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HomeMy WebLinkAboutWQCSD0375_NOD-2020-PC-0067_20200227ROY COOPER Governor MICHAEL S. REGAN secretory S. DANIEL SMITH Director NORTH CAROLINA Environmental Quality February 27t', 2020 Mr. Jeffrey O'Briant -- Director of Central Engineering NC DPT of Public Safety, Central Engineering 4216 Mail Service Center Raleigh, NC 27699-4216 Subject: Notice of Deficiency NOD-2020-PC-0067 Compliance Evaluation Inspection Franklin Co. Correctional Center Collection System Permit WQCSD0375 Franklin County Dear Mr. O'Briant: On Tuesday, February 25111, 2020, Josh Brigham of the Raleigh Regional Office of the Division of Water Resources, conducted a compliance evaluation inspection of the deemed collection system for the Franklin Co. Correctional Center. The purpose of this inspection was to ensure compliance with the subject permit. During the inspection, the presence and cooperation of Rick Richard was helpful and appreciated. This compliance evaluation inspection consisted of the following: Review of the 15A NCAC 02T .0403 permit requirements; Review of the owner/facility information; And on -site inspection of the collection system. Findines durine the inspection and file review were as follows: 1. The subject pen -nit was issued and became effective on March 1", 2000. All deemed permitted facilities are required to adhere to the requirements and procedures for permitting, operation, and maintenance of collection systems as stated in 15A NCAC 02T .0403 2. The Franklin Co. Correctional Center collection system does not have any pump stations or high priority lines on the property. The collection system consists of manholes, a bar screen, and sanitary sewer lines (all gravity) that collect and convey sanitary sewage to the city sewer maintained by the Town of Bunn. The bar screen is cleaned twice per day, seven days per week. 3. Under 15A NCAC 02T .0403 (a)(1), you are required to effectively maintain and operate the collection system at all times in order to prevent discharge to land or surface waters and to N Q �� North Carolina Department of Environmental Quality 1 Division of Water Resources Q E Raleigh Regional Office 13800 Barrett Drive I Raleigh, North Carolina 27609 Hnu:., tea, m �� \ r 919.791.4200 prevent any contravention of groundwater standards or surface water standards. The bar screen at the permitted facility is cleaned twice daily and documented. No problems were noted with the bar screen. Upon further examination of three manholes located within the yard, one manhole was observed to be full of water and in need of jetting. Another manhole was unable to be opened due to a lock that would not open. Jetting of lines is performed inside buildings when necessary and chemicals are used to unclog shower drains. 4. Under 15A NCAC 02T .0403 (a)(2), you are required to develop and maintain a map of the collection system. A map was not available at the time of inspection. A map should be developed that shows the components of the wastewater collection system (sewer Penes, manhole locations, location of bar screen, flow direction, size, age, and material of sewer. lines). 5. Under 15A NCAC 02T .0403 (a)(3), you are required to develop an operation and maintenance plan that includes a preventative maintenance schedule, spare parts inventory, and overflow response plan. An updated overall operation and maintenance plan should continue to be developed. An overflow response plan was available for review during the inspection. 6. Under 15A NCAC 02T .0403 (a)(6), a general observation by the permittee or its representative of the entire collection system shall be conducted once per )ear. At the time of inspection there were no records of annual observations of the entire collection system. 7. Under 15A NCAC 02T .0403 (a)(8)(B), privately owned collection systems will implement a Grease Control Program that includes bi-annual distribution of grease educational materials to users of the collection system by the permittee or its representative. We recommend putting signage in the kitchen that reminds staff about the appropriate disposal of fats, oil, and grease (FOG). It was also noted during the inspection that the grease trap in the kitchen had not been serviced by Greasecycle from 12/5/18 until 2/13/20 due to construction activities. 8. Under 15A NCAC 02T .0403 (a)(] 0), documentation of compliance with Subparagraphs (a)(1) through (a)(9) of this Rule shall be maintained by the collection system owner for three years with the exception of the map, «hick sliall be maintained for the life of the system. Documentation of the previously mentioned requirements should be developed and maintained for the aforementioned time frames. Please respond in writing as to how the bolded items will be addressed within 30 days of receipt of this letter. If you have questions or comments about the inspection, this report, or the requirements to take corrective action (if applicable), please contact: Josh Brigham at 919-791-4251 or via email at joshua.brigham@ncdenr.gov. Sincerely, Scott Vinson, Regional Supervisor Water Quality Regional Operations Section Raleigh Regional Office, Division of Water Resources, NCDEQ Attachments: Compliance Inspection Report Cc: RRO Files Laserf fiche Compliance Inspection Report Permit: WOCSDO375 Effective: 03/01/00 Expiration: SOC: Effective: Expiration: County: Franklin Region: Raleigh Contact Person: Nainesh Patel Title: Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): Related Permits: Inspection Date: 02/25/2020 Primary Inspector: Joshua S Brigham Secondary Inspectons): Entry Time: 08 45AM Certification; owner: North Carolina Department of Public Safety Facility: NC DOC-Franklin Co Corr Ctr Exit Time: 11.30AM Phone: 919-324-1283 Phone: Phone. 