HomeMy WebLinkAboutWQCS00328_Compliance Evaluation Inspection_20210304ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
Mr. Haynes Brigman, City Manager
City of Harrisburg
PO Box 100
Harrisburg, NC 28075
NORTH CAROLINA
Environmental Qualify
March 4, 2021
Subject: Compliance Evaluation Inspection
Permittee: City of Harrisburg Waste Water Collection System
Permit No. WQCS00328
Cabarrus County
Dear Mr. Brigman:
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 March 3, 2021. The assistance of Mr.
Andrew Ulrich, Mr. Matthew Whitley and others 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. Four pump stations were inspected. No issues noted.
b. Numerous manholes were inspected. Several issues noted. Please see attached
report for details.
c. Several right of ways were inspected. No issues noted.
d. One aerial crossing was inspected. No issues noted.
Please review the attached Report for all details and action items.
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
City' 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 su rds.
DEQ
,)
North Carolina Department of Environmental Quality I Division of Water Resources
610 East Center Avenue I Suite 301 I Mooresville, North Carolina 28115
704-663-1699
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 utilizes GIS and various paper maps which show
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 all
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 as 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.
g-
Compliance Status: Compliant.
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 info is provided to all customers via mail outs and the
City' s Annual Report. Info is also available upon request and is available at City
offices.
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.
J.
Observations: Records were reviewed documenting that the right-of-ways are
mowed, inspected and maintained to provide accessibility.
Compliance Status: Compliant.
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 high -priority line inspections, and
observation of the entire system.
Compliance Status: Compliant
The attached 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.
Attachments:
BIMS Inspection Report
CC: MRO
Central Files
PERCS Unit (e-copy)
Sincerely,
DocuSigned by:
c
w N P;ut4
F161FB69A2D84A3...
for
W. Corey Basinger, Regional Supervisor
Mooresville Regional Office
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
Compliance Inspection Report
Permit: WQCS00328
SOC:
County: Cabarrus
Region: Mooresville
Effective: 06/01/18
Effective:
Contact Person: Gregory Peifer
Directions to Facility:
System Classifications: CS2,
Primary ORC: Andrew J Ulrich
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Expiration: 05/31/26
Expiration:
Title: ORC
Owner : Town of Harrisburg
Facility: Harrisburg Collection System
PO Box 100
Harrisburg NC 280750100
Phone: 704-239-9762
Certification: 1005841 Phone: 704-455-4669
NC0036269 Water and Sewer Authority of Cabarrus County - Rocky River WWTP
Inspection Date: 03/03/2021
Primary Inspector: Tony Parker
Secondary Inspector(s):
Reason for Inspection: Routine
Permit Inspection Type: Collection
Facility Status: Compliant
Question Areas:
▪ Miscellaneous Questions
▪ Capital Improvement Plan
▪ Inspections
▪ Lines
Entry Time 10:OOAM
Exit Time: 01:30PM
Phone: 704-663-1699
Inspection Type: Collection System Inspect Non Sampling
system management and operation
❑ Not Compliant
(See attachment summary)
▪ General
▪ Map
▪ Spill Response Plan
▪ Manholes
▪ Sewer & FOG Ordinances
▪ Reporting Requirements
▪ Spills
▪ Pump Stations
Page 1 of 7
Permit: WQCS00328 Owner - Facility: Town of Harrisburg
Inspection Date: 03/03/2021
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Inspection Summary:
Page 2 of 7
Permit: WQCS00328 Owner - Facility: Town of Harrisburg
Inspection Date: 03/03/2021
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
General
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?
# 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?
Comment: The current permit expires 5/31/2026.
Sewer and FOG Ordinances
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?
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.)
Mail outs,news letters, Annual Reports and web site and FOG info in billing.
Comment:
Capital Improvement Plan
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: The current CIP covers a 10 year period.
Map
Yes No NA NE
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Page 3 of 7
Permit: WQCS00328 Owner - Facility: Town of Harrisburg
Inspection Date: 03/03/2021
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: 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?
Comment: Various maps available including GIS maps.
Reporting Requirements
# 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: The city is not free of spills but are reporting as required.
Inspections
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?
Comment: Good record keeping noted for all activities.
Spill Response Action Plan
Is a Spill Response Action Plan available?
Is a Spill Response Action Plan available for all personnel?
Does the plan include:
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Web -site
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Page 4 of 7
Permit: WQCS00328 Owner - Facility: Town of Harrisburg
Inspection Date: 03/03/2021
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: 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: All spills are documented as required.
Spills
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
Please list the Lines/Right of Ways/Aerial Lines Inspected:
Orchard Park outfall, Stallings Rd. Aerial and abbington outfall. No issues observed and all areas appeared
to be well maintained.
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If No, give details on temporary access:
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Comment: The city had cleaned 13.3 miles of gravity mains and CCTV'd 9.3 miles of line. The city also
treats lines for root control and smoke testing is also conducted.
Manholes
Please list the Manholes Inspected:
Numerous manholes inspected. Several M/H vents needed screening. No other 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?
Yes No NA NE
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Page 5 of 7
Permit: WQCS00328 Owner - Facility: Town of Harrisburg
Inspection Date: 03/03/2021
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: 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: Several vent pipes needed screening. No other issues observed.
Pump Stations
Please list the Pump Stations Inspected:
Orchard Park, School Circle, Stallings Park & Abbington P/S's. No issues observed.
# 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:
# Atwo-way "auto polling" communication system (SCADA) installed?
# A simple one-way telemetry/communication system (auto -dialer) installed?
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?
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Page 6 of 7
Permit: WQCS00328 Owner - Facility: Town of Harrisburg
Inspection Date: 03/03/2021
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: 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?
The city uses dedicated and portable generator units.Dedicated units on site tested with no issues.
# 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?
Comment:
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