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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 • ❑ ❑ ❑ • ❑ ❑ ❑ bi- monthly • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ • ❑ ❑ ❑ ❑ • ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ variable • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE 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: • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Web -site Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ 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. • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ • • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑•❑ ❑ ❑•❑ Yes No NA NE 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: 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 • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ 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? • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ • ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE 16 0 0 0 2 16 • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ 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: • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ • ❑ ❑ •❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Page 7 of 7