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HomeMy WebLinkAboutWQCS00051_20221011CEI_updated_20221103Compliance Inspection Report Permit: WQCS00051 Effective: 09/01/16 Expiration: 08/31/24 Owner : Town of Wilkesboro SOC: Effective: Expiration: Facility: Wilkesboro Collection System County: Wilkes 203 W Main St Region: Winston-Salem Contact Person: Kenneth Nolan Directions to Facility: System Classifications: CS2, Primary ORC: Ethan A Williams Secondary ORC(s): Jason Ervin Hart On -Site Representative(s): Related Permits: Wilkesboro NC 28697 Title: Town Manager Phone: 336-838-3951 Certification: 1002360 Phone: 336-838-0188 1002401 336-838-0188 NC0021717 Town of Wilkesboro - Cub Creek WWTP Inspection Date: 10/11/2022 Entry Time 10:30AM Exit Time: 01:30PM Primary Inspector: Patricia Lowery Phone: 336-776-9691 Secondary Inspector(s): Reason for Inspection: Routine Inspection Type: Collection System Inspect Non Sampling Permit Inspection Type: Collection system management and operation Facility Status: Compliant ❑ Not Compliant Question Areas: ▪ Miscellaneous Questions II Capital Improvement Plan ▪ Inspections ▪ Lines (See attachment summary) ▪ General ▪ Map ▪ Spill Response Plan ▪ Pump Stations ▪ Sewer & FOG Ordinances ▪ Reporting Requirements ▪ Spills Page 1 of 10 Permit: WQCS00051 Owner - Facility:Town of Wilkesboro Inspection Date: 10/11 /2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Inspection Summary: Tricia Lowery of the NC Division of Water Resources, Winston-Salem Regional Office conducted a compliance evaluation inspection of the Town of Wilkesboro collection system (WQCS00051) on 10/11/2022. Ethan Williams, ORC, was present for the inspection. Results of the inspection are summarized in the following paragraphs: SECTION III, PERMIT PART I: PERFORMANCE STANDARDS Part I, Paragraph 2, requires the wastewater collection system shall be effectively managed, maintained and operated at all times. Observations: Mr. Williams manages, maintains and operates the collection system well. Compliance Status: Compliant Part I, Paragraph 3, the Permittee shall establish an effective sewer use ordinance (SUO). Observations: SUO is comprehensive and enforced. CS operations conducts inspections concerning FOG. PT coordinator regulates SIU. Compliance Status: Compliant Part I, Paragraph 4, requires the Permittee shall develop and implement an educational fats, oils and grease program and an enforceable fats, oils and grease program for non-residential users. Observations: FOG education is mailed to customers 2x year. Additionally, FOG education can be found on Town's website and Facebook page. Compliance Status: Compliant Part I, Paragraph 5, requires the Permittee shall adopt and implement a Capital Improvement Plan (CIP) to designate fundinc for reinvestment into the wastewater collection system infrastructure. Observations: ORC keeps detailed CIP for collection system. The Town keeps overall CIP (date adopted, budget allocations, etc). ORC did not have a copy of Town's CIP, however, ORC has detailed account of all projects, improvements and estimates of costs concerning CS. It does have a goal statement and an itemized account for projects extending to 5 years. Compliance Status: Compliant Part I, Paragraph 6 requires there be no overflow or bypass structures within the system and if any are discovered that they be immediately eliminated. Observations: No overflow or bypass structures were discovered. Compliance Status: NA Part I, Paragraph 7 requires the Permittee maintain a contingency plan for pump failure at each pump station. Observations: Pump contingency plans are comprehensive and detailed. There is a plan posted at each pump station. The plan can also serve as the ERP (Emergency Response Plan) — this will be detailed further in the report. Compliance Status: Compliant Part I, Paragraph 8 requires each pump station shall be clearly and conspicuously posted with a pump station identifier and an emergency contact telephone number at which an individual who can initiate or perform emergency service for the wastewater collection system 24 hours per day, seven days per week can be contacted. Observations: Satisfactory. No issues found during inspection. Compliance Status: Compliant Part I, Paragraph 9 requires pump station sites, equipment and components shall have restricted access, as per 15A NCAC 02T .305(h)(4). Observations: No issues detected during inspection. Compliance Status: Compliant Part I, Paragraph 10 requires pump stations that do not employ an automatic polling feature (i.e. routine contact with pump stations from a central location to check operational status of the communication system) shall have both audible and visual high water alarms. Observations: MISSIONS system is used for communication. It is operational and functional. Tested during inspection. Compliance Status: Compliant Part I, Paragraph 11 requires that for all newly constructed, modified and rehabilitated pump stations, all equipment and components shall be sealed within a corrosion -resistant coating or encasement to