WQCS00124_NOV-2024-PC-0148_20240319

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
STATE o
NORTH CAROLINA
Environmental Quality
Certified Mail # 7022 2410 0002 5119 6109
Return Receipt Requested
March 19, 2024
Clint Mack, Town Manager
Town of Robbins
PO Box 296
Robbins, NC 27325
SUBJECT: NOTICE OF VIOLATION
Tracking Number: NOV-2024-PC-0148
Permit No. WQCS00124
Robbins Collection System
Moore County
Dear Permittee:
The North Carolina Division of Water Resources conducted an inspection of the Robbins Collection System on
February 2, 2024. This inspection was conducted to verify that the facility is operating in compliance with the
conditions and limitations specified in Collection System Permit No. WQCS00124. A summary of the findings and
comments noted during the inspection are provided in the enclosed copy of the inspection report.
The Collection System Non -sampling inspection was conducted by Division of Water Resources staff from the
Fayetteville Regional Office.
The following violation was noted during the inspection:
Inspection Area Description of Violation
General Permit is expired as of 10/31/2023 and at the time of the inspection the permittee had
not applied for renewal as required per rule:
15A NCAC 02T .0109 PERMIT RENEWALS
Requests for permit renewals shall be submitted to the Director at least 180 days prior to expiration unless the permit has been
revoked by the Director in accordance with Rule .0110 of this Section or a request has been made to rescind the permit. Renewal
requests shall be made in accordance with Rule .0105 and Rule .0106 of this Section.
History Note: Authority G. S. 143-215.3(a)(1);
Eff. September 1, 2006;
Readopted Eff. September 1, 2018.
o.o.�e., e,.•� D ��� North Carolina Department of Environmental Quality I Division of Water Resources
Fayetteville Regional Office 1225 Green Street. Suite 7141 Fayetteville, North Carolina 28301
910.433.3300

Remedial actions should have already been taken to correct this problem and prevent further occurrences in the
future. The Division of Water Resources may pursue enforcement action for this and any additional violations of
State law.
To prevent further action, please respond in writing to this office within 30 days upon your receipt of this Notice
of Violation regarding your plans or measures to be taken to address the indicated violations and other identified
issues, if applicable.
If you should have any questions, please do not hesitate to contact Kirsten Steininger with the Water Quality
Regional Operations Section in the Fayetteville Regional Office at 910-433-3300.
Cc: Ec Laserfiche
Sincerely,
DocuSigned b(ywM1/.N}'�I,�'-
I
E4E1A9691 DB248E...
Mark Brantley, Regional Supervisor
Water Quality Regional Operations Section
Fayetteville Regional Office
Division of Water Resources, NCDEQ
D �-- North Carolina Department of Environmental Quality I Divisionof Water Resources
Fayetteville Regional Office 1225 Green Street, Suit, 7141 Fayetteville, North Carolina 28301
910.433.3300

Compliance Inspection Report
Permit: WQCS00124 Effective: 11/08/16 Expiration: 10/31/23 Owner: Town of Robbins
SOC: Effective: Expiration: Facility: Robbins Collection System
County: Moore PO Box 296
Region: Fayetteville
Robbins NC 27325
Contact Person: Daniel Gray Title: Phone: [phone] Ext.8
Directions to Facility:
System Classifications: CS1,
Primary ORC: Michael Kevin Criscoe
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
NC0062855 Town of Robbins - Robbins WWTP
Certification: 27483 Phone:[phone]
Inspection Date: 02/02/2024 Entry Time 11:OOAM Exit Time: 01:OOPM
D 3"g d by:
Primary Inspector: Kirsten Steininger E - 3/19/2024 Phone: [phone]
SecondaryInS ector S : DocuSi ned bA4soeoFenanFaEE..
p () a y-
El A,,,^ �, ,, 3/19/2024
E4E1A9691DB248E...
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: WQCS00124 Owner - Facility: Town of Robbins
Inspection Date: 02/02/2024 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Inspection Summary:
This permit is expired with no renewal application submitted. The system is operating without a permit and therefore out of
compliance. During the inspection, some additional issues were found that need to be addressed:
1) A large tree growing over the high priority line at Frye street
- this needs to be analyzed by an engineer to see what effect the tree has on
the underlying line
2) Sewer Use Ordinance not available at inspection
3) Annual Wastewater Performance report not available at inspection
The paperwork that was not available at the inspection was made available via email after the inspection. Please have all
paperwork available, including examples of grease education and SSO press releases, at the time of the next inspection.
Paperwork
The Capital Improvement plan, Spill Response Plan, and Sewer system map were all available and included adequate detail.
However, some documents were not available during the inspection. Permittee was not sure of grease education distribution
method or frequency. Permittee did not have copies of press releases for SSOs when applicable. Sewer Use Ordinance and
Annual Wastewater Performance report were not available. All missing documents were made available after the inspection.
Pump Stations
All pump stations were secure with proper signage posted. The wet wells were free of excessive grease and debris. All audio
and visual alarms were operable. Pumps were manually turned on and worked with the exception of one pump at Shields
Wood, which had some electrical issues that are being addressed. SCADA was working properly. To test the backup
system at Hwy 705 pump station, the power was shut off and the generator started automatically and continued to provide
power when pumps were manually turned on.
Other Field Inspections
Manholes were inspected at Church street, Manhas furniture, and Frye street and were in good condition. Right of ways at
Candor pump station and Manhas furniture were inspected and in good condition. High priority lines at church street (aerial)
and Frye street (runs through creek) were inspected; both lines were in good condition, but the line at Frye street has a
large tree growing over it, which needs to be analyzed by an engineer to see what effect it has on the underlying sewer line.
Page 2 of 7

