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Home My WebLink AboutWQCS00312_NOD-2021-PC-0468 CEI_20210913ROY COOPER. Governor ELIZABETH S. BISER Secretary S. DANIEL SMITH Director City of Archdale Attn: Zeb Holden, City Manager P.O. Box 14068 Archdale, NC 27263 NORTH CAROLINA Environmental Quality September 13, 2021 SUBJECT: NOTICE OF DEFICIENCY Tracking Number: NOD-2021-PC-0468 Permit No. WQCS00312 Archdale Collection System Randolph County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Archdale Collection System on August 24, 2021. This inspection was conducted to verify the facility is operating in compliance with the conditions and limitations specified in Collection System Permit No. WQCS00312. A summary of the findings and comments noted during the inspection are provided in the enclosed copy of the inspection report. This inspection was conducted by Division of Water Resources staff from the Winston-Salem Regional Office. The following violation(s) were noted during the inspection: Inspection Area jDescriPtion of Violation Part III. Records Paragraph 1. Records Insufficient records of records review, annual general observations, and pump station inspections. You are hereby reminded that pursuant to NC General Statute 143-215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000) may be assessed against any person who violates or fails to act in accordance with the terms, conditions, or requirements of a permit issued pursuant to NC General Statute 143-215.1. 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 (SOC). NORTH D E Dopartmem of Envimnmomni au.i` North Carolina Department of Environmental Quality Division of Water Resources Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105 336.776.9800 If you have any questions or concerns, please do not hesitate to contact Ron Boone with the Water Quality Regional Operations Section in the Winston-Salem Regional Office at 336-776- 9800. Attachments: Compliance Inspection Report cc: Laserfiche LD_E NORTH CAROLINA Department of Environmental quaky Sincerely, DocuSigned by: L-o,o 'T. <JAAdu- 145B49E225C94EA... Lon T. Snider, Regional Supervisor Water Quality Regional Operations Section Winston-Salem Regional Office Division of Water Resources, NCDEQ North Carolina Department of Environmental Quality j Division of Water Resources Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105 336.776.9800 Compliance Inspection Report Permit: WQCS00312 Effective: 06/01/16 SOC: Effective: County: Randolph Region: Winston-Salem Contact Person: Zeb Holden Directions to Facility: System Classifications: CS2, Primary ORC: Christopher Neil Davis Secondary ORC(s): On -Site Representative(s): Related Permits: Expiration: 05/31/24 Expiration: Title: City Manager Certification: 1006148 NC0024210 City of High Point - East Side WWTP Inspection Date: 08/24/2021 Primary Inspector: Ron Boone Secondary Inspector(s): Entry Time 10:OOAM Patricia Lowery Reason for Inspection: Routine Permit Inspection Type: Collection system management and operation Facility Status: ❑ Compliant Not Compliant Question Areas: ▪ Miscellaneous Questions II Capital Improvement Plan ▪ Inspections ▪ Lines (See attachment summary) ▪ General ▪ Map ▪ Spill Response Plan ▪ Manholes Exit Time: 01:OOPM Owner : City of Archdale Facility: Archdale Collection System PO Box 1406 Phone: 336-434-7346 Phone: 336-431-9141 Phone: 336-776-9690 Inspection Type: Collection System Inspect Non Sampling ▪ Sewer & FOG Ordinances ▪ Reporting Requirements ▪ Spills ▪ Pump Stations Page 1 of 10 Permit: WQCS00312 Owner - Facility: City of Archdale Inspection Date: 08/24/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Inspection Summary: Ron Boone and Tricia Lowery of the NC Division of Water Resources, Winston-Salem Regional Office conducted a compliance evaluation inspection of the Town of Archdale's wastewater collection system on August 24, 2021. Lloyd Wilson, Public Works Director, and Chris Davis and Phillip Yates, ORC and BORC, respectively, were present for the inspection. Results of the inspection are summarized in the following paragraphs: PERMIT PART I, PERFORMANCE STANDARDS Part I, Paragraph 2, collection system shall be effectively managed, maintained and operated. Observations: The system is very well operated and maintained, minimizing spills and malfunctions. So far, only one spill was reported in 2021, and only four spills were reported in both 2020 and 2019. Compliance Status: Compliant Part I, Paragraph 3, sewer use ordinance (SUO). Observations: The SUO presented during the inspection was found to meet all requirements. Compliance Status: Compliant Part I, Paragraph 4, develop and implement an educational fats, oils and grease program and an enforceable fats, oils and grease program for non-residential users. Observations: According to operators, notifications, in the form of newsletters, are sent to all customers yearly along with one of the billing statements, typically in the last quarter of the year when a lot of cooking is being done. The town also has FOG information on their website. Inspectors