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HomeMy WebLinkAboutWQCS00003_Winston_Salem_Collection_System_CEI_Letter_20241029ROY COOPER Governor MARY PENNY KELLEY Secretary RICHARD E. ROGERS, JR. Director NORTH CAROLINA Environmental Quality October 29, 2024 City of Winston-Salem Attn: Courtney L. Driver, Director of Utilities P.O. Box 2511 Winston-Salem, NC 27107-9998 SUBJECT: Compliance Evaluation Inspection City of Winston-Salem Wastewater Collection System Permit No. WQCS00003 Forsyth County Dear Ms. Driver: On September 24, 2024, Division of Water Resources staff Ron Boone, Michael Gearrin, and Brooke Stevens conducted a routine compliance evaluation inspection of the Winston-Salem wastewater collection system, permit number WQCS00003. Operator in responsible charge, Antonio Martinez, as well as Kenny Atkins, Joel Freeman, Derek Stroud, and Tim Neal, were present for the inspection. A review of records was conducted, and then a field evaluation of several system components was conducted. There were no violations or deficiencies noted during the inspection. The only item of concern noted was that the audible alarm at the Lowery Street pump station was not sufficiently loud. Overall, the inspection reflected compliance with the permit. You will find the details from the inspection in the attached compliance inspection report. D E Q�� North Carolina Department of Environmental Quality I Division of Water Resources uomr+caROLINA Winston-Salem Regional Office 1 450 West Hanes Mill Road, Suite 3001 Winston-Salem, North Carolina 27105 `� /`�NMT�H� 336.776.9800 Please feel free to contact Mr. Boone by phone at 336-776-9690 or by email at ron.boone@deg.nc.gov with any questions or concerns you may have. Sincerely, DocuSiTgned by: 145B49E225C94EA... Lon T. Snider, Regional Supervisor Water Quality Regional Operations Section Winston-Salem Regional Office Division of Water Resources, NCDEQ Attachments: Compliance Inspection Report North Carolina Department of Environmental Quality 1 Division of Water Resources Winston-Salem Regional Office 1 450 West Hanes Mill Road, Suite 3001 Winston-Salem, North Carolina 27105 hFORiH CAROLINq i Dore qm m E,.,im�ma,�i u�an� /"� 336.776.9800 Compliance Inspection Report Permit: WQCS00003 Effective: 06/18/21 Expiration: 05/31/29 Owner: City of Winston-Salem SOC: Effective: Expiration: Facility: Winston-Salem Collection System County: Forsyth PO Box 2511 Region: Winston-Salem Winston Salem NC 271079998 Contact Person: William C Brewer Title: Water Treatment Superintenden Phone: 336-727-8000 Directions to Facility: System Classifications: CS4, Primary ORC: Antonio Vernis Martinez Certification: 1005510 Phone: 704-406-7732 Secondary ORC(s): On -Site Representative(s): Related Permits: NC0050342 City of Winston-Salem - Muddy Creek WWTP NC0037834 City of Winston-Salem - Archie Elledge WWTP Inspection Date: 09/24/2024 Entry Time 09:OOAM Exit Time: 02:OOPM Primary Inspector: Ron Boone Phone: 336-776-9690 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 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 8 Permit: WQCS00003 Owner - Facility: City of Winston-Salem Inspection Date: 09/24/2024 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Inspection Summary: A copy of the current permit was on hand. Wastewater collected by the Winston-Salem wastewater collection system is treated in Winston-Salem's Elledge wastewater treatment facility under NPDES permit NCO037834 or the Muddy Creek wastewater treatment facility under NPDES permit NC0050342. The city's sewer use ordinance meets permit requirements. It covers both sewer use and fats, oils, and grease. The city has an excellent fat oils and grease (FOG) program. The program is extensively published on the city's website. On the enforcement side, the city inspects indoor and outdoor grease traps and requires outdoor grease traps to be pumped monthly unless the owner has acquired a variance. There are approximately 900 establishments with grease traps in the city. Failure to comply with program rules may result in fines up to $1,000. As for the educational FOG program the city uses many different tools including the city's