WQCS00056_Compliance Evaluation Inspection 2024_20240626

June 26, 2024
Hank Raper
Siler City– Town Manager
PO Drawer 769
Siler City, NC 27344

Subject: Compliance Evaluation Inspection
Siler City Collection System
WWCS Permit WQCS00056
Chatham County

Dear Mr. Raper:

On June 18, 2024, Kevin Fowler from the Raleigh Regional Office conducted an inspection of
the Town of Siler City wastewater collection system to evaluate compliance with the operation
and maintenance of the subject wastewater collection system permit. The cooperation and
assistance of Chris McCorquodale (ORC), Brittany York (Back up ORC), and Peter Szilvay
(Back up ORC) during the inspection were greatly appreciated.

Our records indicate the wastewater collection system consists of approximately 50.71 miles of
gravity sewer, approximately 4.0 miles of force main, 7 duplex pump stations, and 5 simplex
pump stations that serve a single building. During the time of the inspection, updated system
numbers were given by the ORC which indicated the system containing 57 miles of gravity
sewer.

The subject permit expired on 4/30/2023. A renewal application for this permit was sent to DEQ
on 10/31/2022. This application met the requirement of being submitted more than 6 months
before the expiration date of the permit.

The items below show what conditions were noted during the inspection:

1. Reported Sanitary Sewer Overflows. During the past year from the inspection date,
there was 1 SSO from the town’s collection system with an estimated volume of 5,000
gallons, of which 200 gallons reached surface water. No fish kills were reported because
of the SSO events.
2. Fats, Oils and Grease Program. The permittee has developed and implemented a full
educational fats, oils and grease program that includes at least bi-annual distribution of
DocuSign Envelope ID: 6B0D53DA-411F-482B-89C2-CD0C130D2EDA

Permittee, WQCS00056
6/20/2024

Page 2 of 4

educational material targeted at both residential and non-residential users. Distribution of
educational material has been implemented and included distributed information on the
town’s website as well as a twice a year mailing. During the inspection the ORC
indicated that inspections have not taken place since January due to one staff
member leaving the position. These requirements are covered in 15A NCAC 02T .0108
3. Capital Improvement Plan. The permittee has adopted and implements a Capital
Improvement Plan to designate funding for reinvestment into the wastewater collection
system infrastructure. The CIP covers includes a goal statement, description of the
project area, description of the existing facilities, known deficiencies and forecasted
future needs. The current capital improvement covers 40 years.
4. Contingency Plan for Pump Failure. The permittee maintains a contingency plan for
pump failure at each lift station.
5. Pump Stations Inspected. The following duplex pump stations were inspected: Basic
Machinery, North Avenue, Harmony Hills, and Blood Run. The inspector’s observations
noted in the next 5 items below refer to the 4 pump stations inspected.
6. Pump Station Signage. Each pump station has signage clearly and conspicuously posted
that identifies the pump station, provides an emergency 24-hour contact telephone
number(s), and provides instructions for notification if the visual alarm illuminates and/or
the audible alarm sounds, or if an emergency is apparent.
7. Pump Station Restricted Access. The pump station sites, equipment and components
were observed to have restricted access.
8. Pump Stations Automatic Polling Feature. Each of the pump stations visited had a
one-way telemetry auto-dialer communication installed to notify the permittee/town staff
in case of emergency. During the inspection, the auto-dialer at the Basic Machinery
pump station did not dial out when the high-water float was pulled up. The permit
states that the permittee shall develop and implement a routine pump station inspection
and maintenance program which shall include “verifying the proper operation of alarms,
telemetry system, and auxiliary equipment.” These requirements are covered in 15A
NCAC 02T .0305.
9. Pump Station High Water Alarms. The pump stations are equipped with audible and
visual high-water alarms. During the inspection, all alarms were operational. Note that
the Blood Run pump station alarm was tested only by sending power to alarms and not by
simulating high water conditions.
10. Pump Station Inspection Program. The permittee has developed and implements a
routine inspection of each pump station that includes the following maintenance
activities: cleaning and removing debris from the pump station area and wet well;
inspecting all valves; inspecting pumps and other mechanical equipment; telemetry
system and auxiliary equipment. The inspector reviewed the inspection logs of the pump
stations visited and observed adequate entries of the date and time of the operator’s
inspection, observations made, and any maintenance, repairs, or corrective actions taken.
At the time of inspection, the backup ORC was unable to test the high-water level
alarm through simulating high-water conditions of “bubbler” system due to system
DocuSign Envelope ID: 6B0D53DA-411F-482B-89C2-CD0C130D2EDA

