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HomeMy WebLinkAboutWQCS00223_CEI_Nov2021_20211118Compliance Inspection Report Permit: WQCS00223 Effective: 01/01/17 Expiration: 12/31/25 Owner : Town of Denton SOC: Effective: Expiration: Facility: Denton Collection System County: Davidson PO Box 306 Region: Winston-Salem Contact Person: Troy B Branch Directions to Facility: System Classifications: CS2, Primary ORC: Troy B Branch Secondary ORC(s): Micheal Sean High On -Site Representative(s): Related Permits: Denton NC 272390306 Title: ORC Phone: 336-859-4460 NC0026689 Town of Denton - Denton WWTP Inspection Date: 11/18/2021 Certification: 23102 Phone: 336-859-4460 992681 336-859-5885 Entry Time 10:OOAM Exit Time: 12:15PM Primary Inspector: Patricia Lowery Phone: 336-776-9691 Secondary Inspector(s): 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 II Capital Improvement Plan ▪ Inspections ▪ Lines (See attachment summary) ▪ General ▪ Map ▪ Spill Response Plan ▪ Pump Stations ▪ Sewer & FOG Ordinances ▪ Reporting Requirements ▪ Spills Page 1 of 10 Permit: WQCS00223 Owner - Facility:Town of Denton Inspection Date: 11/18/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Inspection Summary: Tricia Lowery of the NC Division of Water Resources, Winston-Salem Regional Office conducted a compliance evaluation inspection (CEI) of the Town of Denton (WQCS00223) on November 18, 2021. Troy Branch (ORC) and Michael High (BORC & Public Utilities Director) were present for the inspection. Troy Branch was present and assisted Ms. Lowery for the HPL and pump station inspections. Results of the inspection are summarized in the following paragraphs: PERMIT PART I, PERFORMANCE STANDARDS Part I, Paragraph 2, requires the wastewater collection system shall be effectively managed, maintained and operated at all times. Observations: There were 4 SSO's in 2020: Jan 24th, Feb 6th, May 21st, Nov 12th. All >1000 gallons. Proper notices were sent out (with affidavits) and 5-day reports in BIMS were completed. Jan/Feb/May resulted in Notice of Violation with Intent. No SSO's have been reported in 2021 as of November 18th. Substantial improvement in operations, management, and maintenance from last inspection on 10/22/2018. The system is well operated and maintained. Compliance Status: Compliant Part I, Paragraph 3, the Permittee shall establish an effective sewer use ordinance (SUO). Observations: The SUO contains all pertinent information required by the permit. In addition, the SUO can easily be found on the town's website for public notice and educational purposes. Compliance Status: Compliant Part I, Paragraph 4, requires the Permittee shall develop and implement an educational fats, oils and grease program and an enforceable fats, oils and grease program for non-residential users. Observations: The FOG program is comprehensive and detailed. Flyers are sent to residents bi-annually through billing, FOG information is easily accessed from main page of town's website, and they attend the town's annual fall festival where they distribute educational information (ie: brochures, can lids, pencils, etc) to the public. Permittee has implemented and enforced FOG program for non-residential users. Logs are kept with detailed information concerning inspections and enforcements if violations occur. FOG enforcement policy can also be found on town's website. Compliance Status: Compliant Part I, Paragraph 5, requires the Permittee shall adopt and implement a Capital Improvement Plan (CIP) to designate fundinc for reinvestment into the wastewater collection system infrastructure. Observations: The CIP ranges from 2022-2026. Due to the small nature of the town, the CIP is all inclusive of differing departments, however, each department is categorized and detailed concerning funding for improvements and/or repairs. Mr. Branch did clarify funding is low and supplementary money is needed for upgrades and maintenance. Ms. Lowery suggested to inquire with DEQ's Division of Water Infrastructure to apply for ARPA grants for needed funding. Compliance Status: Complaint Part I, Paragraph 6 requires there be no overflow or bypass structures within the system and if any are discovered that they be immediately eliminated. Observations: No structures were identified during the inspection. Compliance Status: Compliant Part I, Paragraph 7 requires the Permittee maintain a contingency plan for pump failure at each pump station. Observations: Permittee maintains a contingency plan for each pump station. It is comprehensive and compliant with permit standards. Compliance Status: Compliant Part I, Paragraph 8 requires each pump station shall be clearly and conspicuously posted with a pump station identifier and an emergency contact telephone number at which an individual who can initiate or perform emergency service for the wastewater collection system 24 hours per day, seven days per week can be contacted. Observations: Permittee has signs posted at pump stations with identifier and emergency phone number with a disclosure if alarm is sounding/flashing, please call number provided. Compliance Status: Compliant Part I, Paragraph 9 requires pump station sites, equipment and components shall have restricted access, as per 15A NCAC 02T .305(h)(4). Observations: Two pump stations observed: Nacoma Park and Wilson Carter. The pump station at Nacoma Park is in a residential community and is securely fenced (with additional barbwire on top). Pump Station at Wilson Carter is in a business parking lot and locked securely with padlocks. No fence is present at this location. Keys to deadbolt are Page 2 of 10 Permit: WQCS00223 Owner - Facility:Town of Denton Inspection Date: 11/18/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine secured. Personnel retain keys and always carry with them. Compliance Status: Compliant Part I, Paragraph 10 requires pump stations that do not employ an automatic polling feature (i.e. routine contact with pump stations from a central location to check operational status of the communication system) shall have both audible and visual high water alarms. Observations: All pump stations are connected to a SCADA (Mission) system. Additionally, they have both audible and visual alarms. Of the two stations inspected, both alarms systems were