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HomeMy WebLinkAboutWQCS00195_NOI-NOV2022PC0405_20220804ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director NORTH CAROLINA Environmental Quality CERTIFIED MAIL 7020 1810 00012074 8119 RETURN RECEIPT REQUESTED August 4, 2022 Town of Ramseur Attn: Vicki Caudle P.O. Box 545 Ramseur, NC 27316-0545 Subject: Compliance Evaluation Inspection & Notice of Violation with Intent to Enforce NOV Tracking #: NOV-2022-PC-0405 Ramseur Wastewater Collection System Permit Number: WQCS00195 Randolph County Dear Ms. Caudle: Ron Boone, of the Winston-Salem Regional Office (WSRO) of the NC Division of Water Resources (DWR), conducted a compliance evaluation inspection (CEI) of the Ramseur wastewater collection system (WWCS) on June 27t", 2022. Collection system operators, Jim McIntosh and Greg Kenyon, were both present for the inspection. Inspection findings are detailed in the attached compliance inspection report. This inspection resulted in a Notice of Violation with Intent to Enforce due to several permit condition violations that were noted. The violations are summarized in the Inspection Summary section of the Compliance Inspection Report on Page 2. The Division is considering assessing civil penalties for the violations, but any additional documentation/information the town submits in response to this notice will be considered in the assessment process. As such, this office requests that you reply to us in writing within 10 business days of receiving this notice. Your written reply should include any additional documentation/information you wish to have considered, along with all proposed corrective actions, with estimated completion dates, for each violation. Since the field portion of the inspection could not be conducted due to a water line break to which both operators had to respond, Mr. Boone will schedule with the operators to conduct the field inspection and review the town's corrective actions within 120 days after the town receives this notice. If we proceed with civil penalty assessment, you should be aware that pursuant to NC General Statute (NCGS) 143-215.6A, we may assess civil penalties of not more than twenty-five thousand dollars ($25,000.00) per day, per violation, or failure to act in accordance with the terms, conditions, or requirements of your permit. DffNorth Carolina Department of Environmental Quality I Division of Water Resources oan caaouNn Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105 M336.776.9800 oep.m.m or em�nmen� Qualm If you have any questions or concerns, please do not hesitate to contact Mr. Boone by phone at 336- 776-9690, or by email at ron.boone@ncdenr.gov. Thank you in advance for your time and attention to this matter. Sincerely, EDocuSiTG gned by: LOti 1 . Jn Jtr 145B49E225CMEA... Lon T. Snider, Regional Supervisor Water Quality Regional Operations Section Winston-Salem Regional Office Division of Water Resources, NCDEQ Attachments: 1. Compliance Inspection Report REQ� North Carolina Department ofEnvironmental Quality I Division ofWater Resources Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Raleigh, North Carolina 27105 NORTH CAROLINA 336.776.9800 naparMeM of EmironmanW 9uallly Compliance Inspection Report Permit: WQCS00195 Effective: 07/12/21 Expiration: 06/30/29 Owner: Town of Ramseur SOC: Effective: Expiration: Facility: Ramseur Collection System County: Randolph PO Box 545 Region: Winston-Salem Ramseur NC 273160545 Contact Person: Vicki Caudle Title: Mayor Phone: 336-824-4111 Directions to Facility: System Classifications: CS2, Primary ORC: Thomas James McIntosh Secondary ORC(s): On -Site Representative(s): Certification: 28031 Phone: 336-302-3154 Related Permits: NC0026565 Town of Ramseur - Ramseur WWTP Inspection Date: 06/27/2022 Entry Time 10:OOAM Primary Inspector: Ron Boone Secondary Inspector(s): Exit Time: 12:OOPM Phone: 336-776-9690 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 Spills Lines Manholes Pump Stations (See attachment summary) Page 1 of 7 Permit: WQCS00195 Owner - Facility: Town of Ramseur Inspection Date: 06/27/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Inspection Summary: Ron Boone, of the Winston-Salem Regional Office (WSRO) of the NC Division of Water Resources (DWR), conducted a compliance evaluation inspection (CEI) of the Ramseur wastewater collection system (WWCS) on June 27th, 2022. Collection system operators, Jim McIntosh and Greg Kenyon, were both present for the inspection. Inspection findings are summarized below and detailed in the subsequent checklist. The town experienced a water line break during the inspection, to which both operators had to respond. Therefore, the field portion of the inspection could not be completed and will need to be rescheduled for a later date, possibly when we return for a follow up inspection to evaluate the town's remedies for the violations enumerated below. 