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HomeMy WebLinkAboutWQCS00071_Compliance Evaluation Inspection_20181017 � STATE4 -ten ROY COOPER NORTH CAROLINA Governor Environmental Quality MICHAEL S.REGAN Secretary LINDA CULPEPPER Interim Director October 3, 2018 Mr. John Ward, Town Manager RECEBI/ED/®ENf DWR Town of Boone P.O. Drawer 192 OCT 201 Boone, NC 28607 teresources Permitting Section Subject: Compliance Evaluation Inspection Summary Letter Permittee: Town of Boone Facility: Town of Boone Wastewater Collection System Permit#: WQCS00071 Watauga County Dear Mr. Ward: 1. Gary Hudson of the Winston-Salem Regional Office of the NC Division of Water Resources (DWR or the Division) conducted a compliance evaluation inspection (CEI) of the Boone wastewater collection system (WWCS) September 11, 2018. The assistance and cooperation of Mr. Jack Harmon, Utilities Collection & Distribution Superintendent (and ORC) was greatly appreciated. An inspection checklist is attached for your records and inspection findings are summarized below. Site/System Review 2. The following system components were inspected: The Industrial Park pump station was inspected and found to be in exceptionally good condition. No discrepancies were noted at the pump stations and all required documentation was complete, current and readily available during the inspection. 3. As you are aware, your permit contains numerous requirements with which the Town must comply. Your compliance status with each of these requirements is summarized below: • Part I, Performance Standards , 111EQ,), NORTH CAROLJNA oeaurmenmwa1ran\ /' North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1450 Hanes Mill Road,Suite 300 I Winston-Salem,North Carolina 27103 336.776.9800 Part I, Paragraph 2: The wastewater collection system shall be effectively ■■ managed, maintained and operated at all times so that there is no SSO to land or surface waters, nor any contamination of groundwater. In the event that the wastewater collection system fails to perform satisfactorily, including the creation of nuisance conditions, the Permittee shall take immediate corrective actions, including actions that may be required by the Division of Water Resources (Division), such as the construction of additional or replacement sewer lines and/or equipment. Observations: In full consideration of all observations made during the inspection, as reflected in paragraph 2 above, as well as in the following paragraphs, the Boone wastewater collection system is hereby deemed compliant with this permit condition. Compliance Status: Compliant. Part I, Paragraph 3: The Permittee shall establish by ordinance its legal authority to require new sewers be properly constructed; to ensure proper inspection and testing of sewer mains and service laterals; to address flows from satellite systems and to take enforcement action as required by Condition I (4). Observations: The Town of Boone's sewer use ordinance (SUO)was reviewed in detail and found to meet all minimum requirements. Compliance Status: Compliant. Part I, Paragraph 4: The Permittee shall develop and implement an educational fats, oils and grease program targeted at both residential and non-residential users. The Permittee shall also develop and implement an enforceable fats, oils and grease program for non-residential users under which the Permittee can take enforcement against users who have not properly installed, operated and maintained grease traps or grease interceptors as directed or otherwise violated the terms of the local ordinance pertaining to fats, oils and grease. Observations: The Town's grease ordinance and Fats, Oils and Grease (FOG) educational program was reviewed in detail and found to meet all minimum requirements. Educational flyers are distributed twice per year as required. Compliance Status: Compliant Part I, Paragraph 5: The Permittee shall adopt and implement a Capital Improvement Plan (CIP) to designate funding for reinvestment into the wastewater collection system infrastructure. The CIP should address the short- term needs and long-term "master plan" concepts. The CIP should typically cover a three to five year period and include a goal statement, description of the project area, description of the existing facilities, known deficiencies (over a 2 reasonable period) and forecasted future needs. Cost analysis is integral to the CIP. Observations_ : The Town of Boone's CIP was reviewed in detail and found to meet most all of the minimum requirements. Compliance Status: Compliant. Part I, Paragraph 6: Existing overflow piping from manholes and pump stations, excluding piping to approved equalization structures, known or discovered after permit issuance shall be immediately removed or permanently capped. Plugged emergency pumping connections are