WQCS00195_Ramseur_Collection_System_CEI_Letter_&_NOI_NOV2023PC0122_20230403

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
April 3, 2023
CERTIFIED MAIL 7020 3160 0002 0860 9925
RETURN RECEIPT REQUESTED
Town of Ramseur
Attn: Vicki Caudle, Mayor
P.O. Box 545
Ramseur, NC 27316-0545
SUBJECT: Compliance Evaluation Inspection and Notice of Violation with Intent to Enforce
NOV #: NOV-2023-PC-0122
Town of Ramseur Wastewater Collection System
Wastewater Collection System Permit #: WQCS00195
Randolph County
Dear Ms. Caudle:
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 Town of Ramseur's
wastewater collection system on March 13th, 2023. Mr. Boone met with Arnold Allred, Jason Helton,
and Greg Kenyon. Inspection findings are summarized below and detailed in the attached compliance
inspection report.
Violations noted by Mr. Boone during the inspection were:
1. The Town's fats, oils, and grease control program is insufficient pursuant to permit condition
L4. Fourteen facilities with grease traps have been identified within the collection system, but
there are no records of grease trap inspections and/or their proper maintenance. A town -wide
survey should be conducted to determine if there are other, not yet identified grease traps and/or
if there may be other establishments that need grease traps but do not currently have them.
2. No capital improvement plan (CIP) has been developed as required by permit condition L5.
3. The pump station signs do not contain all the information required under permit condition L 8.
4. Permit condition H.2. requires operators to regularly review all logs and records, but such
reviews are not documented as required by permit condition 111.1.
5. Permit condition IHI L requires that all records be kept for a minimum of three years. Three
years of the required records were not available for inspection by the Division.
6. There are multiple maps that contain much of the required information, but not ALL required
information is available as required by permit condition 111.3.
7. Not all high priority lines have been properly identified and inspected as required by permit
condition T. 4. During the inspection the town had a list of seven high priority lines, but
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
oep.m.m or em�nmen� Qualm

discussions amongst the three operators present during the inspection revealed the existence of
several others, which to date have not been documented.
8. The pump station contingency plans need to be properly posted and made available to all
personnel, as well as improved to meet the intent of permit condition L 7.
9. The spill response action plan must be made available to all personnel, as well as updated and
improved to demonstrate compliance with permit condition 11.8.
10. The annual general observation of the system required pursuant to permit condition T.3., has
not been documented as required by permit condition 111.1.
Other items of concern that Mr. Boone noted during the inspection were:
1. A copy of the facility's current collection system permit was not available during the inspection.
2. Nine of the 11 pump stations are served by two portable generators None of the nine have quick
connect fittings specific to the two portable generators and would therefore need to be
hardwired into the pumpstation's control systems in the event of a power outage.
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, ore
requirements of such permit.
As such you must take immediate steps to correct the violations noted above. Please reply in writing
to this notice within 10 days of receiving it. Your written response should detail the corrective actions
you have taken and/or plan to take to correct each of the listed violations. If you anticipate corrective
actions taking longer than 10 days, you must provide an estimated completion date for each corrective
action that takes longer than 10 days to complete. Failure to reply in writing, as directed, or to
satisfactorily correct the listed violations, may result in a recommendation by this office to proceed
with the above -mentioned enforcement procedures.
If you have any questions or concerns, please contact Mr. Boone by phone at 336.776.9690 or by email
at ron.boone&ncdenr.gov. Thank you for your time and immediate attention to these issues.
Sincerely,
EDocuSigned by:
L-oti 'C. t >-Alcr
145B49E225C94EA...
Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
Attachments:
Compliance Inspection Report
REQ� North Carolina Department ofEnvironmental Quality I Division ofWater Resources
Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Winston-Salem, North Carolina 27105
NORTH CAROLINA 336.776.9800
onparhnem of EmironmanW 9uallly

Compliance Inspection Report
Permit: WQCS00195 Effective: 07/12/21 Expiration: 06/30/29 Owner: Town of Ramseur
SOC: Effective: Expiration: Facility: Ramseur Collection System
County: Randolph PO Box 545
Region: Winston-Salem
Ramseur NC 273160545
Contact Person: Vicki Caudle Title: Mayor Phone: [phone]
Directions to Facility:
System Classifications: CS2,
Primary ORC: Arnold Eugene Allred
Secondary ORC(s):
On -Site Representative(s):
Certification: 25366 Phone:[phone]
Related Permits:
NC0026565 Town of Ramseur - Ramseur WWTP
Inspection Date: 03/13/2023 Entry Time 11:OOAM Exit Time: 02:OOPM
Primary Inspector: Ron Boone Docusigned by: Phone: [phone]
Secondary Inspector(s): ,O* aed Boo.,,e, 3/30/2023
B20F8DD5F2A3460...
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 8

