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HomeMy WebLinkAboutWQCS00349_Gibsonville_Collection_System_CEI_Letter_20241029ROY COOPER Governor MARY PENNY KELLEY Secretary RICHARD E. ROGERS, JR. Director NORTH CAROLINA Environmental Quality October 29, 2024 Town of Gibsonville Attn: R. Benjamin Baxley, Town Manager 129 West Main Street Gibsonville, NC 27249 SUBJECT: Compliance Evaluation Inspection Town of Gibsonville Wastewater Collection System Permit No. WQCS00349 Alamance County Dear Mr. Baxley: On September 19, 2024, Division of Water Resources staff Ron Boone, Michael Gearren, and Brooke Stevens conducted a routine compliance evaluation inspection of the Gibsonville wastewater collection system, permit number WQCS00349. Operator in Responsible Charge (ORC), Rob Elliott, was 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 noted during the inspection The only item of concern noted during the inspection had to do with the capital improvement plan (CIP). We did not see a goal statement for the CIP and there was not a complete overall document labeled as the CIP that included all the required components in it. Despite this, Mr. Boone believes that the town does, in fact have all the required components, although it might not be kept in a single binder labeled as CIP. Overall, the inspection reflected compliance with the permit. Mr. Boone noted no other deficiencies, items of concern, or violations. You can find inspection details in the attached water compliance inspection report. Ho��� D \E� Q�/�� nWft d.1 Emtronmm n..'m North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1 450 West Hanes Mill Road, Suite 3001 Winston-Salem, North Carolina 27105 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. Attachments: Water Compliance Inspection Report Sincerely, EDocuSigned by: L-oti T. 15m lu- 145B49E225C94EA... Lon T. Snider, Regional Supervisor Water Quality Regional Operations Section Winston-Salem Regional Office Division of Water Resources, NCDEQ hFORiH � CAROLINAD E Q� gape qm of E Im...m I qualV\ 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 336.776.9800 Compliance Inspection Report Permit: WQCS00349 Effective: 04/01/17 Expiration: 03/31/25 Owner: Town of Gibsonville SOC: Effective: Expiration: Facility: Gibsonville Collection System County: Alamance Region: Winston-Salem Contact Person: James R Elliott Title: Public Works Director Phone: 336-449-7188 Directions to Facility: System Classifications: CS2, Primary ORC: James Robert Elliott Secondary ORC(s): On -Site Representative(s): Certification: 26232 Phone:336-449-7188 Related Permits: NC0023876 City of Burlington - Southside WWTP NC0023868 City of Burlington - Eastside WWTP Inspection Date: 09/19/2024 Entry Time 10:OOAM Exit Time: 02:OOPM Primary Inspector: Ron Boone Phone: 336-776-9690 Secondary Inspector(s): Brooke Stevens Michael Gearren 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: WQCS00349 Owner - Facility: Town of Gibsonville Inspection Date: 09/19/2024 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Inspection Summary: On September 19, 2024, Division of Water Resources staff Ron Boone, Michael Gearrin, and Brooke Stevens conducted a routine compliance evaluation inspection of the Gibsonville wastewater collection system, permit number WQCS00349. Operator in responsible charge Rob Elliott was 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 noted during the inspection. Mr. Elliott had a copy of the current permit on hand. Waste water collected by the Gibsonville wastewater collection system is treated in Burlington's East side wastewater treatment facility under NPDES permit NCO023868 or South side wastewater treatment facility under NPDES permit NC0023876. The town's sewer use ordinance meets permit requirements. It sufficiently addresses all areas required by the permit. They have completely adopted the City of Burlington's ordinance. The town of Gibsonville has a good fat oils and grease program. On the enforcement side, inspections of grease producing facilities are conducted once per year. There are 12 grease traps identified in town. There is no pumping frequency standard. Grease producers pump as needed to properly maintain their individual units and send copies of pumping records to the town. On the education side, the town sends a newsletter to all town residents every month and it includes grease educational material in at least two of those newsletters. As for the capital improvement plan (CIP), most of the required items were evaluated during the inspection. Although these items are not kept in one single binder labeled as the CIP, it is believed that the town is meeting the intent of this requirement. 