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HomeMy WebLinkAboutWQCS00314_Compliance Evaluation Inspection_20211027ROY COOPER. Governor ELIZABETH S. BISER Secretary S. DANIEL SMITH Director NORTH CAROLINA Environmental Quality October 27, 2021 Town of Jamestown Attn: Paul Blanchard, Director of Public Services P.O. Box 848 Jamestown, NC 27282 SUBJECT: NOTICE OF VIOLATION Tracking Number: NOV-2021-PC-0528 Permit No. WQCS00314 Jamestown Collection System Guilford County Dear Permittee: The North Carolina Division of Water Resources, Winston-Salem Regional Office, conducted an inspection of the Jamestown Collection System on September 2, 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. WQCS00314. A summary of inspection findings is provided below, and a detailed inspection report is attached. The following violation(s) were noted during the inspection: Inspection Area Description of Violation Part I. Performance Standards Paragraph 4, FOG Program Education is insufficient or insufficiently documented. Paragraph 8. Pump Station Signage Insufficient signage at pump stations. Part III. Records Paragraph 1. Required records Insufficient records. Paragraph 2. Complaints No complaint records. NORTH D E neo.rtm.m .f Envim.mo.t.i Ou.i` North Carolina Department of Environmental Quality Division of Water Resources Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105 336.776.9800 If you have any questions or concerns or wish to provide additional information regarding the noted violation(s), request technical assistance, or discuss overall compliance, please contact Ron Boone by phone at 336-776-9690, or by email at ron.boone@ncdenr.gov. Attachments: Compliance Inspection Report cc: Laserfiche LD_E NORTH CAROLINA Department of Environmental quaky Sincerely, DocuSigned by: 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: WQCS00314 Effective: 05/25/17 SOC: Effective: County: Guilford Region: Winston-Salem Contact Person: Paul R Blanchard Directions to Facility: System Classifications: CS2, Primary ORC: James Edward Johnson Secondary ORC(s): On -Site Representative(s): Related Permits: Expiration: 10/31/24 Expiration: Owner : Town of Jamestown Facility: Jamestown Collection System PO Box 848 Title: Public Services Director Certification: 1008800 NC0024210 City of High Point - East Side WWTP Inspection Date: 09/02/2021 Primary Inspector: Ron Boone Secondary Inspector(s): Entry Time 09:OOAM Patricia Lowery Reason for Inspection: Routine Permit Inspection Type: Collection system management and operation Facility Status: ❑ Compliant Not Compliant Question Areas: ▪ Miscellaneous Questions II Capital Improvement Plan ▪ Inspections ▪ Lines (See attachment summary) ▪ General ▪ Map ▪ Spill Response Plan ▪ Manholes Exit Time: 02:OOPM Phone: 336-454-1138 Phone: 336-454-1138 Phone: 336-776-9690 Inspection Type: Collection System Inspect Non Sampling ▪ Sewer & FOG Ordinances ▪ Reporting Requirements ▪ Spills ▪ Pump Stations Page 1 of 10 Permit: WQCS00314 Owner - Facility: Town of Jamestown Inspection Date: 09/02/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Inspection Summary: Ron Boone and Tricia Lowery of the NC Division of Water Resources, Winston-Salem Regional Office, conducted a compliance evaluation inspection of the Town of Jamestown's wastewater collection system on September 2, 2021. Paul Blanchard, Director of Public Services, and James Johnson, Backup ORC, 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 & Maintenance Observations: The system is very well operated and maintained, minimizing spills and malfunctions. So far, no spills have been reported in 2021, one was reported in 2020, and none were reported in 2019 or 2018. Compliance Status: Compliant Part I, Paragraph 3, Sewer Use Ordinance (SUO) Observations: The SUO is posted on the town's website and meets requirements. Compliance Status: Compliant Part I, Paragraph 4, FOG Program Observations: A FOG educational blurb was placed on water bills one time in 2018, 2019, and 2020, like the one shown below: "The Town of Jamestown has information regarding Fats, Oils, and Grease (FOG) available at the Town webpage under "Downloads" then on the left in the "My Government" section and the "Public Services" heading, under "Fat -Free Sewers". (https://www.jamestown-nc.gov/my-government/fat-free-sewers) Grease causes problems by sticking to pipe linings leading to clogs and sewer overflows. The easiest way to minimize FOG problems is to keep the material out of the sewer in the first place. Please visit the Town website or call with any questions." It will also be done in November 2021. The town has FOG information on their website and has pamphlets available in a carousel in city hall. The FOG information is NOT highly visible/accessible on the website. Recommend the city place a highly visible link to the FOG information on the town's homepage. Highly recommend the town enhance its FOG education program to make it more visible to system customers. Recommend more detailed FOG education materials be developed and better distributed in the future, to include at least one mass mailing with customer bills or separately. Please