WQCS00168_Notice of Violation-NOV-2024-PC-0233_20240417

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
Certified Mail # 7022-2410-0002-5119-6116
Return Receipt Requested
April 17, 2024
Bill Hudson, Mayor
Town of Star
PO Box 97
Star, NC 27356
SUBJECT: NOTICE OF VIOLATION
Tracking Number: NOV-2024-PC-0233
Permit No. WQCS00168
Star Collection System
Montgomery County
Dear Permittee:
The North Carolina Division of Water Resources conducted an inspection of the Star Collection System on April
4, 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. WQCS00168. 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(s) were noted during the inspection:
Inspection Area Description of Violation
Pump Stations All duplex pump stations have only one operable pump. This does not meet permit
requirement as stated in Section I.7. of the permit "... If one of the pumps in a pump
station containing multiple pumps fails, the process of repairing or replacing the pump
shall be initiated immediately and the new parts or pump shall be installed as soon as
possible.... [15A NCAC 02T.0305 (h) (1)] "
Da Q > North Carolina Department of Environmental Quality I Division of Water Resources
Fayetteville Regional Office 1 225 Green Street, Suite 714 1 Fayetteville, North Carolina 28301
o.n.mMmme.om.ma n 910.433.3300

Inspection Area Description of Violation
Sewer and FOG Ordinances Grease education materials have only been distributed once a year at the most. This
does not meet the requirement as stated in permit section I. 4. "The Permittee shall develop
and implement an educational fats, oils and grease program that shall include at least
semiannual distribution of educational material targeted at both residential and non-residential
users.... [15A NCAC 02T.0108 (b)] "
Pump Stations Permittee does not know how to test alarms at seven of the eight pump stations and is
not testing alarms as required in Permit section II. 4 "The Permittee shall develop and
implement a routine pump station inspection and maintenance program which shall
include the following maintenance activities:
a. Cleaning and removing debris from the pump station structure, outside perimeter, and wet
Well;
b. Inspecting and exercising all valves;
c. Inspecting and lubricating pumps and other mechanical equipment; and
d.Verifying the proper operation of the alarms, telemetry system and auxiliary equipment.
[15A NCAC 02T.0108(b)] "
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.
Da Q > North Carolina Department of Environmental Quality I Division of Water Resources
Fayetteville Regional Office 1 225 Green Street, Suite 714 1 Fayetteville, North Carolina 28301
o.n.mMmme.om.ma n 910.433.3300

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 910-433-3339.
Ec: Laserfiche
Sincerely,
DocuSigned by:
6 4/23/2024
E4E1A9691DB248E...
Mark Brantley, Regional Supervisor
Water Quality Regional Operations Section
Fayetteville Regional Office
Division of Water Resources, NCDEQ
D_E Q-� North Carolina Department of Environmental Quality I Division of Water Resources
Fayetteville Regional Office 1 225 Green Street, Suite 714 1 Fayetteville, North Carolina 28301
iaemmm�� 910.433.3300

Compliance Inspection Report
Permit: WQCS00168 Effective: 06/04/18 Expiration: 03/31/26 Owner : Town of Star
SOC: Effective: Expiration: Facility: Star Collection System
County: Montgomery PO Box 97
Region: Fayetteville
Contact Person: James Wesley Brown Title: Phone: [phone]
Directions to Facility:
System Classifications: CS1,
Primary ORC: James Wesley Brown Certification: 14480 Phone: [phone]
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
NC0058548 Town of Star - Star WWTP
Inspection Date: 04/04/2024 Entry Time 10:45AM Exit Time: 12:30PM
Primary Inspector: Kirsten Steininger Cy gtU "' 4/16/2024 Phone: [phone]
A4fiD6fiFEA3AFdEE_.
Secondary Inspectors):
oocusiyned by- 4/2 3/2024
Reason for Inspection: Routine E4E,A9691DB248E. 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: WQCS00168 Owner - Facility: Town of Star
Inspection Date: 04/04/2024 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Inspection Summary:
During the inspection it was found that there are gaps in required paperwork and continued issues with pump stations not
meeting permit requirements.
Paperwork
The 10% gravity sewer cleaning requirement was met. The required paperwork and records were available and met the
requirements, with a few exceptions. The last annual report was made in 2023, but permittee did not report to division or
make available to customers. The online map crashed, so currently only maps from 1924 are available. The CIP goes
through 2024 and needs to be updated before the next inspection. Grease education is only sent out once a year or less,
which does not meet permit requirements. This was mentioned in the inspection report from 2022, but has not been
addressed.
Field Inspections
Pump stations 2, 6, 7, and 8 were inspected. At the time of the inspection, all pump stations were secure with proper
signage and all wet wells were clear of excess debris. Only one alarm was tested during the inspection and it was working
at that time. The permittee does not know how to test the other alarms, which are transducers. The permittee needs to find
out how the alarms can be tested to verify that they are operable. This was mentioned in the 2022 inspection report and has
not been addressed. All the pump stations have only one working pump even though the pump stations are duplex. This
issue was also noted in the 2022 inspection report, for at least one pump station, and has not been addressed.
The manhole at Cotton Creek road school was viewed and was in good condition at the time of the inspection.
The ROWs at Brewer st & Dameron St were viewed during the inspection and were accessible for maintenance at that time.
The ROW at Dameron St was starting to have overgrowth of vegetation, but still appeared to be accessible.
Page 2 of 7

