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HomeMy WebLinkAboutWQCS00329_2023 Compliance Inspection_20230925 September 25th, 2023 Randy Lansing Town of Nashville – Town Manager PO Drawer 987 Nashville, NC 27856 Subject: Compliance Evaluation Inspection Nashville Collection System WWCS Permit WQCS00329 Nash County Dear Mr. Lansing: On September 14th, 2023, Kevin Fowler from the Raleigh Regional Office conducted an inspection of the Town of Nashville wastewater collection system to evaluate compliance with the operation and maintenance of the subject wastewater collection system permit. The cooperation and assistance of Lee Brown (ORC) and Taylor Joiner (Back up ORC) during the inspection were greatl y appreciated. Our records indicate the wastewater collection system consists of approximately 32.7 miles of gravity sewer, approximately 5.1 miles of force main, 13 duplex pump stations. During the time of the inspection, updated system numbers were given by the ORC which indicated the system containing 40.3 miles of gravity sewer, 4.8 miles of force main, and 12 duplex pump stations. The subject permit is effective from February 18, 2019 until January 31, 2027 and is subject to specific conditions and limitations. The items below show what conditions were noted during the inspection: 1. Reported Sanitary Sewer Overflows. During the past year from the inspection date, there were 2 SSOs from the town’s collection system with a combined estimated volume of 6,210 gallons, of which 2,250 gallons reached surface water. No fish kills were reported because of the SSO events. 2. Fats, Oils and Grease Program. The permittee has not developed and implemented a full educational fats, oils and grease program that includes at least bi-annual distribution of educational material targeted at both residential and non-residential users. Distribution of educational material has been implemented and included distributed information on DocuSign Envelope ID: F100B620-6473-49C6-9644-1F7334DC4D7D Permittee, WQCS00329 9/20/2023 Page 2 of 4 the town’s website as well as a booth set up at a town festival. The permittee has not developed and implemented an enforceable FOG program for non-residential users. These requirements are covered in 15A NCAC 02T .0403 3. Capital Improvement Plan. The permittee has adopted and implements a Capital Improvement Plan to designate funding for reinvestment into the wastewater collection system infrastructure. The CIP covers includes a goal statement, description of the project area, description of the existing facilities, known deficiencies and forecasted future needs. The approximate capital improvement budget for the collection system is $2,400,000. 4. Contingency Plan for Pump Failure. The permittee maintains a contingency plan for pump failure at each lift station. 5. Pump Stations Inspected. The following duplex pump stations were inspected: Wheeless Drive, Cottonwood, Regency Drive, Woodfield, Surry Drive, and South Creek. The inspector’s observations noted in the next 5 items below refer to the 6 pump stations inspected. 6. Pump Station Signage. Each pump station except for South Creek station has signage clearly and conspicuously posted that identifies the pump station, provides an emergency 24-hour contact telephone number(s), and provides instructions for notification if the visual alarm illuminates and/or the audible alarm sounds, or if an emergency is apparent. South Creek Station’s sign did not include instructions for notification if visual alarm illuminates and/or the audible alarm sounds. This requirement is covered in 15A NCAC 02T .0305(h) (2). 7. Pump Station Restricted Access. The pump station sites, equipment and components were observed to have restricted access. 8. Pump Stations Automatic Polling Feature. The pump stations are equipped with Telemetry that allow the permittee routine contact with the pump station from a central location to check the operational status of the communication system. During the inspection, the Telemetry acknowledged the alarms when the high-water float was activated. 9. Pump Station High Water Alarms. The pump stations are equipped with audible and visual high-water alarms. During the inspection, the audible alarms at Regency Drive Station, and Cottonwood Station were not operational. This requirement is covered in 15A NCAC 02T .0305(h) (1). 10. Pump Station Inspection Program. The permittee has developed and implements a routine inspection of each pump station that includes the following maintenance activities: cleaning and removing debris from the pump station area and wet well; inspecting all valves; inspecting pumps and other mechanical equipment; and verifying the proper operation of the alarms, telemetry system and auxiliary equipment. The inspector reviewed the inspection logs of the pump stations visited and observed adequate entries of the date and time of the operator’s inspection, observations made, and any maintenance, repairs, or corrective actions taken. DocuSign Envelope ID: F100B620-6473-49C6-9644-1F7334DC4D7D Permittee, WQCS00329 9/20/2023 Page 3 of 4 11. Designated Operators. North Carolina Administrative Code Title 15A Subchapter 8G Section .0201 requires an owner of a classified water pollution control system to designate one ORC and one or more Backup ORCs certified by the Water Pollution Control System (WPCS) Operators Certification Commission (Commission) of the appropriate type and grade for the treatment system. The rule also requires the owner to submit a signed completed “Water Pollution Control System Operator Designation Form” to the Commission countersigned by the designated certified operators within 120 calendar days following a vacancy in the position of ORC or Backup ORC. In the Division’s data system, the designated ORC for the Town of Nashville is listed as Lee Travis Brown, however, the Division’s data system does not reflect a designated Backup ORC for the Town of Hillsborough. Please complete the attached WPCS Operator Designation Form and submit it to the Division. 