the extent practicable and equivalent to the minimum design criteria unless the permittee can demonstrate it is not practicable or another form of corrosion resistance is employed. Observations: When/if pump stations are upgraded/rehabilitated, they will construct to comply with this regulation. Page 2 of 10 Permit: WQCS00051 Owner - Facility:Town of Wilkesboro Inspection Date: 10/11 /2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Compliance Status: Compliant SECTION IV, PERMIT PART II: OPERATION AND MAINTENANCE REQUIREMENTS Part II, Paragraph 1 requires the Permittee shall designate and employ a certified operator to be in responsible charge (ORC; and one or more certified operator(s) to be back-up ORC(s) of the facilities in accordance with 15A NCAC 8G .0201. The ORC shall visit the system within 24 hours of knowledge of a bypass, spill, or overflow of wastewater from the system, unless visited by the Back -Up ORC, and shall comply with all other conditions of 15A NCAC 8G .0204. Observations: Ethan William (ORC — Grade 4 certification); Jason Hart (BORC — Grade 4 certification). Licenses are current and properly designated with the State. Both are listed first in spill response documentation and respond urgently to SSOs. Documentation is in order. Compliance Status: Compliant Part II, Paragraph 2 requires the Permittee shall develop and adhere to a schedule for reviewing all inspection, maintenance, operational and complaint logs. Observations: Small group (3 -including ORC and BORC) work daily in collection system. All maintenance, inspection and operational logs are digital. ORC and BORC have access to and review them daily. Compliance Status: Compliant Part II, Paragraph 3 requires the Permittee shall develop and adhere to a schedule for testing emergency and standby equipment. Observations: Emergency equipment is tested and documentation is kept of all testing procedures. Compliance Status: Compliant Part II, Paragraph 4 requires the Permittee shall develop and implement a routine pump station inspection and maintenance program, which shall include, but not be limited to, the following maintenance activities: a. Cleaning and removing debris from the pump station structure, outside perimeter, and wet well; b. Inspecting and exercising all valves; c. Inspecting and lubricating pumps and other mechanical equipment according to the manufacturer's recommendations; and d. Verifying the proper operation of the alarms, telemetry system and auxiliary equipment. Observations: Physical logs are kept at each pump station. This information is kept in digital logs as well. Compliance Status: Compliant Part II, Paragraph 5 requires for each pump station without pump reliability (i.e. simplex pump stations serving more than a single building or pump stations not capable of pumping at a rate of 2.5 times the average daily flow rate with the largest pump out of service), at least one fully operational spare pump capable of pumping peak flow shall be maintained on hand. Observations: No simplex pumps in system. Compliance Status: NA Part II, Paragraph 6 requires the Permittee shall maintain on hand at least two percent of the number of pumps installed, but no less than two pumps, that discharge to a pressure sewer and serve a single building, unless the Permittee has the ability to purchase and install a replacement pump within 24 hours of first knowledge of the simplex pump failure or within the storage capacity provided in any sewer line extension permit. Observations: No simplex pumps in system. Compliance Status: NA Part II, Paragraph 7 requires that rights -of -way and/or easements shall be properly maintained to allow accessibility to the wastewater collection system. Observations: Right of ways and easements are properly maintained and documented. Compliance Status: Compliant Part II, Paragraph 8 requires the Permittee assess cleaning needs, and develop and implement a program for appropriately cleaning at least 10 percent of the wastewater collection system each year. Observations: The collection system is approximately 65 miles/343,500 feet (1.27 miles force main, the rest gravity). 30,000 feet were cleaned 2021; 14,000 cleaned to date in 2022. Line cleaning and tested is documented. Compliance Status: Compliant Part II, Paragraph 9 requires adequate measures shall be taken to contain and properly dispose of materials associated with SSOs. The Permittee shall maintain a Response Action Plan that addresses the following minimum items: a. Contact phone numbers for 24-hour response, including weekends and holidays; b. Response time; c. Equipment list and spare parts inventory; Page 3 of 10 Permit: WQCS00051 Owner - Facility:Town of Wilkesboro Inspection Date: 10/11 /2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine d. Access to cleaning equipment; e. Access to construction crews, contractors and/or engineers; f. Source(s) of emergency funds; g. Site sanitation and clean up materials; and h. Post-SSO assessment. Observations: The Response Action Plan is limited. Most of the required information can be