website, commercials, vehicle wraps, community and civic events, FOG-themed merchandise, and targeted distribution. The city's capital improvement plan (CIP) was reviewed and found to meet all permit requirements. The city's billed wastewater revenue in fiscal year 2024 totaled $68.65 million and the programmed funding through 2028 for planning/design construction, and contingency is $186 million. There are no structural overflows built into the system and all emergency pumping connections, which are only used as temporary pumping or rerouting connections are properly capped or plugged when not in use. There is an emergency contingency plan that meets all the requirements of the permit. A copy of the plan is kept centrally on the city's computer system as well as on each service truck. The city currently has 45 pump stations. Three pump stations were recently eliminated. All 45 stations are at least duplex stations, and all have SCADA systems, level -detecting MultiTrode tubes, and local audible and visible alarms. All pump stations are inspected on Mondays and Fridays. In addition, various stations are visited throughout the week to perform scheduled maintenance and repair as needed. All 45 stations have the required signage and most have perimeter fences with locked gates and access points. If there is no perimeter fence then all access points are secured. Most stations have "No Trespassing" signs as well. All except one station use submersible pumps and the city keeps a spare pump for each station on hand at all times along with several different often -used spare parts. The city has made it a priority to standardize the type of equipment in all pump stations. As for emergency equipment, 37 of the 45 stations have permanent on -site diesel generators and the city has two mobile generators as well as extensive pump and haul capabilities for the remaining 8 stations. These 8 stations are equipped with connections specific to the mobile generators so they can essentially just be "plugged in". The city also has an emergency contractual fuel source as well as an in-house stock of diesel fuel. In addition to employing a contractor for major maintenance and/or repair of the generators, the city performs monthly preventative maintenance on all generators and exercises each unit at least monthly. The city uses logs to record operator's visits to the pump stations and the activities they perform there during each visit. In addition, when an operator arrives on site at each station they press a button on the control system which records their visit to that station in the SCADA system. All inspection, maintenance, operational, and complaint logs are reviewed by Mr. Martinez and his backups as they are generated. The forms are signed or initialed to record their reviews. All right-of-ways evaluated during the inspection were found to be in good condition. The city maintains their sewer right-of-ways using both in-house and contractual resources. Page 2 of 8 Permit: WQCS00003 Owner - Facility: City of Winston-Salem Inspection Date: 09/24/2024 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine At the time of last permit issuance in June 2021 the city had about 1,782 miles of gravity sewer and 32 miles of force main. The city cleaned 480 miles of gravity sewer during fiscal year 23/24, about 270 percent of what is required. All required SSO records are on file. The city had 63 SSOs in the past 12 months, issued 24 press releases and 8 public notices. Three specific sites had two or more spills and are being monitored and evaluated for further investigation and action. All records required by the permit, including the fog education program, fog enforcement program, review of logs, testing of emergency and standby equipment, routine pump station inspection and maintenance program, right-of-way inspection and maintenance program, line cleaning program, annual reporting program, spill notification requirements, routine wastewater collection inspection, minimum pump station inspection frequency requirements, the annual general observation of the entire wastewater collection system, and high priority line inspections, are complete, current, and kept