Permit: WQCS00195 Owner - Facility: Town of Ramseur
Inspection Date: 03/13/2023 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 Town of Ramseur's wastewater collection system on March 13th, 2023.
Mr. Boone met with Arnold Allred, Jason Helton, and Greg Kenyon. Inspection findings are summarized below and detailed
in the attached compliance inspection report.
Violations noted by Mr. Boone during the inspection were:
1. The Town's fats, oils, and grease control program is insufficient pursuant to permit condition 1.4. Fourteen facilities with
grease traps have been identified within the collection system, but there are no records of grease trap inspections and/or
their proper maintenance. A town -wide survey should be conducted to determine if there are other, not yet identified grease
traps and/or if there may be other establishments that need grease traps but do not currently have them.
2. No capital improvement plan (CIP) has been developed as required by permit condition 1.5.
3. The pump station signs do not contain all the information required under permit condition 1.8.
4. Permit condition 11.2. requires operators to regularly review all logs and records, but such reviews are not documented as
required by permit condition 111.1.
5. Permit condition 111.1. requires that all records be kept for a minimum of three years. Three years of the required records
were not available for inspection by the Division.
6. There are multiple maps that contain much of the required information, but not ALL required information is available as
required by permit condition 111.3.
7. Not all high priority lines have been properly identified and inspected as required by permit condition VA. During the
inspection the town had a list of seven high priority lines, but discussions amongst the three operators present during the
inspection revealed the existence of several others, which to date have not been documented.
8. The pump station contingency plans need to be properly posted and made available to all personnel, as well as
improved to meet the intent of permit condition 1.7.
9. The spill response action plan must be made available to all personnel, as well as updated and improved to demonstrate
compliance with permit condition 11.8.
10. The annual general observation of the system required pursuant to permit condition V.3., has not been documented as
required by permit condition 111.1.
Other items of concern that Mr. Boone noted during the inspection were:
1. A copy of the facility's current collection system permit was not available during the inspection.
2. Nine of the 11 pump stations are served by two portable generators, and no evaluation has been conducted to determine
if they could sustain all pump stations in the event of a town -wide power outage. None of the nine have quick connect fittings
specific to the two portable generators and would therefore need to be hardwired into the pumpstation's control systems in
the event of a power outage. These requirements are specified in chapter 2, subchapter T, section .0300 of the NC
Administrative Code.
Page 2 of 8

Permit: WQCS00195 Owner - Facility: Town of Ramseur
Inspection Date: 03/13/2023 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: Pump station contingency plan is somewhat deficient. It should list points of contact and/or
suppliers for the specific pumps installed at each station as well as where pumps can be taken
for repair, and contractors who would be contacted to get electrical services, plumbing
services, pumping services, etc. It should also indicate what actions to take to determine the
root cause of failure and the actions to take to begin the repair/recovery process. It should also
list town points of contact of those who need to know about failures and can assist in recovery.
The Division of Water Resources should also be listed in case a failure results in a spill of any
amount.
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.)
Website
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
■❑❑❑
Not evaluated
Comment: Inspections of grease traps are not completed regularly and inspections are not currentl
documented. There may be other facilities is town that would require a grease trap. It is
documented that FOG educational materials were distributed twice in 2021, twice in 2022, and
once so far in 2023.
Capital Improvement Plan Yes No NA NE
Has a Capital (CIP) or System Improvement Plan been developed and adopted? ❑ 0 ❑ ❑
Is it designated for wastewater only or does it have a dedicated section?
❑■❑❑
Page 3 of 8

Permit: WQCS00195 Owner - Facility: Town of Ramseur
Inspection Date: 03/13/2023 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Does CIP cover three to five year period of earmarked improvements? ❑ 0 ❑ ❑
Does CIP include description of project area? ❑ 0 ❑ ❑
Does CIP include description of existing facilities? ❑ 0 ❑ ❑
Does CIP include known deficiencies? ❑ 0 ❑ ❑
Does CIP include forecasted future needs? ❑ 0 ❑ ❑
Comment: The town does NOT currently have a complete CIP as required by the permit. The town has
contracted with Carolina Technical Services to install SCADA systems in all 11 pump stations.
The Town has also received an AIA grant which will be used for mapping, smoke testing, and a
rate study. The previous ORC established a budget place holder of $400,000 for the collection
system. A CIP must be developed.
Map Yes No NA NE
Is there a overall sewer system map? 0 ❑ ❑ ❑
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? 0 ❑ ❑ ❑
Comment: The town has a few different maps and each one has different information. Most, but NOT ALL,
of the permit required information, is on the current maps.
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? N/A
Comment: None
Inspections Yes No NA NE
Are adequate maintenance records maintained? 0 ❑ ❑ ❑
Are pump stations being inspected at the required frequency? 0 ❑ ❑ ❑
# Is at least one complete functionality test conducted weekly per pump station? 0 ❑ ❑ ❑
Page 4 of 8

