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Home My WebLink AboutWQCSD0093_Compliance Evaluation Inspection_20140908AT A NCDENR North Carolina Department of Environment and Natural Resources Pat McCrory John E. Skvarla, III Governor Secretary October 20, 2014 'A4.i11Is1:10 ►lfi1_\IWWI) 11I0*11I1111*1111::J![113LAI RETURN RECEIPT REQUESTED Gary Joyner Sugarloaf Utility, Inc. 4208 Six Forks Road, Suite 1400 Raleigh, NC 27609 Subject: NOTICE OF VIOLATION with INTENT TO ENFORCE Tracking No. NOV-2014-PC-0239 Collection System Inspection Deemed Permit No. WQCSDO093 Sugarloaf Utility Collection System Carteret County Dear Mr. Mr. Smith: An inspection of the Sugarloaf Utility Collection System was conducted by Amanda Gaines and Kevin Rowland from this office on September 8, 2014. This inspection was to verify that the facility is operating in compliance with the conditions and limitations specified in Permit No. WQCSDO093 and/or 15A NCAC 02T .0403. The findings and comments noted during this inspection are provided in the enclosed copy of the inspection report entitled "Compliance Inspection Report". The following compliance issues were noted during the inspection: Compliance Issues Operation and maintenance records were insufficient Inspection of pump stations is insufficient* Inspection frequency is insufficient** Emergency contact numbers and pump station identifiers are not present on all pump stations Documentation of Grease Control Program was not available *During onsite conversations with Fortin Contract Services personnel, it was stated that the only items checked during pump station inspections were the pump run times 127 Cardinal Drive Extension Wilmington, NC 28405 Phone: 910-796-7215 / Internet: www.ncwdenr.gov An Equal Opportunity/Affirmative Action Employer- Made in part by recycled paper Sugarloaf Utility Collection System WQCSDO093 Page 2 October 20, 2014 "During onsite conversations with Fortin Contract Services personnel, it was stated that the pump stations without telemetry were inspected weekly not daily and one low flow pump station was only inspected monthly. In addition, the following issue discussed in the inspection summary must also be addressed: • All documentation must be available upon request during an inspection. Including, but not limited to, the 0&M Plan, Spill Response Plan, map, 0&M records, Grease Control Plan documentation Please respond in writing to this office within 30 days upon your receipt of this Notice of Violation with Intent to Enforce regarding your plans or measures to be taken to address the indicated compliance issues and other identified concerns. If you have any questions concerning this Notice of Violation with Intent to Enforce or the enclosed inspection report, you may contact me at the letterhead contact information or via email at Jim.Gregson@ncdenr.gov. Sincerely, James Gregson, Regional Supervisor Water Quality Regional Operations Section Wilmington Regional Office Division of Water Resources, NCDENR Enclosure: Inspection Report Cc: Dan Fortin, ORC Wilmington Regional Office — WQCSDO093 File MSC 1617 Central Files Basement G:\WQ\Shared\Amanda\ALL THINGS SEWER\Collection Systems\Inspections\Inspection Year 2013-2014 Permit: WQCSD0093 SOC: County: Carteret Region: Wilmington Compliance Inspection Report Effective: 03/01/00 Expiration: Owner: Sugarloaf Utility Inc Effective: Expiration: Facility: Sugarloaf Utility Collection System Contact Person: William T Smith Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): Related Permits: Title: Certification: Phone: 919-828-1515 Phone: Inspection Date: 09/08/2014 Entry Time: 11:OOAM Exit Time: 12:45PM Primary Inspector: Amanda L Gaines Phone: 910-796-7215 Secondary Inspector(s): Kevin Rowland Phone : 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 Questions Performance Standards Operation & Maint Reqmts Records Monitoring & Rpting Reqmts Inspections Pump Station (See attachment summary) Page: 1 Permit: WQCSDO093 Owner - Facility: Sugarloaf Utility Inc Inspection Date: 09/08/2014 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Inspection Summary: During this inspection of the Sugarloaf Utilites