WQCS00048_2024 Compliance Evaluation Inspection Letter_20240627

June 27, 2024
Kenneth Griffin
Town of Roxboro
PO Drawer 128
Roxboro, NC 27573-0128

Subject: Compliance Evaluation Inspection
Roxboro Collection System
WWCS Permit WQCS00048
Person County

Dear Mr. Griffin:

On June 20, 2024, Kevin Fowler from the Raleigh Regional Office conducted an inspection of
the Town of Roxboro wastewater collection system to evaluate compliance with the operation
and maintenance of the subject wastewater collection system permit. The cooperation and
assistance of Chad Lawson during the inspection were greatly appreciated.

Our records indicate the wastewater collection system consists of approximately 81 miles of
gravity sewer, approximately 5.4 miles of force main, and 11 duplex pump stations. The most
recent permit application gives updated totals. The permit application indicates that there is
93.75 miles of gravity sewer, 6.25 miles of force main, and 12 duplex pump stations.

The subject permit expired on 10/31/2023. A renewal application for this permit was sent to
DEQ on 8/21/2023. This is a reminder to the permittee for future renewals that it is a
permit condition that the permittee shall file an application for renewal of a permit at least
six months prior to the expiration date.

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 86,400
gallons, of which the entire volume of 86,400 gallons reached surface water. No fish
kills were reported because of the SSO event.
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
DocuSign Envelope ID: D0E0F55F-B374-44DD-8731-16240B6E8020

Permittee, WQCS00048
6/26/2024

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educational material has been implemented and included distributed information on the
town’s website as well as once a year mailing.
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.
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: Brooks,
Duncan, Crown Craft, and Williams Road. 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. All of these telemetry systems were tested during the inspection
and were operational.
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.
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 generator at the Duncan lift station did not
come on when power was interrupted to the station. The generator turned on and run
properly when turned on manually. It is recommended that backup power supplies be
tested regularly to prevent any possible future permit violations.
11. High Priority Line Inspection. During the inspection, the following high priority lines
were inspected: NC License Plate Agency 811 N. Madison Ave, Roses 1029 N. Madison
Blvd, and 418 West Morehead street.
i. The ORC indicated that designated inspections twice a year of the
high priority lines in the system were not being conducted. In the most
recent permit application there are 35 high priority lines documented
DocuSign Envelope ID: D0E0F55F-B374-44DD-8731-16240B6E8020

Permittee, WQCS00048
6/26/2024

Page 3 of 4

in the system. These requirements are covered in 15A NCAC 02T .0108
(b).
ii. A large tree was found to be laying on the Roses 1029 N. Madison
Blvd line. The line did not appear to be damaged or leaking; however,
steps should be taken to reduce the risk of issues that may cause or
lead to the release of wastes to the environment. These requirements
are covered in 15A NCAC 02T .0108 (b).
iii. A rubber boot was found to have a large tear at 418 West Morehead
Street. The line was not found to leaking at the time and showed no
signs of leakage nearby; however, steps should be taken to reduce the
risks of issues that may cause or lead to the release of wastes to the
environment. 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 were provided to indicate that cleaning had taken place;
however, no distances were provided in these files. Due to no total distance of line
being cleaned being known, it is not possible to determine if more than 10% of the
wastewater collection system has been cleaned annually. These requirements are
covered in 15A NCAC 02T .0108 (b).
14. Spill Response Action Plan. The permittee has developed a spill maintenance plan from
2010 that includes 24 contact numbers, response time, equipment list and spare parts
inventory, and source of emergency funds. The plan did not include access to cleaning
equipment, access to construction crews, contractors, and/or engineers, site
sanitation and cleanup materials, or a post overflow/spill assessment. The plan also
did no appear to have been maintained since 2010 and contained multiple out of
date names and phone numbers. Please update and maintain the response action plan
and include the elements listed above. These requirements are covered in 15A NCAC
02T .0108 (b).
15. SSO Records. The permittee has maintained adequate records pertaining to SSOs and
sewer complaints for the three-year period ending 6/20/2024 (day of inspection). The last
reportable SSO occurred on 3/17/2024.
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,
DocuSign Envelope ID: D0E0F55F-B374-44DD-8731-16240B6E8020

Permittee, WQCS00048
6/26/2024

Page 4 of 4

and pump station capacity. These requirements are required as covered in 15A NCAC
02T .0108 (b).

