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HomeMy WebLinkAboutWQ0000193_Compliance Evaluation Inspection_20230125DocuSign Envelope ID: 96ECCBDF-96DB-431 F-8649-BCF80833598E ROY COOPER Governor ELIZABETH S. RISER Secretary RICHARD E. ROGERS, JR. Director Heather Hockaday, Town Manager Town of Burnsville e-mail: hhockaday@townofburnsville.org NORTH CAROLINA Environmental Quality January 25, 2023 SUBJECT: NOTICE OF VIOLATION Tracking Number: NOV-2023-PC-0046 Permit No. WQCS00143 NOV-2023-PC-0046 Burnsville Collection System Yancey County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Burnsville Collection System on January 23, 2023. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in Collection System Permit No. WQCS00143. 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 violation(s) were noted during the inspection: Inspection Area Description of Violation General Documented excessive I&I shall be specifically addressed. Permit Condition II (2) requires the permittee to establish a plan for addressing problems in the collection system that are identified during system inspections. Permit Condition I (5) also recommends continuing long-term plan o address known deficiencies and forecasted future needs. 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. If you should have any questions, please do not hesitate to contact Timothy Heim with the Water Quality Regional Operations Section in the Asheville Regional Office at 828-296-4500. ATTACHMENTS Ec: LF, Shane Dale (ORC) Sincerely, ,-DocuSigned by: J 4-2 "-E397192DABFB4FF... Daniel Boss, Asst. Regional Supervisor Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ North Carolina Department of Environmental Dualhy I Division of Water Resources Ashevllk Regional Office 12090 U.S. Highway 70 Swannanoa, North Carolina 28776 625.296.450C DocuSign Envelope ID: 96ECCBDF-96DB-431 F-8649-BCF80833598E Compliance Inspection Report Secondary Inspector(s): Reason for Inspection: Routine Permit: WQCS00143 Effective: 09/06/18 SOC: S21003 Effective: 01/01/22 County: Yancey Region: Asheville Contact Person: Shane Dale Directions to Facility: System Classifications: CS2, Primary ORC: Michael Shane Dale Secondary ORC(s): On -Site Representative(s): Related Permits: Expiration: 08/31/26 Expiration: 03/31/25 Owner : Town of Burnsville Facility: Burnsville Collection System PO Box 97 Title: Public Works Director Certification: 999213 NC0020290 Town of Burnsville - Burnsville WWTP Inspection Date: 01/23/2023 Entry Time 10:OOAM Primary Inspector: Timothy H Heim ,-Docuslgned by: 110,1411th ii '-08281105A3CA418... Burnsville NC 287140097 Exit Time: 01:OOPM Phone: 828-682-2420 Phone: 828-682-2420 Phone: 828-296-4665 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 ▪ Manholes ▪ Sewer & FOG Ordinances ▪ Reporting Requirements ▪ Spills ▪ Pump Stations Page 1 of 7 DocuSign Envelope ID: 96ECCBDF-96DB-431 F-8649-BCF80833598E Permit: WQCS00143 Owner - Facility:Town of Burnsville Inspection Date: 01/23/2023 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Inspection Summary: Tim Heim of the Asheville Regional Office performed a Compliance Evaluation Inspection of the Burnsville Collection System on January 23, 2023 (WQCS00143). The previous Collection System inspection conducted in 2020 noted Permit Condition violations related to the system experiencing severe I&I during rain events, increasing flow to the WWTP by over 100% in some cases and potential exceedances of the NPDES flow limit, as well as SSOs. M. Shane Dale (ORC & Public Works Director) was present and assisted with the inspection. The inspection included a review of all relevant maintenance and operations records, a visit to each pump station owned and operated by the town, inspection of manholes and gravity sewers in representative areas of town, and a review of flow data a the WWTP during rain events. Since the last inspection, the Town has entered into an SOC with DEQ and initiated a number of significant projects to locate and mitigate defects contributing to I&I. Public Work staff estimate an approximate reduction of 100 kGPD during rain events thus far, and SSOs reported have dropped significantly. Significant repair and replacement work remains to be completed however and the system remains classified as non -complaint due to severe inflow and infiltration (I&). The following items shall be addressed to return the collection system to compliance: The town should continue to work to achieve the milestones in the SOC and pursue a comprehensive and aggressive infrastructure assessment and repair program with a qualified engineering firm and contractors. A general observation of the entire collection system should be performed annually and documented. Continue to clean and document at least 10% of the collection system on an annual basis, plus problems areas as needed. Maintain the Spill Response Action Plan (SRAP), Sewer Use Ordinance (SUO) and other relevant information in an easy to access location that all public works staff are made aware of. The following additional items were noted: The OMC Pump Station Project was competed as planned and is fully operational as of June 2022. The interconnect from the OMC pump station to the East Yancey (South Toe) WWTP is still in design phase. DEQ staff are working with the Burnsville Town Manager and Yancey County Manager to facilitate the town's takeover of the WWTP and associated collection system. The CIP is currently being revised and updated by McGill Associates. Town Public Works staff are now utilizing "Field Maps" software which includes a fully up to date map of water and wastewater infrastructure accessible by mobile devise in the field. Page 2 of 7 DocuSign Envelope ID: 96ECCBDF-96DB-431 F-8649-BCF80833598E Permit: WQCS00143 Owner - Facility:Town of Burnsville Inspection Date: 01/23/2023 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? Comment: The town should continue to work to achieve the milestones in the SOC and pursue a comprehensive and aggressive infrastructure assessment and repair program with a qualified engineering firm and contractors. 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.) Comment: 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? Does CIP include forecasted future needs? Comment: The CIP is currently being revised and updated by McGill Associates. Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Monthly or as needed. • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Page 3 of 7 DocuSign Envelope ID: 96ECCBDF-96DB-431 F-8649-BCF80833598E Permit: WQCS00143 Owner - Facility:Town of Burnsville Inspection Date: 01/23/2023 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine 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? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Comment: Town Public Works staff are now utilizing "Field Maps" software which includes a fully up to date map of water and wastewater infrastructure accessible by mobile devise in the field. 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? Comment: 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: Spill Response Action Plan Is a Spill Response Action Plan available? Yes No NA NE • ▪ ❑ ❑ ❑ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ Page4of7 DocuSign Envelope ID: 96ECCBDF-96DB-431 F-8649-BCF80833598E Permit: WQCS00143 Owner - Facility:Town of Burnsville Inspection Date: 01/23/2023 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine 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: Update contact information as appropriate. 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: Lines/Right-of-Ways/Aerial Lines Please list the Lines/Right of Ways/Aerial Lines Inspected: 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: Manholes Please list the Manholes Inspected: Representative MHs in vicinty of downtown area and points west. 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 • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Page5of7 DocuSign Envelope ID: 96ECCBDF-96DB-431 F-8649-BCF80833598E Permit: WQCS00143 Owner - Facility:Town of Burnsville Inspection Date: 01/23/2023 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: OMC Pump Station, Bakers Creek Pump Station, Mayland Pump Station. # 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? • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE 3 0 0 0 3 0 • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ▪ • • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Page6of7 DocuSign Envelope ID: 96ECCBDF-96DB-431 F-8649-BCF80833598E Permit: WQCS00143 Owner - Facility:Town of Burnsville Inspection Date: 01/23/2023 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 7 of 7