WQCS00113_Compliance Evaluation Inspection_20231117

DocuSign Envelope ID: 25DC94D4-E2A9-4BF7-9AB2-E9C0461 DD7A6
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
Certified Mail # 7017 2680 0000 2237 3338
Return Receipt Requested
November 17, 2023
Sean Medlin, Town Administrator
Town of Louisburg
110 W. Nash Street
Louisburg, NC 27549
Subject: Notice of Violation and Compliance Evaluation Inspection
Case No.: NOV-2023-PC-0563
Town of Louisburg Sewer Collection System
Collection System Permit No: WQCS00113
Franklin County
Dear Mr. Medlin:
On August 23, 2023, Cheng Zhang and Kevin Fowler 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. Carlton Tabron, and Mr. Mike Ascue, 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 CS-2 system. Current permit became effective on
February 9, 2018, and will expire on September 30, 2024. Mr. Carlton Tabron is the Operators in
Responsible Charge (ORC). Mr. Mike Ascue was designated as backup ORC on August 24, 2023.
2.) The Town has developed and implemented a Capital Improvement Plan covering a period from 2023
through 2033. Description of existing facilities and known deficiencies need to be added to the
CIP.
3.) The Town has maintained a map of the collection system, the following elements need to be added
to the map: approximate pipe age, and force main air release valve location/type.
4.) The system has 7 duplex pump stations. All stations were equipped with SCADA system. Five
pump stations (Prison, Hon, Wolf Pen, Green Hill, and Brithaven) were visited during this
inspection. Pump station logbooks only showed monthly visits to each pump station, permit
requires weekly visit. Documentation of pump station inspections shall include the following
items: 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, as required by 15A NCAC 02T.0108(b) and Section II.3. of the
Collection System Permit. The following issues were noted:
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office I 3800 BarrettDrive I Raleigh, North Carolina 27609
NORTH CAROLINA ^ �/ 919.791.4200
n-o ,Mo E-Nmnm- Wlo--I V

DocuSign Envelope ID: 25DC94D4-E2A9-4BF7-9AB2-E9C0461 DD7AB
• Green Hill Lift Station: one check valve was replaced with straight piping.
• Hon Lift Station: one of two Smith Loveless pumps was out of service, replaced with a
submersible pump.
• Prison Lift Station: standby generator was not operable.
• Manhole rings were not properly seated and secured at the upstream manholes of Hon
Lift Station and Prison Lift Station.
5.) The Town has a Sewer Use Ordinance, which requires users who operate establishments that
prepare, process, or serve food and/or food products to install and maintain grease and oil traps or
other interceptors. It was noted that the Town had not inspected grease traps/interceptors on a
regular basis and taken enforcement actions against violators. The Town must develop a
program to inspect grease traps/interceptors at least annually. Distribution of grease
educational material had not been conducted and documented. 15A NCAC 02T.0108(b)
requires bi-annual distribution of educational materials for both commercial and residential
users, distribution of grease/sewer educational material must be documented.
6.) The Town has developed and implemented a spill response action plan; the plan was adequate.
7.) A review of records and logbooks indicates the following:
a) High priority line inspections and easement maintenance were not documented as required
by Section II.6. and V. 4. The Town must document high priority line inspections, and
easement maintenance in detail.
b) No Sanitary Sewer Overflows (SSOs) were discovered or reported in the past three years.
c) About 26540 feet of gravity sewer were cleaned in 2022, which is more than 10% of the 35 miles
of gravity sewer.
8.) The Town has six designated high priority/aerial lines; three high priority lines were observed during
the inspection, the siphon at S. Main Street and aerial line outside Prison Lift Station were in good
condition. Sewage was found seeping out from the joint section of a tall manhole at Sunrise
Biscuit aerial line (see enclosed photo). The right-of-way to these high priority lines were
maintained and accessible.
9.) The Town's 2022 Wastewater Performance Report was submitted to the inspector after the
inspection. The report does not include the performance of the sewer collection system, which is
required. The Town must submit annual wastewater performance reports to the Division and
make the reports available to all customers (by mailing or posting on the Town's website), as
required by North Carolina General Statute §143-215.1C.
This inspection letter is being issued as a Notice of Violation due to the conditions noted above.
Please respond in writing to RRO within 30 days of receipt of this letter regarding Items 2, 3, 4,
5,7,8,and 9.
D � ��� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CAROLINA ��` 919.707.9000
Onpn .mo EnWromm�nfal nual

