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HomeMy WebLinkAboutWQCSD0071_Compliance Evaluation Inspection_20220916DocuSign Envelope ID: 87E0D17C-809D-45BA-8AC4-AC32C1B15707 ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director NORTH CAROLINA Environmental Quality September 16, 2022 The Honorable Martha Strawbridge, Mayor Town of Bunn PO Box 398 Bunn, NC 27508 Subject: Compliance Evaluation Inspection Town of Bunn Sewer Collection System Collection System Permit No: WQCSD0071 Franklin County Dear Mayor Strawbridge: On June 29, 2022, Cheng Zhang of the Raleigh Regional (RRO) Office Division of Water Quality conducted a Compliance Evaluation Inspection of the subject facility. The assistance and cooperation of Mr. Tony Lowery, the Town's Facilities Supervisor, during the inspection, were very helpful and appreciated. A checklist of items is enclosed with this letter. During the inspection the following items were noted: 1.) The Town's Collection System is "Permitted by Regulation" (no individual permit) and covered by a deemed permit number (WQC00071) and is classified as a CS-1 system. Deemed collection systems must meet the requirements of 15A NCAC 02T.0403 (attached). If the system exceeds 200,000 GPD, the Town will need to apply for an individual Collection system permit. Tony Lowery is the Operators in Responsible Charge (ORC). Ashley Roberson is listed as the backup. 2.) The Town has maintained a map of the collection system which lacks several required elements, such as approximate pipe age, pump station ID and capacity. The Town will develop a GIS-based sewer system map in 2023, which will be funded by a grant. 3.) The system has 4 duplex pump stations. All stations were equipped with telemetry system and standby generator. All four pump stations were visited during this inspection. These pump stations were inspected and maintained as required by the permit. 4.) The Town has a grease control program. All four restaurants in town use grease dumpsters, instead of grease traps/interceptors. Distribution of grease/sewer educational material has not been documented. 15A NCAC 02T .0403 (8) requires bi-annual distribution of educational materials for both commercial and residential users, distribution of grease/sewer educational material must be documented. 5.) The Town needs to develop and implement a spill response action plan, which shall include 24- hour contact numbers, response time, equipment list and spare parts inventory, access to D_E Q 1 NORTH CAROLINA DeperhneM of Environmental Oual� North Carolina Department of Environmental Quality I Division of Water Resources Raleigh Regional Office I 3800 Barrett Drive I Raleigh, North Carolina 27609 919.791.4200 DocuSign Envelope ID: 87E0D17C-809D-45BA-8AC4-AC32C1B15707 cleaning equipment, access to construction crews, contractors, and/or engineers, source of emergency funds, site sanitation and cleanup materials, and post-overflow/spill assessment 6.) A review of records and logbooks indicates the following a) Records are maintained adequately for sewer line maintenance, cleaning, high priority line inspection, and right of way maintenance. It was noted that 8100 feet of gravity line was cleaned in 2021, 6261 feet in 2020. b) No Sanitary Sewer Overflows (SSOs) were discovered or reported since the last inspection. 7.) The Town has designated three high priority/aerial lines; these lines are inspected semi-annually according to Mr. Lowery, however high priority line inspections have not been documented. Two high priority lines were observed during the inspection, these lines were in good condition, the right-of-way to these high priority lines were maintained and accessible. Please respond in writing to RRO within 30 days of receipt of this letter regarding Items 4, 5 and 7. If you have any questions regarding the attached report or any of the findings, please contact Cheng Zhang at: (919) 791-4200 (or email: cheng.zhang@ncdenr.gov). Sincerely, DocuSigned by: salt uwsbw BCDA9D825D4A46D... Scott Vinson, Regional Supervisor Water Quality Regional Operations Section Raleigh Regional Office Division of Water Resources Attachments: Compliance Inspection Report 15A NCAC 02T.0403 Cc: Laserfiche Tony Lowery, Town of Bunn (electronic copy only) D_E NORTH CARCLINA gaparhnanl of Environmental quality North Carolina Department of Environmental Quality I Division of Water Resources 512 North Salisbury Street 11611 Mail Service Center I Raleigh, North Carolina 27699-1611 919.707.9000 Compliance Inspection Report Permit: WQCSD0071 Effective: 03/01/00 Expiration: SOC: Effective: Expiration: County: Franklin Region: Raleigh Contact Person: Marsha Strawbridge Directions to Facility: System Classifications: CS1, Primary ORC: Tony Alfred Lowery Secondary ORC(s): On -Site Representative(s): On -site representative Related Permits: Inspection Date: 06/29/2022 Primary Inspector: Cheng Zhang Secondary Inspector(s): Owner : Town of Bunn Facility: Bunn Collection System Title: Mayor Phone: 919-496-2992 Certification: 1006559 Phone: 919-497-7819 Tony Alfred Lowery 919-497-7819 Entry Time 09:30AM Exit Time: 11:40AM Does 9nea by: Phone: 919-791-4200 9/16/2022 "- D6171508E1 EC41 F... 