Permittee, WQCS00056
6/20/2024

Page 3 of 4

setup at the Blood Run Pump Station. The permit states that the permittee shall
develop and implement a routine pump station inspection and maintenance program
which shall include “verifying the proper operation of alarms, telemetry system, and
auxiliary equipment.” These requirements are covered in 15A NCAC 02T .0305.
11. High Priority Line Inspection. During the inspection, the following high priority lines
were inspected: Behind Cape Carnes, Behind Justice MHP, Behind Jordan Matthews
High Schook, Behind Walmart, and Behind U-Auto Wash III. The ORC indicated that
inspections of High Priority Lines had not been completed in the past six months
due to a staff member leaving the position. The permit states that it is required that
all high priority lines be inspected at least once per every six-month period of time.
These requirements are covered in 15A NCAC 02T .0108 (b).
12. Copy Of Permit The system permit states that the permittee shall have available a copy
of the system permit to present upon request by any duly authorized officer, employee, or
representative of the division. During the inspection a copy of the permit was not
available to be viewed by the inspector. These requirements are covered in 15 A
NCAC 025 .0104.
13. Cleaning Sewer Lines. The permittee has developed and implemented a program for
cleaning the sewer lines. As required by Section II.8 of the subject permit, at least 10%
of the wastewater collection system should be cleaned each year. Preventative cleaning
is not required for sewer lines less than five years old, unless an inspection reveals the
need for cleaning. Records provided indicated more than 10% of the system being
cleaned annually.
14. Spill Response Action Plan. The permittee has developed and maintains a Spill
Response Action Plan that includes 24-hour contact numbers, response time, equipment
list and spare parts inventory, access to cleaning equipment, access to construction crews,
sources of emergency funds, site sanitation and cleanup materials, and post-SSO
assessment.
15. SSO Records. The permittee has maintained adequate records pertaining to SSOs and
sewer complaints for the three-year period ending 6/118/2024 (day of inspection). The
last reportable SSO occurred on 4/18/2024.
16. Comprehensive Sewer Map. The permittee maintains an up-to-date comprehensive map
of its sewer collection system. The map includes pipe type, pipe size, and force main air
release valve location. The map did not include pipe material, approximate pipe age,
flow direction, pump station ID, and pump station location and capacity. These
requirements are required as covered in 15A NCAC 02T .0108 (b).

DocuSign Envelope ID: 6B0D53DA-411F-482B-89C2-CD0C130D2EDA

Permittee, WQCS00056
6/20/2024

Page 4 of 4

Please provide this office with a written response to items 2, 8, 10, 11, 12, and 16 above no
later than July 31, 2024. The written response should include the actions the Town will
take to resolve the noted issues.

If you have questions or comments about this inspection or the requirements to take corrective
action if applicable, please contact Kevin Fowler at 919-791-4261

