WQCS00068_NOD-2019-PC-0161 CEI_20190722

ROY COOPER
:io verifor
IMICI AEL S. REGAN
Secretary
LINDA CULPEPPER
Director
NORTH CAROLINA
Environmental Quality
July 22, 2019
Mike Felts, Interim Director
415 Central Ave, Suite B
Butner, North Carolina 27509
Subject: NPDES Compliance Evaluation Inspection
Notice of Deficiency: NOD-2019-PC-0161
SGWASA Wastewater Collection System
Permit No. WQCS00068
Granville County
Dear Mr. Felts:
On June 26, 2019, Erin Deck of the NC Division of Water Resource's Raleigh Regional Office (RRO) conducted a
compliance evaluation inspection of the South Granville Water and Sewer Authority's (SGWASA) Wastewater
Collection System. The assistance of Gavin Bostian, Robert Jackson, Cody Norwood, Chris Smith and Ray Harris
was appreciated. Please see the inspection summary below:
Permit Information:
A. The most recently issued permit (November 01, 2016) states that South Granville Water and
Sewer Authority operates a wastewater collection system consisting of approximately 114
miles of gravity sewer, approximately 40 miles of force main, and 47 duplex pump stations.
The current permit expires on June 30, 2023. A renewal application should be submitted at
least 180 days prior to expiration. A Copy of the permit was not available on site the day of
the inspection.
Operator information:
A. The collection system is classified as a CS-3. Gavin Bastian is the designated Primary Operator
in Charge (ORC). Robert Jackson is the backup Operator in Responsible Charge (bORC). Both
are certified CS-4 operators.
III. Records:
Documents were reviewed with staff at the Butner Wastewater Treatment plant located at 1000
W H Street, Butner. Findings are described below:
North Carolina Department of environmental Qual ty IDiv sion of Vlater Resources
Raleigh Regional I Office 11628 Mail Service Center Raleigh N. 27699-1628
Phvcir;;l Ariri(acc IAN) Rarrarl nri.ro Patanh r1r 97AnG Q10-7Q1-X)0n

SGWASA Wastewater Collection System
Compliance Evaluation
NOD-2019-PC-0161
Permit No. WQCS00068
A. A Sewer Use Ordinance/Charter was not available for review that addresses sewer
construction, grease control, septic tank installation and discharge by septic tank service
comla_nies. Permit Section 1.3 states 'The Permittee shall establish by ordinance, inter -local
agreement or contract its legal authority to require new sewers be properly constructed; to
ensure proper inspection and testing of sewer mains and service laterals; to address flows from
satellite systems and to take enforcement action as required by Condition 1(4). [G.S. 143-
215.9B; G.S. 143-215.1(f)(1)j"
B. Per SGWASA staff, the person who typically deals with the Fats, Oils and Grease program was
on vacation the day of the inspection. On -site staff could not provide documentation
regarding distribution of educational materials. A Public Education Program for Grease
should be implemented that includes distributing education material to residential and non-
residential users at least twice Per year.. On the day of the inspection, these records were
not produced for review. Permit Section 1.4 states "Fats, Oils and Grease: The Permittee shall
develop and implement an educational fat, oils and grease program that shall include at least
semiannual distribution of educational material targeted at both residential and non-
residential users. The Permittee shall also develop and implement an enforceable fats, oils and
grease program for non-residential users under which the Permittee can take enforcement
against users who have not properly installed, operated and maintained grease traps or grease
interceptors as directed or otherwise violated the terms of the enforcement program
pertaining to fats, oils and grease. 115A NCAC 02T.0108 (b)"
C. Capital Improvement Plan (CIP): An annual budget was available for review. A CIP was not
available for review at the time of the inspection. Permit Section 1.5 states "The Permittee
shall adopt and implement a Capital improvement Plan (CIP) to designate funding for
reinvestment into the wastewater collection system infrastructure. The CIP should address the
short-term needs and long-term "master plan" concepts. The CIP should typically cover a three
to five year period and include a goal statement, description of the project area, description of
the existing facilities, known deficiencies (over a reasonable period) and forecasted future
needs. Cost analysis is integral to the CIP. [G.S. 143-215.9B]"
D. Collection System Map: A map was available on GIS that showed the pipe size, material, flow
direction, and pump stations. This map shall be maintained to be up-to-date, accurate and
comprehensive. Age of pipe lif known) and pump station capacities were missing from the
map (Permit Section II1.3).
