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HomeMy WebLinkAboutWQCSD0100_NOD-2022-PC-0033_20220325ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director The Honorable George H. McGee, Mayor Town of Severn PO Box 401 Severn, NC 27877 NORTH CAROLINA Environmental Quality March 25th, 2022 Subject: Notice of Deficiency NOD-2022-PC-0033 Compliance Evaluation Inspection T15A NCAC 02T .0403 — Permitting by Regulation Deemed Collection System Permit WQCSDO100 Facility Name: Severn Collection System Northhampton County Dear Mayor McGee: On March 18, 2022, Josh Brigham of the Raleigh Regional Office conducted a compliance evaluation inspection of the Town of Severn Collection System. The purpose of this inspection was to ensure compliance with the subject regulation. During the inspection, the guidance of Joseph Troy Holloman, Backup ORC, was greatly appreciated. This Deemed Collection System inspection consisted of the following: • Review of the 15A NCAC 02T .0403 permit requirements; • Review of the owner/facility information; • Review of records; and • On -site inspection of the collection system and pump station units. Findings during the pre -inspection file review were as follows: 1. The subject facility is classified as CS-1. The designated Operator in Responsible Charge (ORC), Marshall Lassiter, is classified as CS-1, and the Backup ORC (BORC) Troy Holloman is classified as CS-1. Both have an active status. 2. The Town of Severn has had no Sanitary Sewer Overflows since the last inspection on July 19, 2019. Findings during the inspection were as follows: 3. The Severn collection system has 1 pump station, which was visited during this inspection. The pump station had secured access, and exhibited very little to no waste build-up. Both the audible and visual alarms and pumps were tested. All functioned properly. 4. Per Mr. Holloman, the wastewater collection system consists of approximately 1 mile of force main, 1 duplex pump station, and 4 high priority sewer lines. 5. A map of the sewer system was available and appeared to contain all required information. NO!eo::OLI D_E oewmmnmr�.a..�uia�.mr V North Carolina Department of Environmental Quality ! Division of Water Resources Raleigh Regional Office l 3800 Barrett Chive 1 Raleigh, North Carolina 27609 919.791.4200 6. The Severn collection system has a Fats, Oils, and Grease Program. Materials are distributed with utility bills. 7. Per Mr. Holloman, the Severn collection system has four high -priority lines. All four lines were visited during the inspection and no issues were noted. 8. A Spill Response Action Plan was available for review during the inspection. It contained all required information except for spare parts inventory and post-overflow/spill assessment. Please amend the plan then provide a copy of the Spill Response Action Plan to this department. 9. Right-of-way and sewer system maintenance records were not available for review during the inspection. Any maintenance performed should be documented and maintained. This inspection letter is being sent as a Notice of Deficiency because of the bolded items listed in points 8 and 9. Within 30 day of receiving this letter, please submit a written response addressing how the town has or will resolve the noted deficiencies. If you have questions concerning this report please contact Josh Brigham at 919-791-4251 or joshua.bri hg amkncdenr. og_v. _ Sincerely, Vanessa E. Manuel, Assistant Regional Supervisor Water Quality Regional Operations Section Raleigh Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Compliance Inspection Report Cc: RRO Files Laserfiche D E Q�2314 North Carolina Department of Environmental Quality I Division of Water Resources 512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611 IORM CAROLINA _ ��� 919.707.9000 Compliance Inspection Report Permit: WQCSD0100 Effective: 03/01/00 Expiration SOC: Effective: Expiration County: Northampton Region: Raleigh Contact Person: Joseph T Holloman Title: Directions to Facility: System Classifications: CS1, Primary ORC: Joseph Troy Holloman Secondary ORC(s): On -Site Representative(s): Related Permits: Owner: Town of Severn Facility: Severn Collection System Phone: 252-585-0411 Certification: 999632 Phone:252-585-0411 Inspection Date: 03/17/2022 Entry Time 08:30AM Exit Time: 09:30AM Primary Inspector: Joshua S Brigham Z Z Phone: 919-791 4200 Secondary Inspectors): 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 General Grease Control Spills/Response Plan Inspections Lines Pump Stations (See attachment summary) Page 1 of 5 Permit: WQCSD0100 Owner - Facility: Town of Severn Inspection Date: 03/17/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Inspection Summary: See attached inspection report. Page 2 of 5 Permit: wQCSD0100 Owner - Facility: Town of Severn Inspection Date: 03/17/2022 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: Yes No NA NE ❑■❑❑ ■ ■ ■ Pipe sizes M ❑ ❑ ❑ Pipe materials (PVC, DIP, etc) 0 ❑ ❑ ❑ Pipe location 0 ❑ ❑ ❑ # Flow direction 0 ❑ ❑ ❑ # Approximate pipe age 0 ❑ ❑ ❑ # Pump station ID, location and capacity 0 ❑ ❑ ❑ # Force main air release valve location & type ❑ ❑ 0 ❑ # Location of satellite connections ❑ ❑ 0 ❑ Are system maintenance records maintained? ❑ 0 ❑ ❑ Comment: Any maintenance performed on the sewer system (ex., cleaning sewer lines or manholes) should be documented and the logs/records maintained as required by regulation. Grease Control Yes No NA NE Is grease/sewer education program documented with req'd customer distribution? 