DocuSign Envelope ID: 25DC94D4-E2A9-4BF7-9AB2-E9C0461 DD7AB
If you have any questions regarding the attached report or any of the findings, please contact Cheng
Zhang at: [phone] (or email: Cheng [e-mail]. og_v).
Sincerely,
DocuSigned by:
f.
Vaun t,SSa
B2916E6AB32144F...
Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources
Attachments: Compliance Inspection Report
Cc: Laserfiche
Sewage seeping out of a tall manhole at Sunrise Biscuit Aerial Line
D � ��� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CAROLINA ��` 919.707.9000
nnpn .mo EnWromm�nfal nual

DocuSign Envelope ID: 6773F624-D1B2-439C-BE2A-E59E01FB08A6
Compliance Inspection Report
Permit: WQCS00113 Effective: 02/09/18 Expiration: 09/30/24 Owner : Town of Louisburg
SOC: Effective: Expiration: Facility: Louisburg Collection System
County: Franklin 110 W Nash St
Region: Raleigh
Louisburg NC 275492526
Contact Person: Sean Medlin Title: Town Administrator Phone: [phone]
Directions to Facility:
System Classifications: CS2,
Primary ORC: Carlton Earl Tabron
Secondary ORC(s):
On -Site Representative(s):
Certification: 16193 Phone:[phone]
Related Permits:
NC0020231 Town of Louisburg - Louisburg Water Reclamation Facility
Inspection Date: 08/23/2023
Entry Time 09:30AM Exit Time:
12:30PM
Primary Inspector: Cheng Zhang
DocuSigned by:
Phone: [phone]
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Secondary Inspectors):
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Kevin Fowler DocuSigned by:
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Reason for Inspection: Routine
Inspection Type:
Collection System Inspect Non Sampling
F04A5B95DCE14CC...
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

DocuSign Envelope ID: 6773F624-D1B2-439C-BE2A-E59E01FB08A6
Permit: WQCS00113 Owner - Facility: Town of Louisburg
Inspection Date: 08/23/2023 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Inspection Summary:
Page 2 of 7

DocuSign Envelope ID: 6773F624-D1B2-439C-BE2A-E59E01FB08A6
Permit: WQCS00113 Owner - Facility: Town of Louisburg
Inspection Date: 08/23/2023 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?
Yes No NA NE
Monthly
Yes No NA NE
■❑❑❑
❑■❑❑
❑ ❑ ❑ ❑
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.)
Comment: Grease traps/interceptors have not been inspected by the Town staff. Distribution of grease
educational material has not been conducted.
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? 0 ❑ ❑ ❑
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? 0 ❑ ❑ ❑
Comment: The CIP covers a 10-year period (2023 to 2033). The CIP lacks of description of existing
facilities and know deficiencies.
Page 3 of 7

