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Home My WebLink AboutWQCSD0213_Compliance Evaluation Inspection_20191031ROY COOPER Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Director Certified Mail # 7017 1450 0001 6450 4861 Return Receipt Requested Oak Ridge Military Academy Attn: Dr. Steve Wilson, Interim Executive Director 2317 Oak Ridge Road Oak Ridge, NC 27310 NORTH CAROLINA Environmental Quality October 31, 2019 Subject: Notice of Violation Deemed Permitted Wastewater Collection System Inspection Violation Tracking No. NOV-2019-PC-0725 System Number WQCSD0213 Oak Ridge Collection System Guilford County Dear Dr. Wilson: On October 3, 2019, Paul DiMatteo of the Division of Water Resources (Division), Winston-Salem Regional Office met with Brian Shreve, Director of Operations, and operations staff Tim and Brandy, to conduct Compliance Evaluation Inspections of the above referenced Deemed Permitted Wastewater Collection System. The inspection consists of (1) a review of documentation demonstrating compliance with 15A NCAC 02T .0403, which regulates wastewater collection systems that are not individually permitted, and (2) an on - site inspection of several collection system components. The attached inspection form notes the areas that were evaluated for the inspection, with notable findings outlined as follows. Summary of Non -Compliance 1. Map - .0403(a)(2) requires a map of the collection system to be developed and maintained. Although previous inspections noted an adequate map was available, the operations staff could not locate the map during the inspection. Please locate the existing map or have a new map drawn. 2. Pump Station Inspections - .0403(a)(4) requires pump stations not connected to a telemetry system to be inspected every day. There is one small pump station behind the barber shop building which is inspected occasionally with maintenance activities documented, but it should be checked every day and those checks also documented. 3. High Priority Line Inspections — .0403(a)(5) requires that high priority sewers be inspected every 6 months and the inspections documented. Operators said that they see the aerial line several times per week but the inspections are not documented. 4. General Observation - .0403(a)(6) requires a general observation of the entire collection system to be conducted once per year and the inspections documented. Documentation of such inspections were not available during the inspection. D E Q�� North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1 450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105 Noah CaaouNA ^ n.P. MorMwL.IOWHV� 336.776.9800 5. Grease Control - .0403(a)(8)(B) requires a grease control program to be in place that includes bi-annual distribution of grease educational materials to users of the collection system. As the only significant grease contributor is the food hall, the inspector recommended posting signs about not pouring grease down the drain in the kitchens. 6. Documentation - .0403(a)(10) requires documentation to be kept showing compliance with the other sections of the Rule. As discussed above most documentation was missing. Site Inspections 1. Pump Stations —The simplex pump station behind the barber shop area was inspected. The inspector noted that there were no operable alarms. The pump station should have at least an operable audible and visual high water level alarm, and the alarm should be checked periodically to ensure operation. 2. High Priority Lines —The high priority line near the wastewater treatment plant was inspected and no issues were noted. Requested Response Within 30 days of receipt of this letter, please submit a plan to address the violations noted above for review. If you should have any questions, please do not hesitate to contact Paul DiMatteo at (336) 776-9691 or our office at (336) 776-9800. Sincerely, DocuSigned by: 945B49E225C94EA... Lon T. Snider, Regional Supervisor Water Quality Regional Operations Section Winston-Salem Regional Office Division of Water Resources, NCDEQ Enclosures — Inspection Report, Copy of 15A NCAC 02T .0403 CC: DWR Laserfiche Files Permit: WQCSD0213 SOC: County: Guilford Region: Winston-Salem Contact Person: John Haynes Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): Related Permits: Compliance Inspection Report Effective: 03/01/00 Expiration: Owner: Oak Ridge Military Academy Effective: Expiration: Facility: Oak Ridge Military Academy Collection System Inspection Date: 10/03/2019 Primary Inspector: Paul DiMatteo Secondary Inspector(s): Title: EntryTime: 10:OOAM Certification: Phone: 336-643-4131 Ext.144 Phone: Exit Time: 11:30AM Phone: 336-776-9691 Reason for Inspection: Routine Inspection Type: Collection System Inspect Non Sampling Permit Inspection Type: Deemed permitted collection system management and operation Facility Status: ❑ Compliant Not Compliant Question Areas: Miscellaneous Questions General Grease Control Spills/Response Plan Inspections Lines Manholes Pump Stations (See attachment summary) Page 1 of 6 Permit: WQCSD0213 Owner - Facility: Oak Ridge Military Academy Inspection Date: 10/03/2019 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Inspection Summary: Met with Brian Shreve, along with Tim Bullins and Brandy (last name?) to do the inspection. The primary issues are summarized as follows: - Pump should be checked daily and documented. - HPL and general system inspections should be documented. - Should