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Home My WebLink AboutWQCS00161_Compliance Evaluation Inspection_20210715 SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED. July 15, 2021 Steve Smith Town of Banner Elk Email: ssmith@townofbannerelk.org SUBJECT: Compliance Inspection Report Banner Elk Collection System Collection System Permit No. WQCS00161 Avery County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Banner Elk Collection System on 7/07/2021. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in Collection System Permit No. WQCS00161. The findings and comments noted during this inspection are provided in the enclosed copy of the inspection report entitled "Compliance Inspection Report". There were no significant issues or findings noted during the inspection and therefore, a response to this inspection report is not required. If you should have any questions, please do not hesitate to contact me at 828-296-4500 or via email at stephanie.williams@ncdenr.gov. Sincerely, Stephanie Williams, Environmental Specialist Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Report Ec: Laserfiche Justin Hodges (Public Service Director) DocuSign Envelope ID: 607D9872-43DC-44AC-80BE-E74B326121F3 Compliance Inspection Report Permit:WQCS00161 Effective:06/01/13 Expiration:05/31/21 Owner :Town of Banner Elk SOC: Contact Person: Region: County: Directions to Facility: Avery Asheville Steve Smith Effective:Expiration:Facility:Banner Elk Collection System PO Box 156 Title:Phone:828-898-5398 Secondary ORC(s): Phone:Certification:Primary ORC: CS1,System Classifications: On-Site Representative(s): Related Permits: NC0032115 Town of Banner Elk - Banner Elk WWTP Secondary Inspector(s): Primary Inspector: Inspection Date:Exit Time:Entry Time: Phone: 07/07/2021 01:10PM 04:00PM Stephanie A Williams 828-296-4500 Lauren E Armeni Facility Status: Permit Inspection Type: Reason for Inspection:Inspection Type: Not CompliantCompliant Routine Collection system management and operation Collection System Inspect Non Sampling 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 DocuSign Envelope ID: 607D9872-43DC-44AC-80BE-E74B326121F3 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCS00161 07/07/2021 Collection System Inspect Non Sampling Town of Banner Elk Routine Inspection Summary: Stephanie Williams and Lauren Armeni, with the Asheville Regional Office, conducted a compliance evaluation inspection of the Town of Banner Elk’s collection system on July 7, 2021. This inspection was conducted to determine if the system is being operated and maintained in compliance with permit no. WQCS00161. Justin Hodges (Public Works Director) was present and assisted in the inspection. The facility appears to be well operated and maintained and was found to be compliant at the time of the inspection. The collection system consists of approximately 93,000 feet of line. The main trunk line going to the WWTP is the only known clay line in the system. Sewer and FOG Ordinance: The Town requires restaurants to clean grease traps every 3 months at minimum and inspections of grease traps have increased from yearly to twice per year. We recommend adding information about flushable wipes to education materials if they begin presenting a greater issue in the collection system. Inspections and Line Cleanings: The town contracts Pipe Pros to clean and inspect their lines yearly. In 2020, Pipe Pros cleaned 10,903 feet of line. Cleaning for 2021 is scheduled to begin in September. The town keeps thorough documentation of yearly cleanings and inspections. High Priority Line Maintenance: The last maintenance on any high priority lines occurred 10 years ago. As maintenance becomes necessary, documentation will be required. Inspections of high priority lines are being conducted twice yearly but are not being documented. These inspections should be documented moving forward. Manholes: One manhole on the Old Turnpike West and Silver Springs intersection had minor buildup of rags. We recommend cleaning the rags from the manhole and distributing targeted educational material. All other manholes inspected were found to be in good condition. Pump Stations: There is only one lift station, which has duplex submersible pumps, visual, audio, and telemetry. Floats were tested and operated pumps properly, and telemetry successfully notified the operator when the high-level float was tested. Emergency Generator: The lift station has a propane emergency generator, with an automatic transfer switch. There is a quick connect for a portable generator if needed. The generator exercises weekly and is tested under load every three months. The generator was tested during the inspection and operated properly. The generator is serviced by Mountain Heritage Systems. Propane is supplied by Freeman Gas and levels are checked monthly. Page 2 of 7 DocuSign Envelope ID: 607D9872-43DC-44AC-80BE-E74B326121F3 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCS00161 07/07/2021 Collection System Inspect Non Sampling Town of Banner Elk Routine General Yes No NA NE 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?Every 6 months # 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? The permit expired 05/31/2021; the application was submitted 6 months prior to expiration. The new permit was issued 07/09/2021 and expires 06/30/2029. Comment: Sewer and FOG Ordinances Yes No NA NE 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?3 Months 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.) Inspectors suggested adding information regarding flushable wipes to educational material. Grease traps are inspected twice yearly by the Town. See summary for details. Comment: 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? The Town is working with McGill Associates to update the CIP. The current plan runs through 2024. Comment: Page 3 of 7 DocuSign Envelope ID: 607D9872-43DC-44AC-80BE-E74B326121F3 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCS00161 07/07/2021 Collection System Inspect Non Sampling Town of Banner Elk Routine Map Yes No NA NE 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? Pipe installation date should be added to the map as repairs are made.Comment: Reporting Requirements Yes No NA NE # 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?Mailing The last reportable SSO occurred at Elk River Lift Station in December 2018. There have been no known non-reportable SSOs. If a non-reportable SSO occurs it should be documented. Comment: Inspections Yes No NA NE 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? Inspections of high priority lines are being conducted twice yearly but are not being documented. These inspections should be documented moving forward. Comment: Spill Response Action Plan Yes No NA NE Is a Spill Response Action Plan available? Page 4 of 7 DocuSign Envelope ID: 607D9872-43DC-44AC-80BE-E74B326121F3 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCS00161 07/07/2021 Collection System Inspect Non Sampling Town of Banner Elk Routine 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: Spills 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? Comment: Lines/Right-of-Ways/Aerial Lines Yes No NA NE Please list the Lines/Right of Ways/Aerial Lines Inspected: Lecka Lane 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? No maintenance on aerial lines has been necessary in the last 10 years. The Town of Banner Elk contracts Pipe Pro to clean the lines yearly. See summary for details. Comment: Manholes Yes No NA NE Please list the Manholes Inspected: Manhole at pump station, 2 manholes at Old Turnpike West and Silver Springs intersection, and manhole at Old Turnpike West and Highland Drive Are manholes accessible? # Are manhole covers/vents above grade? Are manholes free of visible signs of overflow? Page 5 of 7 DocuSign Envelope ID: 607D9872-43DC-44AC-80BE-E74B326121F3 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCS00161 07/07/2021 Collection System Inspect Non Sampling Town of Banner Elk Routine 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? One manhole at the Old Turnpike West and Highland Drive intersection had mild buildup of rags. See summary for details. Comment: Pump Stations Yes No NA NE Please list the Pump Stations Inspected: Elk River Lift Station # Number of duplex or larger pump stations in system 1 # 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?1 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? Page 6 of 7 DocuSign Envelope ID: 607D9872-43DC-44AC-80BE-E74B326121F3 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCS00161 07/07/2021 Collection System Inspect Non Sampling Town of Banner Elk Routine Are audio and visual alarms present? Are audio and visual alarms operable? # 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? # 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? Floats were tested and operated components properly. See summary for details. Generator is serviced by Mountain Heritage Systems. Propane is supplied by Freeman Gas. Generator exercises weekly and is tested under load every 3 months. See summary for details. Comment: Page 7 of 7 DocuSign Envelope ID: 607D9872-43DC-44AC-80BE-E74B326121F3