do suggest that a link to the FOG information be placed on the town's homepage, as it is currently at least two to three layers deep in the public works section of the town's website. Grease traps throughout the town are inspected yearly, at a minimum, to verify they are being properly operated, maintained, pumped, and documented. They do not know the exact number of grease traps in town but state there are approximately 50. Trap inspection records were sufficiently detailed and comprehensive. Compliance Status: Compliant Part I, Paragraph 5, adopt and implement a Capital Improvement Plan (CIP). Observations: Operators provided a CIP project list that extends out into the latter half of the decade and covers at least a three -to -five-year period. The list also provides funding amounts, project descriptions, which indicates known deficiencies, and includes both long- and short-term needs. Compliance Status: Compliant Part I, Paragraph 6 no overflow or bypass structures within the system. Observations: No such structures were identified during the inspection and operators stated that none exist within the system. Compliance Status: Compliant Part I, Paragraph 7 maintain a contingency plan for pump failure at each pump station. Observations: Operators presented very detailed and comprehensive PSCPs that meet permit requirements. Compliance Status: Compliant Part I, Paragraph 8 each pump station be clearly and conspicuously posted with a pump station identifier and an emergency contact telephone number. Observations: Stations visited during inspection were properly posted as required. Compliance Status: Compliant Part I, Paragraph 9 requires pump station sites, equipment and components shall have restricted access. Observations: Stations visited during inspection were properly secured. Compliance Status: Compliant Page 2 of 10 Permit: WQCS00312 Owner - Facility: City of Archdale Inspection Date: 08/24/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Part I, Paragraph 10 stations that do not have automatic polling feature shall have both audible and visual high water alarms. Observations: Stations visited during inspection have both audible and visible alarms as well as SCADA. Compliance Status: Compliant Part I, Paragraph 11 requires all newly constructed, modified and rehabilitated pump stations equipment and components be sealed within a corrosion -resistant coating or encasement to the extent practicable. Observations: No conditions noted during inspection demonstrating non-compliance. Compliance Status: Compliant PERMIT PART IIOPERATION AND MAINTENANCE REQUIREMENTS Part II, Paragraph 1 properly designated operators. Observations: Chris Davis is designated as ORC and Steven Davis as BORC. If you wish to also designate Phillip Yates as a BORC, please do so using the proper forms, which can be found on DWR's website: https://deq.nc.gov/about/divisions/water-resources/operator-certification/wastewater-operator-certification/wastewater-operatc r-certification-downloads Compliance Status: Compliant Part II, Paragraph 2 Permittee shall develop and adhere to a schedule for reviewing all inspection, maintenance, operational and complaint logs. Review of all documentation and interviewing operators on how documentation is created and maintained, made inspectors confident that all documentation is reviewed as it is generated. Compliance Status: Compliant Part II, Paragraph 3 Permittee develop/ adhere to schedule for testing emergency and standby equipment. Observations: Six of the ten pump stations have permanently installed diesel operated generators. The town has one portable generator, as well as several other emergency equipment options, such as a Vactor unit, portable emergency bypass pumps, and contract septic haulers. ermanently installed generators are auto -exercised weekly, which is recorded in SCADA. Portable units operated regularly to insure immediate operability. All generators/pumps maintained under contract or in house and it is documented. Compliance Status: Compliant Part II, Paragraph 4 Routine pump station inspection/maintenance program. Observations: Pump station inspection logs are sufficient to meet requirements, but do NOT specifically include the four requirements of permit. Suggest adding all permit required items to the daily pump station inspection logs. Compliance Status: Compliant Part II, Paragraph 5 At least one fully operational spare pump shall be maintained on hand for each pump station without pump reliability. Observations: There are no simplex stations and all duplex stations meet specified requirements. Compliance Status: Compliant Part II, Paragraph 6 Permittee shall maintain on hand at least two percent of the number of pumps installed, but no less than two pumps, that discharge to a pressure sewer and serve a single building. Observations: There are no simplex pump stations in the system. Compliance Status: Not applicable Part II, Paragraph 7 requires rights -of -way and/or easements be properly maintained. Observations: ROWs maintained as needed, but at least twice yearly. Documentation