collection system, 4 of the 12 pump stations were inspected. All pump stations should be operated and maintained in accordance with 15A NCAC 02T .0403. A Operation and Maintenance Plan and Spill Response Plan and map are on file with the Division; however the following should be available upon request at all inspections and available to personnel: -a map of the sewer system -operation and maintenance records -operation and maintenance plan, preventative maintenance schedule, overflow response plan, spare parts inventory -documentation of the Grease Control Plan and means of distribution -a pump station list that includes features of the pump station (location, generator plug, telemetry, etc) *" After contacting owner, Gary Joyner, the inspector will accept for this inspection the map and O&M plan on file with the Division. However, the following are still not documented and are violations: -documentation of the Grease Control Plan and means of distribution -the operation and maintenance records submitted by Fortin Contractors after the inspection were not sufficient. Only run times for pumps recorded and the few notes about maintenance were not legible Pump stations not connected to telemetry must be inspected daily by Permittee or a representative (365 days/yr). Pump stations connected to telemetry must be inspected weekly. **As stated by the collection sytem operator during the inspection, the pump stations without telemetry are being inspected once a week not daily and at least one pump station with telemetry is being inspected only once a month. These are violations. Additionaly, when the operator inspects the pump stations only pump run times are being recorded and as stated during the inpsction by the operator, the floats are not pulled and the pumps and alarms are not tested. These are violations. Inspection of the pump stations should include a check of the exterior grounds, check equipment, visullay inspect electrical, check controls for alternation of run and stanby, check vent lines, inspect and run pumps, test level control floats, check alarms (audible/visual/telemetry), inspect for debris or buildup in wet well. These are included as part of the O&M Plan submitted to the Division by Sugarloaf Utilites. An emergency contact number, pump station identifier, and instructions should be placed on all pump stations in a place where they are easily seen. ." of the four pump stations visited, only two had contact numbers but no pump station identifiers and at one pump station the number was placed at time of inspection. These are violations. Page: 2 Permit: WQCSDO093 Owner - Facility: Sugarloaf Utility Inc Inspection Date: 09/08/2014 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Performance Standards Yes No NA NE Is Public Education Program for grease established and documented? ❑ 0 ❑ ❑ What educational tools are used? The owner indicated on the phone after the inspection that grease education was being sent out but at the date of the report no documentation was provided Is Sewer Use Ordinance/Legal Authority available? ❑ ❑ ❑ Does it appear that the Sewer Use Ordinance is enforced? ❑ ❑ ❑ Is Grease Trap Ordinance available? ❑ ❑ ❑ Is Septic Tank Ordinance available (as applicable, i.e. annexation) ❑ ❑ ❑ List enforcement actions by permittee, if any, in the last 12 months Has an acceptable Capital Improvement Plan (CIP) been implemented? ❑ ❑ ❑ Does CIP address short term needs and long term \"master plan\" concepts? ❑ ❑ ❑ Does CIP cover three to five year period? ❑ ❑ ❑ Does CIP include Goal Statement? ❑ ❑ ❑ 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? ❑ ❑ ❑ Is CIP designated only for wastewater collection and treatment? ❑ ❑ ❑ Approximate capital improvement budget for collection system? Total annual revenue for wastewater collection and treatment? CIP Comments Is system free of known points of bypass? ❑ ❑ ❑ If no, describe type of bypass and location Is a 24-hour notification sign posted at ALL pump stations? ❑ ❑ ❑ # Does the sign include: Instructions for notification? ❑ ❑ ❑ Pump station identifier? ❑ ❑ ❑ 24-hour contact numbers ❑ ❑ ❑ If no, list deficient pump stations Some pump station had no