also note that this is a repeat finding from the inspection in 2018. Grease traps are inventoried and inspected once yearly in February. Operators physically check the grease traps as well as owners' pumping records. Compliance Status: Noncompliant Part I, Paragraph 5, Capital Improvement Plan (CIP) Observations: Operators provided a CIP project list that extends out into 2025/2026 and beyond. The list also provides funding amounts, project descriptions, and includes both long- and short-term needs. Compliance Status: Compliant Part I, Paragraph 6, Overflow/Bypass Structures Prohibited 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: Operators presented a combination contingency/spill plan that meets requirements. However, the phone number for the Winston-Salem Regional Office needs to be updated in the plan. Page 2 of 10 Permit: WQCS00314 Owner - Facility: Town of Jamestown Inspection Date: 09/02/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Compliance Status: Compliant Part I, Paragraph 8, Pump Station Signage Observations: Pump station signs had an emergency phone number with instructions to call but did not have the pump station's names on them. Please update the signs or add a separate sign at each station that shows the stations' identifiers. Please also note that this is a repeat finding from the inspection in 2018. Compliance Status: Noncompliant Part I, Paragraph 9, Pump Station Restricted Access Observations: Stations visited were properly secured. Operators indicated others are similarly secured. Compliance Status: Compliant Part I, Paragraph 10, Pump Station Audible/Visible Alarms Observations: Stations visited have audible/visible alarms in addition to telemetry. Operators indicated others are similarly equipped. Compliance Status: Compliant Part I, Paragraph 11, Pump Station Construction/Modification - Corrosion Resistant Coatings/Equipment Observations: No conditions demonstrating noncompliance were noted. Compliance Status: Compliant PERMIT PART II, OPERATION AND MAINTENANCE REQUIREMENTS Part II, Paragraph 1, Properly Designated Operators Observations: James Conrad and James Johnson are designated as ORC and Backup ORC, respectively. Compliance Status: Compliant Part II, Paragraph 2, Documentation Review Observations: Mr. Blanchard and Mr. Johnson stated all documentation is reviewed as it is generated but the review isn't necessarily documented. Inspectors noted no conditions during the inspection indicating noncompliance with this requirement. Recommend supervisors/ORCs simply sign or initial and date all documentation as it is generated and reviewed. Compliance Status: Compliant (noncompliant with Part III, Paragraph 1) Part II, Paragraph 3, Testing of Emergency and Standby Equipment Observations: Two of three stations have permanent generators that are exercised under load weekly. The third station has a portable generator with compatible hookups and is also tested regularly to verify operability. Compliance Status: Compliant Part II, Paragraph 4, Routine Pump Station Inspection/Maintenance Program Observations: Pump station inspection logs are sufficient. Compliance Status: Compliant Part II, Paragraph 5, Spare Pumps/Station Reliability Observations: There are no simplex stations and all duplex and greater stations meet reliability requirements. Compliance Status: Compliant Part II, Paragraph 6, Spare Pumps for Simplex Stations Observations: There are no simplex stations in the system. Compliance Status: Not applicable Part II, Paragraph 7, Right -of -Way and/or Easement Maintenance Observations: ROW maintenance is contracted and performed as needed. No insufficiently maintained ROWs were identified Page 3 of 10 Permit: WQCS00314 Owner - Facility: Town of Jamestown Inspection Date: 09/02/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine during the inspection. Compliance Status: Compliant Part II, Paragraph 8, Line Cleaning Observations: Line cleaning is partially contracted and partially done in house. The town must clean 5.5 miles (29,040 feet) annually and is meeting this requirement consistently. It is noted the city does not have an extensive history of SSOs. Compliance Status: Compliant Part II, Paragraph 9, Spill Plan Observations: Operators presented a combination contingency/spill plan that meets requirements. Compliance Status: Compliant Part II, Paragraph 10, On -Site Evaluations of SSOs Observations: No conditions were observed that indicate noncompliance with this requirement. Operators stated they respond to all SSOs immediately. The spill plan indicates spills must be evaluated within 30 minutes of the city becoming aware of them. Compliance Status: Compliant Part II, Paragraph 11, SSO Response. Observations: No conditions observed during inspection indicating noncompliance with this requirement. Compliance Status: Compliant PERMIT PART III, RECORDS Part III, Paragraph 1, Records Observations: Operators are keeping excellent records for all conditions for which documentation is required except for the following areas: a. Records review (11,2); and, b. Complaint records (111,2). Compliance Status: Noncompliant Part III, Paragraph 