919-791-4200 Reason for Inspection: Routine Inspection Type: Collection System Inspect Non Sampling Permit Inspection Type: Deemed permitted collection system management and operation Facility Status: Compliant Not Compliant Question Areas: Miscellaneous 4uesuom General Grease Control Spills/Response Plan Inspections Lines Manholes Pump Stations (See attachment summary) Page 1 of 6 Permit: WOCSDO375 Owner -Facility: North Carol -a Department of PuCI c Safety Inspection Date: 02/25/2020 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Inspection Summary: 1. The subject permit was issued and became effective on March 1 st, 2000. All deemed permitted facilities are required to adhere to the requirements and procedures for permitting. operation, and maintenance of collection systems as stated in 15A NCAC 02T .0403 2. The Franklin Co. Correctional Center collection system does not have any pump stations or high priority lines on the properly. The collection system consists of manholes, a bar screen. and san tary sewer lines (all gravity) that collect and convey sanitary sewage to the city sewer maintained by the Town of Bunn. The bar screen is cleaned twice per day, seven days per week. 3. Under 15A NCAC 02T .0403 (a)(1), you are required to effectively maintain and operate the collection system at all times in order to prevent discharge to land or surface waters and to prevent any contravention of groundwater standards or surface water standards. The bar screen at the permitted facility is cleaned twice daily and documented. No problems were noted with the bar screen, Upon further examination of three manholes located within the yard, one manhole was observed to be full of water and in need of jetting. Another manhole was unable to be opened due to a lock that would not open. Jetting of lines is performed inside buildings when necessary and chemicals are used to unclog shower drains 4. Under 15A NCAC 02T .0403 (a)(2), you are required to develop and maintain a map of the collection system. A map was not available at the time of inspection. A map should be developed that shows the components of the wastewater collection system (sewer lines, manhole locations, location of bar screen, flow direction. size age, and material of sewer lines). 5. Under 15A NCAC 02T .0403 (a)(3), you are required to develop an operation and maintenance plan that includes a preventative maintenance schedule, spare parts inventory, and overflow response plan. An updated overall operation and maintenance plan should continue to be developed. An overflow response plan was available for review during the inspection. 6 Under 15A NCAC 02T .0403 (a)(6), a general observation by the permittee or its representative of the entire collection system shall be conducted once per year. At the time of inspection there were no records of annual observations of the entire collection system. 7. Under 15A NCAC 02T .0403 (a)(8)(B), privately owned collection systems will implement a Grease Control Program that includes bi-annual distribution of grease educational materials to users of the collection system by the permittee or its representative. We recommend putting signage in the kitchen that reminds staff about the appropriate disposal of fats, oil, and grease (FOG). It was also noted during the inspection that the grease trap in the kitchen had not been serviced by Greasecycle from 1215118 until 2113120 due to construction activities. 8. Under 15A NCAC 02T .0403 (a)(10), documentation of compliance with Subparagraphs (a)(1) through (a)(9) of this Rule shall be maintained by the collection system owner for three years with the exception of the map, which shall be maintained for the life of the system. Documentation of the previously mentioned requirements should be developed and maintained for the aforementioned time frames. Page 2 of 6 Permit: WOCSDO375 Owner • Facility: North Carolina Department of Public Safety Inspection Date: 0212512020 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine General Yes No NA NE # Is this system a satellite system? 0 ❑ El El # If Yes, what is system name or permit number? Is there a overall sewer system map? Does the map include Pipe sizes El 0 0 El Pipe materials (PVC, DIP, etc) Pipe location 0 # Flow direction # Approximate pipe age El M El El # Pump station ID, location and capacity 11 11M # Force main air release valve location & type # Location of satellite connections El ❑ Are system maintenance records maintained? El 11 . 