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HomeMy WebLinkAboutWQCS00164_Compliance Evaluation Inspection_20200131 North Carolina Department of Environmental Quality  Division of Water Resources 610 East Center Avenue  Suite 301  Mooresville, North Carolina 28115 704-663-1699 31 January 2020 Mr. Kevin Krouse City of Lowell 101 W First St. Lowell, North Carolina 28698 Subject: Compliance Evaluation Inspection Permittee: City of Lowell Waste Water Collection System Permit No. WQCS00164 Gaston County Dear Mr. Krouse: 1. Mr. Tony Parker of the Mooresville Regional Office of the NC Division of Water Resources (DWR or the Division) conducted a compliance evaluation inspection (CEI) of the City’s wastewater collection system (WWCS) on January 30, 2020. The assistance of Mr. Thomas Shrewsbury and Mr. Charles Harper during the inspection was greatly appreciated. A copy of the inspection report is attached for your records and inspection findings are summarized below. Site/System Review 2. The following system components were inspected: a. Three pump stations were inspected. No issues noted. b. Various manholes were inspected. No issues noted. c. One right of way was inspected. No issues noted. d. One aerial crossing was inspected. 3. As you are aware, owners of permitted collection systems must comply with their permit and all rules listed under NC Administrative Code 15A NCAC 02T .0400, et seq. The Town’s compliance status with each of these rules is summarized below: a. 15A NCAC 02T .0403(a)(1): Requires that the system be effectively maintained and operated at all times to prevent discharge to land or surface waters and any contravention of ground or surface water standards. Observations: Each pump station appeared to well maintained and operated. Compliance Status: Compliant b. 15A NCAC 02T .0403(a)(2): Requires that a map of the wastewater collection system be developed and actively maintained. Observations: The City has various paper maps showing locations of lines, direction of flow, force mains, pump stations, manholes and other information. Compliance Status: Compliant c. 15A NCAC 02T .0403(a)(3): Requires that an operation and maintenance (O&M) plan be developed and implemented, which includes pump station inspection frequency, preventative maintenance schedule, spare parts inventory and overflow response. Observations Pump station logs were available. Records were available for maintenance activities. Spare parts and pumps are kept in stock. An overflow response plan was available. Compliance Status: Compliant d. 15A NCAC 02T .0403(a)(4): Requires that the permittee or its representative inspect pump stations that are not connected to a telemetry system (i.e., remote alarm system) every day (i.e., 365 days per year) and pump stations that are connected to a telemetry system at least once per week. Observations: The pump station inspection logs indicate that the pump stations are visited more than required. Compliance Status: Compliant e. 15A NCAC 02T .0403(a)(5): Requires that the permittee or its representative inspect high-priority sewers (HPS - as defined in 15A NCAC 02T .0402(2)) at least once every six months and document the inspections. Observations: All lines are checked and documented. Compliance Status: Compliant f. 15A NCAC 02T .0403(a)(6): Requires that the permittee or its representative conduct a general observation of the entire wastewater collection system at least once per year and document same. Compliance Status: Compliant. g. 15A NCAC 02T .0403(a)(7): Requires that overflows and bypasses from the system be reported to the Division's Mooresville Regional Office in accordance with 15A NCAC 02B .0506(a), and that public notice must be provided as required by G.S. 143-215.1C. Observations: SSO’s have been reported with this system during this review period. The NC regulations and statutes, which cover the reporting requirements for SSOs, are found in NC Administrative Code 15A NCAC 02B .0506(a) and NC General Statute 143-215.1C, respectively. You may access the NC regulations online at the NC Office of Administrative Hearings (OAH) website at: http://www.oah.state.nc.us/rules/ and the NC General Statutes online at the NC General Assembly's website at: http://www.ncga.state.nc.us/gascripts/Statutes/StatutesTOC.pl. You may wish to review them to ensure you are fully familiar with all requirements. When reporting SSOs to DWQ, you must call the Mooresville Regional Office (MRO) at 704-663-1699 during normal business hours. If outside normal business hours, you must report the spill to the NC Division of Emergency Management at 1-800-858-0368. Please note that all reportable SSOs must be reported within 24 hours of the occurrence, or first knowledge, of the SSO. Please also note that voice mail or faxed messages are not considered as the initial verbal report. You must talk to and report the spill to a live person. Compliance Status: Compliant h. 15A NCAC 02T .0403(a)(8): Requires that a grease control program be developed and implemented as follows: 1. For publicly owned collection systems, the Grease Control Program shall include at least bi-annual distribution of grease education materials to users and the legal means to require grease interceptors. The Program shall also include legal means for inspections, enforcement, and legal means to control grease entering the system from other public and private satellite sewer systems. 