WQCS00236_NOD 2019-PC-0163 & Compliance Evaluation Inspection_20190718

U I,
ROY COOPER
Gm•er nor
MICHAEL S. REGAN
Sarr,'f4 f
LINDA CULPEPPER
Djnnct•:r
:Mayor K. Owen Scott
Town of Littleton
PO Box 87
Littleton, NC 27850
Env1ronnt!ntc1 f�,ceitr
July 18, 2019
Subject: Notice of Deficiency and Compliance Evaluation Inspection
Case No.: MOD-2019-PC-0163
Littleton Collection System
Collection System Permit 'pro: WQCS00236
Halifax County
Dear Mayor Scott:
On June 17, 2019, Cheng Zhang of the Raleigh Regional Office (RRO) Division of Water
Resources conducted a Compliance Evaluation Inspection of the subject facility. The assistance
and cooperation of Mr. Keith Hamm, Operator in Responsible Charge (ORC), were very helpful
and appreciated. A checklist of items is enclosed with this letter. During the inspection the
following items were noted:
1.) Permit was renewed on May 2, 2018 and became effective on June 1, 2018. Town of
Littleton collection system is Class I collection system (CS-1). It has approximately 12 miles
of gravity sewer and I mile of force main, and G duplex pump stations. It -was noted that
Mr. Nathaniel Kimble was invalid to be the backup ORC, the Town must designate a
backup ORC within 120 days from the date when this inspection was conducted.
2.) The Town had developed and implemented a Capital Improvement Plan (CIP) for the
collection system. The plan covers a period to from 2013 to 2023. The plan was found
adequate.
3.) The Town's collection system map was reviewed during the inspection, please add the
following components to the map: flow direction, pipe size, pipe material, approximate
pipe age, and each pump station identification, location, and capacity.
4.) The facility has a grease educational program. Grease educational materials are sent to all
customers with bills monthly. The ORC checks grease traps at four local restaurants
periodically. Please be reminded that such inspections need to be documented.
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5.) The collection system has 6 duplex pump stations, 5 of them are equipped with simple
telemetry and audible:`visual high water alarms. Hwy 158 Nest pump station only has
audible visual alarms. All 6 pump stations were visited during the inspections. Following
issues were noted:
• Hwy 158 Nest pump station had not been inspected at the frequency required
by the permit (daily'), inspections of this pump station had not been documented;
RRO strongly recommends that simple telemetry device be installed at this
pump station.
• One or both high water alarms ►vere not functioning at all pump stations at the
time of inspection (see comment in inspection report).
6.) Two aerial lines were observed during the inspection and found in good condition.
7.) A review of records and logbooks indicate the following;
a. Records are maintained adequately for sewer line maintenance and cleaning; 6501
feet of gravity sewer lines were cleaned in 201 S.
b. High priority lines were inspected and casement was maintained as required by
the permit.
c. There have been no reportable Sanitary Sewer Overflows (SSOs) since the last
inspection.
S.) The Town's Response Action Plan for SSO was found adequate.
Please respond to RRO in writing ivithin 30 days of receipt of this letter regarding Items 1,
3, 4, and 5. If you have any questions regarding the attached report or any of the findings, please
contact Cheng Zhang at: [phone] (or email: chene.zhantyrdncdennuov).
Rick Bolich, L.G.
Assistant Supervisor
Division of Water Resources
Raleigh Regional Office
Attachments: Compliance Inspection Report
c: Central Files %�--attachment
Raleigh Regional Office wattachment
Keith Hamm, Town of Littleton, A- attachment (electronic copy only)