signage present and the sign that was present did not identify the pump station # Do ALL pump stations have an "auto polling" feature/SCADA? ❑ ❑ ❑ Number of pump stations 12 Number of pump stations that have SCADA 0 Number of pump stations that have simple telemetry Number of pump stations that have only audible and visual alarms Page: 3 Permit: WQCSDO093 Owner - Facility: Sugarloaf Utility Inc Inspection Date: 09/08/2014 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Number of pump stations that do not meet permit requirements # Does the permittee have a root control program? # If yes, date implemented? Describe: 12 ❑■❑❑ Comment: During the inspection only 4 of the 12 pump stations were observed. Of those, two had telemetry and two did not. Inspections Yes No NA NE Are maintenance records for sewer lines available? ❑ 0 ❑ ❑ Are records available that document pump station inspections? ❑ ❑ ❑ Are SCADA or telemetry equipped pump stations inspected at least once a week? ❑ ❑ ❑ Are non-SCADA/telemetry equipped pump stations inspected every day? ❑ ❑ ❑ Are records available that document citizen complaints? ❑ ❑ ❑ # Do you have a system to conduct an annual observation of entire system? ❑ ❑ ❑ # Has there been an observation of remote areas in the last year? ❑ ❑ ❑ Are records available that document inspections of high -priority lines? ❑ ❑ ❑ Has there been visual inspections of high -priority lines in last six months? ❑ 0 ❑ ❑ Comment: During inspection ORC stated that one pump stations he only visits once a month, the others are only weekly even if they don't have telemetry. Also that when pump stations visited, only pump run times are observed - no floats are pulled and no alarms tested. Operation & Maintenance Requirements Yes No NA NE Are all log books available? ❑ ❑ ❑ Does supervisor review all log books on a regular basis? ❑ ❑ ❑ Does the supervisor have plans to address documented short-term problem areas? ❑ ❑ ❑ What is the schedule for reviewing inspection, maintenance, & operations logs and problem areas? Are maintenance records for equipment available? ❑ 0 ❑ ❑ Is a schedule maintained for testing emergency/standby equipment? ❑ ❑ ❑ What is the schedule for testing emergency/standby equipment? Do pump station logs include: 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? ❑ ❑ ❑ Is there at least one spare pump for each pump station w/o pump reliability? ❑ ❑ ❑ Are maintenance records for right-of-ways available? ❑ ❑ ❑ Are right-of-ways currently accessible in the event of an emergency? ❑ ❑ ❑ Are system cleaning records available? ❑ ❑ ❑ Has at least 10% of system been cleaned annually? ❑ ❑ ❑ Page: 4 Permit: WQCSDO093 Owner - Facility: Sugarloaf Utility Inc Inspection Date: 09/08/2014 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine What areas are scheduled for cleaning in the next 12 months? Is a Spill Response Action Plan available? 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 ❑ ❑ ❑ Is a Spill Response Action Plan available for all personnel? ❑ ❑ ❑ Is the spare parts inventory adequate? ❑ 0 ❑ ❑ Comment: During inpsection the O&M and Spill Response plans were not made available by contract personnel. It is on file with the Division: however, this needs to be available upon request to demonstrate that appropriate personnel have access. Records Yes No NA NE Are adequate records of all SSOs, spills and complaints available? ❑ ❑ ❑ Are records of SSOs that are under the reportable threshold available? ❑ ❑ ❑ Do spill records indicate repeated overflows (2 or more in 12 months) at same location? ❑ ❑ ❑ If yes, is there a corrective action plan? ❑ ❑ ❑ Is a map of the system available? ❑ ❑ ❑ Does the map include: Pipe sizes ❑ ❑ ❑ Pipe materials ❑ ❑ ❑ Pipe location ❑ ❑ ❑ Flow direction ❑ ❑ ❑ Approximate pipe age ❑ ❑ ❑ Number of service taps ❑ ❑ ❑ Pump stations and capacity ❑ ❑ ❑ If no, what percent is complete? 