0 Comment: No map was available for review the day of the inspection. Grease Control Yes No NA NE Is greaselsewer education program documented with req'd customer d stribut-on? # Are other types of education tools used like websites, booths, special meet:ngs, etc? El 0 El ❑ If Yes, what are they? (This can reduce mailing to annual.) There is not currently a grease education program. It was recommended that FOG signage be placed in the kitchen, Prior to December 2018, grease was taken from the kitchen by Greasecycle. However. due to construction, they were not able to to visit until February 2020, For public systems, is there a Grease Control Program via an ordinance, agreement? 0 ❑ ❑ If Yes, does it require grease control devices at applicable locations? X ❑ ❑ El Is the Grease Control Program enforced via periodic inspections;records review? El ❑ ❑ Is action taken against violators? ❑ 11 ❑ . Comment: There is agrease trap at the kitchen. Spills and Response Action Plan Yes No NA NE # Is system free of known points of bypass? El El 0 E If No, describe type of bypass and location # Have there been any sewer spills in the past 3 years? If Yes, were they reported to the Division if meeting the reportable criteria? El El 0 [] If applicable, is there documentation of press releases and public notices issued? Are all spills or sewer related issueslcomplaints documented? f # Are there repeated overflows/problems (2 or more in 12 months) at same location? [] ❑ 0 ri # If Yes, is there a corrective action plan? ❑ i El Page 3 of 6 penult: WOCSD0375 Owner - Facility: North Carolina Department of Public Safety Inspection Date: 0212512020 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine 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 E ❑ ❑ ❑ # Response time E ❑ ❑ ❑ # Equipment list and spare parts inventory ❑ ❑ 0 ❑ # Access to cleaning equipment ❑ ❑ ❑ # Access to construction crews, contractors, andlor engineers ❑ ❑ N ❑ # Source or emergency funds ❑ ❑ ■ ❑ # S•le sanitation and cleanup materials ■ ❑ ❑ ❑ # Past-overflowlspill assessment 0 ❑ ❑ ❑ Comment Inspections Yes No NA NE Are adequate maintenance records maintained? ❑ 0 ❑ ❑ Are pump stations being inspected at the required frequency? ❑ ❑ ■ ❑ Is at least one complete functionality test conducted weekly per pump station? ❑ ❑ N ❑ IS there a system or plan in place to observe the entire system annually? ❑ ®❑ ❑ Is the annual inspection documented? ❑ E ❑ ❑ # Does the system have any high -priority iinesliocations? ❑ ❑ ❑ ❑ Are inspections of HPL documented at least every 6 months? ❑ ❑ ❑ ❑ Are new lines being added to the HPL list when found or created? ❑ ❑ 0 ❑ Comment; Annual inspections are not performed. LineslRi ht-of-WayslAerial Lines Yes No NA NE Please list the Lines/Right of Ways/Aerial Lines Inspected. Are right-of-ways and easements maintained for the full width for access? ❑ ❑ a ❑ If No, give details on temporary access. Is maintenance documented? ❑ ❑ ❑ Were all areas/lines inspected free of issues? ❑ ❑ 0 ❑ Comment: Manholes Yes No NA NE Please list the Manholes Inspected, Two locked manholes located in the yard were inspected. A third was not able to be unlocked, Are manholes accessible? 0 ❑ ❑ ❑ # Are manhole covers/vents above grade? ❑ ❑ ❑ Are manholes free of visible signs of overflow? ❑ ❑ ❑ Are manholes free of sinkholes and depressions? ❑ ❑ ❑ Page 4 of 6 Permit: WOCSDO375 Owner -Facility: North Caro'..na Department-*( Publ a Safety Inspection Data: 07125I2020 Inspection Type : Cogection System Inspezt Non Sampling Reason for visit: Foutrre Are manhole covers present? 0 El❑ # Are manholes properly seated? 0 El ❑ ❑ # Are manholes in good condition? M ❑ # Are inverts in good condition? 0 El 1:1 El Is flow unrestricted in manholes? Are manholes free of excessive amounts of grease? 0 ❑ ❑ Are manholes free of excessive roots? ■ ❑ Are manholes free of excessive sand? El El El Are manhole vents screened? Are vents free of submergence? Are manholes free of bypass structures or pipes? E 0 El El Comment: One of the manholes was full of wastewater at the time of ins ection. It was stated that the. problem would be attended to immediately. Puma Stations Yes No NA NE Please list the Pump Stations Inspected # 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-Maler) installed? For pump stations inspected Are they secure with restricted access? Were they free of by-pass structuresipipes? ❑ ❑ 0 El Were wet wells free of excessive grease/debris? ❑ # Do they all have telemetry installed? ❑ ❑ 0 El Is the telemetry system functional? . El Is a 24-hour notification sign posted ? ❑ M El Does the sign include: Owner Name? El El i Pump station identifier? El El E El # Address? El ❑ M ❑ Instructions for notification? 11 El M El 24-hour emergency contact numbers? Are audio and visual alarms present? El El 0 11 Page 5 of 6 Permit: WQCS00375 Owner - Facility: North Carolina Department of Public Safety Inspection Date: 02125l2020 Inspection Type. Collection System Inspect Non Sampling Reason for Visit: Routine Are audio and visual alarms operable? # Is there a backup generator or bypass pump connected? If tested during inspect on, did it function properly? Is the back-up system tested at least biannually under normal rperalrg conditions? If 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 (UnitslStaffNehiclesletc) are included in Plan? # Does Permittee have the approved percentage of replacement simplex pumps? Is recordkeeping of pump station inspection and ma:ntenance 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•. ❑❑■❑ ❑❑ME] ❑ ❑ M ❑ ❑ ❑ E ❑ ❑ ❑ M ❑ ❑❑ME] ❑❑■❑ ❑❑ME] ❑❑ME] ❑❑ME] ❑ ❑' ❑ ❑❑ME] ❑❑■❑ Page 6 of 6