Compliance Inspection Report
Permit: WOCS00236 Effective: 06101/18 Expiration: 05/31/26 Owner: Town of Littleton
SOC: Effective: Expiration: Facility: Littleton Collection System
County: Halifax PO Box 87
Region: Raleigh
Littleton NC 27850
Contact Person: Harold Keith Hamm Title: Public Works Director Phone. [phone]
Directions to Facility:
System Classifications: CS1,
Primary ORC: Harold Keith Hamm Certification: 991224 Phone: [phone]
Secondary ORC(s):
On -Site Representative(s)-
Ref-Wed Permits:
NCO025691 Town of Littleton - Littleton WWTP
Inspection Date: 0611712019 EntryTime: 10 00AM Exit Time- 01 0C.PNI
Primary Inspector: Cheng Zhang Phone: [phone]
Secondary Inspectors):
Reason for Inspection: Routine Inspection Type: Collection System Inspect Non Sampling
Permit Inspection Type: Collection system management and operal en
Facility Status: Compliant Not Compliant
Question Areas:
M,scellaneous Questions M General
Sewer &FOG Ordinances
Capital Improvement Plan M Nlap Reporting Requirements
Inspections 0 Spill Response Plan Lines
Pump Stations
(See attachment summary)
Page I of 7

Permit. WQC5'0236 Owner • Facility: Town of irittleton
Inspection pale: 06717,7019 Inspection Type : Cdlectxn System Inspect Nan Sampling Reason for Visit: Routine
General
Is [here a property designated primary ORC and at least one back-up of proper grade?
Yes No NA NE
❑ 0 ❑ 11
Are logs being reviewed by the system management or owner on a regular basis?
M on
# what is that frequency?
weekly
# Are there any issues being addressed currently or any n the planning stages?
0❑ M
Is there a specific pump failure plan ava table for all pump stations?
M ❑ ❑ 11
Does plan indicate if pump parts/new pumps are in spare parts equipment inventory?
0❑ ❑ ❑
Are newlsignifiicantly upgraded pump stations equipped with anti -corrosion matey als?
Does the permittee have a copy of their permit?
■ ❑ 1:1 El
# Is permit expiring within the next 6 months?
1:1■ 1:1 El
If Yes. has the Permittee applied for renewal?
❑ El ■ ❑
Comment: The status of backup ORC Mr. Nathaniel Kimble in RIMS is "invalid" due to a past due annual
certification renewal fee. Current Permit expires om May 31 2026.
Sewer and FOG Ordinances
Yes No NA NE
Is Sewer Use Ordinance (SUO) or other Legal Authority ava table? ■ ❑
El 11
Does it appear that the Sewer Use Ordinance is enforced? ■
Is there a Grease Control Program that legally requires grease control devices?
What 's the standard grease trap cleaning requirement in the FOG ordinance? Not less etten than
every 30 days
Is Grease Control Program enforced via periodic inspectionslrecords review? 01111
Is action taken against violators? ❑ ❑ ■
# Have satellite systems adopted an equivalent or more strngent ordinance? .
Is greaselsewer education program documented with req'd customer distribution?
# Are other types of education tools used like websites. booths. special meetings. etc? ❑ M EJ ❑
If Yes. what are they? (This can reduce mailing to annual )
Comment: FOG educational information is pHnted on utilfty bills and sent to customers monthly The ORC
checks grease trans/interceptors from 4 restaurants geriodically,such inspections were not
documented.
Capital Improvement Plan
Yes No NA NE
Has a Capital (CIP) or System Improvement Plan been developed and adopted? . ❑ ❑
El
Is it designated for wastewater only or does it have a dedicated section ■
El 1:10
Does CIP cover three to rve year period of earmarked improvements? ■ ❑
Does CIP include descriptirsn of project area? ■ ❑ ❑ ❑
Does CIP include description of existing facilities? ■ ❑ ❑
Does CIP include known clef dencies? ■ ❑
Does CIP include forecasted future needs? . ❑ ❑
Page 3 of 7

