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Home My WebLink AboutWQCS00363_CEI_NOI_NOV2021PC0493_20211008R.OY COOPER. Governor ELIZABETH S. BISER Secretary S. DANIEL SMITH Director CERTIFIED MAIL #7018 1130 0000 1612 6201 RETURN RECEIPT REQUESTED City of Trinity Attn: Debbie Hinson, City Manager P.O. Box 50 Trinity, NC 27370 NORTH CAROLINA Environmental Quality October 8, 2021 SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY Tracking Number: NOV-2021-PC-0493 Permit No. WQCS00363 Trinity Collection System Randolph County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Trinity Collection System on August 26, 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. WQCS00363. A summary of the findings and comments noted during the inspection are provided in the enclosed copy of the inspection report. This inspection was conducted by Division of Water Resources staff from the Winston-Salem Regional Office. The following violation(s) were noted during the inspection: Inspection Area Description of Violation Part I. Performance Standards Paragraph 4, FOG Program Education and enforcement is insufficient or insufficiently documented. Paragraph 7. Pump Station Contingency Plan Insufficient plan. Part III. Records Paragraph 1. Required records Insufficient records. Part V. Inspections Paragraph 1. System Inspections Insufficient inspections or documentation thereof. Paragraph 4. High Priority Line Inspections High priority lines have not been identified/inspected. You are hereby reminded that pursuant to NC General Statute 143-215.6A, a civil penalty of not more than twenty- five thousand dollars ($25,000) may be assessed against any person who violates or fails to act in accordance with NORTH D E Dopartmem of Envimnmomni au.i` North Carolina Department of Environmental Quality Division of Water Resources Winston-Salem Regional Office 450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105 336.776.9800 the terms, conditions, or requirements of a permit issued pursuant to NC General Statute 143-215.1. If you wish to provide additional information regarding the noted violation(s), request technical assistance, or discuss overall compliance, please respond in writing within ten (10) business days after receipt of this notice. Your response will be considered in determining whether civil penalties will be assessed. If no response is received in this office within the 10-day period, a civil penalty may be assessed at that time. If the violations are of a continuing nature, not related to operation and/or maintenance problems, and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by Consent (SOC). If you have any questions or concerns, please do not hesitate to contact Ron Boone with the Water Quality Regional Operations Section in the Winston-Salem Regional Office at 336-776-9800. Attachments: Compliance Inspection Report cc: Laserfiche LD_E NORTH CAROLINA Department of Environmental quaky Sincerely, DocuSiiggned by: %A. 145B49E225C94EA... Lon T. Snider, Regional Supervisor Water Quality Regional Operations Section Winston-Salem Regional Office Division of Water Resources, NCDEQ North Carolina Department of Environmental Quality j Division of Water Resources Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105 336.776.9800 Compliance Inspection Report Permit: WQCS00363 Effective: 02/01/16 SOC: Effective: County: Randolph Region: Winston-Salem Contact Person: Rodney Gene Johnson Directions to Facility: System Classifications: CS1, Primary ORC: Rodney Gene Johnson Secondary ORC(s): On -Site Representative(s): Related Permits: NC0024210 N C0024112 Expiration: 01/31/24 Owner : City of Trinity Expiration: Facility: Trinity Collection System Title: Interim Public Works Director Certification: 1004394 City of High Point - East Side WWTP City of Thomasville - Hamby Creek WWTP Inspection Date: 08/26/2021 Entry Time 09:OOAM Primary Inspector: Ron Boone Secondary Inspector(s): Reason for Inspection: Routine Exit Time: 01:OOPM Phone: 336-431-2841 Phone: Phone: 336-776-9690 Inspection Type: Collection System Inspect Non Sampling Permit Inspection Type: Collection system management and operation Facility Status: ❑ Compliant Question Areas: ▪ Miscellaneous Questions ▪ Capital Improvement Plan ▪ Inspections ▪ Lines (See attachment summary) Not Compliant ▪ General ▪ Map ▪ Spill Response Plan ▪ Manholes ▪ Sewer & FOG Ordinances ▪ Reporting Requirements ▪ Spills ▪ Pump Stations Page 1 of 10 Permit: WQCS00363 Owner - Facility: City of Trinity Inspection Date: 08/26/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Inspection Summary: Ron Boone of the NC Division of Water Resources, Winston-Salem Regional Office conducted a compliance evaluation inspection of the Town of Trinity's wastewater collection system on August 26, 2021. Rodney Johnson, Scott Cooper, and Rick Austin, collection system operators, were present for the inspection. Results of the inspection are summarized in the following paragraphs: PERMIT PART I, PERFORMANCE STANDARDS Part I, Paragraph 2, Operation and Maintenance. Observations: It appears the system is effectively operated to minimize spills. The town has not reported any SSOs in 2021, four in 2020, none in 2019, and two in 2018. However, the town had numerous significant permit violations during the inspection, as detailed below. Compliance Status: Compliant Part I, Paragraph 3, Sewer Use Ordinance (SUO) Observations: The town's SUO is posted on it's website and appears to meet requirements. Compliance Status: Compliant Part I, Paragraph 4, FOG Program Observations: FOG education is accomplished via newsletters sent twice yearly. However, it is not sufficiently documented. Recommend the town keep dated copies of all newsletters sent to comply with requirements. Also, recommend highly visible link to FOG education material be placed on home page of city's website. The FOG enforcement program appears sufficient with minimal FOG related SSOs reported, however, it is also not sufficiently recorded. Documentation of FOG inspections and enforcement is not being accomplished. The town must begin keeping records of FOG inspections and enforcement. Also, include other potential grease producing facilities, such as schools, medical