found in the pump contingency plans. Advised Mr. Williams to merge information from contingency plans to RAP and to include emergency funds, WSRO and EM phone numbers. Information is proper but found in different documentation (ie: pump contingency plan). Compliance Status: Neither Part II, Paragraph 10 requires the Permittee, or their authorized representative, shall conduct an on -site evaluation for all SSOs as soon as possible, but no more than two hours after first knowledge of the SSO. Observations: All documentation is comprehensive. Response times were satisfactory. No issues found during inspection. Compliance Status: Compliant Part II, Paragraph 11 requires the Permittee, in the event of an SSO or blockage within the wastewater collection system, to restore the system operation, remove visible solids and paper, sanitize any ground area and restore the surroundings. Observations: No issues found in documentation concerning SSO clean up and restoration. Compliance Status: Compliant SECTION V, PERMIT PART III: RECORDS Part III, Paragraph 1 requires that records be maintained to document compliance with Conditions I (4), 11(2) - 11(4), 11(7) - 11(8) IV(3) and V(1) -V(4). Records shall be kept on file for a minimum of three years. Observations: All documentation is kept on file in appropriate time frame. As stated earlier, all documentation (starting —2019) is digital with back up in place. Prior to digital, logbooks are filed. Compliance Status: Compliant Part III, Paragraph 2 requires the Permittee shall maintain adequate records pertaining to SSOs, and complaints for a minimum of three years. These records shall include, but are not limited to, the following information: a. Date of SSO or complaint; b. Volume of wastewater released as a result of the SSO and/or nature of complaint; c. Location of the SSO and/or complaint; d. Estimated duration of the SSO; e. Individual from the Division who was informed about the SSO and/or complaint, when applicable; f. Final destination of the SSO; g. Corrective actions; h. Known environmental/human health impacts resulting from the SSO; and i. How the SSO was discovered. Observations: No issues found during inspection. Documentation is in order. Compliance Status: Compliant Part III, Paragraph 3 requires the Permittee shall maintain an up-to-date, accurate, comprehensive map of its wastewater collection system. The comprehensive map shall include, but is not limited to: pipe size, pipe material, pipe location, flow direction, approximate pipe age, number of active service taps, and each pump station identification, location and capacity. Observations: Map is ArcGIS system that is very detailed and updated quarterly. Compliance Status: Compliant Part III, Paragraph 4 requires the Permittee shall maintain records of all of the modifications and extensions to the collection system permitted herein. The Permittee shall maintain a copy of the construction record drawings and specifications for modifications/extensions to the wastewater collection system for the life of the modification/extension. Information concerning the extension shall be incorporated into the map of the wastewater collection system within one year of the completion of construction. The system description contained within this permit shall be updated to include this modification/extension information upon permit renewal. Observations: No issues found during inspection. GIS is updated quarterly. Compliance Status: Compliant SECTION VI, PERMIT PART IV: MONITORING AND REPORTING REQUIREMENTS Part IV, Paragraph 1 requires any monitoring (including, but not necessarily limited to, wastewater flow, groundwater, surface water, soil or plant tissue analyses) deemed necessary by the Division to ensure surface water and groundwater protection will be established, and an acceptable sampling and reporting schedule shall be followed. Observations: No issues found during inspection. Page 4 of 10 Permit: WQCS00051 Owner - Facility:Town of Wilkesboro Inspection Date: 10/11 /2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Compliance Status: Compliant Part IV, Paragraph 2 requires the Permittee shall verbally report to a Division of Water Resources staff member at the Winston-Salem Regional Office as soon as possible but in no case more than 24 hours following the occurrence or first knowledge of the occurrence of either of the following: a. Any SSO and/or spill over 1,000 gallons; or b. Any SSO and/or spill, regardless of volume, that reaches surface water. Observations: Protocol was followed and all documentation of SSOs filed. Compliance Status: Compliant Part IV, Paragraph 3 requires the Permittee shall meet the annual reporting and notification requirements provided in North Carolina General Statute §143-215.1 C. Observations: Annual reports are done every year and posted to the public; however the reports have not been submitted to DEQ. The last annual performance report submitted to DEQ was Jan 2019 (for 2018 operating year). Inspector sent information via email to Mr. Williams concerning annual reporting (ie: