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HomeMy WebLinkAboutWQCSD0199_NOV-2018-PC-0040_20180212IN ROY COOPER N Governor MICHAEL S. REGAN Secretary Water Resources LINDA CULPEPPER Environmental Quality Interim Director Certified Mail # 70131710 00021865 7126 Return Receipt Requested February 12, 2018 Mr. Daryl Cain, President Cains Way Homeowner's Association PO Box 846 REECENE®'DENPWIV Walkertown, NC 27051 FEB 19 2018 Subject. Compliance Evaluation Inspection Report and Notice of Violation Water resources Deemed Permitted Wastewater Collection System # WQCSDO199 perMitting Section NOV Tracking # NOV-2018-PC-0040 Cains Way Collection System, Forsyth County Dear Mr. Cain: On February 6, 2018, Paul DiMatteo of the Division of Water Resources (Division), Winston-Salem Regional Office met with Mr. Bradley Flynt, wastewater treatment plant ORC, to conduct a Compliance Evaluation Inspection of the above referenced Wastewater Collection System. This inspection consists of (1) a review of the permit and accompanying documentation to determine compliance with permit conditions, and (2) an on-site inspection of several collection system components. Observations and conclusions for each condition evaluated are stated in the following report, and a summary is attached for your records. Requirements — As Specified by 15A NCAC 02T.0403 1. a 1 : Requires the sewer system to be effectively maintained and operated at all times to prevent discharge to land or surface waters, and to prevent any contravention of groundwater standards or surface water standards. Summary: No overflows or bypasses have been reported to date and Mr Flynt said that he wasn't aware of any spills having occurred in recent years. Compliance Status- Compliant 2. a 2 : Requires a map of the sewer system to be developed and actively maintained. Summary: A set of subdivision plans showing lot lines and sewer system locations was available on site during the inspection. Compliance Status: Compliant 3. JaM Requires an operation and maintenance plan including pump station inspection frequency, preventative maintenance schedule, spare parts inventory and overflow response to be developed and implemented. State of North Carolina I Environmental Qualdy 450 W Hanes Mill Road, Suite 300, Winston-Salem, North Carolina 27105 Phone 336-776-98001 FAX 336-776-9797 Summary: Mr. Flynt said that he believed an operation and maintenance plan was developed, but a copy was not available during the inspection. If a plan is not available, one should be developed that includes the following: a. Operation, maintenance and inspection schedules for lines, manholes, cleanouts, rights-of-way, pump stations, septic tanks, etc. b. Spare parts inventory for any parts maintained on site. If no spare parts are maintained, a source of spare parts should be identified and specified within the plan. G Overflow response plan that identifies contact information for responsible parties, spill teams, contractors and reporting agencies; spill thresholds; and response, containment, cleanup and reporting procedures. Compliance Status: Not compliant 4. a 4 : Requires pump stations that are not connected to a telemetry system to be inspected everyday (i.e. 365 days per year), and pump stations that are connected to telemetry to be inspected once per week. Summary: There are no pump stations in the collection system. Pumps are used in the wastewater treatment plant, and Mr. Flynt inspects them daily and documents the inspections. Compliance Status: Not applicable 5. IRIM Requires high-priority sewers to be inspected at least once every six months and inspections to be documented. Summary: Mr. Flynt said that there are no high priority lines in the system. Compliance Status: Not applicable 6. IqHkh Requires a general observation of the entire sewer system to be conducted at least once per year. Summary: Mr. Cain said that the last annual observation was conducted in 2016. No documentation showed that the annual observation had been conducted. Compliance Status: Not compliant 7. a 7 : Requires overflows and bypasses to be reported to the Division regional office in accordance with 15A NCAC 02B .0506(a), and public notice to be issued in accordance with G.S. 143-215.1C. Summary: Mr. Flynt said that there were no recent overflows or bypasses at this collection system. You may wish to review the requirements in 15A NCAC 02B .0506(a) and G.S. 143-215.1C to ensure you are