allowable for portable pumping or rerouting without intentionally bypassing the wastewater treatment facility. Observations: No such overflows were identified during the inspection and the operators stated that they believed none exist. Compliance Status: Compliant. Part I, Paragraph 7: The Permittee shall maintain a contingency plan for pump failure at each pump station. If one of the pumps in a pump station containing multiple pumps fails, the process of repairing or replacing the pump shall be initiated immediately and the new parts or pump shall be installed as soon as possible. If the pump in a simplex pump station fails, it shall be replaced immediately. Observations: Pump station contingency plans were reviewed in detail. The Town of Boone was found to be fully compliant with this condition. Compliance Status: Compliant. Part I, Paragraph 8: Each pump station shall be clearly and conspicuously posted with a pump station identifier and an emergency contact telephone number at which an individual who can initiate or perform emergency service for the wastewater collection system 24 hours per day, seven days per week can be contacted. This emergency contact telephone number shall be coupled with instructions that the emergency contact should be called if the visual alarm illuminates, if the audible alarm sounds, or if an emergency is apparent. Observations: It was indicated by Town staff that all pump stations have the required signage. Compliance Status: Compliant. Part I, Paragraph 9: Pump station sites, equipment and components shall have restricted access, per 15A NCAC 2H .0219(h)(7). 3 Observations: All pump stations inspected were sufficiently secured to provide restricted access. Compliance Status: Compliant. Part I, Paragraph 10: Pump stations that do not employ an automatic polling feature (i.e. routine contact with pump stations from a central location to check operational status of the communication system) shall have both audible and visual high water alarms. The alarms shall be weather-proof and placed in a clear and conspicuous location. Permits issued for the construction of pump stations that included high water alarms in the description must maintain the alarms even if simple telemetry (i.e. notification of an alarm condition initiated by the pump station control feature) is installed. Observations: All pump stations inspected had operational SCADA that is monitored at the WWTP, and all stations are checked three days per week. Compliance Status: Compliant. Part I, Paragraph 11: For all newly constructed, modified and rehabilitated pump stations, all equipment and components located within the pump station shall be corrosion-resistant and components in close proximity of the pump station shall be sealed within a corrosion-resistant coating or encasement. Observations: The Town has no newly constructed or rehabilitated pump stations. Compliance Status: Compliant. Part I, Paragraph 12: All construction and rehabilitation of the wastewater collection system (i.e., permitted or deemed permitted) shall be scheduled to minimize the interruption of service by the existing utilities. Construction and rehabilitation shall not result in the violation of Condition 1.2. of this permit. Observations: No conditions that demonstrate noncompliance with this permit condition were noted during the inspection. Mr. Harmon stated that all such activities are executed in such a manner as to avoid interruption of existing utility services or cause sanitary sewer overflows (SSO). Compliance Status: Compliant. • Part II, Operation and Maintenance Requirements • Part II, Paragraph 1: Upon classification of the collection system by the Water Pollution Control System Operators Certification Commission (WPCSOCC), the Permittee shall designate and employ a certified operator to be in responsible charge (ORC) and one or more certified operator(s) to be back-up ORC(s) of the 4 ►' facilities in accordance with 15A NCAC 8G .0201. The ORC shall visit the system within 24 hours of knowledge of a bypass, spill, or overflow of wastewater from the system, unless visited by the Back-Up ORC, and shall comply with all other conditions of 15A NCAC 8G .0204. Observations: The ORC and backup ORCs have been properly designated as required. Compliance Status: Compliant. Part II, Paragraph 2: The Permittee shall develop and adhere to a schedule for reviewing all inspection, maintenance, operational and complaint logs. If the review process results in the identification of any recurring problem in the wastewater collection system, that cannot be resolved in a short time period, the Permittee shall establish a plan for addressing the problem(s). Observations: Mr. Harmon reviews all such logs on a monthly basis and has developed written plans for identified recurring problems. Compliance