due dates, address, etc). Compliance Status: Non -Compliant SECTION VII, PERMIT PART V: INSPECTIONS Part V, Paragraph 1 requires the Permittee shall inspect the wastewater collection system regularly to reduce the risk of malfunctions and deterioration, operator errors, and other issues that may cause or lead to the release of wastes to the environment, threaten human health or create nuisance conditions. The Permittee shall keep an inspection log or summary including, at a minimum, the date and time of inspection, observations made, and any maintenance, repairs, or corrective actions taken by the Permittee. Observations: Review of logs indicate ORC and BORC are actively inspecting the entire collection system and are proactive in confronting any issues that could arise. Compliance Status: Compliant Part V, Paragraph 2 requires that pump statio Page 5 of 10 Permit: WQCS00051 Owner - Facility:Town of Wilkesboro Inspection Date: 10/11 /2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine General 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? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ Daily • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ Comment: Ethan Williams (ORC) Jason Hart (BORC). Permit expires 8/31/2024 (begin renewal process no later than February 2024). Small group of personnel work with collection system, therefore all work is primarily done together and logbooks are reviewed daily. They have move to a digital recordkeepinq system. All logs are google docs/spreadsheets. Sewer and FOG Ordinances 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.) FOG education can be found on Town's website and Facebook page. Comment: Collection system is responsible for FOG inspection and enforcement (PT Coordinator only handles the SIU). Documentation was in order and issues are enforced. Capital Improvement Plan 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? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ As needed. • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Page 6 of 10 Permit: WQCS00051 Owner - Facility:Town of Wilkesboro Inspection Date: 10/11 /2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Does CIP include forecasted future needs? • ❑ ❑ ❑ Comment: ORC keeps detailed CIP for collection system. The Town keeps overall CIP (date adopted, budget allocations, etc). ORC did not have a copy of Town's CIP, however, ORC has detailed account of all projects, improvements and estimates of costs concerning CS. It does have a goal statement and an itemized account for projects extending to 5 years. Map 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? Comment: Map is ArcGIS system that is very detailed and updated quarterly. Reporting Requirements # 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? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Town's website Comment: Annual reports are done every year and posted to the public, however the reports have not been submitted to DEQ. The last annual performance report submitted to DEQ was Jan 2019 (for 2018 operating year). 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? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Page 7 of 10 Permit: WQCS00051 Owner - Facility:Town of Wilkesboro Inspection Date: 10/11 /2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Are new lines being added to the HPL list when found or created? Comment: See inspection summary for details. Spill Response 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 Does the Permittee appear to respond within 2 hours of first knowledge of a spill? Comment: See inspection summary. Spills 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: See inspection summary. Lines/Right-of-Ways/Aerial Lines Please list the Lines/Right of Ways/Aerial Lines Inspected: Aerial Creek Crossing @ Fish Dam 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? Comment: See inspection summary. Pump Stations • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ • ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE Page 8 of 10 Permit: WQCS00051 Owner - Facility:Town of Wilkesboro Inspection Date: 10/11 /2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Please list the Pump Stations Inspected: 1. Fish Dam 2. Millers Creek # 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 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? All five pump stations have permanment generators. The generators are programmed to run a self -test weekly. Generators are inspected every 6 months. # 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? 5 0 0 0 5 0 • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ • • ❑ ❑ ❑ ❑ ❑ • ❑ ❑ • ❑ ❑ ❑ ❑ • ❑ • ❑ ❑ ❑ Page 9 of 10 Permit: WQCS00051 Owner - Facility:Town of Wilkesboro Inspection Date: 10/11 /2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Inspecting and exercising all valves? Inspecting and lubricating pumps and other equipment? Inspecting alarms, telemetry and auxiliary equipment? Comment: See inspection summary for details. • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Page 10 of 10