WQCS00236_2024 Compliance Evaluation Inspection_20241017

October 17, 2024
Heidi Hogan, Mayor
Town of Littleton
PO Box 87
Littleton, NC 27850

Subject: Compliance Evaluation Inspection
Littleton Collection System
WWCS Permit WQC00236
Halifax County

Dear Mayor Hogan,

On September 18, 2024, Kevin Fowler from the Raleigh Regional Office conducted an
inspection of the Town of Littleton wastewater collection system to evaluate compliance with the
operation and maintenance of the subject wastewater collection system permit. The cooperation
and assistance of David Scott (ORC) during the inspection were greatly appreciated.

Our records indicate the wastewater collection system consists of approximately 12 miles of
gravity sewer, approximately 1 mile of force main, and 6 duplex pump stations.

The subject permit is set to expire on 5/31/2026. This is a reminder to the permittee that a
renewal application should be 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 period from the last inspection, there
have been 7 SSOs from the town’s collection system with an estimated volume of 60,800
gallons, of which 57,800 gallons reached surface water. Most of the incidents were
caused from the pump station located on Church Street. There are plans in the capital
improvement plan to alleviate this issue. No fish kills were reported because of the SSO
events.
2. Fats, Oils and Grease Program. The permittee has not 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. During the
inspection, town staff indicated that FOG material is posted on the town website as
Docusign Envelope ID: C3F40A3D-0570-438C-87D0-323F1A519578

Town of Littleton, WQCS00236
10/17/2024

Page 2 of 4

well at a local fire station kiosk; however, no proof was available for annual mailing
of educational material. Town staff indicated that they knew the mailings had been sent
out but could not supply proof. 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.
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: Bacon
Road, Church Street, Hwy 158 West, McIver School, Warren Street, and West Littleton.
The inspector’s observations noted in the next 5 items below refer to the 6 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 Bacon Road, and
Warren Street 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. After the inspection, the ORC indicated that repairs
had been made by Spectrum to resolve the issues with the one-way telemetry auto-
dialers.
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, no logs of pump station inspection were present for the
Hwy 158 lift station. The permit states that the permittee shall develop and implement a
routine pump station inspection and maintenance program which shall include “verifying
Docusign Envelope ID: C3F40A3D-0570-438C-87D0-323F1A519578

Town of Littleton, WQCS00236
10/17/2024

Page 3 of 4

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: Church Street (Gravity), Church Street (Force Main), Warren Street
(Gravity), and Warren Street (Force Main). Proper inspection logs and documentation
were provided by the ORC to indicate that these HPL had been inspected at the frequency
required by the permit. 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 provided
by the permittee. 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 09/18/2024 (day of inspection). The
last reportable SSO occurred on 6/27/2023.
16. Comprehensive Sewer Map. The permittee maintains an up-to-date comprehensive map
of its sewer collection system. The map did not approximate pipe age or force main
air release valve location and type. The ORC indicated that they were not sure if they
had any force main air release valves. These requirements are required as covered in 15A
NCAC 02T .0108 (b).

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

Docusign Envelope ID: C3F40A3D-0570-438C-87D0-323F1A519578

Town of Littleton, WQCS00236
10/17/2024

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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 E. 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
David Scott - ORC
Docusign Envelope ID: C3F40A3D-0570-438C-87D0-323F1A519578
Compliance Inspection Report
Permit:WQCS00236 Effective:06/01/18 Expiration:05/31/26 Owner :Town of Littleton
SOC:
Contact Person:
Region:
County:
Directions to Facility:
Halifax
Raleigh
Heidi G Hogan
Effective:Expiration:Facility:Littleton Collection System
PO Box 87
Littleton NC 278500087
Title:Phone:[phone]Mayor
Secondary ORC(s):
Phone:Certification:Primary ORC:
CS1,System Classifications:
On-Site Representative(s):
Related Permits:
NC0025691 Town of Littleton - Littleton WWTP
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
09/18/2024 10:00AM 02:00PM
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
Docusign Envelope ID: C3F40A3D-0570-438C-87D0-323F1A519578
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00236
09/18/2024 Collection System Inspect Non Sampling
Town of Littleton
Routine
Inspection Summary:
Page 2 of 7
Docusign Envelope ID: C3F40A3D-0570-438C-87D0-323F1A519578
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00236
09/18/2024 Collection System Inspect Non Sampling
Town of Littleton
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?Weekly
# 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 expires May 31, 2026.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.)
The information is posted at the local fire station kiosk.
Town representative indicated that the mailings are sent out with the water bill multiple times
per year; however, no documentation or proof would be provided of this.
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: C3F40A3D-0570-438C-87D0-323F1A519578
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00236
09/18/2024 Collection System Inspect Non Sampling
Town of Littleton
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?
Paper and GIS map available. Map did not include pipe age or air release valve location. The
ORC indicated that he was not sure if any air release valves were present in the sytem.
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?N/A
Annual wastewater report is not sent out to customers or division.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?
Overall maintenance records are not being maintained. ORC indicated that entire system is
viewed yearly within nomal operations and traveling around town. All right of ways are
maintained yearly.
Comment:
Spill Response Action Plan Yes No NA NE
Is a Spill Response Action Plan available?
Page 4 of 7
Docusign Envelope ID: C3F40A3D-0570-438C-87D0-323F1A519578
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00236
09/18/2024 Collection System Inspect Non Sampling
Town of Littleton
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?
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?
222 Oak Street is the "West Littleton" lift station. During heavy storm events the lift station has
been the source of multiple SSO's in the past five years. There are plans in place in the
capital improvement plan to upgrade this lift station.
Comment:
Lines/Right-of-Ways/Aerial Lines Yes No NA NE
Please list the Lines/Right of Ways/Aerial Lines Inspected:
Church Street Gravity and Forcemain (HPL). Warren street gravity and forecmain (HPL).
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?
Bio-nomic services has cleaned 64,450 linear feet of sanitary sewer lines in the past year.
Records of in-house line cleaning have only started recently. More than 10% has been
cleaned in the past year.
Comment:
Manholes Yes No NA NE
Please list the Manholes Inspected:
LNC23, LNC 33, and LNC 49.
Are manholes accessible?
# Are manhole covers/vents above grade?
Page 5 of 7
Docusign Envelope ID: C3F40A3D-0570-438C-87D0-323F1A519578
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00236
09/18/2024 Collection System Inspect Non Sampling
Town of Littleton
Routine
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 LNC33 had a small amount of roots present.Comment:
Pump Stations Yes No NA NE
Please list the Pump Stations Inspected:
Bacon Road, Church Street, Hwy 158 West, McIver School, Warren Street, West Littleton.
# 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?0
# A simple one-way telemetry/communication system (auto-dialer) installed?6
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?
Page 6 of 7
Docusign Envelope ID: C3F40A3D-0570-438C-87D0-323F1A519578
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00236
09/18/2024 Collection System Inspect Non Sampling
Town of Littleton
Routine
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?
# 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?
Pump station logs are kept in a central locationComment:
Page 7 of 7
Docusign Envelope ID: C3F40A3D-0570-438C-87D0-323F1A519578