DocuSign Envelope ID: 6773F624-D1B2-439C-BE2A-E59E01FB08A6
Permit: WQCS00113 Owner - Facility: Town of Louisburg
Inspection Date: 08/23/2023 Inspection Type : Collection System Inspect Non Sampling
Reason for Visit: Routine
Map
Yes No NA NE
Is there a overall sewer system map?
0
❑ ❑ ❑
Does the map include:
Pipe Type (GS/FM)
0
❑ ❑ ❑
Pipe sizes
0
❑ ❑ ❑
Pipe materials (PVC, DIP, etc)
0
❑ ❑ ❑
Pipe location
0
❑ ❑ ❑
Flow direction
0
❑ ❑ ❑
Approximate pipe age
❑
0 ❑ ❑
Pump station ID, location and capacity
0
❑ ❑ ❑
# Force main air release valve location & type
❑
0 ❑ ❑
# Location of satellite connections
❑
❑ 0 ❑
Is the map being updated for changes/additions within 1 year of activation?
0
❑ ❑ ❑
Comment: Pipe age is available only for newer lines
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 annual wastewater report did not include performance for the collection system. It does not
appear that the annual report is available for all customers.
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?
❑ ❑ ❑
# 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: Only two of six HPL were inspected monthly.
Spill Response Action Plan Yes No NA NE
Is a Spill Response Action Plan available? 0 ❑ ❑ ❑
Is a Spill Response Action Plan available for all personnel? 0 ❑ ❑ ❑
Page 4 of 7

DocuSign Envelope ID: 6773F624-D1B2-439C-BE2A-E59E01FB08A6
Permit: WQCS00113 Owner - Facility: Town of Louisburg
Inspection Date: 08/23/2023 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
$pills Yes No NA NE
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? ❑ ❑ 0 ❑
Comment:
Lines/Right-of-Ways/Aerial Lines Yes No NA NE
Please list the Lines/Right of Ways/Aerial Lines Inspected:
South Main Street Siphon, Prison Pump Station aerial line, and Sunrise Biscuit aerial line.
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? 0 ❑ ❑ ❑
Comment: Sewage was found seeping out from the joint section of a tall manhole at Sunrise Biscuit aerial
line.
Manholes Yes No NA NE
Please list the Manholes Inspected:
Upstream manholes at 5 pump stations, manhole before Sunrise Biscuit aerial line, MH at one end of South
Main Street Siphon.
Are manholes accessible? ❑ ❑ ❑
# Are manhole covers/vents above grade? ❑ ❑ ❑
Are manholes free of visible signs of overflow? ❑ ❑ ❑
Are manholes free of sinkholes and depressions? 0 ❑ ❑ ❑
Page 5 of 7

DocuSign Envelope ID: 6773F624-D1B2-439C-BE2A-E59E01FB08A6
Permit: WQCS00113 Owner - Facility: Town of Louisburg
Inspection Date: 08/23/2023 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?
❑
0 ❑ ❑
# Are inverts in good condition?
0
❑ ❑ ❑
Is flow unrestricted in manholes?
0
❑ ❑ ❑
Are manholes free of excessive amounts of grease?
0
❑ ❑ ❑
Are manholes free of excessive roots?
0
❑ ❑ ❑
Are manholes free of excessive sand?
0
❑ ❑ ❑
Are manhole vents screened?
0
❑ ❑ ❑
Are vents free of submergence?
0
❑ ❑ ❑
Are manholes free of bypass structures or pipes?
0
❑ ❑ ❑
Comment: Several manholes were not properly seated (loose manhole rings).
Pump Stations
Yes No NA NE
Please list the Pump Stations Inspected:
Prison Lift Station, Hon Lift Station, Wolf Pen Lift Station, Greenhill Lift Station, and Brithaven Lift 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?
6
# A simple one-way telemetry/communication system (auto -dialer) installed?
0
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?
❑ ❑ ❑
Page 6 of 7

DocuSign Envelope ID: 6773F624-D1B2-439C-BE2A-E59E01FB08A6
Permit: WQCS00113 Owner - Facility: Town of Louisburg
Inspection Date: 08/23/2023 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: Pump station inspection should be better documented (loqbooks were siqned only once per
month
• Green Hill Lift Station: one check valve was replaced with straight piping.
• Hon Lift Station: one of two Smith Loveless pumps was out of service, replaced with a
submersible pump.
• Prison Lift Station: standby generator was not operable.
Page 7 of 7