12. Cleaning Sewer Lines. The permittee has developed and implements a program for cleaning the sewer lines. As required by Section II.8 of the subject permit, at least 10% of the wastewater collection system should be cleaned each year. Preventative cleaning is not required for sewer lines less than five years old, unless an inspection reveals the need for cleaning. As the operator indicated during the inspection, 23,165 miles of sewer line were cleaned during 2022, and 26,078 miles of sewer line were cleaned during 2021. Records provided indicated more than 10% of the system being cleaned annually. 13. Spill Response Action Plan. The permittee has developed and maintains a Spill Response Action Plan that includes 24-hour contact numbers, response time, equipment list and spare parts inventory, access to cleaning equipment, access to construction crews, sources of emergency funds, site sanitation and cleanup materials, and post-SSO assessment. 14. SSO Records. The permittee has maintained adequate records pertaining to SSOs and sewer complaints for the three-year period ending 9/14/2023 (day of inspection). The last reportable SSO occurred on 5/1/2023. 15. Comprehensive Sewer Map. The permittee maintains an up-to-date comprehensive map of its sewer collection system. The map includes pipe size, pipe material, pipe location, number of active service taps, and each pump station identification, location and capacity. The map did not include flow direction, and approximate pipe age. These parameters are required as covered in 15A NCAC 02T .0108 (b). 16. Inspection of High Priority Lines. As required by Section V-4 of the subject permit, an inspection of all high priority sewer lines shall be performed at least once every six- months. Inspection logs were kept for inspections of high priority lines indicating that inspections were performed at least once every six months. During the inspection, the following high priority lines were inspected: Calvin’s Branch Outfall, Evans Drive, and Universal Leaf. Please provide this office with a written response to items 2, 6, 9, 11 above no later than October 31st, 2023. The written response should include the actions the Town will take to resolve the noted issues. DocuSign Envelope ID: F100B620-6473-49C6-9644-1F7334DC4D7D Permittee, WQCS00329 9/20/2023 Page 4 of 4 If you have questions or comments about this inspection or the requirements to take corrective action if applicable, please contact Kevin Fowler at 919-791-4261 Sincerely, Vanessa Manuel, Assistant Regional Supervisor Water Quality Regional Operations Section Raleigh Regional Office Division of Water Resources, NCDEQ Attachment(s): Collection System Inspection Report Cc: Laserfiche Lee Travis Brown - ORC DocuSign Envelope ID: F100B620-6473-49C6-9644-1F7334DC4D7D Compliance Inspection Report Permit:WQCS00329 Effective:02/15/19 Expiration:01/31/27 Owner :Town of Nashville SOC: Contact Person: Region: County: Directions to Facility: Nash Raleigh Henry Raper Effective:Expiration:Facility:Nashville Collection System Title:Phone:252-459-4511Town Manager (2017) Secondary ORC(s): 252-459-4511Phone:1002019Certification:Lee Travis BrownPrimary 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: 09/14/2023 09:00AM 12:30PM Kevin Fowler 919-791-4200 Cheng Zhang Facility Status: Permit Inspection Type: Reason for Inspection:Inspection Type: Not CompliantCompliant Routine Collection system management and operation Complaint Question Areas: Miscellaneous Questions General Sewer & FOG Ordinances Capital Improvement Plan Map Reporting Requirements Inspections Spill Response Plan Spills Lines Manholes Pump Stations (See attachment summary) Page 1 of 7 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCS00329 09/14/2023 Complaint Town of Nashville Routine Inspection Summary: Page 2 of 7 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCS00329 09/14/2023 Complaint Town of Nashville 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?Bi-Weekly # 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: 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?Not currently enforce 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.) Website, Blooming Festival FOG program is being taken over by a new position and will be setting up inspections in the the future. 