WQCS00068_NOD-2019-PC-0161 Response_20190822

NC Dept of Environmental Quality
AUG 2 2 2019
Raleigh Regional Office
South Granville Water and Sewer Authority
415 Central Ave, Suite B Butner, NC 27509
August 22, 2019
Rick Bolick, L.G., Assistant Regional Supervisor
Water Quality Regional Operations Section
11628 Mail Service Center
Raleigh, NC 27699-1628
Re: Response to NOD-2019-PC-0161: South Granville Water and Sewer Authority -
Permit No. WQCS00068
Mr. Bolich:
An NPDES Compliance Evaluation Inspection was conducted on June 26, 2019 of the South Granville
Water and Sewer Authority's (SGWASA) wastewater collection system. Per your letter to Interim
Director Mike Felts dated July 22, 2019, the inspection identified several items that needed to be
addressed in a written response and submitted to you within 30 days after receiving the Notice of
Deficiency on July 22, 2019. The responses below are in order of those found within the Notice of
Deficiency letter.
I Permit Information
A. System Permit: The System Permit is now placed in a readily -accessible area in the SGWASA
Distribution and Collections Superintendent's office.
II Operator Information
A. No response required.
III Records
A. Sewer Use Ordinance: A copy of the Sewer Use Ordinance (SUO) which addresses sewer
construction, grease control, septic installation and discharge by septic tank service companies
is now placed in a readily accessible area in the SGWASA Distribution and Collections
Superintendent's office. SGWASA also has a separate Oil and Grease Ordinance (OGO). A
copy of the OGO is also maintained in the SGWASA Distribution and Collections
Superintendent's office. Both the SUO and the OGO are available online at
http:l/www.sgwasa.org/technical.htm]. A copy of the Sewer Use Ordinance is attached
(Attachment III A).
B. Fats, Oils, and Grease (FOG) Program: During Fiscal Year 2018 (July 1, 2018 to June 30,
2019) educational materials were only provided once to customers, versus the minimum of
twice per year. Remedy: New controls are in place now to ensure all requirements are met in
terms of public education for the FOG Program.
C. SGWASA's CUP: A copy of SGWASA's CIP has been placed in a readily -accessible area in
the SGWASA Distribution and Collections Superintendent's office. A copy of the CIP is
attached (Attachment III C).

III Records (Cont.)
D. Collection System Map: An updated collection system map with the approximate age of the
pipe and the capacities of the pump stations has been created. A copy of the updated map is
attached (Attachment III D).
E. High -Priority Lines: During Fiscal Year 2018 (July 1, 2018 to June 30, 2019), documentation
is unavailable showing that all high -priority lines have been inspected at least twice per year.
Remedy: New controls are in place to ensure all requirements are met in terms of documenting
the inspection activities required as described in System Permit Section VA.
F. Annual Inspection: SGWASA crews performed inspections during Fiscal Year 2018, yet the
information was not documented consistently, thus making it challenging to substantiate
completeness. Remedy: New controls are in place to ensure all requirements are met in terms
of documenting the inspection activities required.
G. Right-Of-Way/Easements: The Right-of-Way/Easements maintenance and clearing was
performed in Fiscal Year 2018 and continues to be performed in Fiscal Year 2019. A copy of
the documentation is attached (Attachment III G).
H. System Cleaning: During Fiscal Year 2018, four miles of sanitary sewer lines were cleaned.
To achieve the goal of cleaning 10% of the system annually, SGWASA's goal is to clean 11.4
miles of sanitary sewer lines. Remedy: New controls are in place to ensure all requirements are
met in terms of collection system cleaning and documentation. Furthermore, SGWASA will
increase the annual system cleaning during the next few years to offset the deficit created in
Fiscal Year 2018.
I. Maintenance Records: No response required.
J. Spill Response Action Plan: The Spill Response Plan has been updated to show all the
required information. A copy of the updated Spill Response Plan is attached (Attachment III J).
K. Sanitary Sewer Overflows (SSO's) 5-Day Reports: The 5-day Reports and any public notices
associated with the SSO's are attached (Attachment III-K).
L. Annual Report: The Annual Reports from FY 2017-2018 and FY 2018-2019 are attached
(Attachment III L). The Annual Reports are distributed to users via the SGWASA website and
can be found at http://www.sgwasa.org/reports.htmi. Additionally, customers are notified on
their utility bill that the Annual Report is available on the SGWASA website.
IV Collection System Inspection
A. High Priority Lines -Veazey Street Timeline for Construction: The Veazey Road Project is
being funded by FEMA. The project includes replacement of the existing aerial sanitary sewer
line. Sealed Bids for the construction of the sanitary sewer line were opened on August 20,
2019. However, only one bid was received. Therefore, the project will be re -advertised and the
bids will be opened on 8/30/19. A contract award is scheduled in September 2019, with a
projected construction completion date in January, 2020.
B. Pump Stations:
a. Robertson Creek Audible and Visual Alarms: A SGWASA pump station mechanic
replaced the faulty audio/visual alarms at the Robertson Creek Pump Station on 8/5/19.
The invoices for the parts that were ordered for this work are attached (Attachment IV B
(a)).
b. Contingency Plans at Pump Stations: All pump stations now have a copy of the
Contingency Plan (Attachment IV B (b)).
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Summary
I am working diligently with staff to create enhanced work processes to improve the operations and
maintenance of the sanitary sewer collection system to ensure we are meeting the requirements of our
Operating Permit.
Following your review please let me know what additional information you may need regarding my
response to the Notice of Deficiency.
Singly, I
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-scott N.chroyer
Executive Director
Cc: Winfred Dancy, Utilities Director SGWASA
Attachments:
III A.: Sewer Use Ordinance
III C.: CIA
III D.: Collection System Map
III G.: Right -Of -Way Maintenance Log Sheet
III J.: Response Action Plan
III K.: Sanitary Sewer Overflow Reports (only with hardcopy submittal)
I11 L.: 2017-18 System Performance Annual Report
IV B. (a): USA BlueBook Invoice
IV B. (b): Contingency Plan for Pump/Power Failure
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