2. Grease education materials shall be distributed more often than required above if necessary to prevent grease-related sanitary sewer overflows. Observations: Educational materials are mailed out to all customers and the same information is available upon request and is available at City Hall and on line. Compliance Status: Compliant. i. 15A NCAC 02T .0403(a)(9): Requires that right-of-ways (ROW) and easements be maintained to allow for personnel and equipment accessibility. Observations: Records were reviewed documenting that the right-of-ways were mowed, inspected and maintained to provide accessibility. Compliance Status: Compliant. j. 15A NCAC 02T .0403(a)(10): Requires that documentation be kept for all activities you undertake to comply with the requirements of 15A NCAC 02T .0403, subparagraphs (a)(1) through (a)(9), for a minimum of three years, with the exception of the map, which shall be maintained for the life of the system. Observations: Records were reviewed for right of way mowing, high-priority line inspections, and observation of the entire system. Compliance Status: Compliant The inspection report should be self-explanatory; however, if you have any questions regarding the inspection report or this letter please contact Tony Parker at 704-663-1699 or tony.parker@ncdenr.gov. Sincerely, W. Corey Basinger, Regional Supervisor Mooresville Regional Office Water Quality Regional Operations Section Division of Water Resources, NCDEQ Attachments: BIMS Inspection Report CC: MRO Central Files PERCS Unit (e-copy) Compliance Inspection Report Permit:WQCS00164 Effective:07/12/18 Expiration:05/31/26 Owner :City of Lowell SOC: Contact Person: Region: County: Directions to Facility: Gaston Mooresville Thomas Edward Shrewsbury Effective:Expiration:Facility:Lowell Collection System 101 W First St Lowell NC 28098 Title:Phone:704-913-1149Public Works Director Secondary ORC(s): 704-913-1149Phone:989267Certification:Thomas Edward ShrewsburyPrimary ORC: CS2,System Classifications: On-Site Representative(s): Related Permits: NC0025861 City of Lowell - Lowell WWTP Secondary Inspector(s): Primary Inspector: Inspection Date:Exit Time:Entry Time: Phone: 01/30/2020 10:00AM 12:30PM Tony Parker 704-663-1699 Facility Status: Permit Inspection Type: Reason for Inspection:Inspection Type: Not CompliantCompliant Routine Collection system management and operation Collection System Inspect Non Sampling 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 1/31/2020 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCS00164 01/30/2020 Collection System Inspect Non Sampling City of Lowell Routine Inspection Summary: Page 2 of 7 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCS00164 01/30/2020 Collection System Inspect Non Sampling City of Lowell Routine General Yes No NA NE 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?daily # 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? The current permit expires 5/31/2026.Comment: Sewer and FOG Ordinances Yes No NA NE 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?Size based. 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.) News letters, door hangers, pay booths and website. Comment: 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? Comment: Map Yes No NA NE Page 3 of 7 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCS00164 01/30/2020 Collection System Inspect Non Sampling City of Lowell 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? The Town has various paper maps which detail the required features.Comment: 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?Web site. The Town is not free of spills but are reporting as required.Comment: Inspections Yes No NA NE Are adequate maintenance records maintained? Are pump stations being inspected at the required frequency? # Is at least one complete functionality test conducted weekly per pump station? Is there a system or plan in place to observe the entire system annually? Is the annual inspection documented? # 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? All P/S's are inspected daily.Comment: Spill Response Action Plan Yes No NA NE Is a Spill Response Action Plan available? Is a Spill Response Action Plan available for all personnel? Does the plan include: Page 4 of 7 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCS00164 01/30/2020 Collection System Inspect Non Sampling City of Lowell 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: Spills 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? Comment: Lines/Right-of-Ways/Aerial Lines Yes No NA NE Please list the Lines/Right of Ways/Aerial Lines Inspected: Lynn Street R/W and aerial. No issues noted and R/W was well maintained. 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? The Town had cleaned 2.7 miles of gravity mains and slightly exceeded their 10% minimum requirement. Comment: Manholes Yes No NA NE Please list the Manholes Inspected: Various manholes inspected and no major issues noted. 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? Page 5 of 7 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCS00164 01/30/2020 Collection System Inspect Non Sampling City of Lowell Routine # 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: Pump Stations Yes No NA NE Please list the Pump Stations Inspected: Wilkinson Blvd., First St. and Rhyne St P/S's. One issue noted and that was the audiable alarm at First St P/S was not functioning. This was previously identified and a new alarm was already on order. # Number of duplex or larger pump stations in system 8 # 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?6 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? Page 6 of 7 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCS00164 01/30/2020 Collection System Inspect Non Sampling City of Lowell Routine # 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? Some P/S's have on-site generators and some rely on portable units. # 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? All P/S's are inspected daily including stations which have telementry installed.Comment: Page 7 of 7