Permit: WQCS00168 Owner - Facility: Town of Star
Inspection Date: 04/04/2024 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? ❑ ❑ ❑
Are logs being reviewed by the system management or owner on a regular basis? ❑ ❑ ❑
# What is that frequency? NE
# 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?
❑ ❑ ❑
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: Grants awarded for improvements; waitinq to receive the funds; plan for use of funds is to at
least upgrade pump stations; spare pumps inventory & septic tank hauler available for pump
failure/power outage
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? every 30 days
Is Grease Control Program enforced via periodic inspections/records review? ❑ ❑ ❑
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.)
Comment: Statement advising agains pouring grease into drains is distributed about once a year
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: CIP through 2024, needs to be updated before next inspection
Page 3 of 7

Permit: WQCS00168 Owner - Facility: Town of Star
Inspection Date: 04/04/2024 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)
❑
❑ ❑
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
❑
❑ 0 ❑
Is the map being updated for changes/additions within 1 year of activation?
0
❑ ❑ ❑
Comment: online map crashed, using 1924 maps until engineers make new 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? NA
Comment: Last annual report was made in 2023, but permittee did not report to division or make available
to customers
Inspections
Yes No NA NE
Are adequate maintenance records maintained?
0
❑ ❑ ❑
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: HPL at park from East bank street to Monroe street
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

Permit: WQCS00168 Owner - Facility: Town of Star
Inspection Date: 04/04/2024 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? 0 ❑ ❑ ❑
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: complaints not documented, but orc addresses complaints in person and some information is
recorded in other records
Lines/Right-of-Ways/Aerial Lines
Please list the Lines/Right of Ways/Aerial Lines Inspected:
ROWs at Brewer st & Dameron St
Yes No NA NE
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: annual cleaning requirement — 2,640ft; 10% requirement well surpassed; The ROWS at Brewer
st & Dameron St were viewed during the inspection and were accessible for maintenance at
that time. The ROW at Dameron St was starting to get narrow and overgrown, but still
appeared to be accessible.
Manholes Yes No NA NE
Please list the Manholes Inspected:
Cotton Creek Rd
Are manholes accessible? ❑ ❑ ❑
# Are manhole covers/vents above grade? ❑ ❑ ❑
Are manholes free of visible signs of overflow? ❑ ❑ ❑
Page 5 of 7

Permit: WQCS00168 Owner - Facility: Town of Star
Inspection Date: 04/04/2024 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
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: The manhole at Cotton Creek road school was viewed and was in
good condition at the time of
the inspection.
Pump Stations
Yes No NA NE
Please list the Pump Stations Inspected:
#2, #6, #7, #8
# Number of duplex or larger pump stations in system
8
# 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?
# 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?
0
❑ ❑ ❑
Page 6 of 7

Permit: WQCS00168 Owner - Facility: Town of Star
Inspection Date: 04/04/2024 Inspection Type : Collection System Inspect Non Sampling
Reason for Visit: Routine
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?
❑
❑ ❑
# 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: Pump stations 2, 6, 7, and 8 were inspected. At the time of the inspection, all pump stations
were secure with proper signage and all wet wells were clear of excess debris. Only one alarm
was tested during the inspection and it was working at that time. Permittee does not know how
to test the other alarms, which are transducers. All the pump stations have only one working
pump even though the pump stations are duplex. Replacement pumps are avaiable for each
pump station.
Page 7 of 7

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1. Article Addressed to:
TOWN OF STAR
ATTN: BILL HUDSON, MAYOR
P.O. BOX 97
STAR, NC 27356
IIIIIIIII IIII IIIIIIIIIIII III III IIII IIIIII II III
9590 940
�1
O Agent
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Sender: Please print your name,
NCDEQ — DWR - WQROS
ATTN: KIRSTEN STEININGER
225 GREEN STREET, SUITE 714
FAYETTEVILLE, NC 28301
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