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Home My WebLink AboutWQCS00112_NOV-2019_PC-0676_20191003ROY COOPER Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Director NORTH CAROLINA Environmental Quality October 3, 2019 Certified Mail # 70171450 0001 6450 4786 Return Receipt Requested Michael Boaz, Town Manager Town of Pilot Mountain 124 West Main Street Pilot Mountain, NC 27041 Subject: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY Tracking Number: NOV-2019-PC-0676 Compliance Evaluation Inspection Report Pilot Mountain Wastewater Collection System Permit WQCS00112 Surry County Dear Mr. Boaz: Gary Hudson of the Division of Water Resources Winston-Salem Regional Office met with Mark King, Wastewater Treatment Plant Operator, on August 2, 2019 and Ronald Holt, Public Works Director, on September 23, 2019 to conduct a Compliance Evaluation Inspection of the Pilot Mountain Wastewater Collection System. The pump stations were inspected during the August site visit. Out of the 19 duplex pump stations inspected, 11 of them had one of the pumps out of operation for extended periods of time. The records review was conducted during the September visit. At that time, there were no records available for review for calendar year 2019 other than the pump station inspection reports kept by the wastewater treatment plant staff. Therefore, a Notice of Violation/Intent to Issue Civil Penalty is being issued for the noted violations of North Carolina General Statute (G.S.) 143-215.1 and the facility's NPDES WW Permit. Pursuant to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) may be assessed against any person who violates or fails to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S. 143-215.1. If you wish to provide additional information regarding the noted violation, request technical assistance, or discuss overall compliance please respond in writing within ten (10) business days after receipt of this Notice. A review of your response will be considered along with any information provided on the submitted Monitoring Report(s). You will then be notified of any civil penalties that may be assessed regarding the violations. If no response is received in this Office within the 10-day period, a civil penalty assessment may be prepared. NORTH CARPLINAD EIQ�� North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1 450 Hanes Mill Road, Suite 300 1 Winston-Salem, North Carolina 27105 336.776.9800 Remedial actions should have already been taken to correct this problem and prevent further occurrences in the future. The Division of Water Resources may pursue enforcement action for this and any additional violations of State law. If the violations are of a continuing nature, not related to operation and/or maintenance problems, and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by Consent. If you have any questions concerning this matter or to apply for an SOC, please contact Gary Hudson or me at the Winston-Salem Regional Office at 336-776-9800. Sincerely, EDocuSigned by: LUn. -T Sti1Gff' 145849E225C94EA... Lon T. Snider, Regional Supervisor Water Quality Regional Operations Section Winston-Salem Regional Office Division of Water Resources, NCDEQ Enclosures — Inspection Report CC: Winston-Salem Regional Office Laserfiche Files Compliance Inspection Report Permit: WQCS00112 SOC: County: Surry Region: Winston-Salem Contact Person: Ronald Holt Directions to Facility: Effective: 04/01/17 Expiration: 03/31/25 Owner: Town of Pilot Mountain Effective: Expiration: Facility: Pilot Mountain Collection System 126 W Main St System Classifications: CS1, Primary ORC: Ronald Lynn Holt Secondary ORC(s): On -Site Representative(s): Title: Public Works Dir Certification: 986654 Related Permits: NC0026646 Town of Pilot Mountain - Pilot Mountain WWTP Inspection Date: 09/23/2019 Entry Time: 04:OOPM Primary Inspector: Gary Hudson Secondary Inspector(s): Pilot Mountain NC 27041 Phone: 336-934-3303 Phone: 336-934-3303 Exit Time: 05:OOPM Phone: 336-776-9694 Reason for Inspection: Routine Inspection Type: Collection System Inspect Non Sampling Permit Inspection Type: Collection system management and operation Facility Status: Compliant Not Compliant Question Areas: Miscellaneous Questions General Sewer & FOG Ordinances Capital Improvement Plan Map Reporting Requirements Inspections Spill Response Plan Pump Stations (See attachment summary) Page 1 of 6 Permit: WQCS00112 Owner - Facility: Town of Pilot Mountain Inspection Date: 09/23/2019 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Inspection Summary: The following permit conditon violations were noted: 'At the time of the inspection a specific pump station contengiency/failure plan along with a spare parts inventory was not provided for review. At the time of the inspection a copy of the pemit was not provided for review. 'At the time of the inspection a Sewer Use Ordinance and FOG ordinance was not provided for review. No educational tools were provided as well. 'At the time of the inspection there was no Capital Improvement Plan available for review. 'An overall sewer system map was not available during the inspection. 'No records were available for calendar year 2019. An Annual Performance Report was not available for inspection. SSO records were not available during the inspection. 