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HomeMy WebLinkAboutWQCS00361_Compliance Evaluation Inspection_20220630Compliance Inspection Report Permit: WQCS00361 Effective: 01 /01 /16 SOC: Effective: County: Davidson Region: Winston-Salem Contact Person: Jerry Lee Kennedy Directions to Facility: System Classifications: CS1, Primary ORC: Charles Arthur Brushwood Secondary ORC(s): Logan Taylor Storey On -Site Representative(s): Related Permits: Expiration: 12/31/24 Owner : Davidson County Expiration: Facility: Davidson County Collection System Title: Utility Technician Certification: 999522 1009263 NC0050342 City of Winston-Salem - Muddy Creek WWTP Inspection Date: 06/30/2022 Entry Time 09:OOAM Primary Inspector: Patricia Lowery Secondary Inspector(s): Reason for Inspection: Routine Exit Time: 12:30PM Phone: 336-236-3120 Phone: 336-240-0303 336-236-3120 Phone: 336-776-9691 Inspection Type: Collection System Inspect Non Sampling Permit Inspection Type: Collection system management and operation Facility Status: Compliant Question Areas: ▪ Miscellaneous Questions II Capital Improvement Plan ▪ Inspections ▪ Lines ❑ Not Compliant (See attachment summary) ▪ General ▪ Map ▪ Spill Response Plan ▪ Manholes ▪ Sewer & FOG Ordinances ▪ Reporting Requirements ▪ Spills ▪ Pump Stations Page 1 of 10 Permit: WQCS00361 Owner - Facility: Davidson County Inspection Date: 06/30/2022 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 of Davidson County wastewater collection system (WQCS00361) on 6/30/2022. Logan Storey (BORC) and Kenneth Moon were present for the inspection. The inspection was conducted in 2 parts: 1) In house records review, and 2) field inspection. Results of the inspection are summarized in the following paragraphs: SECTION III, 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: Overall the management and operation of the collection system is satisfactory. Compliance Status: Compliant Part I, Paragraph 3, the Permittee shall establish an effective sewer use ordinance (SUO). Observations: The SUO is complete and comprehensive Compliance Status: Complaint 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: FOG education is mailed out annually and can also be found online (County website). It is adequate and satisfactory. Compliance Status: Compliant Part I, Paragraph 5, requires the Permittee shall adopt and implement a Capital Improvement Plan (CIP) to designate funding for reinvestment into the wastewater collection system infrastructure. Observations: There was no CIP on site for inspector to review. BORC sent via email post -inspection, "We don't have anything in the capital improvement plan for the next 5 years." The CIP is a conglomeration of all depts, not specific to collection system. Compliance Status: Neither/Neutral 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 overflow or bypass structures have been found in system, but if discovered, will be immediately handled (eliminated). Compliance Status: Compliant Part I, Paragraph 7 requires the Permittee maintain a contingency plan for pump failure at each pump station. Observations: Pump contingency plan is satisfactory. The plan is not posted at each pump station but is stored in all staff vehicles (better protection from weather/elements). Since the requirement states the plan must be at each pump station, inspector suggests laminating plan to place at each pump station. Compliance ''wither/Neutral 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: Proper signage with appropriate information was posted of pump station inspected. 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: Pump station was secured with proper fencing with locked gates. 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: Pump stations have both audible/visual alarms — connected to telemetry/auto dialer system. 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 recent new construction, upgrades or rehabilitation projects. Future projects will incorporate Page 2 of 10 Permit: WQCS00361 Owner - Facility: Davidson County Inspection Date: 06/30/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine sealant/encasement anti -corrosion materials. Compliance Status: Compliant SECTION IV, 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: Proper ORC and BORC are employed to operate, maintain, and respond to critical events in the collection system. 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: ORC and BORC hold monthly meetings to review all relevant operations of collection system. Compliance Status: Compliant Part II, Paragraph 3 requires the Permittee shall develop and adhere to a schedule for testing emergency and standby equipment. Observations: Plan in place and in good order. 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: Pump stations are inspected weekly. Inspections are thorough, documented and records are in good order. 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 employ duplex pump systems. Compliance Status: NA 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 employ duplex pump 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: Inspection of the maintenance logs and Miller's Creek Outfall reveals ROWs and easements are properly maintained. 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: Approximately 19,605 miles cleaned in 2021 which satisfies more than the 10% requirement. Historic logs show proper 10% cleaning of collection system yearly. 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; Page 3 of 10 Permit: WQCS00361 Owner - Facility: Davidson County Inspection Date: 06/30/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine 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: Spill response plan is detailed, comprehensive and in excellent order. Only need to update contact phone numbers. Inspector supplied updated contact information for regional office. Issue is easily remedied. 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: No SSO's reported in the last three years. Review of the spill response plan outlines on -site evaluations and the time in which personnel must respond. In good order. 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: Again, no SSO's in last 3 years, however extensive outline for response is documented with clear direction. Compliance Status: Compliant SECTION V, PERMIT PART III: RECORDS Part III, Paragraph 1 requires that records be maintained to document compliance with Conditions I (4), 11(2) - 11(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 proper documentation and logs are kept for the suitable amount of time. 