WQCS00112_Pilot_Mountain_Collection_System_NOI_NOV2-23PC0120_20230329

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
April 6, 2023
CERTIFIED MAIL 7020 3160 0002 0860 9932
RETURN RECEIPT REOUESTED
Town of Pilot Mountain
Attn: Michael Boaz, Town Manager
124 West Main Street
Pilot Mountain, NC 27041
SUBJECT: Compliance Evaluation Inspection and Notice of Violation with Intent to Enforce
NOV #: NOV-2023-PC-0133
Town of Pilot Mountain Wastewater Collection System
Wastewater Collection System Permit #: WQC SOO 112
Surry County
Dear Mr. Boaz:
Ron Boone and Jesse Barnes, 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 Pilot Mountain's wastewater collection system on March 17'h, 2023. Mr. Boone and Mr.
Barnes met with operators James Utt and Brandon Cooke. Inspection findings are summarized
below and detailed in the attached compliance inspection report.
Violations noted by Mr. Boone during the inspection were:
1. FOG educational and enforcement documentation, as required by permit condition L4.,
was not available during the inspection.
2. A capital improvement plan (CIP), as required bypermit condition L5. was not available
for review during the inspection.
3. Pump station signs have not been updated with all information required by permit
condition L 8.
4. Review of records, as required bypermit condition H 2., is not sufficiently documented as
required bypermit condition HIL
5. Six of the 20 pump stations only have one pump currently installed, a violation ofpermit
conditions L 7 & H 5. This is a continued violation since 2019.
6. Pump station inspection logs do not include all required items pursuant to permit condition
H.4.
7. Some pump station audible/visible alarms were inoperable during the inspection, a
violation of permit condition L10.
North C lina Department ofEnvironmental Quality I Division ofWater Resources
Winston-Salem Regional Office 1450 W. Hanes Mill Rd, Suite 300 1 Winston-Salem, North Carolina 27105
336.776.9800

8. It was not demonstrated during the inspection that the system map shows all required
information pursuant to permit condition 111. 3.
9. High priority lines (HPL) have not been properly identified and inspected as required
pursuant to permit condition V 4., and the inspections and maintenance of the HPLs have
not been properly documented in accordance with permit condition 1111.
10. Right-of-way maintenance is not sufficiently documented in accordance with permit
condition 1111.
11. Documentation of annual line cleaning does not sufficiently meet requirements of permit
condition 118.
12. The annual general observation of the system, as required bypermit condition V3., is not
documented as required bypermit condition 1111.
13. A sewer use ordinance was not available during the inspection, as required by permit
conditions L3.
14. A spill response action plan, as required byperm it condition IL 9., was not available during
the inspection.
Other items of concern that Mr. Boone noted during the inspection were:
I . A copy of the facility's current collection system permit was not available during the
inspection.
2. Some of the perimeter fences located at the pump stations visited during the inspection
need repair to be compliant with permit condition L9.
3. Only two of the 20 pump stations have permanent onsite installed generators. There is only
one portable genset for the other 18 stations and not all 18 stations have quick connect
connectors installed that are specific to the portable genset. There is also no distribution
plan/evaluation to assess the single portable generator's ability to support all 18 stations in
the event of a town -wide power outage.
Mr. Boaz contacted Mr. Boone on March 2 1 st, 2023, and was able to provide some documentation
as listed below:
I . A CIP, but it does not meet all requirements ofpermit condition L5.
2. Some FOG related materials, but they do not demonstrate full compliance with permit
conditions L3., L4., andIII.I.
3. One pump station contingency plan, which if a similar template is used for all pump stations,
is sufficient to meet the intent ofpermit condition L 7.
4. An overall map of the town's wastewater collection system, which includes most of the
information required by permit condition 1113.
5. According to an email from Mr. Boaz to Mr. Boone on March 21", 2023, Mr. Boaz is
currently working toward identifying all HPLs in the Pilot Mountain collection system and
trying to gather all of the town's existing HPL inspection records.
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.
2�
e,�­oREQ�
North Carolina Department ofEnvironmental Quality I Division ofWater Resources
Winston-Salem Regional Office 1450 W. Hanes Mill Rd, Suite 300 1 Winston-Salem, North Carolina 27105
336.776.9800

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(&ncdenrjzov. Thank you for your time and immediate attention to these issues.
Sincerely,
EDocuSigned by:
'T. 15-Alcr
-"49E225C94EA..
Lon T . Snider, Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
Attachments:
Compliance Inspection Report
North Carolina Department ofEnvironmental Quality I Division ofWater Resources
Winston-Salem Regional Office 1450 W. Hanes Mill Rd, Suite 300 1 Winston-Salem, North Carolina 27105
e,�­#REQ�
n_�.m � �.­w 336.776.9800