Permit: w4C500236 owner - Facility:TewnofLmleton
inspection Date: 06117/2019 Inspection Type : Collection System Inspect Non sampi:ng
Reason for Visit: Routine
Comment: The CIP appears adequate.
Mau
Yes No NA NE
Is there a overall sewer system map?
■
Does the map include:
Pipe Type (GS1FN1)
El . El 0
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
❑ ■ ❑ El
# Location of satellite connections
■ El
Is the map being updated for changesladditions within 1 year of activation?
■ El El
Comment: The mans has not been updated since 2012. Bacon Road Dump station was not shown on the
man.
Reporting Recluirements
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 criterial ■
If applicable, is there documental on of press releases and public notices issued? .
Is an Annual Wastewater Performance Report being riled with the -3ivision, if required? ❑ ❑ E ❑
Is the report being made available to all its sewer customers? ❑ El . ❑
# How is it being made available?
Comment. No SSOs reported in the past three years.
Ins ections
Yes No NA NE
Are adequate maintenance records maintained? ■ ❑
Are pump stations being inspected at the required frequency? . ❑
11
# 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? ■11❑
El
Is the annual inspection documented? El .
# Does the system have any high -priority lines/localions? .
El El El
Are inspections of HPL documented at least every 6 months? ■
Are new lines being added to the HPL list when found or created"? ❑ El ■
El
Comment: Hwy 158 West -RUMP station is notequipped with either SCADA or simple telemetrV, therefore
requires daily inspection, No records show that the lift station has been visited daily.
Spill Response Action Plan
Yes No NA NE
Page 4 of 7

Permit: VJOCS00236 Owner - facility: Town of Ltiletan
Inspection Dale: 0611712019 Inspection Type : Ccllection System Inspect Non Sampling Reason for Visit: Routine
Is a Spill Response Action Plan available? ■ ❑ ❑ ❑
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 eng-veers
■ ❑
Source of emergency funds
■ El 0 El
Site sanitation and cleanup materials
■
Post-overtlowlspill assessment
■ ❑ ❑
Does the Permittee appear to respond within 2 hours of first knowledge of a spill?
❑ 0 ❑
Comment: The Plan aviprears adequate.
Lines/Right-of-Ways/Aerial Lines
Yes No NA NE
Please list the Lines/Right of Ways/Aerial Lines Inspected
1. 4-inch force main coming out of West Littleton pump station crossing a stream (in good condition, no
pillars),
2, 6-inch force main coming out of Warren Street pump station cross ng a stream (in good condition, no
pillars).
Are right-of-waysleasemenls maintained for full width for access by staff/equipment?
0❑
If No. give details on temporary access
Is maintenance documented? ■
0 On
Are gravity sewer cleaning records available? ■
11 Elm
Has at least 10% of lines older than 5 yrs been cleaned annually'? ■ ❑ ❑
11
Were all areasilines inspected free of issues? N
Comment:
Pump Stations
Yes No NA NE
Please list the Pump Stations Inspected
1, Bacon Road
2. Church Street
3. Hwy 158 West
4_ McIver School
5 Warren Street
6. 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 o
How many pumpivacuum stations have
Page 5 of 7

Permit: VVQCS00236 Owner - Facility: Town cl Littleton
Inspection pate: 06t17/2019 Inspection Type : Collection System Inspect Non Sampi " 3
Reason for Visit: R'!-A ie
# A two-way "auto polling" communication system (SCADA) installed)
_
# A simple one-way lelemetrylcommunication system (auto -dialer) installed?
6
For pump stations inspected
Are they secure with restricted access?
■ ❑ ❑ ❑
Were they free of by-pass structuresipipes?
■ ❑ ❑ ❑
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?
■ ❑ ❑ ❑
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's
❑ . ❑ ❑
# If Yes, is there a distribution plan?
❑ ❑ ■ ❑
If Yes, what resources (Units/Staff/Vehicles/etc) are included In Plan?
# Does Permiltee have the approved percentage of replacement simplex pumps'
❑ ❑ ❑
Is recordkeeping of pump station inspection and maintenance program adectuateo
❑ ■ ❑ ❑
Oo 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?
. ❑ ❑ ❑
Page 6 of 7

permit WOCS00236 Owner - Facility: Town of Littleton
Inspection Date: 0611712019 Inspection Type : Ccllecuon System Inspect Non Sampling Reason for Visit: routine
Comment. Rwy 158 pump station only has audible/visual alarms. inspections of this lift station has not been
documented.
Alarms were found not operable at all Dump stations
1. Bacon Road: visual alarm not operable
2. Church Street, visual and audible alarms not operable
3. Hwy 158 West. visual alarm not operable
4. McIver School: visual alarm not operable
5. Warren Street._ audible alarm not operable
6 West Littleton: visual alarm not operable
Telemetries at five Dump stations were found operable.
Page 7 of 7