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HomeMy WebLinkAboutWQCS00332_Compliance Evaluation Inspection_20200916DocuSign Envelope ID: AB7D3B10-4D57-4045-BAAC-9819D50BFD21 ,.,srnreq Rov CooPEA Governor M[CHAEL S. REGAN secmrury .tt R" S. DANIEL SMITH NCR7H cARouNA Dlrecf r Environmental Qaality September 28, 2020 Gwendolyn B Vann, Mayor Town of Magnolia PO Box 459 Magnolia, NC 28453-0459 SUBJECT: NOTICE OF VIOLATION Tracking Number: NOV-2020-PC-0431 Permit No. WQCS00332 Magnolia Collection System Duplin County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Magnolia Collection System on September 16, 2020. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in Collection System Permit No. WQCS00332. A summary of the findings and comments noted during the inspection are provided in the enclosed copy of the inspection report. The Collection System Evaluation inspection was conducted by Division of Water Resources staff from the Wilmington Regional Office. The following violation(s) were noted during the inspection: Inspection Area Description of Violation Sewer and FOG Ordinances Need to ensure that the FOG/Sewer education materials are being provided to each customer at least every 6 months and that it is documented. Additionally, need to ensure that all potential commercial users are abiding by the FOG ordinance as far installation and maintenance of controls. General Overall better documentation and recordkeeping of actions & activities are needed. Example forms will be provided to the Town via email that can be used to meet these requirements. Map The sewer system map needs updating to meet the requirements in the permit and listed in the report. The asset study mentioned below in the CIP could assist with this endeavor, but otherwise it will require survey and perhaps video work to be done. Pump Stations The visual alarms in 2 of the 4 pump stations were out and need to be replaced. Capital Improvement Plan Town needs to have a formal Capital/System Improvement Plan developed and implemented. To facilitate its development, an asset inventory and assessment study could be performed and grants have been available for these in the past. �rw North Ca—,ms Department of Environmental Qualrtv 6!vsvn of Water Resources lVf ) Wdrn:ngweg+�neiaff;ce 1127 CaNimlDnve Eztensan Ni4r'wr -, North :ara"ra 254DE 910-796-7215 DocuSign Envelope ID: AB7D3B10-4D57-4045-BAAC-9819D50BFD21 Remedial actions should be taken to correct these issues and prevent further occurrences in the future. The Division of Water Resources may pursue enforcement action for this and any additional violations of State law. To prevent further action in the future, please ensure these are corrected as soon as possible and prior to the next inspection. If you should have any questions, please do not hesitate to contact Dean Hunkele with the Water Quality Regional Operations Section in the Wilmington Regional Office at 910-796-7215. Sincerely, EDocuSigned by: Cuµ 7F141E73B6F3456... Tom Tharrington, Asst. Regional Supervisor Water Quality Regional Operations Section Wilmington Regional Office Division of Water Resources, NCDEQ ATTACHMENTS Cc: Upload to Laserfiche �E North Caro G ma Department of Environmental Quality I Dioision of Water Resources W lmingon Reg—] Office I 127 Cardinal Dave Exteason I Wilmington, North Carof ma 23405 91D-796-7215 Compliance Inspection Report Permit: WQCS00332 Effective: 11/09/17 Expiration: 10/31/25 Owner: Town of Magnolia SOC: Effective: Expiration: Facility: Magnolia Collection System County: Duplin Region: Wilmington Contact Person: Sudie G Matthis Title: Public Works Director Phone: 910-284-6557 Directions to Facility: System Classifications: CS1, Primary ORC: Sudie G Matthis Secondary ORC(s): Brent McCoy Dean On -Site Representative(s): On -site representative Certification: 24880 144O :IR Sudie G Matthis Related Permits: NC0020346 Town of Magnolia - Magnolia WWTP Phone: 910-284-6557 910-285-5927 910-284-6557 Inspection Date: 09/16/2020 Entry Time 10:45AM Exit Time: 01:OOPM Primary Inspector: Dean Hunkele Docusigned by: Phone: 910-796-7215 Secondary Inspector(s): EE 9/28/2020 E1 D9294C4D3746E... 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: WQCS00332 Owner - Facility: Town of Magnolia Inspection Date: 09/16/2020 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Inspection Summary: Overall, the Town is doing a fair job in managing its collection system given its budget and staffing constraints. The following issues were noted during the inspection that need to be addressed: 1. Need to ensure that the FOG/Sewer education materials are being provided to each customer at least every 6 months and that it is documented. Additionally, need to ensure that all potential commercial users are abiding by the FOG ordinance as far installation and maintenance of controls. 