fully familiar with all requirements. When reporting SSOs to DWR, you must call the Winston-Salem Regional Office at 336-776-9800 during normal business hours. If outside normal business hours, you must report the spill to the NC Division of Emergency Management at 1-800-858-0368. Please note that all reportable SSOs must be reported within 24 hours of the occurrence, or first knowledge, of the SSO. Please also note that voice mail or faxed messages are not considered as the initial verbal report. You must talk to and report the spill to a live person. Compliance Status: Compliant 8. IgHah Requires a Grease Control Program to be in place as follows: a. For publicly owned collection systems, the Grease Control Program shall include at least bi-annual distribution of educational materials for both commercial and residential users and the legal means to require grease interceptors for new construction and retrofit, if necessary, of grease interceptors at existing establishments. The plan shall also include legal means for inspections of the grease interceptors, enforcement for violators and the legal means to control grease entering the system from other public and private satellite sewer systems. [Note — not applicable to this permit] b. For privately owned collection systems, the Grease Control Program shall include at least bi-annual distribution of grease education materials to users of the collection system by the permittee or its representative. c. Grease education materials shall be distributed more often than required in Parts (A) and (B) of this Subparagraph if necessary to prevent grease -related sanitary sewer overflows. Summary: Mr. Cain said that grease material was handed out once per year during HOA meetings. Documentation of the distribution was not kept. Please be sure to distribute FOG materials at least twice per year and document the distributions. Compliance Status: Not compliant 9. Statement: Requires that rights-of-way and easements are maintained in the full easement width for personnel and equipment accessibility. Summary: Rights-of-way appeared well maintained during the inspection. Compliance Status: Compliant 10, (a)(10): Requires documentation to be kept for subparagraphs (a)(1) through (a)(9) of this Rule for a minimum of three years with exception of the map, which is required to be maintained for the life of the system. Summary: As discussed above, documentation was not available for the operation and maintenance plan, annual observation or educational FOG program. Compliance Status: Not compliant Site Inspections 1. Two manholes near the wastewater treatment plant were inspected. Both had a minor amount of debris in the invert. Required Response Please respond to this notice within 30 calendar days of receipt. Your response should be sent to this office at the letterhead address and should include timelines for developing programs to comply with the items noted as not compliant above. Please be advised that, in accordance with G.S. 143-215.6A, these violations are subject to civil penalty assessments not to exceed $25,000.00 per day, per violation. Your written response and the actions you take to address these violations listed herein will be considered in deciding whether or not such penalties are necessary to compel compliance. 46 If you should have any questions, please do not hesitate to contact Paul DiMatteo at (336) 776-9691 or our office at (336) 776-9800. Sincerely, Sherri V. Knight, P.E., Regional Supervisor 'Vater Quality Regional Operations Section Winston-Salem Regional Office Division of Water Resources, NCDEQ Enclosures—Inspection Report, Appendices CC: Bradley Flynt, by email WQS Winston-Salem Regional Office - Enforcement File PERCS Unit Central Files Permit: WQCSDO199 SOC: County: Forsyth Region: Winston-Salem Compliance Inspection Repoli Effective. 