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 ▪ Manholes (See attachment summary) ▪ General ▪ Inspections ▪ Pump Stations ▪ Grease Control ▪ Lines Page 1 of 6 Permit: WQCSD0071 Owner - Facility:Town of Bunn Inspection Date: 06/29/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Inspection Summary: See attached report. Page 2 of 6 Permit: WQCSD0071 Owner - Facility:Town of Bunn Inspection Date: 06/29/2022 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: The Town will develop a GIS-based sewer map funded by a grant next year. 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? Comment: Distribution of grease educational material has not been documented. 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? # 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 3 of 6 Permit: WQCSD0071 Owner - Facility:Town of Bunn Inspection Date: 06/29/2022 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: The Town needs to develop and implement 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: HPL inspections have not been documented. Lines/Right-of-Ways/Aerial Lines Please list the Lines/Right of Ways/Aerial Lines Inspected: East Carolina and Crooked Creek Crossing 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? ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ • ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Comment: The HPLs were found in good condition. 6261 feet of gravity line was cleaned in 2020, 8100 feet in 2021, which did not meet the 10% target. Manholes Please list the Manholes Inspected: MH at the end of Crooked Creek Crossing easement. 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? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ Page 4 of 6 Permit: WQCSD0071 Owner - Facility:Town of Bunn Inspection Date: 06/29/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine # 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 Please list the Pump Stations Inspected: Elementary School; East Carolin; Warren Ave.; and Holinsworth # 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? 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? • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE 4 0 0 0 0 4 • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Page 5 of 6 Permit: WQCSD0071 Owner - Facility:Town of Bunn Inspection Date: 06/29/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine # 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: • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Page 6 of 6 15A NCAC 02T .0403 PERMITTING BY REGULATION (a) Collection systems having an actual, permitted or Division -approved average daily flow less than 200,000 gallons per day shall be deemed permitted, pursuant to Rule .0113 of this Subchapter if the system meets the criteria in Rule .0113 of this Subchapter and all criteria required in this Rule: (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. (2) A map of the collection system shall have been developed and shall be maintained. (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. (4) Pump stations that are not connected to a telemetry system shall be inspected by the permittee or its representative every day, 365 days per year, unless the permittee demonstrates that 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. (5) High -priority sewers shall be inspected by the permittee or its representative once every six - months, and inspections shall be documented. (6) A general observation by the permittee or its representative of the entire collection system shall be conducted once per year. (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 - 215.1C. (8) A Grease Control Program shall be in place as follows: (A) For publicly owned collection systems, the Grease Control Program shall include bi- annual distribution of educational materials for both commercial and residential users and the legal means to require grease interceptors for new construction and retrofit and if necessary, of grease interceptors at existing establishments. The plan shall also include legal means for inspections of the grease interceptors, enforcement for violators and the legal means to control grease entering the system from other public and private satellite collection systems. (B) For privately owned collection systems, the Grease Control Program shall include bi- annual distribution of grease education materials to users of the collection system by the permittee or its representative. (C) Grease education materials shall be distributed more often than required in Parts (A) and (B) of this Subparagraph if necessary to prevent grease -related sanitary sewer overflows. (9) Right-of-ways and easements shall be maintained in the full easement width for personnel and equipment accessibility. (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. (b) Private collection systems on a single property serving an industrial facility from which the domestic wastewater contribution is less than 200,000 gallons per day shall be deemed permitted. (c) The Director may determine that a collection system shall not be deemed to be permitted in accordance with this Rule and Rule .0113 of this Subchapter. This determination shall be made in accordance with Rule .0113(e) of this Subchapter. History Note: Authority G.S. 143-215.1(a); 143-215.3(a); 143-215.9B; Eff September 1, 2006; Readopted Eff September 1, 2018.