'The only records that were available during the two inspections was the daily pump station inspection logs. There were no maintenance logs for 2019 available for review. There were no inspection records for high priority lines. 'A Spill Response Action Plan was not provided for inspection. 'All 19 pump stations were inspected on August 2, 2019. The following duplex pump stations had one of the pumps out of service: Station 2, Station 4, Station 5, Station 6, Station 10, Station 11, Station 12, Station 14, Station 18, Station 16, and Station 17. 'It was noted during the inspection that the 24-hour emergency contact numbers was incorrect. 'Inspection records for pump staions were available and kept by the wastewater treatment plant staff. However, pump station maintenance logs were not available. There were no cleaning logs available to document that 10 % of the sewer lines had been cleaned. Page 2 of 6 Permit: WQCS00112 Owner - Facility: Town of Pilot Mountain Inspection Date: 09/23/2019 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine General Yes No NA NE Is there a properly designated primary ORC and at least one back-up of proper grade? 0 ❑ ❑ ❑ Are logs being reviewed by the system management or owner on a regular basis? ❑ ❑ ❑ # What is that frequency? # 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? ❑ ❑ ❑ Comment: At the time of the inspection a sDecific DumD station contenaiencv/failure Dlan alona with a sDare parts inventory was not provided for review. At the time of the inspection a copy of the pemit was not provided for review. 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? 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.) No FOG educational tools were provided for review. Comment: At the time of the inspection a Sewer Use Ordinance and FOG ordinance was not provided for review. No educational tools were provided as well. 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? ❑ ❑ ❑ Page 3 of 6 Permit: WQCS00112 Owner - Facility: Town of Pilot Mountain Inspection Date: 09/23/2019 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Comment: At the time of the inspection there was no Capital Improvement Plan available for review. Map Yes No NA NE Is there a overall sewer system map? ❑ ❑ ❑ Does the map include: Pipe Type (GS/FM) ❑ 0 ❑ ❑ Pipe sizes ❑ 0 ❑ ❑ Pipe materials (PVC, DIP, etc) ❑ 0 ❑ ❑ Pipe location ❑ ❑ ❑ Flow direction ❑ ❑ ❑ Approximate pipe age ❑ 0 ❑ ❑ Pump station ID, location and capacity ❑ 0 ❑ ❑ # Force main air release valve location & type ❑ 0 ❑ ❑ # Location of satellite connections ❑ 0 ❑ ❑ Is the map being updated for changes/additions within 1 year of activation? ❑ 0 ❑ ❑ Comment: An overall sewer system map was not available during the inspection. Reportinq 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? Comment: No records were available for calendar year 2019. An Annual Performance Report was not available for inspection. SSO records were not available during the inspection. 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? ❑ 0 ❑ ❑ Comment: The only records that were available during the two inspections was the daily pump station inspection logs. There were no maintenance logs for 2019 available for review. There were no inspection records for high priority lines. There were no cleaning logs available to document that 10 % of the sewer lines had been cleaned. Page 4 of 6 Permit: WQCS00112 Owner - Facility: Town of Pilot Mountain Inspection Date: 09/23/2019 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine 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? ❑ ❑ ❑ Does the plan include: 24-hour contact numbers ❑ 0 ❑ ❑ Response time ❑ 0 ❑ ❑ Equipment list and spare parts inventory ❑ 0 ❑ ❑ Access to cleaning equipment ❑ 0 ❑ ❑ Access to construction crews, contractors, and/or engineers ❑ 0 ❑ ❑ Source of emergency funds ❑ 0 ❑ ❑ Site sanitation and cleanup materials ❑ 0 ❑ ❑ Post-overflow/spill assessment ❑ ❑ ❑ Does the Permittee appear to respond within 2 hours of first knowledge of a spill? ❑ ❑ ❑ Comment: A Spill Response Action Plan was not provided for inspection. Pump Stations Yes No NA NE Please list the Pump Stations Inspected: All 19 pump stations were inspected on August 2, 2019. The following duplex pump stations had one of the pumps out of service: Station 2, Station 4, Station 5, Station 6, Station 10, Station 11, Station 12, Station 14, Station 18, Station 16, and Station 17. # Number of duplex or larger pump stations in system 19 # 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? 0 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? ❑ ❑ ❑ Page 5 of 6 Permit: WQCS00112 Owner - Facility: Town of Pilot Mountain Inspection Date: 09/23/2019 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Instructions for notification? ❑ ❑ ❑ 24-hour emergency contact numbers? ❑ 0 ❑ ❑ Are audio and visual alarms present? 0 ❑ ❑ ❑ Are audio and visual alarms operable? ❑ ❑ ❑ # Is there a backup generator or bypass pump connected? ❑ 0 ❑ ❑ 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? It was noted during the inspection that the 24-hour emergency contact numbers was incorrect. # 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? ❑ 0 ❑ ❑ Inspecting and exercising all valves? ❑ 0 ❑ ❑ Inspecting and lubricating pumps and other equipment? ❑ 0 ❑ ❑ Inspecting alarms, telemetry and auxiliary equipment? ❑ 0 ❑ ❑ Comment: Inspection records for pump staions were available and kept by the wastewater treatment plant staff. However, pump station maintenance logs were not available. Page 6 of 6