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; 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: No SSOs reported within the last 3 years, therefore no records to inspect. Compliance Status: NA Part III, Paragraph 3 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 location, flow direction, approximate pipe age, number of active service taps, and each pump station identification, location and capacity. Observations: Overall map of system is posted in facility. They are in process of transferring all information to GIS system. Mr. Storey showed inspector the GIS system. Everything looks good and is comprehensive. Compliance Status: Compliant Part III, Paragraph 4 requires the Permittee shall maintain records of all of 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 modifications and/or extensions have occurred within the system. Compliance Status: NA SECTION VI, PERMIT PART IV: MONITORING AND REPORTING REQUIREMENTS Part IV, Paragraph 1 requires any monitoring (including, but not necessarily limited to, wastewater flow, groundwater, surface water, soil or plant tissue analyses) deemed necessary by the Division to ensure surface water and groundwater protection will be established, and an acceptable sampling and reporting schedule shall be followed. Page 4 of 10 Permit: WQCS00361 Owner - Facility: Davidson County Inspection Date: 06/30/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Observations: No issues found Compliance Status: Compliant Part IV, Paragraph 2 requires the Permittee shall verbally report to a Division of Water Resources staff member at the Winston-Salem Regional Office as soon as possible but in no case more than 24 hours following the occurrence or first knowledge of the occurrence of either of the following: a. Any SSO and/or spill over 1,000 gallons; or b. Any SSO and/or spill, regardless of volume, that reaches surface water. Observations: No SSOs reported over past 3 years, however Spill Response Plans outlines proper procedures for reporting SSO's/spills. Compliance Status: Compliant Part IV, Paragraph 3 requires the Permittee shall meet the annual reporting and notification requirements provided in North Carolina General Statute §143-215.1 C. Observations: Annual report reviewed. Report is in order and is sent out as a pamphlet to customers. Compliance Status: Compliant SECTION VII, PERMIT PART V: INSPECTIONS Part V, Paragraph 1 requires the Permittee shall inspect the wastewater collection system regularly to reduce the risk of malfunctions and deterioration, operator errors, and other issues that may cause or lead to the release of wastes to the environment, threaten human health or create nuisance conditions. The Permittee shall keep an inspection log or summary including, at a minimum, the date and time of inspection, observations made, and any maintenance, repairs, or corrective actions taken by the Permittee. Observations: O&M logs are kept and in order. Compliance Status: Compliant Part V, Paragraph 2 requires that pump stations without Supervisory Control and Data Acquisition (SCADA) systems or telemetry shall be inspected everyday (i.e. 365 days per year). Pump stations equipped with SCADA systems or telemetry shall be inspected at least once per week. Observations: All 5 pump stations are connected via telemetry (auto -dialer). No SCADA system. Pump stations are inspected weekly, Part V, Paragraph 3 requires a general observation of the entire collection system shall be performed throughout the course of every year. Observations: ORC and BORC conduct a general observation of the collection system, however it is not documented. They conduct monthly meetings with staff to discuss operation and maintenance of collection system. BORC stated he would begin documenting observations. Compliance Status: Non -compliant (but easily remedied) Part V, Paragraph 4 requires that inspections of all high priority lines (i.e. aerial line, sub -waterway crossing, line contacting surface waters, siphon, line positioned parallel to stream banks that are subject to eroding in such a manner that may threaten the sewer line, or line designated as high -priority in a permit) shall be performed at least once per every six-month period of time. Observations: Permittee inspects and performs maintenance in these areas every six months with proper documentation. Inspected the Miller's Creek Outfall during inspection. Area is being maintained properly. No issues found. Compliance Status: Compliant Page 5 of 10 Permit: WQCS00361 Owner - Facility: Davidson County Inspection Date: 06/30/2022 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: Charlie Brushwood ORC, Logan Storey BORC. Permit expires 12/31/2024. 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.) On County website. 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? Does CIP include forecasted future needs? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ Monthly ❑ ❑ • ❑ • ❑ ❑ ❑ ❑ • ❑ ❑ ❑ ❑ •❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ Monthly or as needed • ❑ ❑ ❑ ❑ ❑ • ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE ❑ ❑ ❑ • • ❑ ❑ ❑ ❑ ❑ ❑ • ❑ ❑ ❑ • Page 6 of 10 Permit: WQCS00361 Owner - Facility: Davidson County Inspection Date: 06/30/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Comment: There was no CIP on site for inspector to review. BORC sent via email post -inspection, "We don't have anything in the capital improvement plan for the next 5 years." The CIP is a conglomeration of all depts, not specific to collection system. 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: A physical map is posted in office with most parameters listed (pipe age, type, material - missing). However, they have implemented a GIS system and still working to add, update and transfer all information pertaining to collection system to GIS. Inspector was able to view GIS map and the infrastructure so far is satisfactory. 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? Yes No NA NE ❑ ❑ • ❑ ❑ ❑ • ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Pamphet mailed ou to customers Comment: No SSO reported in the past 3 years. Last SSO reported was 4/1/2010. Inspector reviewed annual performance report - satisfactory. 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? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ • ❑ ❑ • ❑ ❑ ❑ Page 7 of 10 Permit: WQCS00361 Owner - Facility: Davidson County Inspection Date: 06/30/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Are new lines being added to the HPL list when found or created? Comment: See summary 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: Miller's Creek Outfall (aerial line & right of way) 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: 10% requirement = 14,520 ft. (CS = approx. 145,200 ft in total) 19,605 ft cleaning of lines completed in 2021 and documented appropriately. Manholes • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE Page 8 of 10 Permit: WQCS00361 Owner - Facility: Davidson County Inspection Date: 06/30/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Please list the Manholes Inspected: MH #8, #16-17, #30 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? # 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: No issues. Pump Stations Please list the Pump Stations Inspected: Fryes # 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? • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE 5 0 0 0 0 5 • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Page 9 of 10 Permit: WQCS00361 Owner - Facility: Davidson County Inspection Date: 06/30/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine 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? # 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: See summary • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Page 10 of 10