Compliance Inspection Report
Permit: WQCS00112 Effective: 04/01/17 Expiration: 03/31/25 Owner : Town of Pilot Mountain
SOC: Effective: Expiration: Facility: Pilot Mountain Collection System
County: Surry 126 W Main St
Region: Winston-Salem Pilot Mountain NC 27041
Contact Person: Ronald Holt Title: Public Works Dir Phone: [phone]
Directions to Facility:
System Classifications: CS1,
Primary ORC: James R Utt
Secondary ORC(s):
On -Site Representative(s):
Certification: 1012047 Phone: [phone]
Related Permits:
NCO026646 Town of Pilot Mountain - Pilot Mountain WWTP
Inspection Date: 03/17/2023 Entry Time 09:OOAM Exit Time: 12:OOPM
Primary Inspector: Ron Boone DocuSigned by: 4/6/2023 Phone: [phone]
Secondary Inspector(s): Bolorve,
E?B20F8DD5F2A3460...
Jesse Barnes
Reason for Inspection: Routine Inspection Type: Collection System Inspect Non Sampling
Permit Inspection Type: Collection system management and operation
Facility Status: E] 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: WQCS00112 Owner - Facility: Town of Pilot Mountain
Inspection Date: 03/17/2023 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Inspection Summary:
Ron Boone and Jesse Barnes, 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 Pilot Mountain's wastewater collection system
on March 17th, 2023. Mr. Boone and Mr. Barnes met with operators James Utt and Brandon Cooke. Inspection findings are
summarized below and detailed in the attached compliance inspection report.
Violations noted by Mr. Boone during the inspection were:
1. No FOG educational or enforcement program has been developed, implemented, or documented as required by permit
conditions 1.3., 1.4., and 111.1.
2. No capital improvement plan (CIP) has been developed as required by permit condition 1.5.
3. Pump station signs must be updated with current information and include all information required by permit condition 1.8.
4. It is believed that operators do regularly review all logs and documentation as required by permit condition 11.2., but
reviews these reviews are not being documented as required by permit condition 111.1.
5. Six of the 20 pump stations only have one pump currently installed, which is a major improvement from the previous
inspection, but still violations of permit conditions 1.7 & 11.5.
6. Only two of the 20 pump stations have permanent onsite installed generators. There is only portable genset for the other
18 stations and not all 18 stations have quick connect connectors installed that are specific to the portable generator. There
is also no distribution plan/evaluation to assess the single portable generator's ability to support all 18 stations in the event
of a town -wide power outage. These conditions constitute violations of NC Administrative Code 15A NCAC 02T.0305(h)(1)(B
& (C).
7. Pump station inspection logs do NOT include all permit required items pursuant to permit condition 11.4.
8. Not all station's audible/visible alarms were operational or sufficiently loud and/or visible during the inspection, as
required by permit condition 1.10.
9. There are multiple maps that contain much of the required information, but it was not demonstrated during the inspection
that ALL required information is available pursuant to permit condition 111.3.
10. High priority lines (HPL) have not been properly identified and inspected as required pursuant to permit condition VA.
and the inspections and maintenance of the HPLs has not been properly documented in accordance with permit condition
111.1.
11. Not all right-of-ways are documented as required by permit condition 11.7. and not all right-of-way maintenance is
documented in accordance with permit condition 111.1.
12. Line cleaning documentation is NOT demonstrative of the town completing all cleaning required by permit condition 11.8.
13. Although the inspector noted no conditions during the inspection that demonstrate that the annual general observation of
the system, as required by permit condition V.3., is not being done, the activity is NOT being documented as required by
permit condition I 11. 1.
14. Neither a sewer use nor a FOG ordinance was available during the inspection, as required by permit conditions 1.3. and
1.4., respectively.
15. A spill response action plan, as required by permit condition 11.9., was not available during the inspection.
Other items of concern that Mr. Boone noted during the inspection were:
1. No one had access to a current copy of the town's collection system permit.
2. Some of the perimeter fences located at the pump stations visited during the inspection need repair permit condition 1.9.
3. The town's map is currently being digitized but operators only have access to it through mobile devices, not computers.
It is noted that Mr. Boaz did contact Mr. Boone on March 21st, 2023. Mr. Boaz was able to provide some of the required
documentation as listed below:
1. A CIP that does NOT currently meet all requirements of permit condition 1.5.
2. Some FOG related materials, which still do not demonstrate full compliance with permit conditions 1.3., 1.4., and 111.1.
3. A pump station contingency plan, which if a similar template is used for all pump stations, is sufficient to meet the intent
of permit condition 1.7.
Page 2 of 8

