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HomeMy WebLinkAboutWQCSD0016_Inspection_20220506DocuSign Envelope ID: 7B690965-8BE0-4A3B-9740-2CD48187D172 ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director NORTH CAROLINA Environmental Quality Certified Mail # 7020 3160 0000 4115 3555 Return Receipt Requested Emily Turner, Mayor 203 W. Green Street P.O. Box 185 Macclesfield, NC 27557 Subject: Dear Mayor Turner: May 6, 2022 NOTICE OF VIOLATION: NOV-2022-PC-0249 Compliance Evaluation Inspection Macclesfield Collection System Deemed Permitted Collection System No. WQCSD0016 Edgecombe County This letter serves as a Notice of Violation (NOV) for the Town of Macclesfield's (Town's) wastewater collection system, which is a Deemed Permitted System under permit number WQCSD0016. The Town has not created or retained the required records and plans which must be associated with the collection system, as required by 15A North Carolina Administrative Code Section 02T.0400 (15A NCAC 02T.0403). On April 20, 2022, Alys Hannum and Jason Robinson of the Division of Water Resources conducted an inspection of the Town Collection System to evaluate compliance with the operation and maintenance of the subject deemed wastewater collection system permit. The cooperation and assistance of Benjy Lassiter, Operator in Responsible Charge (ORC) was greatly appreciated. Findings during the inspection were as follows: 1. The wastewater collection system has 2 pump stations. Both pump stations are connected to a communication system (SCADA) and have connections for portable generators. 2. The Town provided a map of the collection system, but the map was for proposed additions to the system in 1999. The Town's current map is NOT a map of current collection system assets. Within 60 days of receipt of this letter, please create an updated map which reflects current collection system assets or submit a plan to create one. This map should include: pipe location, material, approximate age, and size; flow direction; pump station locations, names, and capacity; and force main release valves. NORTH CAROLINA Department of Environmental Quality North Carolina Department of Environmental Quality I Division of Water Resources Raleigh Regional Office 13800 Barrett Drive I Raleigh, North Carolina 27609 919.791.4200 DocuSign Envelope ID: 7B690965-8BE0-4A3B-9740-2CD48187D172 Notice of Violation: NOV-2022-PC-0249 Macclesfield Collection System Permit No. WQCSD0016 Page 2 of 3 3. No sanitary sewer overflows to State Waters were discovered during the most recent 3- year period ending March 2022. 4. The Town did not have an Operations and Maintenance plan. Within 60 days of receipt of this letter, please submit to this office a draft Operations and Maintenance Plan for review - or a schedule for creating one - which includes at minimum the following: 1. Pump Station Inspection Frequency 2. Preventative Maintenance Schedule 3. Spare Parts Inventory 4. Overflow Response Plan 5. The Town did not have Grease Control Program. Within 60 days of receipt of this letter, please submit to this office a draft Grease Control Program for review - or a schedule for creating one - which includes at minimum the following: 1. The schedule of the bi-annual distribution of educational materials for both commercial and residential users; 2. The legal means to require grease interceptors for new construction and retrofit if necessary, of grease interceptors at existing establishments; 3. The legal means for inspections of grease interceptors, enforcement for violators; and 4. The legal means to control grease entering the collection system from other public and private satellite collection systems. 6. The Town's two pump stations were inspected. Both had identification signs, secured access, appeared in good condition and were free of excess debris. All audible and visual alarms functioned when tested. The pump stations inspected were as follows: a. Wilson Street Pump Station (#1) b. North Railroad Pump Station (#2) 7. A logbook for each pump station was available to view during the inspection. According to Town staff, pump station logs do not accurately reflect the frequency of inspections. The logbooks show approximately one inspection per month. Pump stations that are connected to a telemetry system, like the Town's, are required to be inspected at least once per week. Within 60 days of receipt of this letter, please ensure collection system staff are trained on the frequency of inspections required and remind them to record every pump station visit in the logbooks. Within 60 days of receipt of this letter, please submit a written response to this office and indicate the actions the Town will take, or has taken, to comply with the requirements for Deemed