HomeMy WebLinkAboutWQCSD0293_Compliance Evaluation Inspection_20220127R.OY COOPER.
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
Appalachian State University
Attn: Daniel Gryder
265 Dale Street
Boone, NC 28608
NORTH CAROLINA
Environmental Quality
February 22, 2022
SUBIECT: Compliance Evaluation Inspection
ASU Collection System, WQCSD0293
Watauga County
Dear Mr. Gryder:
Tricia Lowery, of the NC Division of Water Resources (DWR), Winston-Salem Regional Office (WSRO),
visited ASU's collection system on January 27, 2022, to perform a Compliance Evaluation Inspection (CEI). The
assistance and cooperation of Eric Greer was greatly appreciated. Details of the inspection are recorded on the
attached EPA Water Compliance Inspection Report.
You are reminded that, in accordance with NC General Statute 143-215.6A, failure to comply with all
conditions of the permit subjects the City to civil penalties not to exceed $25,000.00 per violation, per day.
If you have any questions or require further assistance, please contact Tricia Lowery by phone at 336-776-
9691, or by email at tricia.lowery@ncdenr.gov . You may also contact me by phone at 336-776-9700, or by email at
lon.snider@ncdenr.gov.
Sincerely,
DocuSiiggned by:by�
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Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
Attachments:
1. EPA Water Compliance Inspection Report
cc: LaserFiche
WSRO electronic files
NORTH
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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
Compliance Inspection Report
Permit: WQCSD0293 Effective: 03/01/00 Expiration:
SOC: Effective: Expiration:
County: Watauga
Region: Winston-Salem
Contact Person: Eric Lane Greer
Directions to Facility:
System Classifications:
Primary ORC: Eric Lane Greer
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 01/27/2022
Owner : Appalachian State University
Facility: Appalachian State University Collection Systerr
Title: Phone: 828-262-4551
Certification: 28374 Phone: 828-262-3190
Entry Time 10:30AM Exit Time: 01:30PM
Primary Inspector: Patricia Lowery Phone: 336-776-9691
Secondary Inspector(s):
Reason for Inspection: Complaint Inspection Type: Collection System Inspect Non Sampling
Permit Inspection Type: Deemed permitted collection system management and operation
Facility Status: Compliant ❑ Not Compliant
Question Areas:
▪ Miscellaneous Questions
II Spills/Response Plan
▪ Pump Stations
(See attachment summary)
▪ General
▪ Inspections
▪ Grease Control
▪ Lines
Page 1 of 7
Permit: WQCSD0293 Owner - Facility:Appalachian State University
Inspection Date: 01/27/2022
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Complaint
Inspection Summary:
Tricia Lowery of the NC Division of Water Resources, Winston-Salem Regional Office conducted a compliance evaluation
inspection of ASU's collection system (WQCSD0293) on January 27, 2022. Eric Greer, head of collection system
operations, was present for the inspection. Results of the inspection are summarized in the following paragraphs:
15A NCAC 02T .0403 Permitting By Regulation
(a)(1) The collection system shall be effectively maintained and operated at all times to prevent discharge to land or surface
waters and to prevent any contravention of groundwater standards or surface water standards.
Observations: The collection system is well maintained with proper documentation.
Compliant: Yes
(a)(2) A map of the collection system shall have been developed and shall be maintained.
Observations: GIS mapping system is in place with appropriate labeling of parameters and updated regularly.
Complaint: Yes
(a)(3) An operation and maintenance plan, including pump station inspection frequency, preventative maintenance schedule,
spare parts inventory, and overflow response shall have been developed and implemented.
Observations: The pump station is inspected weekly. 0 & M logs are maintained properly. Inspector reviewed overflow
response plan, inventory of equipment and spare parts and believed it to be satisfactory.
Compliant: Yes
(a)(4) Pump stations that are not connected to telemetry system shall be inspected by the permittee or its representative
every day, 365 days per year, unless the permittee demonstrates that the daily inspections are not necessary because the
pump station has sufficient storage capacity, above the elevation at which the pump activates, to justify a longer inspection
interval. In no case shall the inspection interval exceed seven days. Pump stations that are connected to a telemetry
system shall be inspected once per week.
Observations: There is only one pump station in ASU's system, and connected to SCADA. It is located at the baseball
field, therefore the only significant flow coming from pump station is during baseball season (March - July). It is in place to
aid flow to primary system. Permanent generator at pump station. Generator, float, alarm system is tested with
documentation. ASU electrical department maintains the upkeep and inspections on generator. Logs of maintenance and
inspections are given to Mr. Greer as inspections and/or maintenance is conducted. Logs are satisfactory. Additionally, it
is posted if alarm sounds at pump station, ASU police is listed as number to call. ASU police will notify personnel.
Compliant: Yes
(a)(5) High -priority sewers shall be inspected by the permittee or its representative once every six months, and inspections
shall be documented.
Observations: ASU has only one HPL. It is inspected every 6 months with proper documentation of bi-annual inspection
Compliant: Yes
(a)(6) A general observation by the permittee or its representative of the entire collection system shall be conducted once
per year.
Observations: Documentation given to inspector demonstrations the collection system is inspected by Mr. Greer annually.
Compliant: Yes
(a)(7) Overflows and bypasses shall be reported to the appropriate Division regional office in accordance with 15A NCAC
02B .0506(a), and public notice shall be provided as required by G.S. 143-215.1 C.