establishments, nursing homes, etc. in the FOG enforcement program. Compliance Status: Noncompliant Part I, Paragraph 5, Capital Improvement Plan (CIP) Observations: The town has a CIP that covers 5 years and meets requirements. Please note the CIP must be updated as required to ensure it perpetually covers a three to five year period. Compliance Status: Compliant Part I, Paragraph 6, Overflows or Bypasses Observations: No such structures were identified during the inspection and operators stated that none exist within the system. Compliance Status: Compliant Part I, Paragraph 7, Pump Station Contingency Plan (PSCP) Observations: The pump failure plan, does not independently exist but the spill plan covers parts of it. A stand alone pump failure plan should be developed. Alternatively, a combined spill and pump failure plan can be developed. Regardless of which route is selected, make sure the plan(s) meet all specific requirements listed in the permit for both the spill plan and the pump failure plan. Compliance Status: Noncompliant Part I, Paragraph 8, Pump Station Signage Observations: Pump stations inspected have signs that meet permit requirements and operators stated all other stations are similarly posted. Compliance Status: Compliant Part I, Paragraph 9, Pump Station Security Observations: Pump stations visited are satisfactorily secured and operators stated all other stations are similarly secured. Compliance Status: Compliant Page 2 of 10 Permit: WQCS00363 Owner - Facility: City of Trinity Inspection Date: 08/26/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Part I, Paragraph 10, Audible/Visible Alarms Observations: All eleven stations have SCADA systems along with audible and visible alarms. All that were inspected were fully operational. Compliance Status: Compliant Part I, Paragraph 11, Corrosion in Pump Stations Observations: No conditions demonstrating noncompliance with this permit condition were noted during the inspection. Compliance Status: Compliant PERMIT PART II, OPERATION AND MAINTENANCE REQUIREMENTS Part II, Paragraph 1 requires the Permittee shall designate and employ a certified operator to be in responsible charge (ORC; and one or more certified operator(s) to be back-up ORC(s) of the facilities in accordance with 15A NCAC 8G .0201. Observations: All operators have been properly designated. Compliance Status: Compliant Part II, Paragraph 2 Documentation Review Observations: Review of records is done but not sufficiently documented. Recommend those who review documentation always initial or sign and date all documentation to indicate their review of it. Compliance Status: Compliant Part II, Paragraph 3 Schedule for Testing Emergency and Standby Equipment Observations: All pump stations have onsite diesel generators. Operators stated generators are exercised manually on a weekly basis. Compliance Status: Compliant Part II, Paragraph 4 Routine Pump Station Inspection and Maintenance Program Observations: Pump station inspection logs meet requirements. Compliance Status: Compliant Part II, Paragraph 5 Pump Station Reliability Observations: No simplex stations exist in system and all duplex and greater stations meet reliability requirements. Compliance Status: Compliant Part II, Paragraph 6 Spare Pumps Observations: There are no simplex pump stations in the system. Compliance Status: Not applicable Part II, Paragraph 7 Right-of-ways and/or Easements Observations: ROWs are maintained at least three times annually. None were observed during the inspection that were insufficiently maintained. However, documentation is minimal. Compliance Status: Compliant Part II, Paragraph 8 Line Cleaning Observations: Town must clean about 20,000 feet annually. They have consistently met this requirement and documenation is sufficient. Compliance Status: Compliant Part II, Paragraph 9 Spill Response Action Plan (SRAP) Observations: An acceptable spill response action plan was reviewed during the inspection. Compliance Status: Compliant Page 3 of 10 Permit: WQCS00363 Owner - Facility: City of Trinity Inspection Date: 08/26/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Part II, Paragraph 10 SSO Response Observations: No conditions observed during the inspection that indicate noncompliance with this requirement. Compliance Status: Compliant Part II, Paragraph 11 SSO Cleanup Observations: No conditions observed during the inspection that indicate noncompliance with this requirement. Compliance Status: Compliant PERMIT PART III, RECORDS Part III, Paragraph 1 Records Observations: Sufficient records were not available during the inspection for the following permit conditions: 1(4) — FOG Program; 11(2) — Records Review; 11(7) — ROW Maintenance; V(1) — System Inspections; V(3) — Annual General Observation; and, V(4) — High Priority Lines. Compliance Status: Noncompliant Part III, Paragraph 2 SSO/Complaint Records Observations: SSO and complaint records are sufficient. Compliance Status: Compliant Part III, Paragraph 3 System Map Observations: The town's collection system is digitally mapped using computer software. Much of the required information is in the database and it is updated as required. Any part of, or the entire system, can be printed at any time. Compliance Status: Compliant Part III, Paragraph 4 System Map Update Observations: No conditions demonstrating noncompliance with this condition were noted during the inspection. Compliance Status: Compliant PERMIT PART IV, MONITORING AND REPORTING REQUIREMENTS Part IV, Paragraph 1 Monitoring Reporting Observations: No conditions demonstrating noncompliance with this condition were observed during the inspection. Compliance Status: Compliant Part IV, Paragraph 2 SSO Reporting Observations: No conditions were observed during the inspection, or in the processing of past reported SSOs, that indicate noncompliance with this requirement. Compliance Status: Compliant Part IV, Paragraph 3 Annual Report Observations: Total daily flow is <200,000 gallons per day, therefore, an annual report is not required. Compliance Status: Not Applicable PERMIT PART V, INSPECTIONS Part V, Paragraph 1 Collection System Inspection Observations: Given the observations enumerated above and below this permit