162 (aerial, —18' of 24" ductile
iron pipe); 36.0571,-79.414818 (aerial, —160' of 8" ductile iron pipe)
Are right-of-ways/easements maintained for full width for access by staff/equipment? 0 ❑ ❑ ❑
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? 0 ❑ ❑ ❑
Comment: None
Manholes Yes No NA NE
Please list the Manholes Inspected:
None
Are manholes accessible? ❑ ❑ ❑
# Are manhole covers/vents above grade? ❑ ❑ ❑
Are manholes free of visible signs of overflow? ❑ ❑ ❑
Are manholes free of sinkholes and depressions? ❑ ❑ ❑
Page 5 of 7

Permit: WQCS00065 Owner - Facility: City of Graham
Inspection Date: 03/20/2023 Inspection Type : Collection System Inspect Non Sampling
Reason for Visit: Routine
Are manhole covers present?
0
❑ ❑ ❑
# Are manholes properly seated?
0
❑ ❑ ❑
# 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?
0
❑ ❑ ❑
Are manholes free of bypass structures or pipes?
0
❑ ❑ ❑
Comment: None
Pump Stations
Yes No NA NE
Please list the Pump Stations Inspected:
Haw River Pump Station, Boyd Creek Pump Station, and Pyrtle Drive Pump Station
# 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?
5
# A simple one-way telemetry/communication system (auto -dialer) installed?
1
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 communication system functional?
0
❑ ❑ ❑
Is a 24-hour notification sign posted ?
0
❑ ❑ ❑
Does the sign include:
Owner Name?
0
❑ ❑ ❑
Pump station identifier?
0
❑ ❑ ❑
# Address?
0
❑ ❑ ❑
Instructions for notification?
0
❑ ❑ ❑
24-hour emergency contact numbers?
0
❑ ❑ ❑
Are audio and visual alarms present?
0
❑ ❑ ❑
Page 6 of 7

Permit: WQCS00065 Owner - Facility: City of Graham
Inspection Date: 03/20/2023 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?
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?
Comment: None
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Page 7 of 7