Permit: WQCS00112 Owner - Facility: Town of Pilot Mountain
Inspection Date: 03/17/2023 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
4. An overall map of the town's wastewater collection system, which includes most of the information required by permit
condition 111.3.
5. According to an email from Mr. Boaz to Mr. Boone on March 21st, 2023, Mr. Boaz is currently working toward
identifying all HPLs in the Pilot Mountain collection system and trying to gather all of the town's existing HPIL inspection
records.
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
[e-mail]. Thank you for your time and immediate attention to these issues.
Page 3 of 8

Permit: WQCS00112 Owner - Facility: Town of Pilot Mountain
Inspection Date: 03/17/2023 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
1:11:1 1:1
Are logs being reviewed by the system management or owner on a regular basis?
0
E] 1:1 1:1
# What is that frequency?
As generated
# Are there any issues being addressed currently or any in the planning stages?
0
E] El El
Is there a specific pump failure plan available for all pump stations?
0
E] El El
Does plan indicate if pump parts/new pumps are in spare parts/equipment inventory?
0
El El El
Are new/significantly upgraded pump stations equipped with anti -corrosion materials?
0
El El El
Does the permittee have a copy of their permit?
El
0 El El
# Is permit expiring within the next 6 months?
El
0 El El
If Yes, has the Permittee applied for renewal?
El
El 0 El
Comment: Loqs are reviewed as thev are qenerated but the reviews are NOT documented. A Pum
station contingency plan was present at each of the six stations visited during the inspection.
It's unknown whether they are posted at the other 14 stations but operators indicated that they
are. The operators did NOT have a copy of the perimt but they believe the town manager,
Michael Boaz, likely has one.
Sewer and FOG Ordinances Yes No NA NE
Is Sewer Use Ordinance (SUO) or other Legal Authority available? E] 0 El El
Does it appear that the Sewer Use Ordinance is enforced?
El
0 El El
Is there a Grease Control Program that legally requires grease control devices?
El
0 El El
What is the standard grease trap cleaning requirement in the FOG ordinance?
N/A
Is Grease Control Program enforced via periodic inspections/records review?
El
0 El El
Is action taken against violators?
El
0 El El
# Have satellite systems adopted an equivalent or more stringent ordinance?
El
El 0 El
Is grease/sewer education program documented with req'd customer distribution?
El
0 El El
# Are other types of education tools used like websites, booths, special meetings, etc?
El
0 El El
If Yes, what are they? (This can reduce mailing to annual.)
Comment: The ordinances were not available durina the inspection. The town should provide access to its
ordinances for sewer use and FOG control to the Division for review as part of their response
to this inspection report. The operators are aware that grease traps exist in the collection
system but an inventory and regular inspection schedule for them is not developed or
implemented. The current state of existing grease traps is unknown and it is unknown whether
others are needed where they currently do not exist at FOG producing establishments.
Capital Improvement Plan Yes No NA NE
Has a Capital (CIP) or System Improvement Plan been developed and adopted? 1:1 0 1:11:1
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?
Page 4 of 8

Permit: WQCS00112 Owner - Facility: Town of Pilot Mountain
Inspection Date: 03/17/2023 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Does CIP include description of existing facilities?
Does CIP include known deficiencies?
Does CIP include forecasted future needs?
El 0 El El
El 0 El El
El 0 El El
Comment: Operators were NOT aware durinq the inspeciton of the existence of a CIP althouqh thev are
aware of future plans and efforts for collection system improvement. The town should provide
access to its CIR if one exists, to the Division for review as part of their response to this
inspection report.
Map Yes No NA NE
Is there a overall sewer system map? 0 El El E-1
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? El El El 0
Comment: There are several different maps and each contains different data sets. The operators
indicated that the town's collection system is current being mapped using GIS software. Not all
currently existing maps were availabe during the inspection to allow the inspectors to conclude
whether a complete data set for each data category is currently in the town's possession.
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?
Comment: The town reported two overflows in 2017, two in 2018, two in 2019, one in 2020, and none
since. The operators did NOT have access during the inspection to the last three years of
overflow records.
Inspections Yes No NA NE
Are adequate maintenance records maintained? E] 0 1:1
Are pump stations being inspected at the required frequency?
# Is at least one complete functionality test conducted weekly per pump station?
Page 5 of 8