condition, the inspector believes the permittee is not fully compliant with this condition. Compliance Status: Noncompliant Part V, Paragraph 2 Pump Station Inspections Observations: According to operators, all eleven pump stations have SCADA and audible/visible alarms. All pump stations Page 4 of 10 Permit: WQCS00363 Owner - Facility: City of Trinity Inspection Date: 08/26/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine are inspected at least once per week and inspections are sufficiently documented. Compliance Status: Compliant Part V, Paragraph 3 Annual General Observation of Entire System Observations: Operators stated they believe the entire system is inspected annually and the inspector noted no conditions indicative of noncompliance with this condition. It is partly documented by all records generated to comply with other permit requirements, however, not all required documentation is being generated. It is recommended that operators certify annually, by way of a short/simple in-house signed and dated memo, that they believe the entire system has been observed over the course of the previous year. A sample can be provided if desired. Compliance Status: Compliant Part V, Paragraph 4. High Priority Lines (HPL) Observations: To date, no HPLs have been identified, but operators were informed by previous operators that none existed and were not aware of the permit's definition of HPLs. The inspector believes that many HPLs do exist in the system. The town must fully examine its system in detail to identify all HPLs in accordance with the permit and begin inspection each HPL at least once per six month period of time, and document the inspections. Compliance Status: Noncompliant Page 5 of 10 Permit: WQCS00363 Owner - Facility: City of Trinity Inspection Date: 08/26/2021 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? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ As generated • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ Comment: Review of records is done but not sufficiently documented. Recommend those who review documentation always initial or sign and date all documentation to indicate their review of it. The pump failure plan, does not independently exist but the spill plan covers parts of it. A stand alone pump failure plan should be developed. Alternatively, a combined spill and pump failure plan can be developed. Regardless of which route is selected, make sure the plan(s) meet all specific requirements listed in the permit for both the spill plan and the pump failure plan. 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.) Website Comment: Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ 60 days or less Recommend highly visible link to FOG education material be placed on home page of city's website. Documentation of FOG inspections and enforcement is not being accomplished. Twice per year newsletters that contain FOG educational material are sent via mail. However, there is no documentation. Recommend town simply keep dated copies of all newsletters that contain FOG educational materials to record distribution. Additionally, town must begin keeping records of FOG inspections and enforcement. Also, include other potential grease producing facilities, such as schools, medical establishments, nursing homes, etc. in the FOG enforcement program. Capital Improvement Plan Has a Capital (CIP) or System Improvement Plan been developed and adopted? • Yes No NA NE ❑ ❑ ❑ Page 6 of 10 Permit: WQCS00363 Owner - Facility: City of Trinity Inspection Date: 08/26/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine 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: None Map 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? • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Comment: Map is completely digitized and any or all sections can be printed at any time. Most required data points are known but constant updates are performed as new data is discovered. 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: None 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? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ • ❑ ❑ • ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Page 7 of 10 Permit: WQCS00363 Owner - Facility: City of Trinity Inspection Date: 08/26/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine # 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: Operators understood that no HPLs existed in the system and weren't fully aware of the definition of a HPL in the permit. Recommend full examination of system to identify all HPLs and begin inspecting them and documenting the inspections as required by the permit. 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: 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: None 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: None Lines/Right-of-Ways/Aerial Lines Please list the Lines/Right of Ways/Aerial Lines Inspected: Two high priority lines were inspected and found to be in good condition. An inventory of HPLs must be created. 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? • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ ❑ ❑ • ❑ Yes No NA NE • ❑ ❑ ❑ Page 8 of 10 Permit: WQCS00363 Owner - Facility: City of Trinity Inspection Date: 08/26/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Comment: None Manholes Please list the Manholes Inspected: 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? # 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: None Pump Stations Please list the Pump Stations Inspected: Steeplegate Welburn # 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: # A two-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 ? Yes No NA NE ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • Yes No NA NE 11 0 0 0 0 0 • ❑ ❑ ❑ ❑ • ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Page 9 of 10 Permit: WQCS00363 Owner - Facility: City of Trinity Inspection Date: 08/26/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine 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? # 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? Comment: None ❑ • ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ • ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Page 10 of 10