for a minimum of three years. Complaint records are also kept on file for at least three years but typically and essentially, forever. The city uses electronic systems for maintenance, repair, and complaint management. CityLink is part of the city's complaint management system. The wastewater collection system map was reviewed and found to be up-to-date, accurate and comprehensive. It does annotate points at which other systems become tributary, a well as pipe sizes, pipe materials, pipe locations, flow direction, approximate pipe ages, number of active service steps, pump station locations, pump station identifiers, and pump station capacities. All of this is electronically managed through a combination of GIS and asset inventory management systems. Specifications and plans of projects which add to the city's collection system are essentially kept forever. These new extensions are added to the system map within one year of construction completion. The city has copies of all its annual reports on file and posts them to its webpage so all customers have access to them. The city conducts an annual general observation of the entire collection system. All forms and records on which they record the operation, maintenance, and repair of all their different assets cumulatively attest to the annual observation of the entire system. The city currently has 800 high priority lines (HPL) on record. They conducted 813 HPL inspections during the fall of 2023 and 802 inspections in the spring of 2024. The HPLs are also inventoried electronically and mapped. The Lowery Street pump station, located at 3201 Lowery Street, was inspected and found to meet all requirements. This is a duplex station that handles about 800-thousand gallons per day. It employs submersible pumps and has a diesel generator that operated properly during the inspection. The only deficiency found at this station was the audible alarm was not very loud. The Idols Road pump station was also inspected. This is a triplex submersible pump station with a diesel generator that operated properly during the inspection. It too, was found to be compliant. HPLs that were inspected were: Southwest corner of West Academy Street and Old Salem Rd, near the Strollway — Aerial line over Tar Branch, 40' ductile iron 12" pipe, no problems noted. Immediately east Wade Frye Lane and north of South Stratford Road —Aerial line over Muddy Creek, 100' ductile iron 8" pipe, no problems noted. Page 3 of 8 Permit: WQCS00003 Owner - Facility: City of Winston-Salem Inspection Date: 09/24/2024 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine General Yes No NA NE Is there a properly designated primary ORC and at least one back-up of proper grade? 0 ❑ ❑ ❑ Are logs being reviewed by the system management or owner on a regular basis? 0 ❑ ❑ ❑ # What is that frequency? As generated # Are there any issues being addressed currently or any in the planning stages? 0 ❑ ❑ ❑ Is there a specific pump failure plan available for all pump stations? 0 ❑ ❑ ❑ Does plan indicate if pump parts/new pumps are in spare parts/equipment inventory? 0 ❑ ❑ ❑ Are new/significantly upgraded pump stations equipped with anti -corrosion materials? 0 ❑ ❑ ❑ Does the permittee have a copy of their permit? 0 ❑ ❑ ❑ # Is permit expiring within the next 6 months? ❑ 0 ❑ ❑ If Yes, has the Permittee applied for renewal? ❑ ❑ 0 ❑ Comment: None Sewer and FOG Ordinances Yes No NA NE Is Sewer Use Ordinance (SUO) or other Legal Authority available? 0 ❑ ❑ ❑ Does it appear that the Sewer Use Ordinance is enforced? 0 ❑ ❑ ❑ Is there a Grease Control Program that legally requires grease control devices? 0 ❑ ❑ ❑ What is the standard grease trap cleaning requirement in the FOG ordinance? Monthly Is Grease Control Program enforced via periodic inspections/records review? 0 ❑ ❑ ❑ Is action taken against violators? 0 ❑ ❑ ❑ # Have satellite systems adopted an equivalent or more stringent ordinance? 0 ❑ ❑ ❑ Is grease/sewer education program documented with req'd customer distribution? 