2. Town needs to have a formal Capital/System Improvement Plan developed and implemented. To facilitate its development an asset inventory and assessment study should be performed and grants have been available for these in the past. 3. The sewer system map needs updating to meet the requirements in the permit and listed in the report. The asset study in Item 2 could assist with this endeavor, but otherwise it will require survey and perhaps video work to be done. 4. Overall better documentation and recordkeeping of actions & activities are needed. Example forms will be provided to the Town via email that can be used to meet these requirements. 5. The visual alarms in 2 of the 4 pump stations were out and need to be replaced. A Notice of Violation is being issued for the above. Page 2 of 7 Permit: WQCS00332 Owner - Facility: Town of Magnolia Inspection Date: 09/16/2020 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? daily/weekly # 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? 0 ❑ ❑ ❑ 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: 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? ❑ ❑ ❑ 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? 30 days 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: Town only has one full -service restaurant it collects trap cleaning records from, but inspector observed that a convenience store and taco stand along West Main Street should be included in the reauirement to have arease controls installed & maintained Der FOG ordinance. 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? ❑ ❑ ❑ Page 3 of 7 Permit: WQCS00332 Owner - Facility: Town of Magnolia Inspection Date: 09/16/2020 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Comment: Town needs a more formal CIP developed: public works director has an itemized "wish list", but lacks some formal detail and any funding. Seems like Town could use an asset & inventory study to help outline its needs and develop a plan to address. Map Is there a overall sewer system map? Does the map include: Yes No NA NE ■❑❑❑ 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? ❑ ❑ ❑ Comment: Map is lacking some of the required detail, but should be complete by now as only up to 10 year: allowed from first permit issuance to have done; permit originally issued 11-2009. Reporting Requirements Yes No NA NE # Have there been any sewer spills in the past 3 years? ❑ ❑ 0 ❑ If Yes, were they reported to the Division if meeting the reportable criteria? ❑ ❑ 0 ❑ 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: No SSOs have ever been reported 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? ❑ 0 ❑ ❑ 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? 0 ❑ ❑ ❑ Comment: More detail could be provided on inspection and O&M records. Page 4 of 7 Permit: WQCS00332 Owner - Facility: Town of Magnolia Inspection Date: 09/16/2020 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Spill Response Action Plan Yes No NA NE Is a Spill Response Action Plan available? 0 ❑ ❑ ❑ 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: 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: Lines/Right-of-Ways/Aerial Lines Yes No NA NE Please list the Lines/Right of Ways/Aerial Lines Inspected: 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: Cleaning records provided after inspection shows that 4597 ft was cleaned in 2017, 4072 ft in 2018, and 5586 ft in 2019. According to last permit issuance the system had 7.36 miles of gravity sewer or 38,860 ft, thus cleaning target would be 3886 ft. Town staff indicated they have 43,130 ft thus target would be 4313 ft. Manholes Please list the Manholes Inspected: Yes No NA NE Are manholes accessible? ❑ ❑ ❑ Page 5 of 7 Permit: WQCS00332 Owner - Facility: Town of Magnolia Inspection Date: 09/16/2020 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine # 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: Pump Stations Yes No NA NE Please list the Pump Stations Inspected: Newberry, Hwy 903, Blanton, and Off -site Influent # Number of duplex or larger pump stations in system 4 # 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? 0 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? ❑ ❑ ❑ Page 6 of 7 Permit: WQCS00332 Owner - Facility: Town of Magnolia Inspection Date: 09/16/2020 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Instructions for notification? 0 ❑ ❑ ❑ 24-hour emergency contact numbers? 0 ❑ ❑ ❑ Are audio and visual alarms present? 0 ❑ ❑ ❑ Are audio and visual alarms operable? ❑ 0 ❑ ❑ # 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? ❑ ❑ ❑ # 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? ❑ ❑ ❑ 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? ❑ ❑ ❑ ❑ Inspecting and exercising all valves? ❑ ❑ ❑ ❑ Inspecting and lubricating pumps and other equipment? ❑ ❑ ❑ ❑ Inspecting alarms, telemetry and auxiliary equipment? ❑ ❑ ❑ ❑ Comment: Has 4 stations if you count the off -site WWTP influent. Both the influent and Newberry visual alarms were out. Newberry could use to be replaced with proper station, but the control panel esDecially aiven its aae and condition. Could use more detail on activities and O&M at stations. Page 7 of 7