The URL can be used to link to this page

Home My WebLink AboutWQCS00139_NOD2022PC0102 & CEI Report_20220629 SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED. June 29, 2022 Rick Hensley, Mayor Town of Old Fort Email: mayor@oldfortnc.com SUBJECT: NOTICE OF DEFICIENCY Tracking Number: NOD-2022-PC-0102 Permit No. WQCS00139 Old Fort Collection System McDowell County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Old Fort Collection System on June 23, 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. WQCS00139. 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 deficiencies were noted during the inspection: Inspection Area Description of Deficiency _________________________________________________________________________________________________________________________________________________________________________ Sewer and FOG Ordinances A FOG Ordinance that includes an enforceable Grease Trap Program has not been created. _________________________________________________________________________________________________________________________________________________________________________ Inspections A plan to observe the entire Collection System annually has not been put into place or documented. _________________________________________________________________________________________________________________________________________________________________________ Lines/Right-of-Ways/Aerial Gravity sewer line cleaning has not been documented. Lines _________________________________________________________________________________________________________________________________________________________________________ DocuSign Envelope ID: 3D521754-2260-4609-A8D7-D9FBEBC656DA In addition, the issues below must also be addressed: Compliance Issue: Remove debris from the Mill Creek at Old Fort Elementary School aerial line. 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, carefully review these deficiencies and address the causes of non-compliance to prevent the recurrence of similar situations. If you should have any questions, please do not hesitate to contact Lauren Armeni with the Water Quality Regional Operations Section in the Asheville Regional Office at 828-296-4667. Sincerely, Daniel Boss, Assistant Regional Supervisor Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Report Ec: Laserfiche Joshua Cagle (ORC) DocuSign Envelope ID: 3D521754-2260-4609-A8D7-D9FBEBC656DA Compliance Inspection Report Permit:WQCS00139 Effective:11/01/14 Expiration:10/31/22 Owner :Town of Old Fort SOC: Contact Person: Region: County: Directions to Facility: McDowell Asheville Tony West Effective:Expiration:Facility:Old Fort Collection System PO Box 520 Old Fort NC 28762 Title:Phone:828-668-4561Contact Secondary ORC(s): Phone:1008385Certification:Joshua Kenneth CaglePrimary ORC: CS1,System Classifications: On-Site Representative(s): Related Permits: NC0021229 Town of Old Fort - Old Fort WWTP Secondary Inspector(s): Primary Inspector: Inspection Date:Exit Time:Entry Time: Phone: 06/23/2022 10:00AM 12:45PM Lauren E Armeni 828-296-4500 Stephanie A Williams Facility Status: Permit Inspection Type: Reason for Inspection:Inspection Type: Not CompliantCompliant Routine Collection system management and operation Collection System Inspect Non Sampling Question Areas: Miscellaneous Questions General Sewer & FOG Ordinances Capital Improvement Plan Map Reporting Requirements Inspections Spill Response Plan Spills Lines Manholes (See attachment summary) Page 1 of 6 DocuSign Envelope ID: 33C6821F-5592-44BD-85EF-35AFC39F4790 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCS00139 06/23/2022 Collection System Inspect Non Sampling Town of Old Fort Routine Inspection Summary: Lauren Armeni and Stephanie Williams, with the Asheville Regional Office, conducted a Compliance Evaluation Inspection of the Old Fort Collection System on June 23, 2022. This inspection was conducted to determine if the system is being operated and maintained in compliance with Permit No. WQCS00139. Mr. Joshua Cagle (ORC) was present during the inspection. Mr. Cagle started as the Collection System/WWTP ORC in September 2021. The Collection System consists of no pump stations, approximately 9.1 miles of gravity sewer lines and a total of six high priority lines. Current Collection System staff includes Mr. Cagle and two maintenance workers. Mr. Cagle stated that at least one other position is currently posted, and having at least one additional staff member will help him to focus on projects within the Collection System. Sewer and FOG Ordinances: A FOG Ordinance that includes an enforceable Grease Trap Program has not been created. The Sewer Use Ordinance contains a short paragraph on grease traps, but does not include enough detail. Ms. Armeni emailed Mr. Cagle an example, and he indicated that he would start working on this document and get approval from the board. Capital Improvement Plan: The permit renewal application received March 2022 indicated that the approximate Capital Improvement budget for the Collection System is $90,234. The 2018 Capital Improvement Plan provided in the Wastewater Asset Inventory and Assessment Report lists sewer line condition assessments and work recommendations based on the videod sewer lines. Mr. Cagle indicated that since he started in September 2021, none of these projects have been completed, but he will begin working on them. Additionally, Mr. Cagle has recently been conducting smoke testing with Mr. Troy Cassidy with NC Rural Water Association, Inc., and the majority of the issues have been from broken cleanouts on private properties and a small amount of terra cotta line that needs replaced. Ms. Armeni recommended that the Town apply for fall ARPA funding, and these applications are due in September 2022. Inspections: A plan to observe the entire Collection System annually needs to be put into place and documented. Lines/Right-of-Ways/Aerial Lines: Mr. Cagle indicated that the previous ORC jetted at least 10% of the gravity lines in 2021; however, documentation could not be found. Moving forward, 10% of gravity sewer lines should be cleaned annually for lines five years or older, and cleaning records should be maintained. The following deficiencies were noted during the inspection: 1. Sewer and FOG Ordinances: A FOG Ordinance that includes an enforceable Grease Trap Program has not been created. 