0 ❑ ❑ ❑ # Are other types of education tools used like websites, booths, special meetings, etc? 0 ❑ ❑ ❑ If Yes, what are they? (This can reduce mailing to annual.) City's website, commercials, vehicle wraps, community and civic events, FOG-themed merchandise, and targeted distribution. Comment: None 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? 0 ❑ ❑ ❑ Does CIP include known deficiencies? 0 ❑ ❑ ❑ Does CIP include forecasted future needs? 0 ❑ ❑ ❑ Comment: None Page 4 of 8 Permit: WQCS00003 Owner - Facility: City of Winston-Salem Inspection Date: 09/24/2024 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Map Yes No NA NE Is there a overall sewer system map? 0 ❑ ❑ ❑ Does the map include: Pipe Type (GS/FM) 0 ❑ ❑ ❑ Pipe sizes 0 ❑ ❑ ❑ Pipe materials (PVC, DIP, etc) 0 ❑ ❑ ❑ Pipe location 0 ❑ ❑ ❑ Flow direction 0 ❑ ❑ ❑ Approximate pipe age 0 ❑ ❑ ❑ Pump station ID, location and capacity 0 ❑ ❑ ❑ # Force main air release valve location & type 0 ❑ ❑ ❑ # Location of satellite connections 0 ❑ ❑ ❑ Is the map being updated for changes/additions within 1 year of activation? M ❑ ❑ ❑ Comment: None 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 Comment: None Inspections Yes No NA NE Are adequate maintenance records maintained? 0 ❑ ❑ ❑ Are pump stations being inspected at the required frequency? 0 ❑ ❑ ❑ # Is at least one complete functionality test conducted weekly per pump station? 0 ❑ ❑ ❑ Is there a system or plan in place to observe the entire system annually? 0 ❑ ❑ ❑ Is the annual inspection documented? 0 ❑ ❑ ❑ # 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: None Spill Response Action Plan Yes No NA NE Is a Spill Response Action Plan available? 0 ❑ ❑ ❑ Is a Spill Response Action Plan available for all personnel? 0 ❑ ❑ ❑ Page 5 of 8 Permit: WQCS00003 Owner - Facility: City of Winston-Salem Inspection Date: 09/24/2024 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 ❑ ❑ ❑ Does the Permittee appear to respond within 2 hours of first knowledge of a spill? ❑ ❑ ❑ Comment: None $pills 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? 0 ❑ ❑ ❑ Comment: None Lines/Right-of-Ways/Aerial Lines Yes No NA NE Please list the Lines/Right of Ways/Aerial Lines Inspected: Southwest corner of West Academy Street and Old Salem Rd, near the Strollway — Aerial line over Tar Branch, 40' ductile iron 12" pipe, no problems noted. Immediately east Wade Frye Lane and north of South Stratford Road —Aerial line over Muddy Creek, 100' ductile iron 8" pipe, no problems noted. 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? 0 ❑ ❑ ❑ Comment: None Manholes Yes No NA NE Please list the Manholes Inspected: Are manholes accessible? ❑ ❑ ❑ # Are manhole covers/vents above grade? ❑ ❑ ❑ Are manholes free of visible signs of overflow? ❑ ❑ ❑ Page 6 of 8 Permit: WQCS00003 Owner - Facility: City of Winston-Salem Inspection Date: 09/24/2024 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Are manholes free of sinkholes and depressions? 0 ❑ ❑ ❑ Are manhole covers present? 0 ❑ ❑ ❑ # Are manholes properly seated? 0 ❑ ❑ ❑ # Are manholes in good condition? 0 ❑ ❑ ❑ # Are inverts in good condition? 0 ❑ ❑ ❑ Is flow unrestricted in manholes? 0 ❑ ❑ ❑ Are manholes free of excessive amounts of grease? 0 ❑ ❑ ❑ Are manholes free of excessive roots? 0 ❑ ❑ ❑ Are manholes free of excessive sand? 0 ❑ ❑ ❑ Are manhole vents screened? 0 ❑ ❑ ❑ Are vents free of submergence? 0 ❑ ❑ ❑ Are manholes free of bypass structures or pipes? 0 ❑ ❑ ❑ Comment: None Pump Stations Yes No NA NE Please list the Pump Stations Inspected: Lowery Street and Idols Road # Number of duplex or larger pump stations in system 45 # Number of vacuum stations in system 0 # Number of simplex pump stations in system 0 # Number of simplex pump stations in system serving more than one building 0 How many pump/vacuum stations have: # A two-way "auto polling" communication system (SCADA) installed? 45 # 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? ❑ ❑ ❑ Page 7 of 8 Permit: WQCS00003 Owner - Facility: City of Winston-Salem Inspection Date: 09/24/2024 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine 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: 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: None • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ ❑ ■❑❑❑ ❑❑■❑ ■❑❑❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Page 8 of 8