Please provide this office with a written response to items 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
Chad Lawson - ORC
DocuSign Envelope ID: D0E0F55F-B374-44DD-8731-16240B6E8020
Compliance Inspection Report
Permit:WQCS00048 Effective:11/01/15 Expiration:10/31/23 Owner :City of Roxboro
SOC:
Contact Person:
Region:
County:
Directions to Facility:
Person
Raleigh
Andrew M Oakley
Effective:Expiration:Facility:Roxboro Collection System
PO Box 128
Title:Phone:[phone]Public Service Director
Secondary ORC(s):
Phone:Certification:Primary ORC:
CS2,System Classifications:
On-Site Representative(s):
Related Permits:
NC0021024 City of Roxboro - Roxboro WWTP
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
06/20/2024 10:00AM 04:00PM
Kevin Fowler 919-791-4200
Facility Status:
Permit Inspection Type:
Reason for Inspection:Inspection Type:
Not CompliantCompliant
Routine
Collection system management and operation
Collection System Inspect Non Sampling
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
06/27/2024
DocuSign Envelope ID: D0E0F55F-B374-44DD-8731-16240B6E8020
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00048
06/20/2024 Collection System Inspect Non Sampling
City of Roxboro
Routine
Inspection Summary:
Chad Lawson is the new ORC and this was first inspection under his management. Multiple permit conditions were not
being met at the time of the inspection.
1) Duncan Lift station generator did not turn on when power was interupted.
2)High Priotiy Line Inspections were not being conducted by the town at the time of inspection. Multiple issues found at
different high priority lines with inspection.
3)No copy of the permit was available.
4)No record of distances of sewer cleaned. (record was kept indicating that they were cleaned)
5)Spill response plan was outdated and missing multiple components.
6)Sewer map was missing multiple components.
Page 2 of 7
DocuSign Envelope ID: D0E0F55F-B374-44DD-8731-16240B6E8020
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00048
06/20/2024 Collection System Inspect Non Sampling
City of Roxboro
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?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?
Permit is expired and application was put in less than 6 months prior to expiration.
In the process of getting a new back up ORC.
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?Yearly Inspections
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.)
Website
Crystal Shotwell is the overseer of the Oil and Grease inspections.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?
Combined CIPComment:
Page 3 of 7
DocuSign Envelope ID: D0E0F55F-B374-44DD-8731-16240B6E8020
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00048
06/20/2024 Collection System Inspect Non Sampling
City of Roxboro
Routine
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?
Pipe materials, approximate pipe age, pump station capacity, and air release valves are
missing from map.
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?Mailing
Only 1 SSO since 2018.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?
HPL inspections are not being completed as of inspection.Comment:
Spill Response Action Plan Yes No NA NE
Is a Spill Response Action Plan available?
Page 4 of 7
DocuSign Envelope ID: D0E0F55F-B374-44DD-8731-16240B6E8020
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00048
06/20/2024 Collection System Inspect Non Sampling
City of Roxboro
Routine
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?
Plan was from 2010 with multiple old contact numbers/people. Multiple components missing
from 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?
Only one SSO since 2018.Comment:
Lines/Right-of-Ways/Aerial Lines Yes No NA NE
Please list the Lines/Right of Ways/Aerial Lines Inspected:
NC license Plate Agency (811 N Madison Blvd), Roses (1029 N. Madison Blvd), and 418 West Morehead
Street
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?
Cleaning records showed cleanings but lacked distances of line so impossible to determine if
10% cleaning requirment has been met.
418 West Morehea street prioity line had a rubber "boot" near connection that appeared to
have a crack. No leaks or evidence of prior spills was found.
A large tree was sitting across the Roses (1029 N. Madison Blvd) high priority line. No signs of
cracks/spill were found.
Comment:
Manholes Yes No NA NE
Page 5 of 7
DocuSign Envelope ID: D0E0F55F-B374-44DD-8731-16240B6E8020
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00048
06/20/2024 Collection System Inspect Non Sampling
City of Roxboro
Routine
Please list the Manholes Inspected:
Downstream of DMV, Downstream of Roses, Top of forcemain of Williams pump station, Top of force main of
Duncan pump station.
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?
Manhole at the top of the williams pump station forcemain was in poor condition.Comment:
Pump Stations Yes No NA NE
Please list the Pump Stations Inspected:
Brooks, Duncan, Crown Craft, Williams Road
# Number of duplex or larger pump stations in system 12
# 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?0
# A simple one-way telemetry/communication system (auto-dialer) installed?12
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:
Page 6 of 7
DocuSign Envelope ID: D0E0F55F-B374-44DD-8731-16240B6E8020
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00048
06/20/2024 Collection System Inspect Non Sampling
City of Roxboro
Routine
Owner Name?
Pump station identifier?
# Address?
Instructions for notification?
24-hour emergency contact numbers?
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?
Only two portable generators present. Town has vehicles to transport.
# 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?
Generator at Duncan liftstation did not come on when power source was interupted. Staff
indicated that generators are not tested under normal operating conditions.
Comment:
Page 7 of 7
DocuSign Envelope ID: D0E0F55F-B374-44DD-8731-16240B6E8020