E. High -Priority lines: Documentation should be kept that demonstrates that all high -priority
lines are inspected at least twice per year as required by the permit. Permit Section V.4 states
"Inspections of all high priority lines (i.e. aerial line, sub -waterway crossing, line contacting
surface waters, siphon, line positioned parallel to stream banks that are subject to eroding in
such a manner that may threaten the sewer line, or line designated as high -priority in a
permit) shall be performed at least once per every six-month period of time. A list of high -
priority lines is presented as Attachment A and is hereby incorporated into this permit
condition. New high priority lines installed or identified after permit issuance are incorporated
by reference and subject to this permit condition until permit renewal where they shall be
referenced in writing in Attachment A. [15A NCAC 02T .0108 (b)]"
F. Annual inspection: A program should be implemented to ensure that the entire system is
Inspected at least once every year. Records should be kept to reflect this requirement. Permit
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SGWASA Wastewater Collection System
Compliance Evaluation
NOD-2019-PC-0161
Permit No. WQCS00068
Section V.3 states "A general observation by the permittee or its representative of the entire
wastewater collection system shall be conducted at least once per year. [15A NCAC 02T.0108
(b)]"
G. Right -of -Way / Easements: Documentation should be kept that describes all
maintenance/clearingmaintenance/clearing of the systems right-of-way/easements. Permit Section 11.7 states,
"Rights -of -way and/or easements shall be properly maintained to allow accessibility to the
wastewater collection system unless the Permittee can demonstrate the ability to gain
temporary access in an emergency situation where existing land -use conditions do not allow
the establishment and maintenance of permanent occess. In this case, the Permittee shall
continue to observe the lines visually, utilize remote inspection methods (e.g. CCTV) and use
the opportunity of drier conditions to perform further inspections and necessary maintenance.
[15A NCAC 02T .0108 (b)]
H. System Cleaning: The permit requires that at least 10% of the system is cleaned annually, and
the entire system is cleaned every 10 years. SGWASA_should implement a program to ensure
this is done and documentation should be kel2t that describes what portion has been cleaned
when and when future oortions will be cleaned. Permit Section 11.8 states, "The Permittee
shall assess cleaning needs, and develop and implement a program for appropriately cleaning,
whether by hydraulic or mechanical methods, the wastewater collection system. At least 10
percent of the gravity wastewater collection system, selected at the discretion of the ORC, shall
be cleaned each year. Preventative cleaning is not required for sewer lines less than five years
old unless inspection otherwise reveals the need for cleaning or cleaning is required by a sewer
line extension permit. [15A NCAC 02T .0108 (b)]"
Maintenance Records: These were available for review. Records should be kept for all
maintenance done to the system as well as Citizens' complaints.
Spill Response Action Plan: A plan for addressing SSOs was available for review. The plan was
incomplete. Permit Section 11.9 states, "The Permittee shall maintain a Response Action Plan
that addresses the following minimum items;
a. Contact phone numbers for 24•hour response, including weekends and holidays;
b. Response time,
c. Equipment list and spare parts inventory;
d. Access to cleaning equipment;
e. Access to construction crews, contractors and/or engineers;
f. Source(s) of emergency funds;
g. Site restoration and clean up materials; and
h. Post-SSO assessment.
[15A NCAC 02T .0108 (b)]
K. Sanitary Sewer Overflows (SS0s): SSO S-dayreports were not available for review. Any 13ress
releases and public notices associated with the SSOs should be kept with these records
(Permit Sections 111.2 & IV.2).
L. Annual Report:. An annual report should be developed at the end of the calendar/fiscal year
and distributed to users, as described in G.S_ 143-2151C (Section IV.3 of permit).