1. The FOG program needs improvement. For the educational component, the operators stated that the town sends out newsletters that include FOG educational material twice per year via USPS. They were able to provide an undated example of a newsletter but copies of other previously issued newsletters were not readily available. Also, the newsletters are undated, as they should be to show when they were distributed. As for the enforceable component of the program, the ordinance looks very good and sufficiently detailed, however, the ORCs do not have a comprehensive list of grease traps anc they are NOT inspected regularly. It is therefore unknown whether they are being properly maintained. 2. There are 11 pump stations. Five of the eleven have telemetry and audible/visual alarms. The other six only have audible/visual alarms. All are checked 365 days/year except the King Rd and Tower Components pumpstations, which both have telemetry and are checked on Mondays, Wednesdays, and Fridays. Only two of the eleven pumpstations have permanent onsite generators. Two of the remaining nine pumpstations are plumbed for emergency bypass pumps and the town rents pumps when needed to use the emergency bypasses. One of the remaining seven pumpstations has emergency hookups for the town's portable generator, however, the operators stated that the portable generator has not run or been tested for several years and it's current condition is unknown. 3. Operators indicated that review of inspection, maintenance, operational, and complaint logs is done as the logs are generated. However, there is no documentation of those reviews. 4. Operators stated that all right-of-ways (ROW) are bushhogged three to four times per year and that high priority lines (HPL) are checked at the same time. However, there are no records of either activity. 5. Operators indicated that they clean the Brooklyn section of the collection system every year because it represents about 10 percent of the system and all the pipes in that area have very low grades, making it more susceptible to stoppages and overflows. However, the operators could not provide any records of line cleaning activities. 6. Records of all SSOs, and all their required accompanying documentation, i.e. press releases and public notices, were not readily available during the inspection. 7. The system map presented during the inspection does not meet all requirements. 8. Documentation of the annual general observation of the entire system was not available during the inspection. Page 2 of 7 Permit: WQCS00195 Owner - Facility: Town of Ramseur Inspection Date: 06/27/2022 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? 0 ❑ ❑ ❑ # What is that frequency? As generated # Are there any issues being addressed currently or any in the planning stages? 0 ❑ ❑ ❑ Is there a specific pump failure plan available for all pump stations? 0 ❑ ❑ ❑ 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? 0 ❑ ❑ ❑ Does the permittee have a copy of their permit? 0 ❑ ❑ ❑ # Is permit expiring within the next 6 months? ❑ 0 ❑ ❑ If Yes, has the Permittee applied for renewal? 0 ❑ ❑ ❑ Comment: Permit already expired in 5/2021. ORC says documentation is reviewed as it is generated but there is no documentation of reviews. Sewer and FOG Ordinances Yes No NA NE Is Sewer Use Ordinance (SUO) or other Legal Authority available? 0 ❑ ❑ ❑ Does it appear that the Sewer Use Ordinance is enforced? ❑ 0 ❑ ❑ Is there a Grease Control Program that legally requires grease control devices? 0 ❑ ❑ ❑ What is the standard grease trap cleaning requirement in the FOG ordinance? As needed Is Grease Control Program enforced via periodic inspections/records review? ❑ 0 ❑ ❑ Is action taken against violators? ❑ ❑ ❑ # Have satellite systems adopted an equivalent or more stringent ordinance? ❑ ❑ 0 ❑ Is grease/sewer education program documented with req'd customer distribution? ❑ 0 ❑ ❑ # Are other types of education tools used like websites, booths, special meetings, etc? ❑ 0 ❑ ❑ If Yes, what are they? (This can reduce mailing to annual.) Comment: ORC stated that newsletters containing FOG educational information are distributed via USPS twice per year. ORC provided two copies of newsletters during the inspection but not all are readily available and the newsletters are not dated to demonstrate when they were distributed. 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? 