Permit: WQCS00112 Owner - Facility: Town of Pilot Mountain
Inspection Date: 03/17/2023 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? El 0 El El
Is the annual inspection documented? El 0 El El
# Does the system have any high -priority lines/locations? 0 El El El
Are inspections of HPL documented at least every 6 months? El 0 El 0
Are new lines being added to the HPIL list when found or created? 0 El El 0
Comment: There were either no records, or incomplete records of FOG education/enforcement
right-of-way inspection/maintenance, high priority line inspections/maintenance, the annual
system general observation, records review,
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?
Comment: No written spill response plan was available durinq the inspection.
aftiL
Is system free of known points of bypass?
If No, describe type of bypass and location
El El 0 El
El El 0 0
El El 0 El
El El 0 El
El El 0 El
El El 0 El
El El 0 El
El El 0 0
El El 0 El
Yes No NA NE
0 El E] E]
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? El El 0 El
Comment: The town uses an electronically based work order system for complaints and related events
which includes all the data/information required by the permit. This system theoretically be
used for all other permit requirements as well.
Lines/Right-of-Ways/Aerial Lines Yes No NA NE
Please list the Lines/Right of Ways/Aerial Lines Inspected:
None
Are rig ht-of-ways/easements maintained for full width for access by staff/equipment?
If No, give details on temporary access:
Is maintenance documented?
Page 6 of 8

Permit: WQCS00112 Owner - Facility: Town of Pilot Mountain
Inspection Date: 03/17/2023 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Are gravity sewer cleaning records available? 0 El El El
Has at least 10% of lines older than 5 yrs been cleaned annually? El El El 0
Were all areas/lines inspected free of issues? 0 El El El
Comment: Line cleaning records were available but annual totals of line cleaned was NOT readily
available. The town should provide the amount of line cleaned each year for the
past three
years as part of their response to this inspection report. This should include copies of the
records documenting all cleaning.
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?
0
El El El
Comment: Some elevated vents are screened. Manhole cover vent holes are NOT screened and are
submerged if the manholes are flooded.
Pump Stations Yes No NA NE
Please list the Pump Stations Inspected:
Station #13 - JR Lynch; Station #12 - Nelson Street; Station #11 - Fitall; Station #10 - Lower Crestwood;
Station #9 - Upper Crestwood; and, Station #17 - Lola Lane
# Number of duplex or larger pump stations in system 20
# 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? 20
# A simple one-way telemetry/communication system (auto -dialer) installed? 0
Page 7 of 8

Permit: WQCS00112 Owner - Facility: Town of Pilot Mountain
Inspection Date: 03/17/2023 Inspection Type Collection System Inspect Non Sampling
Reason for Visit: Routine
For pump stations inspected:
Are they secure with restricted access?
0
El El El
Were they free of by-pass structures/pipes?
0
El El El
Were wet wells free of excessive grease/debris?
El
0 El 0
# Do they all have telemetry installed?
El
0 El 0
Is the communication system functional?
0
El El 0
Is a 24-hour notification sign posted ?
El
0 El El
Does the sign include:
Owner Name?
0
El El El
Pump station identifier?
0
El El 0
# Address?
El
0 El 0
Instructions for notification?
El
0 El 0
24-hour emergency contact numbers?
El
0 El El
Are audio and visual alarms present?
0
El El El
Are audio and visual alarms operable?
0
El El El
# Is there a backup generator or bypass pump connected?
El
0 El El
If tested during inspection, did it function properly?
El
El 0 El
Is the back-up system tested at least bi-annually under normal operating conditions?
El
0 El El
# Does it have a dedicated connection for a portable generator?
0
El El El
# Is the owner relying on portable units in the event of a power outage?
0
El El El
# If Yes, is there a distribution plan?
El
0 El El
If Yes, what resources (Units/Staff/Vehicies/etc) are included in Plan?
Some stations have only locked access points/panels. Others also have fences and locked gates. Some
fences need repair. Upper Crestwood station has a lot of grease from immediately adjacent tributary
restaurant, indicative of need for FOG control. Signs must be udpated with correct phone numbers and
reporting instructions. Visited stations have audible/visible alarms but not all worked or were sufficiently loud.
Town has 22 stations, including two at wastewater plant. Of the 20 collection system stations, only two have
permanent generators. Town has one portable generator used to support the other 18 stations. Many of the
18 stations have quick connectors for the generator but not all currently have them. No evaluation has been
completed to assess whether the one portable generator could support all 18 generators if a town -wide
power outage occurs. Some of the pump stations do have emergency bypass pumping connections and the
town has access to rental bypass pumps. The town also has a pumper truck.
# Does Permittee have the approved percentage of replacement simplex pumps? El El 0 El
Is recordkeeping of pump station inspection and maintenance program adequate? El 0 El El
Do pump station logs include at a minimum:
Inside and outside cleaning and debris removal? El 0 E] El
Inspecting and exercising all valves? El 0 El El
Inspecting and lubricating pumps and other equipment? El 0 El El
Inspecting alarms, telemetry and auxiliary equipment? El 0 El El
Comment: The pump station logs do NOT currently include all the permit -required items.
Page 8 of 8