functioning properly (inspector requested ORC to raise floats for alarm test). Nacoma park audible alarm's volume was lowered due to neighbor complaints. Although the alarm is notably clear, operational, and could be heard, Inspector advised Permittee to raise the volume of alarm level. Compliance Status: Compliant Part I, Paragraph 11 requires that for all newly constructed, modified and rehabilitated pump stations, all equipment and components shall be sealed within a corrosion -resistant coating or encasement to the extent practicable and equivalent to the minimum design criteria unless the permittee can demonstrate it is not practicable or another form of corrosion resistance is employed. Observations: No conditions were noted in inspection to suggest non-compliance. Compliance Status: NA PERMIT PART II OPERATION AND MAINTENANCE REQUIREMENTS Part II, Paragraph 1 requires the Permittee shall designate and employ a certified operator to be in responsible charge (ORC,' and one or more certified operator(s) to be back-up ORC(s) of the facilities in accordance with 15A NCAC 8G .0201. The ORC shall visit the system within 24 hours of knowledge of a bypass, spill, or overflow of wastewater from the system, unless visited by the Back -Up ORC, and shall comply with all other conditions of 15A NCAC 8G .0204. Observations: Permittee has designated and employed suitable ORC and BORC for facility. Troy Branch is ORC and Michael High is BORC (and public utilities director). Both are licensed Grade IV operators (one grade above system's status of Grade III). It has been demonstrated and documented both have responded appropriately to emergency situations and other conditions of 15A NCAC 8G .0204. Compliance Status: Compliant Part II, Paragraph 2 requires the Permittee shall develop and adhere to a schedule for reviewing all inspection, maintenance, operational and complaint logs. Observations: Inspector reviewed logs pertaining to scheduled inspections of collection system, including review of maintenance and complaint logs. Logs are segmented by month. All logs include supervisory signature, demonstrating Mr. Branch consistently surveys operations conducted in collection system. Inspector is confident all logs are reviewed in compliance with permit standards. Compliance Status: Compliant Part II, Paragraph 3 requires the Permittee shall develop and adhere to a schedule for testing emergency and standby equipment. Observations: As in Part II, Paragraph 2, ORC reviews and signs logs concerning testing/standby equipment monthly. Generators are on site at most pump stations with a portable available for Wilson Carter pump station. Compliance Status: Compliant Part II, Paragraph 4 requires the Permittee shall develop and implement a routine pump station inspection and maintenance program, which shall include, but not be limited to, the following maintenance activities: a. Cleaning and removing debris from the pump station structure, outside perimeter, and wet well; b. Inspecting and exercising all valves; c. Inspecting and lubricating pumps and other mechanical equipment according to the manufacturer's recommendations; and d. Verifying the proper operation of the alarms, telemetry system and auxiliary equipment. Observations: Permittee has satisfactorily developed and implemented a pump station inspection and maintenance program. Logs are kept and reviewed with supervisory signature. Compliance Status: Compliant Part II, Paragraph 5 requires for each pump station without pump reliability (i.e. simplex pump stations serving more than a single building or pump stations not capable of pumping at a rate of 2.5 times the average daily flow rate with the largest pump out of service), at least one fully operational spare pump capable of pumping peak flow shall be maintained on hand. Observations: All pump stations are duplex systems. Lead/lag system as to not intensify wear to one pump. Duplex Page 3 of 10 Permit: WQCS00223 Owner - Facility:Town of Denton Inspection Date: 11/18/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine system meets requirements. Compliance Status: Compliant Part II, Paragraph 6 requires the 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, unless the Permittee has the ability to purchase and install a replacement pump within 24 hours of first knowledge of the simplex pump failure or within the storage capacity provided in any sewer line extension permit. Observations: All pump stations are duplex systems. Compliance Status: NA Part II, Paragraph 7 requires that rights -of -way and/or easements shall be properly maintained to allow accessibility to the wastewater collection system. Observations: ROWs are maintained as needed, but no less than twice a year. Maintenance is properly documented. No impediments were noted during inspection. Compliance Status: Compliant Part II, Paragraph 8 requires the Permittee assess cleaning needs, and develop and implement a program for appropriately cleaning at least 10 percent of the wastewater collection system each year. Observations: Permit indicates the collection system contains 17 miles of gravity sewer (approx. 89,760 ft), therefore, 10% (approx. 8,976 ft) is the required minimum to be cleaned annually. Records reviewed during inspection showed 9,583 ft were cleaned in 2019; and 8,325 ft were cleaned in 2020. Year 2020 was slightly less than targeted goal (-650 ft), however due to COVID epidemic (severe staff shortages) collection system operations were adversely affected. However, they were able to clean 9.2% during adversarial conditions. Compliance Status: Compliant Part II, Paragraph 9 requires adequate measures shall be taken to contain and properly dispose of materials associated with SSOs. 