0 ❑ ❑ ❑ Comment: None Page 3 of 7 Permit: WQCS00195 Owner - Facility: Town of Ramseur Inspection Date: 06/27/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Map Yes No NA NE Is there a overall sewer system map? 0 ❑ ❑ ❑ Does the map include: Pipe Type (GS/FM) 0 ❑ ❑ ❑ Pipe sizes 0 ❑ ❑ ❑ Pipe materials (PVC, DIP, etc) ❑ 0 ❑ ❑ Pipe location 0 ❑ ❑ ❑ Flow direction 0 ❑ ❑ ❑ 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: Map does not meet all requirements. Reporting 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: Not all SSO records, with all the required accompanying documentation, i.e. press releases and public notices, were readily available. Inspections Yes No NA NE Are adequate maintenance records maintained? 0 ❑ ❑ ❑ Are pump stations being inspected at the required frequency? 0 ❑ ❑ ❑ # 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: There is no documentation of ROW or HPL inspections and/or maintenance. The ORC stated that ROWS are bushhogged three to four times yearly and that HPLs are checked during that process. Spill Response Action Plan Yes No NA NE Page 4 of 7 Permit: WQCS00195 Owner - Facility: Town of Ramseur Inspection Date: 06/27/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Is a Spill Response Action Plan available? 0 ❑ ❑ ❑ Is a Spill Response Action Plan available for all personnel? 0 ❑ ❑ ❑ 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: None Spllls Yes No NA NE 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? ❑ ❑ 0 ❑ Comment: None Lines/Right-of-Ways/Aerial Lines Yes No NA NE Please list the Lines/Right of Ways/Aerial Lines Inspected: None Are right-of-ways/easements maintained for full width for access by staff/equipment? ❑ ❑ ❑ If No, give details on temporary access: Is maintenance documented? ❑ 0 ❑ ❑ Are gravity sewer cleaning records available? ❑0 ❑ ❑ Has at least 10% of lines older than 5 yrs been cleaned annually? ❑ ❑ ❑ Were all areas/lines inspected free of issues? ❑ ❑ On Comment: The ORC stated that they clean the Brooklyn part of the system every year, which represents 10 percent of the system, because the whole area has very low pipe grades, which can lead to stoppages and overflows. The line cleaning is not being documented. The ORC stated he may be able to find some records of line cleaning. Manholes Please list the Manholes Inspected: None Yes No NA NE Are manholes accessible? 0 ❑ ❑ ❑ Page 5 of 7 Permit: WQCS00195 Owner - Facility: Town of Ramseur Inspection Date: 06/27/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine # 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? ❑ ❑ ❑ # 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: Several manholes were observed at ground level and no issues were noted. Pump Stations Yes No NA NE Please list the Pump Stations Inspected: None # Number of duplex or larger pump stations in system 11 # 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? 5 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? ❑ 0 ❑ ❑ Is the communication system functional? ❑ ❑ ❑ Is a 24-hour notification sign posted ? ❑ ❑ ❑ Does the sign include: Owner Name? ❑ ❑ ❑ Pump station identifier? ❑ ❑ ❑ # Address? ❑ ❑ ❑ Page 6 of 7 Permit: WQCS00195 Owner - Facility: Town of Ramseur Inspection Date: 06/27/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Instructions for notification? ❑ ❑ ❑ 24-hour emergency contact numbers? ❑ ❑ ❑ 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? ❑ ❑ 0 ❑ Is the back-up system tested at least bi-annually under normal operating conditions? 0 ❑ ❑ ❑ # Does it have a dedicated connection for a portable generator? ❑ 0 ❑ ❑ # Is the owner relying on portable units in the event of a power outage? 0 ❑ ❑ ❑ # If Yes, is there a distribution plan? ❑ 0 ❑ ❑ If Yes, what resources (Units/StaffNehicles/etc) are included in Plan? # Does Permittee have the approved percentage of replacement simplex pumps? ❑ ❑ 0 ❑ Is recordkeeping of pump station inspection and maintenance program adequate? 0 ❑ ❑ ❑ 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: There are 11 pump stations. Five of the eleven have telemetry and audible/visual alarms. The other six only have audible/visual alarms. All are checked 365 days/year except the King Rd and Tower Components pumpstations, which both have telemetry and are checked on Mondays, Wednesdays, and Fridays. Only two of the eleven pumpstations have permanent onsite generators. Two of the remaining nine pumpstations are plumbed for emergency bypass and the town rents pumps when needed to use the bypasses. One of the remaining seven pumpstations has emergency hookups for the town's portable generator, however, the operators stated that the portable generator has not run or been tested for several years and it's current condition is unknown. Page 7 of 7