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SGWASA Wastewater Collection System
Compliance Evaluation
NOD-2019-PC-0161
Permit No. WQCS00068
IV. Collection System Inspection
A. High Priority Lines: The Town's permit lists 48 high priority lines listed with the most recent
permit. The following High Priority Lines were observed during the inspection:
a. 4-inch line at F street
b. 8-inch line at F street: Debris was noted around one of the pylon.
c. 121h Street. Veazy Street: This areal line broke during Hurricane Florence in September
2018. At the time of the inspection, a bypass of this line was still occurring. Please
explain to this office what steps are being taken and the timeline for this aerial to be
replaced.
B. Pump Stations: SGWASA has 47 duplex pump stations.
a. The following pump stations were visited during this site inspection:
L Granville Oaks
ii. Mt. Hope
iii. Rogers Pointe
iv. 11`h & B Street
v. Robertson Creek- The audible and visual alarms were not working at the time
of the inspection.
b. A contingencv plan was not available at the pump stations for review, Permit Section
1.7 states, "The Permittee shall maintain a contingency plan for pump failure at each
pump station. 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. The permittee shall provide
justification for delay in initiating the process for repair or replacement at the
Division's request. If the pump in a simplex pump station serving more than a single
building or pump stations not capable of pumping at a rate of 2.5 times the average
doily flow rate with the largest pump out of service fails, it shall be replaced
immediately. j15A NCAC 02T .0305 (h) (1 )]"
The items underlined above should be addressed in a written response submitted to this office within 30 days
after receiving this Notice of Deficiency. If you have any questions regarding the report or any of the findings,
please contact Erin Deck at: [phone] (or email: Erin.Deck( ncdenr.gov).
ATTACHMENTS
Inspection Checklist
Cc: Central Files w/attachment
Raleigh Regional Office w/attachment
c
Bol
h, L.G., Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
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Compliance Inspection Report
Peril: WOCS00068 Effective: 11/01+16 Expiration: 1?]r31r24 Owner: South Granville Water & Sewer Authority
SOC: Effective: Expiration: Facility: South Granville Water and Sewer Authority (SGWAS
County: Granville 205-C W E St
Region: Raleigh
Contact Person: Gary Michael Yates Title- Utility Superintendent Phone: [phone]
Directions to Facility:
System Classifications: CS3,
Primary ORC: Gavin Owen Bostian
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Certification: 1CO3044 Phone: [phone]
NC0026824 South Granville Water & Sewer Authority - SGWASA WWTP
Inspection pate: 06126/2019 Entry Time: 09 OOAM Exit Time: 02-OOPM
Primary Inspector_ Erin M peck / ]� p jc_ Phone: [phone]
Secondary Inspector(s):UI
Reason for Inspection: Rout ne Inspection Type: Collection System Inspect Non Sampl ng
Per it Inspection Type: Collection system management and operation
Facility Status: ❑ Compliant E Not Compliant
Question Areas:
M.scellaneous Questions General Sewer & FOG Ordinances
Capital Improvement Plan Map Reporting Requirements
Inspect:ons Spill Response Plan Spills
Lines Manholes Pump Stations
(See attachment summary)
Page 1 of 7

Permit: WOCSO0068 Owner - Facility: South Granville Water S Sewer Authority
Inspection Date: 06126l2019 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Inspection Summary
Page 2 of 7

Permit: waCS00068 Owner - Facility: South Granville Water & Sewer Authu;ty
Inspection Date: 0612612019 Inspection Type: Collection System Inspect Non Samplir g Reason for Visit: R out ne
General
Yes No NA NE
Is there a properly designated primary ORC and at least one back-up of proper grade? 0 111:1 El
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? M El El
Does plan indicate if pump parts/new pumps are in spare parts/equipment inventory?
Are newlsignificantly 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 Pennittee applied for renewal? .
Comment: There was not a permit on sie. Records were insufficient.
Sewer and FOG Ordinances
Yes No NA NE
Is Sewer Use Ordinance (SUO) or other Legal Authority available?