Permit: WQCS00124 Owner - Facility: Town of Robbins
Inspection Date: 02/02/2024 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?
Yes No NA NE
■❑❑❑
❑ ❑ ❑
❑ ❑ ❑
■❑❑❑
■❑❑❑
■❑❑❑
❑■❑❑
Comment: Permit is expired as of 10/31/2023 and at the time of the inspection the permittee had not
applied for renewal; electrical issues with one of the pumps at Shields Wood pump station are
being addressed.
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.)
online
Yes No NA NE
❑■❑❑
• ❑ ❑ ❑
• ❑ ❑ ❑
at least every 30
days or more often
if needed
• ❑ ❑ ❑
• ❑ ❑ ❑
❑❑■❑
❑❑❑■
■❑❑❑
Comment: Sewer Use Ordinance not available at time of inspection; Grease education flyer is available on
the town website, but other education/ distribution of flyers was not known at time of inspection.
There are restaurants with grease control devices and the China King restaurant that has had
repeat issues has been fined for lack of compliance.
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? 0 ❑ ❑ ❑
Page 3 of 7

Permit: WQCS00124 Owner - Facility: Town of Robbins
Inspection Date: 02/02/2024 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Does CIP include known deficiencies? 0 ❑ ❑ ❑
Does CIP include forecasted future needs? 0 ❑ ❑ ❑
Comment:
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
❑
❑ ❑
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: Online Map
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? unknown
Comment: Permittee reported that press releases are issued for spills, but copies were not available at
the inspection; Annual Wastewater Performance Report was not available; the most recent one
that is on the town website is from 2018
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?
❑
❑ ❑
Page 4 of 7

Permit: WQCS00124 Owner - Facility: Town of Robbins
Inspection Date: 02/02/2024 Inspection Type : Collection System Inspect Non Sampling
Reason for Visit: Routine
Comment:
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?
❑ ❑ ❑
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:
Spllls 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: Bypass set up at Hwy 705 pump station as an emergency/ backup option- not in use during
regular operation
Lines/Right-of-Ways/Aerial Lines Yes No NA NE
Please list the Lines/Right of Ways/Aerial Lines Inspected:
Right of ways at Candor pump station and Manhas furniture; High priority lines at church street (aerial) and
Frye street (runs through creek)
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: 7300 feet of lines cleaned of required 7377 feet; large tree growing over Frye street high
priority line
Manholes Yes No NA NE
Page 5 of 7

Permit: WQCS00124 Owner - Facility: Town of Robbins
Inspection Date: 02/02/2024 Inspection Type : Collection System Inspect Non Sampling
Reason for Visit: Routine
Please list the Manholes Inspected:
Church street, Manhas furniture, Frye street
Are manholes accessible?
0
❑ ❑ ❑
# Are manhole covers/vents above grade?
0
❑ ❑ ❑
Are manholes free of visible signs of overflow?
0
❑ ❑ ❑
Are manholes free of sinkholes and depressions?
0
❑ ❑ ❑
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?
❑
❑ ❑
Are vents free of submergence?
0
❑ ❑ ❑
Are manholes free of bypass structures or pipes?
0
❑ ❑ ❑
Comment:
Pump Stations
Yes No NA NE
Please list the Pump Stations Inspected:
Hwy 705, Shields Wood, Candor
# Number of duplex or larger pump stations in system
3
# 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?
3
# 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?
0
❑ ❑ ❑
Page 6 of 7

Permit: WQCS00124 Owner - Facility: Town of Robbins
Inspection Date: 02/02/2024 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
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?
# 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:
Inside and outside cleaning and debris removal?
0
❑ ❑ ❑
Inspecting and exercising all valves?
0
❑ ❑ ❑
Inspecting and lubricating pumps and other equipment?
0
❑ ❑ ❑
Inspecting alarms, telemetry and auxiliary equipment?
0
❑ ❑ ❑
Comment: permanent backup generator at Hwy 705 pump station, which auto -exercises weekly;
emergency plan for other pump stations is use of a septic company pump truck; One
pump
at
Shields Wood pump station isn't functioning properly due to electrical issues which are in the
process of being addressed
Page 7 of 7