Observations: One spill reported on 10/5/2020. Spill was 100 gallons; therefore no press release was required. NCDEQ
was notified of spill appropriately according to regulations. ASU utilizes an emergency phone for after hours in emergency
response. ASU has appropriate logs of equipment list, spill assessment, with the Town of Boone listed as back up for
emergency response.
Compliant: Yes
Page 2 of 7
Permit: WQCSD0293 Owner - Facility:Appalachian State University
Inspection Date: 01/27/2022
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Complaint
(a)(8)(B) Grease Control Program shall be in place for private owned collection systems that will include bi-annual
distribution of grease education materials to users of the collection system by the permittee or representative.
Observations: Posters with instructions for grease control are posted in every facility, (ie: dining halls, sports complex,
dorm kitchen areas) where food is prepared and/or served on campus. App State's collection system discharges into the
Town of Boone's collection system. They are directed by and follow Town of Boone's sewer use ordinance (SUO), therefore
the Town of Boone conducts all FOG inspections. The facility distributes a mass email for all students each semester
concerning what not to flush or place in drains. Additionally Triple'T' company is used to pump and haul the 30 gallon tallow
bin at daycare facility.
Compliant: Yes
(a)(9) Right-of-ways and easements shall be maintained in the full easement width for personnel and equipment
accessibility.
Observations: Right of ways are maintained by ASU landscaping department. Copies are given to Mr. Greer when ROW's
are maintained and Mr. Greer visually inspects and documents his inspection after landscaping department has completed
maintenance.
Compliant: Yes
(a)(10) Documentation of compliance with Subparagraphs (a)(1) through (a)(9) of this Rule shall be maintained by the
collection system owner for three years with the exception of the map, which shall be maintained for the life of the system.
Observations: Records are kept for >5 years. Mr. Greer keeps records organized and were easily accessible for inspector
to review.
Compliant: Yes
Page 3 of 7
Permit: WQCSD0293 Owner - Facility:Appalachian State University
Inspection Date: 01/27/2022
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Complaint
General
# Is this system a satellite system?
# If Yes, what is system name or permit number?
Is there a overall sewer system map?
Does the map include:
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
Are system maintenance records maintained?
Comment: GIS mapping system. System maintenance records are well maintained and follow
requirements.
Grease Control
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.)
Posters with instructions for grease control are posted in every facility, (ie: dining halls, sports complex, dorm
kitchen areas) where food is prepared and/or served on campus.
For public systems, is there a Grease Control Program via an ordinance/agreement?
If Yes, does it require grease control devices at applicable locations?
Is the Grease Control Program enforced via periodic inspections/records review?
Is action taken against violators?
Yes No NA NE
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Yes No NA NE
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Comment: App State's collection system discharges into the Town of Boone's collection system. They are
directed by and follow Town of Boone's sewer use ordinance (SUO), therefore the Town of
Boone conducts all FOG inspections. The facility distributes a mass email for all students each
semester concerning what not to flush or place in drains. Additionally Triple 'T' company is
used to pump and haul the 30 gallon tallow bin at daycare facility.
Spills and Response Action Plan
# Is system free of known points of bypass?
If No, describe type of bypass and location
# 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?
Yes No NA NE
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Page4of7
Permit: WQCSD0293 Owner - Facility:Appalachian State University
Inspection Date: 01/27/2022
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Complaint
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?
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
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Comment: One spill reported on 10/5/2020. Spill was 100 gallons; therefore no press release was
required. NCDEQ was notified of spill appropriately according to regulations. ASU utilizes an
emergency phone for after hours in emergency response. ASU has appropriate logs of
equipment list, spill assessment, with the Town of Boone listed as back up for emergency
response.
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?
Yes No NA NE
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Comment: There is only one pump station in ASU's system. It is located at the baseball field, therefore the
only significant flow coming from pump station is during baseball season (March - July). It is in
place to aid flow to primary system. The pump station is inspected weekly. 0 & M logs are
maintained properly. Generator, float, alarm system is tested with documentation. Additionally,
ASU has only one HPL. It is inspected every 6 months with proper documentation of bi-annual
inspection.
Lines/Right-of-Ways/Aerial Lines
Please list the Lines/Right of Ways/Aerial Lines Inspected:
Right of ways are maintained by ASU landscaping department. Copies are given to Mr. Greer when ROW's
are maintained and Mr. Greer visually inspects and documents his inspection after landscaping department
has completed maintenance.
Are right-of-ways and easements maintained for the full width for access?
Yes No NA NE
Page5of7
Permit: WQCSD0293 Owner - Facility:Appalachian State University
Inspection Date: 01/27/2022
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Complaint
If No, give details on temporary access:
Is maintenance documented?
Were all areas/lines inspected free of issues?
Comment: Right of ways are properly maintained with respective logs to document maintenance.
Pump Stations
Please list the Pump Stations Inspected:
Baseball Pump Station
# 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 telemetry 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?
# 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?
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Yes No NA NE
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Page6of7
Permit: WQCSD0293 Owner - Facility:Appalachian State University
Inspection Date: 01/27/2022
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Complaint
# 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?
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Comment: Permanent generator at pump station. ASU electrical department maintains the upkeep and
inspections on generator. Logs of maintenance and inspections are given to Mr. Greer as
inspections and/or maintenance is conducted. Logs are adequate.
It is posted if alarm sound at pump station, ASU police is listed as number to call. ASU police
will notify personnel.
Page 7 of 7