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Home My WebLink AboutWQCSD0238_Compliance Evaluation Inspection_20220215ROY COOPER. Governor ELIZABETH S. BISER Secretary S. DANIEL SMITH Director Tweetsie Railroad Collection System Attn: Chris Robbins, Vice President 300 Tweetsie Railroad Ln Blowing Rock, NC 28605 NORTH CAROLINA Environmental Quality March 2, 2022 SUBJECT: Compliance Evaluation Inspection Tweetsie Railroad Collection System, WQCSD0238 Watauga County Dear Chris Robbins: Tricia Lowery, of the NC Division of Water Resources (DWR), Winston-Salem Regional Office (WSRO), visited the Tweetsie Railroad Collection System on February 15, 2022, to perform a Compliance Evaluation Inspection (CEI). The assistance and cooperation of Bobby Rowe and Travis Spencer was greatly appreciated. Details of the inspection are recorded on the attached EPA Water Compliance Inspection Report. Overall, the collection system is very well maintained and operated. The only areas of concern were: 1. Maps need to be updated with proper information (ie: pipe size, material, and flow). By implementing the use of GIS, this will resolve the issue. 2. No grease control program. With areas on site preparing food, the education of proper grease control procedures is critical in the overall health of the collection system. This could be in the form of posters in food prep areas detailing proper disposal of grease material. 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:< t— l . ciA,ac - "- 145B49E225C94EA... 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 NORTH D E D.o.rtm.m .f Dnim.mo.t.i au.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 LD_E NORTH CAROLINA gapartmeM of Environmental quaky 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: WQCSD0238 Effective: 03/01/00 Expiration: SOC: Effective: Expiration: County: Watauga Region: Winston-Salem Contact Person: Chris B Robbins Directions to Facility: Owner : Tweetsie Railroad Facility: Tweetsie Railroad Collection System Title: Vp Phone: 828-264-9061 System Classifications: Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): Related Permits: Inspection Date: 02/15/2022 Entry Time 11:OOAM Exit Time: 01:OOPM Primary Inspector: Patricia Lowery Phone: 336-776-9691 Secondary Inspector(s): Reason for Inspection: Routine 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 6 Permit: WQCSD0238 Owner - Facility:Tweetsie Railroad Inspection Date: 02/15/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Inspection Summary: Tricia Lowery of the NC Division of Water Resources, Winston-Salem Regional Office conducted a compliance evaluation inspection of WQCSD0238 — Tweetsie Railroad Collection Systems on February 15, 2022. Bobby Rowe and Travis Spencer were 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: Overall the collection system is maintained well. Compliant: Compliant (a)(2) A map of the collection system shall have been developed and shall be maintained. Observations: Map is effective for overall view of collection system. It consists of line locations and locations of pump stations, but it does not reference pipe size, pipe material, pipe age or flow direction. They are currently looking into developing a GIS mapping for facility. Inspector stated GIS will be a tremendous asset to correct map deficiencies and recommended to expedite the use of GIS. Complaint: Non -compliant (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: Inspector is satisfied with O&M plan as it is detailed and comprehensive. Detailed logbooks are kept and reviewed concerning pump stations and maintenance schedules. Spill response plan was recently updated and satisfactory. Compliant: Compliant (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 are 2 simple pump stations in the system. `Main' PS is duplex system and is currently undergoing rehabilitation which will include installing a telemetry system. Mr. Rowe continually emails inspector updates on progress. The rehabilitation started after inspection date. The second pump station 'High County' is a simplex system with no telemetry. As both currently are not connected to a telemetry system, they are inspected daily, multiple times a day. Compliant: Compliant (a)(5) High -priority sewers shall be inspected by the permittee or its representative once every six months, and inspections shall be documented. Observations: No high priority lines exists in this collection system Compliant: NA (a)(6) A general observation by the permittee or its representative of the entire collection system shall be conducted once per year. Observations: The overall collection system is inspected by Mr. Rowe and Mr. Spencer on a regular basis throughout the year with proper documentation of inspections. Compliant: Compliant (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: There have been no SSO's or bypasses reported over the past 3 years with this collection system. Compliant: Compliant (a)(8)(B) Grease Control Program shall be in place for private owned collection systems that will include bi-annual Page 2 of 6 Permit: WQCSD0238 Owner - Facility:Tweetsie Railroad Inspection Date: 02/15/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine distribution of grease education materials to users of the collection system by the permittee or representative. Observations: There was no grease control program observed at the time of inspection. Inspector explained this need to be implemented to comply with regulations of the deemed system. The facility contains 5 restaurants/dining areas. Compliant: Non -compliant (a)(9) Right-of-ways and easements shall be maintained in the full easement width for personnel and equipment accessibility. Observations: There are no ROW's within the collection system. Compliant: NA (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: All documentation, with the exception of (a)(8)(B) `grease control program', are maintained in appropriate time frame. Compliant: Compliant Special note concerning Main pump station rehabilitation. Mr. Rowe emailed inspector details (from the estimate given by contractor) of the work being conducted to this pump station. Excerpt from estimate: "Install control panel rack and excavate force main. Remove existing pumps, meet pump truck onsite to clean wet well and plug invert. Set up for OSHA permitted Confined Space Entry (CSE). Remove all existing piping and guide rails. Install new force main piping, check valves and isolation valves. Set new pump bases and install new guide rails. Reconnect existing pumps and install new float brackets. Wire in new floats and test for leaks. Mount existing control panel to new panel rack. Reuse existing junction box for incoming power only. Install conduit from control panel to well. Install new concrete lid with hatch. Install new telemetry -based Mission Unit. Test for proper operation." Overall, the collection system is very well maintained and operated. The only areas of concern were: 1. Maps need to be updated with proper information (ie: pipe size, material, and flow). By implementing the use of GIS, this will resolve the issue. 2. No grease control program. With areas on site preparing food, the education of proper grease control procedures is critical in the overall health of the collection system. This could be in the form of posters in food prep areas detailing proper disposal of grease material. Page 3 of 6 Permit: WQCSD0238 Owner - Facility:Tweetsie Railroad Inspection Date: 02/15/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine 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: See Summary 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.) See summary 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? Comment: N/A Spills and Response Action Plan # Is system free of known points of bypass? # 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? 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? Yes No NA NE ▪ • • ❑ ❑ ❑ ▪ • ▪ • ▪ • ❑•❑ ❑ ❑•❑ ❑ ❑•❑ ❑ ▪ • ▪ • • ❑ ❑ ❑ Yes No NA NE ❑ • ❑ ❑ ❑•❑ ❑ ❑ ❑•❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑•❑ Yes No NA NE • ❑ ❑ ❑ ❑•❑ ❑ ❑ ❑•❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ • ❑ ❑ ❑ ❑ • ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Page 4 of 6 Permit: WQCSD0238 Owner - Facility:Tweetsie Railroad Inspection Date: 02/15/2022 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 Comment: See summary 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: See summary Lines/Right-of-Ways/Aerial Lines Please list the Lines/Right of Ways/Aerial Lines Inspected: See Summary Are right-of-ways and easements maintained for the full width for access? If No, give details on temporary access: None Is maintenance documented? Were all areas/lines inspected free of issues? Comment: None Pump Stations Please list the Pump Stations Inspected: Main (duplex) and Secondary (simplex) # 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: • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ Yes No NA NE ❑ ❑ • ❑ ❑ ❑ • ❑ Yes No NA NE 0 0 Page 5 of 6 Permit: WQCSD0238 Owner - Facility:Tweetsie Railroad Inspection Date: 02/15/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine # 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? See summary # 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: See summary 0 0 • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Page 6 of 6