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? Comment: Page 3 of 7 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCS00329 09/14/2023 Complaint Town of Nashville Routine 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? Site is routinely updated by Matt Gay (engineer)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?Website Annual Wastewater Performance Report not being filed with the division. No mailing of annual report being done. Annual report is however availalbe on the town 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? No official plan to observe whole system annually; however, through combined actions of a tasks it is believed by the ORC that the system is being visually inspected annualy. Comment: Spill Response Action Plan Yes No NA NE Is a Spill Response Action Plan available? Page 4 of 7 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCS00329 09/14/2023 Complaint Town of Nashville 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: 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? Manhole near South Creek pump station has had multiple overflow events. The line was relined to help combat I&I. Potential future plans to increase size of forcemain pipe. Comment: Lines/Right-of-Ways/Aerial Lines Yes No NA NE Please list the Lines/Right of Ways/Aerial Lines Inspected: Calvin's Branch Outfall, Evans Drive, Universal Leaf 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 Yes No NA NE Please list the Manholes Inspected: South Creek (Beside Creek), South Creek (Road), Upstream Regency Station Are manholes accessible? # Are manhole covers/vents above grade? Are manholes free of visible signs of overflow? Are manholes free of sinkholes and depressions? Page 5 of 7 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCS00329 09/14/2023 Complaint Town of Nashville Routine 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: Pump Stations Yes No NA NE Please list the Pump Stations Inspected: Wheeless Drive., Regency Drive, Cottonwood, Woodfield, Surry Drive, South Creek # Number of duplex or larger pump stations in system 12 # 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?0 # A simple one-way telemetry/communication system (auto-dialer) installed?12 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? Page 6 of 7 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCS00329 09/14/2023 Complaint Town of Nashville Routine 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: 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? Alarm at Regency and Cottonwood Stations did not work. No Simplex pumps present in system.Comment: Page 7 of 7 North Carolina Water Treatment Facility Operators Certification Board ORC DESIGNATION FORM System Name: ____________________________________________________________________ PWS ID: ___________________ County: ________________ Name: ___________________________________________________ Address: ________________________________________________ _________________________________________________________ Tele: Work ( ) ____ _______ Home ( )_________________ Designated ORC Signature _________________________________ “I certify that I agree to my designation as the Operator in Responsible Charge for the facility noted. I understand and will abide by the rules and regulations pertaining to the responsibilities of the ORC as set forth in 15A NCAC 18D .0701 and failing to do so can result in Disciplinary Actions by the North Carolina Water Treatment Facility Operators Certification Board”. Name: __________________________________________________ Address: ________________________________________________ _________________________________________________________ Tele: Work ( ) ____________ Home ( )__________________ Designated ORC Signature __________________________________ “I certify that I agree to my designation as the Operator in Responsible Charge for the facility noted. I understand and will abide by the rules and regulations pertaining to the responsibilities of the ORC as set forth in 15A NCAC 18D .0701 and failing to do so can result in Disciplinary Actions by the North Carolina Water Treatment Facility Operators Certification Board”. If water is treated, a treatment ORC is required. Distribution ORC is exempt if system has a treatment ORC and serves 100 or fewer connections. Treatment ORC Distribution ORC Operator's Certification Level: Operator's Certification Level: Certification # Certification # A B C D Well Surface A B C D Distribution Name: ___________________________________________________ Address: _________________________________________________ _________________________________________________________ Tele: Work ( ) ____________ Home ( )__________________ Designated ORC Signature __________________________________ “I certify that I agree to my designation as the Operator in Responsible Charge for the facility noted. I understand and will abide by the rules and regulations pertaining to the responsibilities of the ORC as set forth in 15A NCAC 18D .0701 and failing to do so can result in Disciplinary Actions by the North Carolina Water Treatment Facility Operators Certification Board”. Cross Connection ORC Certification # Owner Name: ____________________________________________ Address: _________________________________________________________ Tele: ____________________ FAX: __________________________ Owner Email: ____________________________________________ Written permission must be obtained from the Board to use the same operator as ORC for more than one type of system. The ORC must hold the proper level of certifications. If you wish an operator to be designated for more than one type of system, please attach a letter to this form and it will be submitted for the Board's review at our next quarterly Board meeting. Board meetings are held March, June, September and December. I certify this information is accurate and complete. Owner Signature__________________________________________ Title: ___________________________ Date: __________________ Date: ____________________________________________________ ***Signatures are REQUIRED by owner and ORC(s)*** 1635 Mail Service Center Raleigh, North Carolina 27699-1635 (919) 707-9040 FAX: (919) 715-2726 Revised 4/2018 Owner Information Cross Connection Control ORC is needed if the distribution system has a need for five or more testable backflow prevention assemblies as required by 15A NCAC 18C .0406(b).