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Home My WebLink AboutWQCSD0086_NOV2022PC141 & CEI Report_20220321 SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED. March 21, 2022 Abigail Norton, Mayor Town of Hot Springs Email: mayor@townofhotsprings.org SUBJECT: NOTICE OF VIOLATION Tracking Number: NOV-2022-PC-0141 Permit No. WQCSD0086 Hot Springs Collection System Madison County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Hot Springs Collection System on March 1, 2022. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in Collection System Permit No. WQCSD0086. A summary of the findings and comments noted during the inspection are provided in the enclosed copy of the inspection report. The Collection System Non-sampling inspection was conducted by Division of Water Resources staff from the Asheville Regional Office. The following violation(s) were noted during the inspection: Inspection Area Description of Violation _________________________________________________________________________________________________________________________________________________________________________ Pump Stations The Collection System contains a simplex pump station that serves more than one building. _________________________________________________________________________________________________________________________________________________________________________ Spills and Response Action Plan The Town has not developed and implemented a Spill Response Action Plan. _________________________________________________________________________________________________________________________________________________________________________ DocuSign Envelope ID: 585F0123-F68F-4203-A5CF-46F9060812DD Remedial actions should have already been taken to correct this problem and prevent further occurrences in the future. The Division of Water Resources may pursue enforcement action for this and any additional violations of State law. To prevent further action, please respond in writing to this office within 30 days upon your receipt of this Notice of Violation regarding your plans or measures to be taken to address the indicated violations and other identified issues, if applicable. If you should have any questions, please do not hesitate to contact Stephanie Williams with the Water Quality Regional Operations Section in the Asheville Regional Office at 828-296-4500. Sincerely, Daniel Boss, Assistant Regional Supervisor Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Report Ec: Laserfiche Juanita James (ORC) DocuSign Envelope ID: 585F0123-F68F-4203-A5CF-46F9060812DD Compliance Inspection Report Permit:WQCSD0086 Effective:03/01/00 Expiration:Owner :Town of Hot Springs SOC: Contact Person: Region: County: Directions to Facility: Madison Asheville Randy A Joseph Effective:Expiration:Facility:Hot Springs Collection System Title:Phone:828-622-7591 Secondary ORC(s): Phone:Certification:Primary ORC: CS1,System Classifications: On-Site Representative(s): Related Permits: Secondary Inspector(s): Primary Inspector: Inspection Date:Exit Time:Entry Time: Phone: 03/01/2022 12:30PM 02:00PM Stephanie A Williams 828-296-4500 Lauren E Armeni Facility Status: Permit Inspection Type: Reason for Inspection:Inspection Type: Not CompliantCompliant Routine Deemed permitted collection system management and operation Collection System Inspect Non Sampling Question Areas: Miscellaneous Questions General Grease Control Spills/Response Plan Inspections Lines Manholes Pump Stations (See attachment summary) Page 1 of 6 DocuSign Envelope ID: 585F0123-F68F-4203-A5CF-46F9060812DD Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCSD0086 03/01/2022 Collection System Inspect Non Sampling Town of Hot Springs Routine Inspection Summary: Stephanie Williams and Lauren Armeni, with the Asheville Regional Office, conducted a Compliance Evaluation Inspection of the Hot Springs Collection System on March 1, 2022. This inspection was conducted to determine if the system is being operated and maintained in compliance with permit no. WQCSD0086. Jaunita James (ORC), Jeremy Trantham (maintenance), and Cody Fisher (maintenance) were present during the inspection. The town was under a sewer tap moratorium through the State from April 2015 until September 2021. The moratorium was lifted in September 2021 because flow had dropped below 80% of design capacity; however, the Town recently self-imposed another moratorium due to increased flows. The Town is working with McGill and Associates to conduct smoke testing in the collection system within the next two months. It is unclear how frequently grease/sewer education materials have been distributed in the past. During the inspection we discussed the requirements that these materials be distributed twice per year. Town staff check grease traps regularly and ensure that owners are pumping the grease traps per the Town’s requirements. It was noted during the inspection that documentation pertaining to the grease control program was excellent. The Town has not developed an overflow/spill response plan. The annual inspection has been conducted in the past but has not been document. It will be documented moving forward. There are 4 lift stations owned by the Town in the collection system - 3 duplex stations and 1 simplex station which serves more than one building (Red Bridge Lift Station). There are plans to add a second pump to this lift station to bring it into compliance. The Town also maintains two additional simplex lift stations which serve one building each. The lift station at the diner is owned by the diner and maintained by the Town. The lift station at the end of the line is also maintained by the Town, but it is unclear who owns this lift station. The following deficiency was noted during the inspection: 1. Spill and Response Action Plan: The Town does not have a Spill Response Plan. 2. Lift Stations: The Collection System contains a simplex pump station that serves more than one building. Page 2 of 6 DocuSign Envelope ID: 585F0123-F68F-4203-A5CF-46F9060812DD Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCSD0086 03/01/2022 Collection System Inspect Non Sampling Town of Hot Springs Routine General Yes No NA NE # 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: Grease Control Yes No NA NE 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.) 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? It is unclear how frequently grease/sewer education materials have been distributed in the past. See summary for details. Comment: Spills and Response Action Plan Yes No NA NE # 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? 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? Page 3 of 6 DocuSign Envelope ID: 585F0123-F68F-4203-A5CF-46F9060812DD Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCSD0086 03/01/2022 Collection System Inspect Non Sampling Town of Hot Springs Routine 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 The Town has not developed and implemented a spill response plan. See summary for details.Comment: 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? The annual inspection has not been documented in the past. See summary for details.Comment: Lines/Right-of-Ways/Aerial Lines Yes No NA NE Please list the Lines/Right of Ways/Aerial Lines Inspected: Red Bridge Aerial Line Are right-of-ways and easements maintained for the full width for access? If No, give details on temporary access: Is maintenance documented? Were all areas/lines inspected free of issues? Maintenance on aerial lines has not been required, but will be documented as it becomes necessary. Comment: Manholes Yes No NA NE Please list the Manholes Inspected: Red Bridge MH, 182 Lawson St. Are manholes accessible? # Are manhole covers/vents above grade? Are manholes free of visible signs of overflow? Are manholes free of sinkholes and depressions? Page 4 of 6 DocuSign Envelope ID: 585F0123-F68F-4203-A5CF-46F9060812DD Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCSD0086 03/01/2022 Collection System Inspect Non Sampling Town of Hot Springs Routine 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: Pump Stations Yes No NA NE Please list the Pump Stations Inspected: Post Office PS, Red Bridge PS # Number of duplex or larger pump stations in system 3 # Number of vacuum stations in system 0 # Number of simplex pump stations in system 0 # Number of simplex pump stations in system serving more than one building 1 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? 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? Page 5 of 6 DocuSign Envelope ID: 585F0123-F68F-4203-A5CF-46F9060812DD Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCSD0086 03/01/2022 Collection System Inspect Non Sampling Town of Hot Springs Routine 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? Stationary generator at Post Office lift station, portable generator # 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? The Red Bridge Lift Station is a simplex lift station which serves more than one building. See summary for details. Comment: Page 6 of 6 DocuSign Envelope ID: 585F0123-F68F-4203-A5CF-46F9060812DD