Permit: WQCS00195 Owner - Facility: Town of Ramseur
Inspection Date: 03/13/2023 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
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? 0 ❑ ❑ ❑
Comment: The town has experienced much turn over in the ORC/BORC positions. The positions have
been filled over the years by contractors as well as town employees. A large amount of the
required documentation was lost when these changes were made. Some of the older
documentation is still available and new documentation has been being produced since the
town took over operations again a few years back. But not ALL required documentation is
available.
Spill Response Action Plan Yes No NA NE
Is a Spill Response Action Plan available? ❑ ❑ ❑
Is a Spill Response Action Plan available for all personnel? ❑ ❑ ❑
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? 0 ❑ ❑ ❑
Comment: Not all spill records for the past three years were available on site. Some details of the spill
plan must be updated.
Spllls 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? ❑ ❑ ❑
# Are there repeated overflows/problems (2 or more in 12 months) at same location? ❑ ❑ ❑
# If Yes, is there a corrective action plan? ❑ ❑ 0 ❑
Comment: None
Lines/Right-of-Ways/Aerial Lines Yes No NA NE
Page 5 of 8

Permit: WQCS00195 Owner - Facility: Town of Ramseur
Inspection Date: 03/13/2023 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Please list the Lines/Right of Ways/Aerial Lines Inspected:
Old Mill Aerial #1 - 160' of 8" ductile iron pipe, in good condition but a small diameter tree has fallen on it. It
does not appear to have damaged the pipe.
Old Mill Aerial #2 - 30' of 8" ductile iron pipe, good condition.
Steel Street Outfall - very well maintained, no concerns.
Salisbury Street subwaterway crossing - approximately 20' long, no obvious damage or problems.
Salisbury Street aerial - line actually passes thru the creek. It appears to be sound and in good condition.
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? 0 ❑ ❑ ❑
Are gravity sewer cleaning records available? 0 ❑ ❑ ❑
Has at least 10% of lines older than 5 yrs been cleaned annually? 0 ❑ ❑ ❑
Were all areas/lines inspected free of issues? 0 ❑ ❑ ❑
Comment: The town has done some cleaning itself and contracted some cleaning to Pit Busters, LLC.
Records are not complete but it appears the required amount of cleaning has been completed.
The town MUST concentrate and strive to keeD better records of the line cleanina activities.
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?
❑ ❑ ❑
Are manhole covers present?
❑ ❑ ❑
# 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: No manholes were opened during the inspection.
Pump Stations Yes No NA NE
Please list the Pump Stations Inspected:
Megan Drive pump station, Tube pump station, and West Ridge pump station
# Number of duplex or larger pump stations in system 11
Page 6 of 8

Permit: WQCS00195 Owner - Facility: Town of Ramseur
Inspection Date: 03/13/2023 Inspection Type : Collection System Inspect Non Sampling
Reason for Visit: Routine
# 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?
5
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
❑ ❑ ❑
Are audio and visual alarms operable?
0
❑ ❑ ❑
# Is there a backup generator or bypass pump connected?
❑
0 ❑ ❑
If tested during inspection, did it function properly?
❑
❑ 0 ❑
Is the back-up system tested at least bi-annually under normal operating conditions?
0
❑ ❑ ❑
# Does it have a dedicated connection for a portable generator?
❑
0 ❑ ❑
# Is the owner relying on portable units in the event of a power outage?
0
❑ ❑ ❑
# If Yes, is there a distribution plan?
❑
0 ❑ ❑
If Yes, what resources (Units/Staff/Vehicles/etc) are included in Plan?
There are only two onsite permanently installed generators at the Tube station and the West Ridge station.
There are two portable generators for use at the other 9 pump stations. None of the other 9 pumpstations are
equipped for quick connect to the portable units. No evaluation of whether the two generators would suffice in
the event of a town -wide power outage has been conducted. All of the pump station signs must be updated
because they contain information for the former ORC. The current signs also do NOT contain all the
information required by the permit. Please refer to the permit to ensure the signs contain all the required
information. Only two of the 11 pump stations are fully fence and gated. Two of the remaining 9 have a locked
gate which can be simply walked around. All do have locked access points and control boxes.
# Does Permittee have the approved percentage of replacement simplex pumps? 0 ❑ ❑ ❑
Is recordkeeping of pump station inspection and maintenance program adequate? 0 ❑ ❑ ❑
Do pump station logs include at a minimum:
Page 7 of 8

Permit: WQCS00195 Owner - Facility: Town of Ramseur
Inspection Date: 03/13/2023 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
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
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Page 8 of 8