0 ❑ ❑ ❑ # Are other types of education tools used like websites, booths, special meetings, etc? ❑ 0 ❑ ❑ If Yes, what are they? (This can reduce mailing to annual.) FOG pamplet sent 2x a year with water bills. 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: Spills and Response Action Plan Yes No NA NE # Is system free of known points of bypass? 0 ❑ ❑ ❑ If No, describe type of bypass and location # Have there been any sewer spills in the past 3 years? ❑ 0 ❑ ❑ If Yes, were they reported to the Division if meeting the reportable criteria? ❑ ❑ 0 ❑ If applicable, is there documentation of press releases and public notices issued? ❑ ❑ 0 ❑ Are all spills or sewer related issues/complaints documented? ❑ ❑ 0 ❑ # Are there repeated overflows/problems (2 or more in 12 months) at same location? ❑ ❑ M ❑ # If Yes, is there a corrective action plan? ❑ ❑ 0 ❑ Page 3 of 5 Permit: WQCSD0100 Owner - Facility: Town of Severn Inspection Date: 03/17/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Is a Spill Response Action Plan available? 0 ❑ ❑ ❑ Is a Spill Response Action Plan available for all personnel? 0 ❑ ❑ ❑ Does the plan include: # 24-hour contact numbers 0 ❑ ❑ ❑ # Response time 0 ❑ ❑ ❑ # Equipment list and spare parts inventory ❑ 0 ❑ ❑ # Access to cleaning equipment 0 ❑ ❑ ❑ # Access to construction crews, contractors, and/or engineers 0 ❑ ❑ ❑ # Source of emergency funds E ❑ ❑ ❑ # Site sanitation and cleanup materials 0 ❑ ❑ ❑ # Post-overflow/spill assessment ❑ 0 ❑ ❑ Comment: Spill response plan did not have inventory and post-assesment. Inspections Yes No NA NE Are adequate maintenance records maintained? 0 ❑ ❑ ❑ Are pump stations being inspected at the required frequency? 0 ❑ ❑ ❑ Is at least one complete functionality test conducted weekly per pump station? 0 ❑ ❑ ❑ Is there a system or plan in place to observe the entire system annually? E ❑ ❑ ❑ Is the annual inspection documented? ❑ 0 ❑ ❑ # 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: Pump station inspected daily. 4HPL inspected monthly. No documentation of annual inspection. Lines/Right-of-Ways/Aerial Lines Yes No NA NE Please list the Lines/Right of Ways/Aerial Lines Inspected: 1. Main street; 2. South street; 3. Water street; 4. New street. Are right-of-ways and easements maintained for the full width for access? 0 ❑ ❑ ❑ If No, give details on temporary access: Is maintenance documented? ❑ 0 ❑ ❑ Were all areas/lines inspected free of issues? 0 ❑ ❑ ❑ Comment: Inspections should be documented. Pump Stations Yes No NA NE Please list the Pump Stations Inspected: 1. New Street Pump 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 Page 4 of 5 Permit: WQCSDO100 Owner - Facility:Town of Severn Inspection Date: 03/17/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine # 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? 0 For pump stations inspected: Are they secure with restricted access? 0 ❑ ❑ ❑ Were they free of by-pass structures/pipes? M ❑ ❑ ❑ Were wet wells free of excessive grease/debris? 0 ❑ ❑ ❑ # Do they all have telemetry installed? ❑ 0 ❑ ❑ Is the telemetry system functional? ❑ ❑ 0❑ Is a 24-hour notification sign posted ? 0 ❑ ❑ ❑ Does the sign include: Owner Name? ❑0 ❑ ❑ Pump station identifier? ❑ E ❑ ❑ # Address? ❑ 0 ❑ ❑ Instructions for notification? 0 ❑ ❑ ❑ 24-hour emergency contact numbers? 0 ❑ ❑ ❑ Are audio and visual alarms present? 0 ❑ ❑ ❑ Are audio and visual alarms operable? M ❑ ❑ ❑ # Is there a backup generator or bypass pump connected? 0 ❑ ❑ ❑ If tested during inspection, did it function properly? 0 ❑ ❑ ❑ Is the back-up system tested at least bi-annually under normal operating conditions? 0 ❑ ❑ ❑ # Does it have a dedicated connection for a portable generator? 0 ❑ ❑ ❑ # Is the owner relying on portable units in the event of a power outage? ❑ M ❑ ❑ # If Yes, is there a distribution plan? ❑ ❑ 0 ❑ If Yes, what resources (Units/StaffNehicles/etc) are included in Plan? No telemetry, not relying on portable units. # Does Permittee have the approved percentage of replacement simplex pumps? ❑ ❑ 0 ❑ Is recordkeeping of pump station inspection and maintenance program adequate? ❑0 ❑ ❑ Do pump station logs include at a minimum: Inside and outside cleaning and debris removal? ❑ 0 ❑ ❑ Inspecting and exercising all valves? ❑ 0 ❑ ❑ Inspecting and lubricating pumps and other equipment? ❑ 0 ❑ ❑ Inspecting alarms, telemetry and auxiliary equipment? ❑ 0 ❑ ❑ Comment: Pump station lops have flow and pump run time Page 5 of 5