have some form of grease control - we discussed posting signs in the kitchen. Page 2 of 6 Permit: WQCSD0213 Owner - Facility: Oak Ridge Military Academy Inspection Date: 10/03/2019 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine General Yes No NA NE # Is this system a satellite system? ❑ 0 ❑ ❑ # If Yes, what is system name or permit number? Is there a overall sewer system map? ❑ ❑ ❑ Does the map include: 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 ❑ ❑ ❑ Are system maintenance records maintained? ❑ ❑ ❑ Comment: Records - there was a loa sheet next to the seDtic tank/effluent DumD behind the barber sho area. There were not records of other maintenance activities. Maps - the previous inspection said that there was a map, but it was not available during this inspection. According to operators, they had some recent turn over, and in the time since the last inspection the old (now current) operators left and came back, so things were not well organized. Grease Control 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.) For public systems, is there a Grease Control Program via an ordinance/agreement? If Yes, does it require grease control devices at applicable locations? Is the Grease Control Program enforced via periodic inspections/records review? Is action taken against violators? Comment: The onlv maior arease contributor is the food hall. We discussed ways to aet an "education program" together, e.g. signs or training for kitchen employees. Spills and Response Action Plan # Is system free of known points of bypass? If No, describe type of bypass and location # 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? Yes No NA NE ❑■❑❑ ❑■❑❑ ❑❑■❑ ❑❑■❑ ❑❑■❑ ❑❑■❑ Yes No NA NE ■❑❑❑ ❑■❑❑ ❑❑■❑ ❑❑■❑ Page 3 of 6 Permit: WQCSD0213 Owner - Facility: Oak Ridge Military Academy Inspection Date: 10/03/2019 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Are all spills or sewer related issues/complaints documented? 0 ❑ ❑ ❑ # Are there repeated overflows/problems (2 or more in 12 months) at same location? ❑ ❑ ❑ # If Yes, is there a corrective action plan? ❑ ❑ ❑ Is a Spill Response Action Plan available? ❑ ❑ ❑ Is a Spill Response Action Plan available for all personnel? 0 ❑ ❑ ❑ Does the plan include: # 24-hour contact numbers 0 ❑ ❑ ❑ # Response time ❑ ❑ ❑ # Equipment list and spare parts inventory ❑ ❑ ❑ # Access to cleaning equipment ❑ ❑ ❑ # Access to construction crews, contractors, and/or engineers ❑ ❑ ❑ # Source of emergency funds ❑0 ❑ ❑ # Site sanitation and cleanup materials ❑ ❑ ❑ # Post-overflow/spill assessment 0 ❑ ❑ ❑ Comment: Spill response plan - I gave them a copy of what we had in our files during the inspection. As previously mentioned, their own records were not well organized/not available. It should be reviewed and updated. 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? ❑ 0 ❑ ❑ # 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: HPL inspections are reportedly conducted but not documented. Lines/Right-of-Ways/Aerial Lines Yes No NA NE Please list the Lines/Right of Ways/Aerial Lines Inspected: Main aerial line Are right-of-ways and easements maintained for the full width for access? ❑ ❑ ❑ If No, give details on temporary access: Is maintenance documented? ❑ ❑ ❑ Were all areas/lines inspected free of issues? N ❑ ❑ ❑ Comment: Some growth in the ROW but didn't look inaccessable. Growth should be controlled as needed. Manholes Yes No NA NE Page 4 of 6 Permit: WQCSD0213 Owner - Facility: Oak Ridge Military Academy Inspection Date: 10/03/2019 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Please list the Manholes Inspected: Are manholes accessible? 0 ❑ ❑ ❑ # Are manhole covers/vents above grade? 0 ❑ ❑ ❑ Are manholes free of visible signs of overflow? 0 ❑ ❑ ❑ Are manholes free of sinkholes and depressions? 0 ❑ ❑ ❑ Are manhole covers present? 0 ❑ ❑ ❑ # Are manholes properly seated? 0 ❑ ❑ ❑ # Are manholes in good condition? 0 ❑ ❑ ❑ # 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? ❑ ❑ 0 ❑ Are vents free of submergence? ❑ ❑ 0 ❑ Are manholes free of bypass structures or pipes? ❑ ❑ ❑ Comment: Didn't look inside a manhole. Pump Stations Yes No NA NE Please list the Pump Stations Inspected: PS behind barber shop area # Number of duplex or larger pump stations in system 0 # Number of vacuum stations in system 0 # Number of simplex pump stations in system 1 # Number of simplex pump stations in system serving more than one building 1 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 telemetry system functional? ❑ ❑ ❑ Is a 24-hour notification sign posted ? ❑ ❑ ❑ Does the sign include: Owner Name? ❑ ❑ ❑ Page 5 of 6 Permit: WQCSD0213 Owner - Facility: Oak Ridge Military Academy Inspection Date: 10/03/2019 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Pump station identifier? ❑ ❑ 0 ❑ # Address? ❑ ❑ 0 ❑ Instructions for notification? ❑ ❑ 0 ❑ 24-hour emergency contact numbers? ❑ ❑ 0 ❑ Are audio and visual alarms present? ❑ 0 ❑ ❑ Are audio and visual alarms operable? ❑ 0 ❑ ❑ # 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? # 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? ❑ ❑ ❑ Comment: There was a log sheet that the operator signs whenever he looks at the pump station. We talked about making sure to check it daily, logging it, and other requirements. The only pump station is across the street from the main campus. It used to serve 5 buildings but now only the barber shop is in use, it gets very little flow. Page 6 of 6