03/01/00 Expiration: Owner: Cainsway Homeowners Association Effective: Expiration: Facility: Cams Way MHP Collection System Contact Person: Bradley Todd Flynt Title: Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): Related Permits: Inspection Date: 02/06/2018 Entry Time: 09 45AM Primary Inspector: Paul DiMatteo Secondary Inspector(s): Certification: Phone: 336-433-7262 Phone: Exit Time: 10 30AM Phone: 336-776-9691 Reason for Inspection: Routine Inspection Type. Collection System Inspect Non Sampling Permit Inspection Type: Deemed permitted collection system management and operation Facility Status: ❑ Compliant Not Compliant Question Areas: Miscellaneous Questions Operation & Mamt Reqmts Records Inspections Manhole (See attachment summary) Page- 1 Permit WQCSDO199 Owner - Facility Camsway Homeowners Association Inspection Date 02/06/2018 Inspection Type • Collection System Inspect Non Sampling Reason for Visit Routine Inspection Summary. I met with Bradley Flynt, ORC of the wastewater treatment plant, to conduct the inspection He said he normally operates the plant and that Daryl Cain does ROW maintenance, FOG distributions and line inspections. Mr. Flynt talked to Mr Cain over the phone while I was there and Mr. Cain indicated that he did not keep records for his activities. Page 2 . 6 Permit: WQCSDO199 Owner - Facility. Cainsway Homeowners Association Inspection Date: 02/06/2018 Inspection Type . Collection System Inspect Non Sampling Reason for Visit: Routine Inspections Yes No NA NE Are maintenance records for sewer lines available? ❑ 0 1:11:1 Are records available that document pump station Inspections? ❑ ❑ M ❑ Are SCADA or telemetry equipped pump stations inspected at least once a week? ❑ ❑ 0 ❑ Are non-SCADA/telemetry equipped pump stations inspected every day? ❑ ❑ 0 ❑ Are records available that document citizen complaints? ❑ ❑ M ❑ # Do you have a system to conduct an annual observation ofIentire system? ❑ ❑ 0 ❑ # Has there been an observation of remote areas in the last year? ❑ ❑ 0 ❑ Are records available that document inspections of high-priority lines? ❑ ❑ M ❑ Has there been visual inspections of high-priority Imes in last six months? ❑ -❑ M ❑ Comment: Mr. Flynt reported that there are no high priority lines. Operation & Maintenance Requirements Yes No NA NE Are all log books available? ❑ 0 111:1 Does supervisor review all log books on a regular basis? 1:1110 ❑ Does the supervisor have plans to address documented short-term problem areas? ❑ ❑ 0 ❑ What is the schedule for reviewing inspection, maintenance, & operations logs and problem areas? Are maintenance records for equipment available? ❑ ❑ 0 ❑ Is a schedule maintained for testing emergency/standby equipment? ❑ ❑ ❑ What is the schedule for testing emergency/standby equipment? Do pump station logs include Inside and outside cleaning and debris removal? ❑ ❑ ❑ Inspecting and exercising all valves? ❑ ❑ M ❑ Inspecting and lubricating pumps and other equipment? ❑ ❑ 0 ❑ Inspecting alarms, telemetry and auxiliary equipment? ❑ ❑ 0 ❑ Is there at least one spare pump for each pump station w/o pump reliability? ❑ ❑ 0 ❑ Are maintenance records for right-of-ways available? ❑ 0 ❑ ❑ Are right-of-ways currently accessible in the event of an emergency? M ❑ ❑ ❑ Are system cleaning records available? ❑ ❑ ❑ Has at least 10% of system been cleaned annually? ❑ ❑ ❑ What areas are scheduled for cleaning in the next 12 months? Is a Spill Response Action Plan available? ❑ ❑ ❑ Does the plan include 24-hour contact numbers M ❑ ❑ ❑ Response time ❑ ❑ ❑ Equipment list and spare parts inventory ❑ ❑ ❑ Page- 3 Permit: WQCSDO199 Owner - Facility Cainsway Homeowners Association Inspection Date: 02/06/2018 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Access to cleaning equipment M ❑ ❑ ❑ Access to construction crews, contractors, and/or engineers M ❑ ❑ ❑ Source of emergency funds 0 ❑ ❑ ❑ Site sanitation and cleanup materialsM ❑ ❑ ❑ Post-overflow/spill assessment 0 ❑ ❑ ❑ Is a Spill Response Action Plan available for all personnel? 0 ❑ ❑ ❑ Is the spare parts inventory adequate? M ❑ ❑ ❑ Comment: Documentation was not kept for FOG distributions, ROW maintenance or the annual Inspection. Records Yes No NA NE Are adequate records of all SSOs, spills and complaints available? ❑ ❑ 0 ❑ Are records of SSOs that are under the reportable threshold available? 1:11:10 ❑ Do spill records indicate repeated overflows (2 or more in 12 months) at same location? ❑ ❑ N ❑ If yes, is there a corrective action plan? ❑ ❑ ❑ Is a map of the system available? ❑ ❑ ❑ Does the map include. Pipe sizes ❑ ❑ ❑ Pipe materials ❑ ❑ ❑ Pipe locaticn ❑ ❑ ❑ Flow direction M ❑ ❑ ❑ Approximate pipe age ❑ ❑ ❑ Number of service taps ❑ ❑ ❑ Pump stations and capacity ❑ ❑ M ❑ If no, what percent is complete? List any modifications and extensions that need to be added to the map Pipe size, material and age all appear to be on the subdivision plans, which is what they're using as their map. # Does the per, nittee have a copy of their permit? ❑ ❑ 0 ❑ Comment- No SSOs have been reported. Page: 4