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HomeMy WebLinkAboutWQCS00370_Compliance Evaluation Inspection_20221019 North Carolina Department of Environmental Quality Division of Water Resources Raleigh Regional Office 3800 Barrett Drive Raleigh, North Carolina 27609 919.791.4200 October 18, 2022 CERTIFIED MAIL # 7020 3160 0000 4115 2909 RETURN RECEIPT REQUESTED Mayor Robert Williams Town of Sharpsburg PO Box 1759 Sharpsburg, NC 27878 Subject: Notice of Violation-Notice of Intent to Enforce NOV-2022-PC-0639 Compliance Evaluation Inspection Town of Sharpsburg Wastewater Collection System Permit Number WQCS00370 Nash County Dear Mr. Williams: On September 19, 2022, Stephanie Goss of the Division of Water Resources conducted the subject inspection. The assistance of Brian Sullivan and Jason Landvater during the inspection was appreciated. Below is a list of findings observed during the inspection: 1. The permit became effective June 9, 2017 and expires on February 28, 2025. 2. The Town of Sharpsburg’s wastewater collection system has approximately 14 miles of gravity sewer, approximately 8 miles of force main, 1 simplex pump station and 8 duplex pump stations. 3. Mr. Sullivan stated that the Town’s Fats, Oil and Grease (FOG) program is currently not in use. Educational materials are not being mailed out twice a year to both residential and non-residential users as required by the subject permit requirements. Please provide a written response within 30-days of receipt of this letter detailing actions the Town will take to comply with permit requirements [15A NCAC 02T .0108(b)]. 4. A copy of a Capital Improvement Plan (CIP) was not available for inspection. In the inspection letter dated May 10, 2019, the Town was informed an updated CIP should be developed. Please provide a written response within 30-days of receipt of this letter detailing actions the Town will take to comply with permit requirements. A CIP must address the short-term needs and long-term “master plan” concepts. This plan should cover a three-to-five-year period and include a goal statement, description of the project area, description of existing facilities, known deficiencies and forecasted future needs including cost analysis [G.S. 143-215.9B] DocuSign Envelope ID: 08231119-FEFE-458A-AA10-4BE7241CA01C North Carolina Department of Environmental Quality Division of Water Resources Raleigh Regional Office 3800 Barrett Drive Raleigh, North Carolina 27609 919.791.4200 WQCS00370: Town of Sharpsburg Wastewater Collection System NOV-2022-PC-0639 Page 2 of 4 5. Records for Sanitary Sewer Overflows (SSO’s) were not available for inspection. In the inspection letter dated May 10, 2019, the Town was informed to keep SSO 5-day reports and any associated press releases and public notices (Section III.2 & IV.2 of permit). Adequate records pertaining to SSO’s must be documented and kept for a minimum of three years and must contain the information as detailed in 15A NCAC 02T .0108(b). Please provide a written response within 30-days of receipt of this letter detailing actions the Town will take to comply with permit requirements. 6. Per the subject permit, there are approximately 8 miles of gravity line. According to Mr. Sullivan’s records, approximately 2.1 miles of gravity sewer line were cleaned in 2021 which is 26.5% and 2.3 miles of gravity sewer line were cleaned in 2020 which is 29%. 7. During the subject inspection, six of the Town’s nine pump stations were visited: Batchelor Road, Brickyard, Barnhill, RBI, Taylor Woods, and Pine Needles. All pump stations have identification signs, secured access, and audio/visual alarms. The SCADA system was not in operation during the time of the inspection. Mr. Landvater stated the pump stations are checked daily. Six of the nine pump stations have an on-site generator except for Batchelor Road, RBI and Taylor Woods which have portable generators and are tested weekly. The following deficiencies were noted during the inspection. • Batchelor Road Pump Station: the visual alarm functioned when the high-water float was activated; however, the audio alarm did not function. The wet well contained a buildup of grease. Mr. Landvater stated the wet wells are sprayed down twice a year, but the grease and debris are not pumped out. • Brickyard Pump Station: the visual alarm functioned when the high-water float was activated; however, the audio alarm did not function. The generator was tested, and it did not operate successfully. The wet well contained a buildup of grease and debris. • RBI Pump Station: The audio and visual alarms did not function as required. • Taylor Woods Pump Station: The audio and visual alarms do not function as required. Mr. Landvater stated the visual alarm stays on permanently and audio is kept off otherwise the audio alarm stays activated. The pumps do not operate as required and need to be turned on manually. • Pine Needles Pump Station: The audio and visual alarms are kept turned off at the pump station. Mr. Landvater stated they are turned off because the pumps will run all the time if they are left on. The wet well contained a significant amount of grease and debris. The generator did not operate when tested. • Barnhill Pump Station: The audio and visual alarms did not function as required when the high-water float was activated. The visual alarm stays on permanently. The wet well was full of grease and debris (See Photograph 1). The generator did operate successfully when tested. Mr. Landvater stated the pump station required a constant source of attention. The wet well stays inundated with grease, rags and debris which prohibits the pumps from operating successfully. The wastewater collection system shall be effectively managed, maintained and operated at all times to prevent discharge to land or surface waters, and prevent any contravention of groundwater standards or surface water standards [15A NCAC 02T .0108(b)]. Please provide a written response within 30-days of receipt of this letter detailing actions the Town will take to comply with permit requirements. This response must include a timeline detailing when the items described above will be fixed. DocuSign Envelope ID: 08231119-FEFE-458A-AA10-4BE7241CA01C North Carolina Department of Environmental Quality Division of Water Resources Raleigh Regional Office 3800 Barrett Drive Raleigh, North Carolina 27609 919.791.4200 WQCS00370: Town of Sharpsburg Wastewater Collection System NOV-2022-PC-0639 Page 3 of 4 Photograph 1: Barnhill Pump Station Wet Well (September 19, 2022) 8. An inspection and maintenance log for each pump station was available to view during the inspection. The logs include a check list for items such as inspecting the fence, testing the floats and audio/visual alarms, and checking for oil leaks. 