Sincerely,

Vanessa Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ

Attachment(s): Collection System Inspection Report

Cc: Laserfiche
Christopher McCorquodale - ORC
DocuSign Envelope ID: 6B0D53DA-411F-482B-89C2-CD0C130D2EDA
Compliance Inspection Report
Permit:WQCS00056 Effective:05/01/15 Expiration:04/30/23 Owner :Town of Siler City
SOC:S22003
Contact Person:
Region:
County:
Directions to Facility:
Chatham
Raleigh
Terry Green
Effective:04/01/23 Expiration:01/01/26 Facility:Siler City Collection System
PO Box 769
Siler City NC 27344
Title:Phone:[phone]Director of Public Works
Secondary ORC(s):
Phone:Certification:Primary ORC:
CS2,System Classifications:
On-Site Representative(s):
Related Permits:
NC0026441 Town of Siler City - Siler City WWTP
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
06/18/2024 10:00AM 04:00PM
Kevin Fowler 919-791-4200
Facility Status:
Permit Inspection Type:
Reason for Inspection:Inspection Type:
Not CompliantCompliant
Complaint
Collection system management and operation
Complaint
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
6/26/2024
DocuSign Envelope ID: 6B0D53DA-411F-482B-89C2-CD0C130D2EDA
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00056
06/18/2024 Complaint
Town of Siler City
Complaint
Inspection Summary:
8.Pump Stations Automatic Polling Feature. Each of the pump stations visited had a one-way telemetry auto-dialer
communication installed to notify the permittee/town staff in case of emergency. During the inspection, the auto-dialer at
the Basic Machinery pump station did not dial out when the high-water float was pulled up. The permit states that the
permittee shall develop and implement a routine pump station inspection and maintenance program which shall include
“verifying the proper operation of alarms, telemetry system, and auxiliary equipment.” These requirements are covered in 15A
NCAC 02T .0305.
2.Fats, Oils and Grease Program. The permittee has developed and implemented a full educational fats, oils and grease
program that includes at least bi-annual distribution of educational material targeted at both residential and non-residential
users. Distribution of educational material has been implemented and included distributed information on the town’s website
as well as a twice a year mailing. During the inspection the ORC indicated that inspections have not taken place since
January due to one staff member leaving the position. These requirements are covered in 15A NCAC 02T .0108
8.Pump Stations Automatic Polling Feature. Each of the pump stations visited had a one-way telemetry auto-dialer
communication installed to notify the permittee/town staff in case of emergency. During the inspection, the auto-dialer at
the Basic Machinery pump station did not dial out when the high-water float was pulled up. The permit states that the
permittee shall develop and implement a routine pump station inspection and maintenance program which shall include
“verifying the proper operation of alarms, telemetry system, and auxiliary equipment.” These requirements are covered in 15A
NCAC 02T .0305.
10.Pump Station Inspection Program. The permittee has developed and implements a routine inspection of each pump
station that includes the following maintenance activities: cleaning and removing debris from the pump station area and wet
well; inspecting all valves; inspecting pumps and other mechanical equipment; telemetry system and auxiliary equipment.
The inspector reviewed the inspection logs of the pump stations visited and observed adequate entries of the date and time
of the operator’s inspection, observations made, and any maintenance, repairs, or corrective actions taken. At the time of
inspection, the backup ORC was unable to test the high-water level alarm through simulating high-water conditions of
“bubbler” system due to system
11.High Priority Line Inspection. During the inspection, the following high priority lines were inspected: Behind Cape Carnes,
Behind Justice MHP, Behind Jordan Matthews High Schook, Behind Walmart, and Behind U-Auto Wash III. The ORC
indicated that inspections of High Priority Lines had not been completed in the past six months due to a staff member
leaving the position. The permit states that it is required that all high priority lines be inspected at least once per every
six-month period of time. These requirements are covered in 15A NCAC 02T .0108 (b).
12.Copy Of Permit The system permit states that the permittee shall have available a copy of the system permit to present
upon request by any duly authorized officer, employee, or representative of the division. During the inspection a copy of the
permit was not available to be viewed by the inspector. These requirements are covered in 15 A NCAC 025 .0104.
16.Comprehensive Sewer Map. The permittee maintains an up-to-date comprehensive map of its sewer collection system.
The map includes pipe type, pipe size, and force main air release valve location. The map did not include pipe material,
approximate pipe age, flow direction, pump station ID, and pump station location and capacity. These requirements are
required as covered in 15A NCAC 02T .0108 (b).
Page 2 of 7
DocuSign Envelope ID: 6B0D53DA-411F-482B-89C2-CD0C130D2EDA
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00056
06/18/2024 Complaint
Town of Siler City
Complaint
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?Monthly
# 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?
Did not have copy of their permit. Permit expiered 4/30/2023 and they applied for renewal on
10/30/2022.
Comment:
Sewer and FOG Ordinances Yes No NA NE
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?Quarterly
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.)
Town website
Due to one member of town staff leaving, inspections have not been taking place for past few
months.
Comment:
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?
Does CIP include known deficiencies?
Does CIP include forecasted future needs?
Comment:
Page 3 of 7
DocuSign Envelope ID: 6B0D53DA-411F-482B-89C2-CD0C130D2EDA
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00056
06/18/2024 Complaint
Town of Siler City
Complaint
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?
Some pump stations were on GIS and some were not.Comment:
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?Billing and website
Comment:
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?
ORC indicated no one has been inspecting HPL since one indivdual stopped working for the
city. Indicated they would be start doing it again.
Comment:
Spill Response Action Plan Yes No NA NE
Is a Spill Response Action Plan available?
Page 4 of 7
DocuSign Envelope ID: 6B0D53DA-411F-482B-89C2-CD0C130D2EDA
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00056
06/18/2024 Complaint
Town of Siler City
Complaint
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?
No formal post overflow/spill assessment was present in plan.Comment:
Spills 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?
No overflows at same location.Comment:
Lines/Right-of-Ways/Aerial Lines Yes No NA NE
Please list the Lines/Right of Ways/Aerial Lines Inspected:
Behind Cape Carnes, Behind Justice MHP, Behind Jordan Matthews High School, Behind Wal-mart, Behind
U Auto Wash III
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?
Comment:
Manholes Yes No NA NE
Please list the Manholes Inspected:
Cul-de-sac of singing sound way, Intersection of second street and Garden Ave, Downstream of Cape
Carnes aerial line, Downstream of "Behind Walmart" aerial line
Are manholes accessible?
# Are manhole covers/vents above grade?
Are manholes free of visible signs of overflow?
Page 5 of 7
DocuSign Envelope ID: 6B0D53DA-411F-482B-89C2-CD0C130D2EDA
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00056
06/18/2024 Complaint
Town of Siler City
Complaint
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?
Singing Sound Way manhole had an accumulation of rags/wipes.Comment:
Pump Stations Yes No NA NE
Please list the Pump Stations Inspected:
Basic Machinery, North Avenue, Harmony Hills, Blood Run
# Number of duplex or larger pump stations in system 8
# Number of vacuum stations in system 0
# Number of simplex pump stations in system 5
# 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?1
# A simple one-way telemetry/communication system (auto-dialer) installed?7
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?
Page 6 of 7
DocuSign Envelope ID: 6B0D53DA-411F-482B-89C2-CD0C130D2EDA
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00056
06/18/2024 Complaint
Town of Siler City
Complaint
Are audio and visual alarms present?
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?
Two stations have portable generators that are parked on-site at the lift station. The other 6 have permenant
generators.
# 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?
Basic Machinery Lift station telemetry was not functional on day of inspection.
Blood Run Lift Station does not have a way to simulate high water alarm conditions.
Comment:
Page 7 of 7
DocuSign Envelope ID: 6B0D53DA-411F-482B-89C2-CD0C130D2EDA