is comprehensive and detailed. No insufficiently maintained ROWs observed during inspection. Page 3 of 10 Permit: WQCS00312 Owner - Facility: City of Archdale Inspection Date: 08/24/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Compliance Status: Compliant Part II, Paragraph 8 requires Permittee to assess cleaning needs, and develop and implement a program for appropriately cleaning at least 10 percent of the system yearly. Observations: Permit's facility description states the system contains about 79 miles of gravity sewer. Therefore, a minimum of 41,712 feet must be cleaned annually. They typically clean at least 45,000 feet yearly and documentation consistently shows they exceed the minimum. Compliance Status: Compliant Part II, Paragraph 9 adequate measures shall be taken to contain and properly dispose of SSO materials. Permittee shall maintain a Response Action Plan Observations: A detailed and thorough plan was presented for review. Compliance Status: Compliant Part II, Paragraph 10 requires Permittee to conduct on -site evaluations of SSOs no more than two hours after first knowledge. Observations: No conditions were observed that indicate noncompliance with this requirement. Operators stated they respond to all SSOs immediately. Compliance Status: Compliant Part II, Paragraph 11 requires Permittee to restore system operation, remove visible solids/paper, sanitize ground area and restore the surroundings for all SSOs. Observations: No conditions observed during inspection indicating noncompliance with this requirement. Compliance Status: Compliant PERMIT PART III, RECORDS Part III, Paragraph 1 requires records be maintained to document compliance with Conditions 1(4), 11(2) - II(4), 11(7) - II(8), IV(3) and V(1) -V(4). Records shall be kept for a minimum of three years. Observations: Operators are keeping excellent records for all activities for which documentation is required. The only activities for which insufficient documentation was observed during the inspection was the regular review of records and the annual general observation. Compliance Status: Noncompliant Part III, Paragraph 2 requires Permittee to maintain adequate records pertaining to SSOs, and complaints for a minimum of three years. Observations: SSO and complaint records were available during the inspection and are compliant with this requirement. Please note that press releases must be kept for a period of one year following issuance. Compliance Status: Compliant Part III, Paragraph 3 requires Permittee to maintain an up-to-date, accurate, comprehensive map. Observations: The collection system is fully mapped using computer software and ongoing efforts continue to capture and update information. All required data is available in various record drawings as well as the current computer system. Town has budgeted $200,000 for the completion of a comprehensive remapping. Compliance Status: Compliant Part III, Paragraph 4 requires Permittee maintain records of all system modifications and extensions. Drawings and specifications shall be maintained for the life of the modification/extension. Extensions shall be incorporated into the map within one year of construction completion. Observations: Operators acknowledged requirement. No conditions demonstrating noncompliance were noted. Compliance Status: Compliant Page 4 of 10 Permit: WQCS00312 Owner - Facility: City of Archdale Inspection Date: 08/24/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine PERMIT PART IV, MONITORING AND REPORTING REQUIREMENTS Part IV, Paragraph 1 requires monitoring deemed necessary by the Division to ensure surface water and groundwater protection will be established. Observations: No conditions demonstrating noncompliancewere observed during the inspection. Compliance Status: Compliant Part IV, Paragraph 2 requires Permittee to verbally report as soon as possible but in no case more than 24 hours following the occurrence or first knowledge of reportable SSOs. Observations: No conditions observed during inspection indicating noncompliance with this requirement. Compliance Status: Compliant Part IV, Paragraph 3 requires Permittee to meet annual reporting and notification requirements. Observations: A fully compliant annual report was provided for review during the inspection. Compliance Status: Compliant PERMIT PART V, INSPECTIONS Part V, Paragraph 1 requires Permittee to inspect the collection system regularly and keep inspection logs or summaries. Observations: Inspectors believe permittee to be compliant with this condition. Compliance Status: Compliant Part V, Paragraph 2 requires pump stations without Supervisory Control and Data Acquisition systems or telemetry be inspected everyday. Those so equipped may be inspected weekly. Observations: All ten stations have audible/visible alarms and SCADA systems. All are inspected at least three times per week and inspections are well documented. Compliance Status: Compliant Part V, Paragraph 3 requires a general observation of the entire system annually. Observations: Review of all documentation and the system reveals the entire system is observed over the course of a year. 11 is recommended, however, that operators sign an annual certification stating that the entire system has been observed over the course of the previous year. Compliance Status: Compliant Part V, Paragraph 4 requires inspections of all high priority lines at least every six -months. Observations: Records of high priority line inspections were reviewed and found to be detailed, complete, and comprehensive. Compliance Status: Compliant Page 5 of 10 Permit: WQCS00312 Owner - Facility: City of Archdale Inspection Date: 08/24/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine General Is there a properly designated primary ORC and at least one back-up of proper grade? 