2, SSO/Complaint Records Observations: SSO records are kept as required. Please note that press releases must be kept for a year following issuance. Documentation of complaints is insufficient. Compliance Status: Noncompliant Part III, Paragraph 3, System Map Observations: The collection system is fully mapped using computer software and ongoing efforts continue to capture and update information. All required data is available in various record drawings and specifications, as well as the current computer system. The city has budgeted $200,000 for the completion of a comprehensive remapping. Compliance Status: Compliant Part III, Paragraph 4, Records of System Modifications/Extensions Observations: Operators acknowledged requirement. No conditions demonstrating noncompliance were noted. Compliance Status: Compliant PERMIT PART IV, MONITORING AND REPORTING REQUIREMENTS Part IV, Paragraph 1, Required Monitoring Observations: No conditions demonstrating noncompliance were observed during the inspection. Compliance Status: Compliant Page 4 of 10 Permit: WQCS00314 Owner - Facility: Town of Jamestown Inspection Date: 09/02/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Part IV, Paragraph 2, Reporting SSOs Observations: No conditions observed during inspection indicated noncompliance with this requirement. Compliance Status: Compliant Part IV, Paragraph 3, Annual Report Observations: A fully compliant annual report was provided for review during the inspection. Compliance Status: Compliant PERMIT PART V, INSPECTIONS Part V, Paragraph 1, Collection System Inspection Observations: Inspectors believe permittee to be compliant with this condition. Compliance Status: Compliant Part V, Paragraph 2, Pump Station Inspection Frequency Observations: All stations have audible/visible alarms and telemetry systems and all are inspected at least weekly. Compliance Status: Compliant Part V, Paragraph 3, Annual System General Observation Observations: Operators believe the whole system is inspected over the course of each year. Inspectors noted no conditions indicating otherwise and the city records all activities undertaken to comply with its permit, except for those noted above under condition 11,2. It is recommended that operators sign an annual certification stating that they believe the entire system has been observed over the course of the previous year. Compliance Status: Compliant Part V, Paragraph 4, High Priority Line Inspections Observations: Records of high priority line inspections were reviewed and found to be detailed, complete, and comprehensive. Compliance Status: Compliant Page 5 of 10 Permit: WQCS00314 Owner - Facility: Town of Jamestown Inspection Date: 09/02/2021 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: Records review should be better documented. Recommend that supervisors/reviewers sign or initial and date all logs to document their review of them as they are turned in to management by field personnel. 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, public events. Pamphlets on display in town hall. Educational notices are mailed with bills. Comment: None 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: None Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ 30 days • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE • ▪ ❑ ❑ ❑ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Page 6 of 10 Permit: WQCS00314 Owner - Facility: Town of Jamestown Inspection Date: 09/02/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: 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? ❑ • ❑ ❑ Comment: Map doesn't show pump station capacities. Reporting Requirements Yes No NA NE # Have there been any sewer spills in the past 3 years? • El El El 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? Website Comment: None 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? • ❑ ❑ ❑ Comment: None Spill Response Action Plan Is a Spill Response Action Plan available? Is a Spill Response Action Plan available for all personnel? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ Page 7 of 10 Permit: WQCS00314 Owner - Facility: Town of Jamestown Inspection Date: 09/02/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine 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: Bullrun outfall and aerial pipe, 10", 140' long, good. 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: None Manholes Please list the Manholes Inspected: Bullrun outfall 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 ❑ • ❑ ❑ ❑ ❑ • ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ Page 8 of 10 Permit: WQCS00314 Owner - Facility: Town of Jamestown Inspection Date: 09/02/2021 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: None Pump Stations Please list the Pump Stations Inspected: Grandover and Mendenhall # 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 ? 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 3 0 0 0 0 0 • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Page 9 of 10 Permit: WQCS00314 Owner - Facility: Town of Jamestown Inspection Date: 09/02/2021 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? # 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