80% List any modifications and extensions that need to be added to the map # Does the permittee have a copy of their permit? ❑ ❑ 0 ❑ Comment: Spill records were not requested at time of inspection but should be maintained and available upon request. This is a deemed permitted system therefore was not issued a permit but is regulated under 15A NCAC 02T .0403 Monitoring and Reporting Requirements Yes No NA NE Page: 5 Permit: WQCSDO093 Owner - Facility: Sugarloaf Utility Inc Inspection Date: 09/08/2014 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Are copies of required press releases and distribution lists available? Are public notices and proof of publication available? ❑■❑❑ ❑❑❑■ # Is an annual report being prepared in accordance with G.S. 143-215.1 C? ❑ ❑ ❑ # Is permittee compliant with all compliance schedules in the permits? ❑ ❑ 0 ❑ If no, which one(s)? Comment: The shell for a press release is available in the Spill Response Plan; however, a distribution list is not included HWY58/CORAL BAY - Pump Station Yes No NA NE Pump station type Duplex Are pump station logs available? ❑ 0 ❑ ❑ Is it accessible in all weather conditions? 0 ❑ ❑ ❑ # Is general housekeeping acceptable? 0 ❑ ❑ ❑ Are all pumps present? 0 ❑ ❑ ❑ Are all pumps operable? 0 ❑ ❑ ❑ Are wet wells free of excessive debris? 0 ❑ ❑ ❑ Are upstream manholes free of excessive debris/signs of overflow? ❑ ❑ ❑ Are floats/controls for pumps/alarms operable? ❑ ❑ ❑ Is "auto polling" feature/SCADA present? ❑ ❑ ❑ Is "auto polling" feature/SCADA operational? ❑ ❑ ❑ Is simple telemetry present? ❑ ❑ ❑ Is simple telemetry operational? ❑ ❑ ❑ Are audio and visual alarms present? ❑ ❑ ❑ Are audio and visual alarms operable? ❑ ❑ ❑ Is the Pump station inspected as required? ❑ ❑ ❑ Are backflow devices in place? ❑ ❑ ❑ Are backflow devices operable? ❑ ❑ ❑ Are air relief valves in place? ❑ ❑ ❑ Are air relief valves operable? ❑ ❑ ❑ # Is an emergency generator available? ❑ ❑ ❑ Can the emergency generator run the pumps? ❑ ❑ ❑ Is the pump station equipped for quick hook-up? ❑ ❑ ❑ Is the generator operable? ❑ ❑ ❑ # Is fuel in tank and sufficient? ❑ ❑ ❑ Is the generator inspected according to their schedule? ❑ ❑ ❑ Is a 24-hour notification sign posted? ❑ ❑ ❑ Page: 6 Permit: WQCSDO093 Owner - Facility: Sugarloaf Utility Inc Inspection Date: 09/08/2014 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Does it include: Instructions for notification? ❑ 0 ❑ ❑ Pump station identifier? ❑ 0 ❑ ❑ Emergency phone number ❑ 0 ❑ ❑ Is public access limited? ❑0 ❑ ❑ Is pump station free of overflow piping? ❑ ❑ ❑ Is the pump station free of signs of overflow? ❑ ❑ ❑ Are run times comparable for multiple pumps? Comment: The alarm was not functioning but Dan Fortin from Fortin Contractors fixed during inspection. ORC stated that the alarms and floats were not tested during weekly visits. No telemetry - the pump station should be inpsected daily. PS#2 NEEDLE RUSH BAY - Pump Station Yes No NA NE Pump station type Duplex Are pump station logs available? ❑ 0 ❑ ❑ Is it accessible in all weather conditions? ❑ ❑ ❑ # Is general housekeeping acceptable? ❑ ❑ ❑ Are all pumps present? ❑ ❑ ❑ Are all pumps operable? ❑ ❑ ❑ Are wet wells free of excessive debris? ❑ ❑ ❑ Are upstream manholes free of excessive debris/signs of overflow? ❑ ❑ ❑ Are floats/controls for pumps/alarms operable? ❑ ❑ ❑ Is "auto polling" feature/SCADA present? ❑ ❑ ❑ Is "auto polling" feature/SCADA operational? ❑ ❑ ❑ Is simple telemetry present? ❑ ❑ ❑ Is simple telemetry operational? ❑ ❑ ❑ Are audio and visual alarms present? ❑ ❑ ❑ Are audio and visual alarms operable? ❑ ❑ ❑ Is the Pump station inspected as required? ❑ ❑ ❑ Are backflow devices in place? ❑ ❑ ❑ Are backflow devices operable? ❑ ❑ ❑ Are air relief valves in place? ❑ ❑ ❑ Are air relief valves operable? ❑ ❑ ❑ # Is an emergency generator available? ❑ ❑ ❑ Can the emergency generator run the pumps? ❑ ❑ ❑ Is the pump station equipped for quick hook-up? ❑ ❑ ❑ Is the generator operable? ❑ ❑ ❑ Page: 7 Permit: WQCSDO093 Owner - Facility: Sugarloaf Utility Inc Inspection Date: 09/08/2014 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine # Is fuel in tank and sufficient? ❑ ❑ 0 ❑ Is the generator inspected according to their schedule? ❑ ❑ 0 ❑ Is a 24-hour notification sign posted? 