Permitted Collection Systems. The response should address items 2, 4, 5, and 7 above, as well as include the requested O&M and Grease Control Program Plans or a schedule for their NORTH CAROLINAD_E Department of Environmental Quality North Carolina Department of Environmental Quality I Division of Water Resources Raleigh Regional Office 13800 Barrett Drive I Raleigh, North Carolina 27609 919.791.4200 DocuSign Envelope ID: 7B690965-8BE0-4A3B-9740-2CD48187D172 Notice of Violation: NOV-2022-PC-0249 Macclesfield Collection System Permit No. WQCSD0016 Page 3 of 3 creation. This office will review this information and any additional information you provide to determine whether to take further action. If you have any questions concerning this NOV or the required submissions, please contact Alys Hannum at alys.hannum@ncdenr.gov or by phone at (919) 791-4255. Sincerely, —DocuSigned by: Vatiuussa t. D'ttatiuwL B2916E6AB32144F... Vanessa E. Manuel, Assistant Regional Supervisor Water Quality Regional Operations Section Raleigh Regional Office Division of Water Resources, NCDEQ Attachment: EPA Water Compliance Inspection Report cc: RRO Files // Laserfiche Benjy Lassiter, ORC (lassiter.benjy@gmail.com) GD_E NORTH CofEn NA Deparbnent iR of Environmental Quality North Carolina Department of Environmental Quality I Division of Water Resources Raleigh Regional Office 13800 Barrett Drive I Raleigh, North Carolina 27609 919.791.4200 DocuSign Envelope ID: 7B690965-8BE0-4A3B-9740-2CD48187D172 Compliance Inspection Report Permit: WQCSD0016 Effective: 03/01/00 Expiration: SOC: Effective: Expiration: County: Edgecombe Region: Raleigh Contact Person: Eric Johnson Directions to Facility: Owner : Town of Macclesfield Facility: Macclesfield Collection System Title: Mayor Phone: 252-827-4823 System Classifications: Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): Related Permits: Inspection Date: 04/20/2022 Primary Inspector: Alys K Hannum Secondary Inspector(s): Entry Time 10:OOAM 1- DocuSigned by: "-4C22170C5AA04F3... Exit Time: 12:OOPM 5/2/2022 Phone: 919-791-4255 Jason T Robinson 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 II Spills/Response Plan Inspections Pump Stations (See attachment summary) Page 1 of 5 DocuSign Envelope ID: 7B690965-8BE0-4A3B-9740-2CD48187D172 Permit: WQCSD0016 Owner - Facility:Town of Macclesfield Inspection Date: 04/20/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Inspection Summary: Page 2 of 5 DocuSign Envelope ID: 7B690965-8BE0-4A3B-9740-2CD48187D172 Permit: WQCSD0016 Owner - Facility:Town of Macclesfield Inspection Date: 04/20/2022 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? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Comment: The map provided was for proposed additions to the system back in 1999 and is NOT a map of current collection system assets as they stand on the ground now. Needs to be updated to reflect current collection system status. 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.) 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 ❑ ❑ • ❑ Comment: Municipality does not have a written grease ordinance or program. Previously sent out FOG flyers 2x per year, but due to staff turnover flyers have not been retained or sent out this year yet. 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? Are all spills or sewer related issues/complaints documented? # Are there repeated overflows/problems (2 or more in 12 months) at same location? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ • ❑ ❑ Page 3 of 5 DocuSign Envelope ID: 7B690965-8BE0-4A3B-9740-2CD48187D172 Permit: WQCSD0016 Owner - Facility:Town of Macclesfield Inspection Date: 04/20/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine # 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 Comment: Town does not have a Spill Response Action Plan. 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: Not all inspections to pump stations are recorded. Official one visit per month. Pump Stations Please list the Pump Stations Inspected: #1 - Wilson Street // #2 - North Railroad # 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? ❑ ❑ • ❑ Yes No NA NE ❑ ❑ • ❑ ❑ ❑ • ❑ records at the pump stations show Yes No NA NE 2 0 0 0 2 0 • ❑ ❑ ❑ • ❑ ❑ ❑ Page 4 of 5 DocuSign Envelope ID: 7B690965-8BE0-4A3B-9740-2CD48187D172 Permit: WQCSD0016 Owner - Facility:Town of Macclesfield Inspection Date: 04/20/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine 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? # 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: Town staff stated during the inspection that one of the emergency contact numbers on the contact sign was for an ex -employee's personal cell number. Please update the signage with the correct contact numbers. Page 5 of 5