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 at each pump station. The town has three pump stations. All three pump stations are duplex stations. The Broad Street station has a permanent onsite generator while the other two use mobile units with quick connect hook ups. The one permanent onsite generator is exercised regularly and all generator maintenance and repair is conducted in house or by contractors depending on exactly what is needed. Generator fuel levels are monitored, and the town does have an emergency fuel source. All pump stations have both audible and visible alarms as well as a cellular based telemetry system that calls Mr. Elliott first and then several of the other backup operators in series if no one can be contacted. All pump stations are visited every Monday, Wednesday and Friday. The town also conducts a detailed inspection of each pump station twice per month. As for back up pumps, one complete pump assembly is kept on hand for each pump station. Each pump station is clearly and conspicuously posted with a sign that lists the pump station identifier, its location and an emergency contact telephone number. The signs also include instructions that the emergency contact should be called if the visual alarm illuminates or the audible alarm sounds or if an emergency is otherwise apparent. All three pump stations are sufficiently secured with either a fence and locked gate or locked access points. Mr. Elliott and his backups review all inspection, maintenance, operational, and complaint logs as they are generated. They also sign or initial these forms when they review them. Page 2 of 8 Permit: WQCS00349 Owner - Facility: Town of Gibsonville Inspection Date: 09/19/2024 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine All right-of-ways evaluated during the inspection were found to be in good condition. The town maintains the right-of-ways as needed, but try to mow them at least twice per year. The town currently has about 54 miles of gravity sewer, and therefore aims to clean about 5-1/2 miles of pipe per year. The town has a detailed log that tallies the amount of line cleaned as it is accomplished. The town is well on its way to meeting its 5-1/2 mile annual goal for this year. The town keeps copies of all SSO's on file, along with all other related documentation, such as press releases and public notices. The spill response action plan was reviewed and found to meet all requirements of the permit. There are no concerns or deficiencies noted with regard to the town's handling of SSOs. The town does not experience any recurring SSOs. 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 and were found to be complete. The records include all items required by the permit. 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 to the Gibsonville collection system, pipe size, pipe material, pipe location, flow direction, approximate pipe age, number of active service steps, pump station locations, pump station identifiers, and pump station capacities. Specifications and plans of projects which add to the town's collection system are kept forever. These new extensions are added to the system map within one year of construction completion. The town has copies of all its annual reports on file. The town also posts these annual reports to its webpage so all customers have access to them. The town does conduct an annual general observation of the entire collection system, and Mr. Elliott writes and signs an annual statement certifying this. All high priority lines are inspected once every 180-day period of time. All records of high priority line inspections are kept on file as needed. We believe that the town has indeed identified all high priority lines within its operational area The Broad Street pump station was inspected. It has an on -site permanent generator that is exercised once per month. The generator was inspected and tested during the inspection and operated without error. The Broad Street pump station has two pumps. All alarms and level detection systems were found to be in good condition and operated properly. The pump station contingency plan was properly posted. The pump station identifier sign was properly posted, and all access points were sufficiently secured with padlocks. This pump station also has a perimeter fence with locked gate. This pump station has a dry well/wet well set up. The Scott Street pump station was also inspected and found to be in good condition. It uses a mobile generator. The audible and visible alarms and level detection systems all appeared to be functioning correctly. This pump station is fenced in and has a locked gate. The pump station identifier sign was properly posted and contained all the required information. The condition of the wet well seemed good and there was not a lot of grease and solids accumulation inside the wet well. Page 3 of 8 Permit: WQCS00349 Owner - Facility: Town of Gibsonville Inspection Date: 09/19/2024 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? As required 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.) Website Comment: Section 29 of the town's ordinances states, " Sec. 29-3. - Incorporation of water supply and wastewater treatment agreements with City of Burlington. The water supply agreement and the wastewater treatment agreement between the town and the City of