❑ 0Ll❑
Does it appear that the Sewer Use Ordinance is enforced?
❑ ❑ ■
Is there a Grease Control Program that legally requires grease control devices?
11❑ ❑ 0
What is the standard grease Iraq cleaning requirement in the FOG ordinance?
Is Grease Control Program enforced via periodic inspections/records review?
0 L1❑ ❑
Is action taken against violators?
■ ❑
# Have satellite systems adopted an equivalent or more stringent ordinance?
Is greaselsewer 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.)
Comment: Shand Thomas is the person who Primarily deals with FOG Program.
She was on vacation the
day of the inse ction and no one on site could assist with getting
this information to DWR staff.
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?
13 .
Does CIP include description of existing facilities?
11■
Does CIP include known deficiencies?
❑ . ❑
Does CIP include forecasted future needs?
El 0
Comment; CIP was not avalibie for review.
Yes No NA NE
Page 3 of 7

Permit; WQCS00068 Owner - facility: South Granville Water & Sewer Authority
Inspection Date: 0612612019 Inspection Type : Collection System Inspect Non Samplkng
Reason for Visit: Routine
Is there a overall sewer system map?
M ❑ ❑ ❑
Does the map include:
Pipe Type (GSIFM)
M ❑ ❑ ❑
Pipe sizes
M ❑ ❑ ❑
Pipe materials (PVC, DIP, etc)
❑ ❑ ❑
Pipe location
❑ ❑ ❑
Flow direction
0 ❑ ❑ ❑
Approximate pipe age
❑ 0 ❑ ❑
Pump station ID, location and capacity
❑ M ❑ ❑
# Force main air release valve location & type
M ❑ ❑ ❑
# Location of satellite C,,nnechons
■ ❑ ❑ ❑
Is the map be',ng updated fir changesradditions within 1 year of activation?
■ ❑ ❑ ❑
Comment: Acie of pipe and pump station capacities were missing from the current map.
Reporting Requirements Yes No NA NE
# Have there been any sewer sp.11s ,n the past 3 years? ❑ ❑ ❑
If Yes. were they reported to the Divis.on if meeting the reportable criteria? ❑ ❑ ❑
It applicable, is there documentation of press releases and public notices issued? ❑ 0 ❑ ❑
Is an Annual Wastewater Performance Report being filed with the Division, if required? ❑ ❑ ❑ M
Is the report being made available to all its sewer customers? ❑ ❑ ❑ 0
# How is it being made available?
Comment: Documents not aval. for review.
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? ❑0 ❑ ❑
Is the annual inspection documented? ❑ 0 ❑ ❑
# Does the system have any high -priority lines/locations? M ❑ ❑ ❑
Are inspections of HPL documented at least every 6 months'? ❑ 0 ❑ ❑
Are new lines being added to the HPL list when found or created? 0 ❑ ❑ ❑
Comment: fulls stem and HPL inspection records were not avalible for review.
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? ❑ M ❑ ❑
Does the plan include
Page 4 of 7

Permit: VMCS00068 Owner - Facility: South Granville Water & Sewer Authc rive
Inspection Elate: 06/2612019 Inspection Type: Collection System Inspect Non Sampl;-2
Reason for Visit. Routine
24-hour contact numbers
❑ . El ❑
Response time
El ■ El 0
Equipment list and spare parts inventory
■
Access to cleaning equipment
El . 0 El
Access to construction crews, contractors, andlor engineers
Source of emergency funds
■
Site sanitation and cleanup materials
■
Post-overflow/spill assessment
El ■ 0 El
Does the Permittee appear to respond within 2 hours of first knowledge of a spill?
Comment: an insufficient Man was avalible to review.
Spills
Yes No NA NE
Is system free of known points of bypass? ■
110
If No, describe type of bypass and location
An aerial line on Veazy street broke during hurrican florence. this line is still being bypassed.
Are all spills or sewer related issues/complaints documented?