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 sanitation and clean up materials; and h. Post-SSO assessment. Observations: A detailed and comprehensive plan was presented for review. Compliance Status: Compliant Part II, Paragraph 10 requires the Permittee, or their authorized representative, shall conduct an on -site evaluation for all SSOs as soon as possible, but no more than two hours after first knowledge of the SSO. Observations: Upon review of SSO events in 2020, proper response and reporting time during SSOs were conducted. Compliance Status: Compliant Part II, Paragraph 11 requires the Permittee, in the event of an SSO or blockage within the wastewater collection system, to restore the system operation, remove visible solids and paper, sanitize any ground area and restore the surroundings. Observations: Upon review of SSO events in 2020, actions were taken to clean and sanitize the affected areas according to permit standards. Compliance Status: Compliant PERMIT PART III, RECORDS Part III, Paragraph 1 requires that records be maintained to document compliance with Conditions I (4), 11(2) - II(4), 11(7) -11(8) IV(3) and V(1) -V(4). Records shall be kept on file for a minimum of three years. Observations: All records have been maintained properly according to permit conditions. Compliance Status: Compliant Part III, Paragraph 2 requires the Permittee shall maintain adequate records pertaining to SSOs, and complaints for a minimum of three years. These records shall include, but are not limited to, the following information: a. Date of SSO or complaint; b. Volume of wastewater released as a result of the SSO and/or nature of complaint; c. Location of the SSO and/or complaint; Page 4 of 10 Permit: WQCS00223 Owner - Facility:Town of Denton Inspection Date: 11/18/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine d. Estimated duration of the SSO; e. Individual from the Division who was informed about the SSO and/or complaint, when applicable; f. Final destination of the SSO; g. Corrective actions; h. Known environmental/human health impacts resulting from the SSO; and i. How the SSO was discovered. Observations: All records and information pertaining to SSO events are sufficiently maintained and kept in compliance with permit standards. Compliance Status: Compliant Part III, Paragraph 3 requires the Permittee shall maintain records of all the modifications and extensions to the collection system permitted herein. The Permittee shall maintain a copy of the construction record drawings and specifications for modifications/extensions to the wastewater collection system for the life of the modification/extension. Information concerning the extension shall be incorporated into the map of the wastewater collection system within one year of the completion of construction. The system description contained within this permit shall be updated to include this modification/extension information upon permit renewal. Observations: No indications were noted during inspection of any non-compliance concerning this permit standard. Compliance Status: Compliant Part III, Paragraph 4 requires the Permittee shall maintain an up-to-date, accurate, comprehensive map of its wastewater collection system. The comprehensive map shall include, but is not limited to: pipe size, pipe material, pipe to Page 5 of 10 Permit: WQCS00223 Owner - Facility:Town of Denton Inspection Date: 11/18/2021 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: Current Interim Town Manager is Kelly Craver. See summary concerning questions. 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.) FOG information is readily available on the Town's website. Additionally, personnel attend the Town's annual fall festival. They hand out education information to residents along with can caps and pencils with logo concerning proper disposal of FOG. Comment: See summary 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? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ Monthly • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ▪ • • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Pumped as needed and/or quarterly basis • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Page 6 of 10 Permit: WQCS00223 Owner - Facility:Town of Denton Inspection Date: 11/18/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Does CIP include forecasted future needs? Comment: See summary Map 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? • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ ❑ • ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Comment: The town is actively trying to update maps with proper information and currently under revision. They are trying to implement GIS, however issues have come up, pausing the project right now. See summary for details. 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: Average daily flow is 400,000 gallons. Annual report was in order with no deficiencies. 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? Comment: See summary Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Local newspaper and website Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ • Page 7 of 10 Permit: WQCS00223 Owner - Facility:Town of Denton Inspection Date: 11/18/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine 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: 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: See summary Spills Is system free of known points of bypass? If No, describe type of bypass and location 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: See summary Lines/Right-of-Ways/Aerial Lines Please list the Lines/Right of Ways/Aerial Lines Inspected: 1. Peacock; 2. Councl Access Rd. In good shape, no deficiencies found. See summary for details. 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: See summary Pump Stations Please list the Pump Stations Inspected: 1. Nacoma Park; 2. Wilson Carter See summary for details. # Number of duplex or larger pump stations in system Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE 6 Page 8 of 10 Permit: WQCS00223 Owner - Facility:Town of Denton Inspection Date: 11/18/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine # 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? 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? Only one portable back up unit is needed for one pump station - Wilson Carter pump station. Back up generator is nearby and port readily available for hook up. The remaining pump stations have installed generators connected and on -site. See summary for details. # 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? 0 0 0 6 0 • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Page 9 of 10 Permit: WQCS00223 Owner - Facility:Town of Denton Inspection Date: 11/18/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Comment: See summary Page 10 of 10