Burlington both dated March 21, 2005, together with any amendments thereto, are hereby incorporated by reference and made a part of this chapter as if fully set forth herein. Together, the agreements obligate the town to full compliance with: pertinent provisions of the City of Burlington water treatment and supply ordinances and the sewer use ordinances, including without limitation all rules and regulations of the City of Burlington whether now in existence or hereafter enacted, relating to the operation and maintenance of its water supply and treatment facilities, its sewer collection and wastewater treatment facilities, and with all applicable state and federal regulations as presently existing and may from time to time be subsequently amended. " 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? ❑ ❑ ❑ Page 4 of 8 Permit: WQCS00349 Owner - Facility: Town of Gibsonville Inspection Date: 09/19/2024 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Does CIP cover three to five year period of earmarked improvements? 0 ❑ ❑ ❑ Does CIP include description of project area? 0 ❑ ❑ ❑ Does CIP include description of existing facilities? 0 ❑ ❑ ❑ Does CIP include known deficiencies? 0 ❑ ❑ ❑ Does CIP include forecasted future needs? 0 ❑ ❑ ❑ Comment: The CIP components evaluated during the inspection were not all together in a binder labeled CIP, although it is believed that all required components are readily available. The goal statement is the only component not seen or evaluated during the inspection was the goal statement. Map Yes No NA NE Is there a overall sewer system map? 0 ❑ ❑ ❑ 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? 0 ❑ ❑ ❑ 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? 0 ❑ ❑ ❑ # 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? ❑ ❑ ❑ Is there a system or plan in place to observe the entire system annually? ❑ ❑ ❑ Page 5 of 8 Permit: WQCS00349 Owner - Facility: Town of Gibsonville Inspection Date: 09/19/2024 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Is the annual inspection documented? 0 ❑ ❑ ❑ # Does the system have any high -priority lines/locations? 0 ❑ ❑ ❑ Are inspections of HPL documented at least every 6 months? 0 ❑ ❑ ❑ Are new lines being added to the HPL list when found or created? 0 ❑ ❑ ❑ Comment: None 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? 0 ❑ ❑ ❑ Comment: None Spllls Yes No NA NE Is system free of known points of bypass? 0 ❑ ❑ ❑ 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: 1. Aerial NW corner of 70 and Springwood Church Road —100 feet of 18" ductile iron in very good condition; 2. The right-of-way at the above aerial is in good condition Are right-of-ways/easements maintained for full width for access by staff/equipment? 0 ❑ ❑ ❑ 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? ❑ ❑ ❑ Page 6 of 8 Permit: WQCS00349 Owner - Facility: Town of Gibsonville Inspection Date: 09/19/2024 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Comment: None Manholes Yes No NA NE Please list the Manholes Inspected: Second manhole downstream of aerial at NW corner of Hwy 70 and Springwood Church Road is in very good condition 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? ❑ ❑ ❑ # 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: None Pump Stations Yes No NA NE Please list the Pump Stations Inspected: Broad Street and Scott Drive # Number of duplex or larger pump stations in system 3 # 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? 0 # A simple one-way telemetry/communication system (auto -dialer) installed? 3 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? ❑ ❑ ❑ Page 7 of 8 Permit: WQCS00349 Owner - Facility: Town of Gibsonville Inspection Date: 09/19/2024 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Is a 24-hour notification sign posted ? 0 ❑ ❑ ❑ Does the sign include: Owner Name? 0 ❑ ❑ ❑ Pump station identifier? 0 ❑ ❑ ❑ # Address? 0 ❑ ❑ ❑ Instructions for notification? 0 ❑ ❑ ❑ 24-hour emergency contact numbers? 0 ❑ ❑ ❑ Are audio and visual alarms present? 0 ❑ ❑ ❑ Are audio and visual alarms operable? 0 ❑ ❑ ❑ # Is there a backup generator or bypass pump connected? 0 ❑ ❑ ❑ If tested during inspection, did it function properly? 0 ❑ ❑ ❑ Is the back-up system tested at least bi-annually under normal operating conditions? 0 ❑ ❑ ❑ # Does it have a dedicated connection for a portable generator? 0 ❑ ❑ ❑ # Is the owner relying on portable units in the event of a power outage? 0 ❑ ❑ ❑ # If Yes, is there a distribution plan? 0 ❑ ❑ ❑ If Yes, what resources (Units/StaffNehicles/etc) are included in Plan? # Does Permittee have the approved percentage of replacement simplex pumps? ❑ ❑ 0 ❑ Is recordkeeping of pump station inspection and maintenance program adequate? 0 ❑ ❑ ❑ Do pump station logs include at a minimum: Inside and outside cleaning and debris removal? 0 ❑ ❑ ❑ Inspecting and exercising all valves? 0 ❑ ❑ ❑ Inspecting and lubricating pumps and other equipment? 0 ❑ ❑ ❑ Inspecting alarms, telemetry and auxiliary equipment? 0 ❑ ❑ ❑ Comment: None Page 8 of 8