Status: Compliant. Part II, Paragraph 3: The Permittee shall develop and adhere to a schedule for testing emergency and standby equipment. Observations: Generators, pumps, sewer cleaning equipment, etc, are inspected on a monthly basis, if not used more often. Records of testing activities are also kept. Compliance Status: Compliant. Part II, Paragraph 4: The Permittee shall develop and implement a routine pump station inspection and maintenance program, which shall include, but not be limited to, the following maintenance activities: 1. Cleaning and removing debris from the pump station structure, outside perimeter, and wet well; 2. Inspecting and exercising all valves; 3. Inspecting and lubricating pumps and other mechanical equipment according to the manufacturer's recommendations; and 4. Verifying the proper operation of the alarms, telemetry system and auxiliary equipment. Observations: The pump station inspection/maintenance program includes all the above minimum items. Compliance Status: Compliant. 5 Part II, Paragraph 5: For each pump station without pump reliability(i.e. simplex pump stations serving more than a single building or pump stations not capable of pumping at a rate of 2.5 times the average daily flow rate with the largest pump out of service), at least one fully operational spare pump capable of pumping peak flow shall be maintained on hand. Observations: The Town of Boone has six duplex pump stations. The Town has in stock, a spare pump for each pump station. Compliance Status: Compliant. Part II, Paragraph 6: The Permittee shall maintain on hand at least two percent of the number of pumps installed, but no less than two pumps, that discharge to a pressure sewer and serve a single building, unless the Permittee has the ability to purchase and install a replacement pump within 24 hours of first knowledge of the simplex pump failure or within the storage capacity provided in any sewer line extension permit. Observations: The Town has no pressure sewers in its collection system. Compliance Status: Compliant Part II, Paragraph 7: Rights-of-way and/or easements shall be properly maintained to allow accessibility to the wastewater collection system unless the Permittee can demonstrate the ability to gain temporary access in an emergency situation where existing land-use conditions do not allow the establishment and maintenance of permanent access. In this case, the Permittee shall continue to observe the lines visually, utilize remote inspection methods (e.g. CCTV) and use the opportunity of drier conditions to perform further inspections and necessary maintenance. Observations: All right-of-ways (ROW) evaluated during the inspection were properly maintained. Records are being properly kept. Compliance Status: Compliant. Part II, Paragraph 8: The Permittee shall assess cleaning needs and develop and implement a program for appropriately cleaning, whether by hydraulic or mechanical methods, all sewer lines. At least 10 percent of the wastewater collection system, selected at the discretion of the ORC, shall be cleaned each year. Preventative cleaning is not required for sewer lines less than five years old unless inspection otherwise reveals the need for cleaning or cleaning is required by a sewer line extension permit. Observations: The sewer line-cleaning program has been fully developed and implemented. Line cleaning efforts over the last year have resulted in • 6 i approximately 10 percent of the system being cleaned. All records are complete, current and were readily available for inspection. Compliance Status: Compliant. Part II, Paragraph 9: Adequate measures shall be taken to contain and properly dispose of materials associated with SSOs. The Permittee shall maintain a Response Action Plan that addresses the following minimum items: 1. Contact phone numbers for 24-hour response, including weekends and holidays; 2. Response time; 3. Equipment list and spare parts inventory; 4. Access to cleaning equipment; 5. Access to construction crews, contractors and/or engineers; 6. Source(s) of emergency funds; 7. Site sanitation and clean up materials; and 8. Post-SSO assessment. Observations: The Sanitary. Sewer Overflow (SSO) Response Action Plan (RAP) includes all the above minimum items. All measures necessary to contain and properly dispose of SSO materials are employed for all SSOs. Compliance Status: Compliant. Part II, Paragraph 10: The Permittee, or their authorized representative, shall conduct an on-site evaluation for all SSOs as soon as possible, but no more than two hours after first knowledge of the SSO. Observations: The ORC or one of the BORCs normally responds to every SSO within two hours. Records demonstrating this are kept through the city's database where emergency response calls are normally reported. The