2. Inspections: A plan to observe the entire Collection System annually has not been put into place or documented. 3. Lines/Right-of-Ways/Aerial Lines: Gravity sewer line cleaning has not been documented. Page 2 of 6 DocuSign Envelope ID: 33C6821F-5592-44BD-85EF-35AFC39F4790 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCS00139 06/23/2022 Collection System Inspect Non Sampling Town of Old Fort Routine General Yes No NA NE Is there a properly designated primary ORC and at least one back-up of proper grade? Are logs being reviewed by the system management or owner on a regular basis? # What is that frequency? # Are there any issues being addressed currently or any in the planning stages? Is there a specific pump failure plan available for all pump stations? Does plan indicate if pump parts/new pumps are in spare parts/equipment inventory? Are new/significantly upgraded pump stations equipped with anti-corrosion materials? Does the permittee have a copy of their permit? # Is permit expiring within the next 6 months? If Yes, has the Permittee applied for renewal? The lines were assessed via camera in 2018. Problem areas were identified and added to the Capital Improvement Plan. Currently, none of these problem areas are being addressed, but Mr. Cagle indicated that staff would start addressing them soon. Comment: Sewer and FOG Ordinances Yes No NA NE Is Sewer Use Ordinance (SUO) or other Legal Authority available? Does it appear that the Sewer Use Ordinance is enforced? Is there a Grease Control Program that legally requires grease control devices? What is the standard grease trap cleaning requirement in the FOG ordinance? Is Grease Control Program enforced via periodic inspections/records review? Is action taken against violators? # Have satellite systems adopted an equivalent or more stringent ordinance? 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.) Mr. Cagle indicated that FOG educational material will be posted on the Town of Old Fort's website and FOG educational pamphlets will be sent to customers once a year at the end of August through the first of September. A FOG Ordinance that includes an enforceable Grease Trap Program has not been created. See summary for details. Comment: Capital Improvement Plan Yes No NA NE Has a Capital (CIP) or System Improvement Plan been developed and adopted? Is it designated for wastewater only or does it have a dedicated section? Does CIP cover three to five year period of earmarked improvements? Does CIP include description of project area? Does CIP include description of existing facilities? Does CIP include known deficiencies? Page 3 of 6 DocuSign Envelope ID: 33C6821F-5592-44BD-85EF-35AFC39F4790 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCS00139 06/23/2022 Collection System Inspect Non Sampling Town of Old Fort Routine Does CIP include forecasted future needs? A Wastewater Asset Inventory and Assessment Report from 2018 contains the most recent Capital Improvement Plan. See summary for details. Comment: Map Yes No NA NE Is there a overall sewer system map? Does the map include: Pipe Type (GS/FM) 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 Is the map being updated for changes/additions within 1 year of activation? The map was last updated in 2018. The flow direction and approximate pipe age should be added to the map. Comment: Reporting Requirements Yes No NA NE # 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? Is an Annual Wastewater Performance Report being filed with the Division, if required? Is the report being made available to all its sewer customers? # How is it being made available?Newspaper The last Annual Wastewater Performance Report was last submitted for June 2020 through July 2021. Mr. Cagle is in the process of putting another report together. He stated that the next report will be made available on the Town's website. 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? Page 4 of 6 DocuSign Envelope ID: 33C6821F-5592-44BD-85EF-35AFC39F4790 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCS00139 06/23/2022 Collection System Inspect Non Sampling Town of Old Fort Routine There is not a system in place to observe the entire system annually, and therefore this inspection has not been documented. See summary for details. Comment: Spill Response Action Plan Yes No NA NE 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 Does the Permittee appear to respond within 2 hours of first knowledge of a spill? The Spill Response Action Plan is available at the WWTP building, but copies should be made and distributed to the other staff members and any newly hired employees. Comment: Spills Yes No NA NE Is system free of known points of bypass? If No, describe type of bypass and location 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? Comment: Lines/Right-of-Ways/Aerial Lines Yes No NA NE Please list the Lines/Right of Ways/Aerial Lines Inspected: 1. Mauney and Public Library 2. Mill Creek at Old Fort Elementary School 3. Mills Creek at Catawba Avenue. Are right-of-ways/easements maintained for full width for access by staff/equipment? If No, give details on temporary access: Is maintenance documented? Are gravity sewer cleaning records available? Has at least 10% of lines older than 5 yrs been cleaned annually? Were all areas/lines inspected free of issues? Page 5 of 6 DocuSign Envelope ID: 33C6821F-5592-44BD-85EF-35AFC39F4790 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCS00139 06/23/2022 Collection System Inspect Non Sampling Town of Old Fort Routine The Mill Creek at Old Fort Elementary School aerial line had a build-up of tree limbs that were resting on the line. These tree limbs need to be removed to prevent damage to the line. At the time of the inspection, gravity sewer cleaning records were not available. See summary for details. Comment: Manholes Yes No NA NE Please list the Manholes Inspected: 1. Old Fort Elementary 2. Commerce Street Are manholes accessible? # Are manhole covers/vents above grade? Are manholes free of visible signs of overflow? Are manholes free of sinkholes and depressions? 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: Page 6 of 6 DocuSign Envelope ID: 33C6821F-5592-44BD-85EF-35AFC39F4790