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: None Sewer and FOG Ordinances 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.) Website Comment: None Capital Improvement Plan 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? Comment: None Map Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ As generated • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ Annual • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE Page 6 of 10 Permit: WQCS00312 Owner - Facility: City of Archdale Inspection Date: 08/24/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Is there a overall sewer system map? Does the map include: Pipe Type (GS/FM) 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 Is the map being updated for changes/additions within 1 year of activation? Comment: None Reporting Requirements # 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: None Inspections 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? • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Website Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Comment: Review of records and annual general observation are insufficiently documented. Please refer to summary for further observations. Spill Response Action Plan Is a Spill Response Action Plan available? Is a Spill Response Action Plan available for all personnel? Does the plan include: Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ Page 7 of 10 Permit: WQCS00312 Owner - Facility: City of Archdale Inspection Date: 08/24/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine 24-hour contact numbers Response time Equipment list and spare parts inventory Access to cleaning equipment Access to construction crews, contractors, and/or engineers Source of emergency funds Site sanitation and cleanup materials Post-overflow/spill assessment Does the Permittee appear to respond within 2 hours of first knowledge of a spill? Comment: None Spills Is system free of known points of bypass? If No, describe type of bypass and location None Are all spills or sewer related issues/complaints documented? # Are there repeated overflows/problems (2 or more in 12 months) at same location? # If Yes, is there a corrective action plan? Comment: None Lines/Right-of-Ways/Aerial Lines Please list the Lines/Right of Ways/Aerial Lines Inspected: Weant Rd aerials, right-of-ways and pump station Suits Drive right-of-ways and pump station Are right-of-ways/easements maintained for full width for access by staff/equipment? 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? Comment: None Manholes Please list the Manholes Inspected: Are manholes accessible? # Are manhole covers/vents above grade? Are manholes free of visible signs of overflow? Are manholes free of sinkholes and depressions? Are manhole covers present? # Are manholes properly seated? • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE ❑ ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ Yes No NA NE Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Page 8 of 10 Permit: WQCS00312 Owner - Facility: City of Archdale Inspection Date: 08/24/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine # Are manholes in good condition? # 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? Are vents free of submergence? Are manholes free of bypass structures or pipes? Comment: None Pump Stations Please list the Pump Stations Inspected: Weant Rd and Suits Drive # Number of duplex or larger pump stations in system # Number of vacuum stations in system # Number of simplex pump stations in system # Number of simplex pump stations in system serving more than one building How many pump/vacuum stations have: # A two-way "auto polling" communication system (SCADA) installed? # A simple one-way telemetry/communication system (auto -dialer) installed? 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? 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? • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE 10 0 0 0 10 0 • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ • ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Page 9 of 10 Permit: WQCS00312 Owner - Facility: City of Archdale Inspection Date: 08/24/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine 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: None • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Page 10 of 10