9. An overall map of the collection system was not available during the time of the inspection. Mr. Sullivan provided scaled down maps of the collection system that included pipe direction and pump station locations. Within 30-days of receipt of this letter, please provide a copy of a comprehensive up-to-date map which includes pipe size, pipe material, flow direction, and approximate pipe age [15A NCAC 02T .0108(b)]. 10. A Response Action Plan was not available for review during the inspection. Within 30- days of receipt of this letter, please provide a written response detailing actions the Town will take to comply with permit requirements [15A NCAC 02T .0108(b)]. A Notice of Violation/Intent to Issue Civil Penalty is being issued for the noted violation of North Carolina General Statute (G.S.) 143-215.1. Pursuant to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) may be assessed against any person who violates or fails to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S. 143-215.1. Within 30-days receipt of this letter, please submit a written response to this office indicating the actions you will take or have taken to comply with or resolve the issues noted in items 3-5 7, 9 and 10 above. DocuSign Envelope ID: 08231119-FEFE-458A-AA10-4BE7241CA01C North Carolina Department of Environmental Quality Division of Water Resources Raleigh Regional Office 3800 Barrett Drive Raleigh, North Carolina 27609 919.791.4200 WQCS00370: Town of Sharpsburg Wastewater Collection System NOV-2022-PC-0639 Page 4 of 4 If you have any questions concerning this report, please contact Stephanie Goss at 919-791-4256 or by e-mail at stephanie.goss@ncdenr.gov. Sincerely, Vanessa E. Manuel, Assistant Regional Supervisor Water Quality Regional Operations Section Raleigh Regional Office Division of Water Resources, NCDEQ cc: Laserfiche DocuSign Envelope ID: 08231119-FEFE-458A-AA10-4BE7241CA01C Compliance Inspection Report Permit:WQCS00370 Effective:06/09/17 Expiration:02/28/25 Owner :Town of Sharpsburg SOC: Contact Person: Region: County: Directions to Facility: Nash Raleigh Brian Richard Sullivan Effective:Expiration:Facility:Sharpsburg Collection System Title:Phone:252-908-3612Public Works Director Secondary ORC(s): 252-908-3612Phone:1000010Certification:Brian Richard SullivanPrimary ORC: CS2,System Classifications: On-Site Representative(s): Related Permits: NC0030317 City of Rocky Mount - Tar River Regional WWTP Secondary Inspector(s): Primary Inspector: Inspection Date:Exit Time:Entry Time: Phone: 09/19/2022 09:30AM 11:30AM Stephanie Goss 919-791-4200 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 Sewer & FOG Ordinances Capital Improvement Plan Map Inspections Spill Response Plan Spills Pump Stations (See attachment summary) Page 1 of 6 10/18/2022 DocuSign Envelope ID: 08231119-FEFE-458A-AA10-4BE7241CA01C Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCS00370 09/19/2022 Collection System Inspect Non Sampling Town of Sharpsburg Routine Inspection Summary: Page 2 of 6 DocuSign Envelope ID: 08231119-FEFE-458A-AA10-4BE7241CA01C Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCS00370 09/19/2022 Collection System Inspect Non Sampling Town of Sharpsburg Routine 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. Sullivan stated that their Fats, Oil and Grease (FOG) program is not in use. Educational materials are not being mailed out twice a year per permit requirements. 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? Does CIP include forecasted future needs? A copy of a Capital Improvement Plan (CIP) was not available on the date of the inspection.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? Page 3 of 6 DocuSign Envelope ID: 08231119-FEFE-458A-AA10-4BE7241CA01C Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCS00370 09/19/2022 Collection System Inspect Non Sampling Town of Sharpsburg Routine An overall map of the collection system was not available during the time of the inspection. Mr. Sullivan provided scaled down maps that included pipe direction and pump station locations. 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? Documentation is not being kept for when rig-of-ways are being mowed.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? Spill Response plan was not available.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? Records for SSO’s are not documented.Comment: Pump Stations Yes No NA NE Page 4 of 6 DocuSign Envelope ID: 08231119-FEFE-458A-AA10-4BE7241CA01C Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCS00370 09/19/2022 Collection System Inspect Non Sampling Town of Sharpsburg Routine Please list the Pump Stations Inspected: 7.Six of the Town’s nine pump stations were inspected: Batchelor Road, Brickyard, Barnhill, RBI, Taylorwoods and Pine Needles. All pump stations have identification signs, secured access, and audio/visual alarms. The SCADA system was not in operation during the time of the inspection. Mr. Landvater stated the pump stations are checked daily. Six of the nine pump stations have an on-site generator except for Batchelor Road, RBI and Tayorwoods which have portable generators and are tested weekly. # Number of duplex or larger pump stations in system 8 # Number of vacuum stations in system # Number of simplex pump stations in system 1 # 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?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 communication 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: Page 5 of 6 DocuSign Envelope ID: 08231119-FEFE-458A-AA10-4BE7241CA01C Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCS00370 09/19/2022 Collection System Inspect Non Sampling Town of Sharpsburg Routine 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? See inspection letter for detailsComment: Page 6 of 6 DocuSign Envelope ID: 08231119-FEFE-458A-AA10-4BE7241CA01C