# Are there repeated overflowstproblems (2 or more in 12 months) at same location? ❑ ❑ ❑
# If Yes, is there a corrective action plan? 11 El CIE
Comment: Documents were no aval. for review
Lines/Right-of-Ways/Aerial Lines Yes No NA NE
Please list the Lines/Right of WayslAerial Lines Inspected.
12th street
18inonFst
4inonFst
Are right-of-waysleasemenls maintained for full width for access by stafflequipmenl?
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? E 110 ❑
Comment: the 18 in line at 1✓ street had debris piled along the pylon
Manholes
Yes No NA NE
Please list the Manholes Inspected
Random Mhs were inspected. No MH numbers were given to OWR
Are manholes accessible? ■ ❑ ❑ ❑
# Are manhole covers/vents above grade? 0❑ El ❑
Are manholes free of visible signs of overflow? E❑
Are manholes free of sinkholes and depressions?
Page 5 of 7

Permit: WOCSO0068 Owner - Facility: South Granville Water & Sewer Authority
Inspection Dale: 06/2612019 Inspection Type : Coltection System Inspect Non Sampling
Reason for Visit: Routine
Are manhole covers present?
E ❑ ❑
# Are manholes properly seated?
❑ ❑ ❑
# Are manholes in good condition?
❑ ❑ ❑
# Are inverts in good condition?
❑ Cl ❑
Is flow unrestricted in manholes?
❑ ❑ ❑
Are manholes free of excessive amounts of grease?
❑ ❑ ❑
Are manholes free of excessive roots?
N ❑ ❑ ❑
Are manholes free of excessive sand?
0 ❑ ❑ ❑
Are manhole vents screened?
E ❑ ❑ ❑
Are vents free of submergence?
■ ❑ ❑ ❑
Are manholes free of bypass structures or pipes?
N ❑ ❑ ❑
Comment:
Puma Stations
Yes NQ NA NE
Please list the Pump Stations Inspected:
Mt. Hope
Rogers Pointe
Granville Oaks
11Ih & B street
Robertson Creek
# Number of duplex or larger pump stations in system
47
# Number of vacuum stations in system
# Number of simplex pump stations In system
o
# Number of simplex pump stations in system serving more than one building
0
How many pumplvacuum stations have.
# A two-way "auto polling" communication system (SCADA) installed?
47
# A simple one-way telemetry/communication system (auto -dialer) installed?
0
For pump stations inspected
Are they secure with restricted access?
N ❑ ❑ ❑
Were they free of by-pass structureslpipes?
E ❑ ❑ ❑
Were wet wells free of excessive grease/debris?
N ❑ ❑ ❑
# Do they all have telemetry installed?
0 ❑ ❑ ❑
Is the communication system functional?
❑ ❑ ❑
Is a 24-hour notification sign posted ?
❑ ❑ ❑
Does the sign include -
Owner Name?
E ❑ ❑ El
Pump station identifier?
0 ❑ 1111
# Address?
0 ❑ ❑ ❑
Instructions for notification?
N ❑ ❑ ❑
Page 6 of 7

Permit: WOCS00068 Owner - Facility: South Granville Water & Sewer Authority
Inspection Date: 06126126t9 Inspection Type • Collection System Inspect Non Sampi ng
Reason for Visit: Roub"
24-hour emergency contact numbers?
■
Are audio and visual alarms present?
■ ❑ 11
Are audio and visual alarms operable?
■11
# Is there a backup generator or bypass pump connected?
If tested during inspection, did it function properly?
13
Is the back-up system tested at least bi-annually under normal operating conditions?
E
# 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/Sta(fNehiclesletc) are included in Plan?
Al Does Permitlee have the approved percentage of replacement simplex pumps?
Is recordkeeping of pump station inspection and maintenance program adequate?
■ 11 U
❑o pump station logs include at a minimum
Inside and outside cleaning and debris removal?
Inspecting and exercising all valves?
■ El El 0
Inspecting and lubricating pumps and other equipment?
. ❑ ❑
Inspecting alarms, telemetry and auxiliary equipment?
■ ❑ El 0
Comment: PS all lacked a contingency Ian
Roberston Creek PS alarm was not workinci
Page 7 of 7