0 ❑ ❑ ❑ Does it include: Instructions for notification? ❑ 0 ❑ ❑ Pump station identifier? ❑ 0 ❑ ❑ Emergency phone number 0❑ ❑ ❑ Is public access limited? ❑ ❑ ❑ Is pump station free of overflow piping? ❑ ❑ ❑ Is the pump station free of signs of overflow? ❑ ❑ ❑ Are run times comparable for multiple pumps? yes Comment: The map indicated that this pump station has telemetry but no phone line. The O&M plan has list of pump stations but for this PS there is no data. It states that there is no development at Needle Rush Bay. There was no emergency signage on the Pump station; however, during the inspection emergency numbers were placed on the station. No identifier was placed and no instructions. AS #3 - Pump Station Yes No NA NE Pump station type Duplex Are pump station logs available? ❑ ❑ ❑ Is it accessible in all weather conditions? ❑ ❑ ❑ # Is general housekeeping acceptable? ❑ ❑ ❑ Are all pumps present? ❑ ❑ ❑ Are all pumps operable? ❑ ❑ ❑ Are wet wells free of excessive debris? 0 ❑ ❑ ❑ Are upstream manholes free of excessive debris/signs of overflow? ❑ ❑ ❑ Are floats/controls for pumps/alarms operable? ❑ ❑ ❑ Is "auto polling" feature/SCADA present? ❑ ❑ ❑ Is "auto polling" feature/SCADA operational? ❑ ❑ ❑ Is simple telemetry present? ❑ ❑ ❑ Is simple telemetry operational? ❑ ❑ ❑ Are audio and visual alarms present? ❑ ❑ ❑ Are audio and visual alarms operable? ❑ ❑ ❑ Is the Pump station inspected as required? ❑ ❑ ❑ Are backflow devices in place? ❑ ❑ ❑ Are backflow devices operable? ❑ ❑ ❑ Are air relief valves in place? ❑ ❑ ❑ Page: 8 Permit: WQCSD0093 Owner - Facility: Sugarloaf Utility Inc Inspection Date: 09/08/2014 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Are air relief valves operable? ❑ ❑ ❑ # Is an emergency generator available? ❑ ❑ 0 ❑ Can the emergency generator run the pumps? ❑ ❑ 0 ❑ Is the pump station equipped for quick hook-up? ❑ 0 ❑ ❑ Is the generator operable? ❑ ❑ 0 ❑ # Is fuel in tank and sufficient? ❑ ❑ 0 ❑ Is the generator inspected according to their schedule? ❑ ❑ 0 ❑ Is a 24-hour notification sign posted? 0 ❑ ❑ ❑ Does it include: Instructions for notification? ❑ 0 ❑ ❑ Pump station identifier? ❑ 0 ❑ ❑ Emergency phone number 0❑ ❑ ❑ Is public access limited? ❑ ❑ ❑ Is pump station free of overflow piping? ❑ ❑ ❑ Is the pump station free of signs of overflow? ❑ ❑ ❑ Are run times comparable for multiple pumps? Comment: Run time lops are available but no other inspection was performed and noted for this pump station BAY RIDGE - Pump Station Yes No NA NE Pump station type Duplex Are pump station logs available? ❑ ❑ ❑ Is it accessible in all weather conditions? ❑ ❑ ❑ # Is general housekeeping acceptable? ❑ ❑ ❑ Are all pumps present? ❑ ❑ ❑ Are all pumps operable? ❑ ❑ ❑ Are wet wells free of excessive debris? ❑ ❑ ❑ Are upstream manholes free of excessive debris/signs of overflow? ❑ ❑ ❑ Are floats/controls for pumps/alarms operable? ❑ ❑ ❑ Is "auto polling" feature/SCADA present? ❑ ❑ ❑ Is "auto polling" feature/SCADA operational? ❑ ❑ ❑ Is simple telemetry present? ❑ ❑ ❑ Is simple telemetry operational? ❑ ❑ ❑ Are audio and visual alarms present? ❑ ❑ ❑ Are audio and visual alarms operable? ❑ ❑ ❑ Is the Pump station inspected as required? ❑ ❑ ❑ Page: 9 Permit: WQCSDO093 Owner - Facility: Sugarloaf Utility Inc Inspection Date: 09/08/2014 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Are backflow devices in place? ❑ ❑ ❑ Are backflow devices operable? ❑ ❑ ❑ Are air relief valves in place? ❑ ❑ ❑ Are air relief valves operable? ❑ ❑ ❑ # Is an emergency generator available? ❑ ❑ ❑ Can the emergency generator run the pumps? ❑ ❑ ❑ Is the pump station equipped for quick hook-up? ❑ ❑ ❑ Is the generator operable? ❑ ❑ ❑ # Is fuel in tank and sufficient? ❑ ❑ ❑ Is the generator inspected according to their schedule? ❑ ❑ ❑ Is a 24-hour notification sign posted? ❑ 0 ❑ ❑ Does it include: Instructions for notification? ❑ 0 ❑ ❑ Pump station identifier? ❑ 0 ❑ ❑ Emergency phone number ❑ 0 ❑ ❑ Is public access limited? ❑0 ❑ ❑ Is pump station free of overflow piping? ❑ ❑ ❑ Is the pump station free of signs of overflow? ❑ ❑ ❑ Are run times comparable for multiple pumps? Comment: There is no telemetry and the alarm was not functional. ORC only visits site once a week. No telemetry requires daily visits. No emergency contact info was on the pump station. ORC stated that owner did not give permission to display emergency info. Page: 10