records in this database specifically for SSOs are printed and kept in the SSO record binder in the ORC's office along with the required 5-day reports, press releases and public notices, as necessary. Compliance Status: Compliant. Part II, Paragraph 11: In the event of a SSO or blockage within the wastewater collection system, the Permittee shall restore the system operation, remove visible solids and paper, sanitize any ground area and restore the surroundings. Observations: No conditions were noted that demonstrate noncompliance with this permit condition. The RAP details all steps taken to respond to an SSO, from the initial report to the final 5-day report. The RAP containment, cleanup and system restoration procedures are quite detailed and considered sufficient to address all SSOs. 7 V Compliance Status: Compliant. Part Ill, Records Part Ill, Paragraph 1: Records shall be maintained to document compliance with Conditions 1(4), 11(2) - 11(4), 11(7) - 11(8), IV(3) and V(1) -V(4). Records shall be kept on file for a minimum of three years. Observations: All required records were readily available for inspection and were found to be complete, accurate and current. Compliance Status: Compliant. Part Ill, Paragraph 2: The Permittee shall maintain adequate records pertaining to SSOs, and complaints for a minimum of three years. These records shall include, but are not limited to, the following information: 1. Date of SSO or complaint; 2. Volume of wastewater released as a result of the SSO and/or nature of complaint; 3. Location of the SSO and/or complaint; 4. Estimated duration of the SSO; 5. Individual from the Division who was informed about the SSO and/or complaint, when applicable; 6. Final destination of the SSO; 7. Corrective actions; 8. Known environmental/human health impacts resulting from the SSO; and 9. How the SSO was discovered. Observations: All required SSO/Complaint records were readily available for inspection and were found to be complete, accurate and current. Compliance Status: Compliant. Part III, Paragraph 3: The Permittee shall maintain an up-to-date, accurate, comprehensive map of its wastewater collection system that also notes the locations where other wastewater collection systems become tributary. If a comprehensive map of the collection system has not been established, a rough sketch shall be drawn. The Permittee shall map approximately 10 percent of its existing collection system each year for the next ten years, or until complete, whichever is sooner. The comprehensive map shall include, but is not limited to: pipe size, pipe material, pipe location, flow direction, approximate pipe age, number of active service taps, and each pump station identification, location and capacity. 8 Observations: The Town of Boone has a comprehensive map of the collection system. Compliance Status: Compliant. Part Ill, Paragraph 4: The Permittee shall maintain records of all of the modifications and extensions to the collection system permitted herein. The Permittee shall maintain a copy of the construction record drawings and specifications for modifications/extensions to the wastewater collection system for the life of the modification/extension. Information concerning the extension shall be incorporated into the map of the wastewater collection system within one year of the completion of construction. The system description contained within this permit shall be updated to include this modification/extension information upon permit renewal. Observations: All such records are maintained and will be incorporated into the system map as required. Compliance Status: Compliant. Part IV, Monitoring and Reporting Requirements Part IV, Paragraph 2: The Permittee shall verbally report to a Division of Water Resources staff member at the Winston-Salem Regional Office, at telephone number (336) 776-9800 as soon as possible, but in no case more than 24 hours following the occurrence or first knowledge of the occurrence of either of the following: 1. Any SSO and/or spill over 1,000 gallons; or 2. Any SSO and/or spill, regardless of volume, that reaches surface water. Observations: The permittee reports all SSOs as required by the permit. Compliance Status: Compliant. Part IV, Paragraph 3: The Permittee shall meet the annual reporting and notification requirements provided in North Carolina General Statute §143- ' 215.1C. Observations: The permittee develops and distributes an annual compliance report to all users of the system. Compliance Status: Compliant. 9 1 Part V, Inspections Part V, Paragraph 1: The Permittee or the Permittee's designee shall inspect the wastewater collection system regularly to reduce the risk of malfunctions and deterioration, operator errors, and other issues that may cause or lead to the release of wastes to the environment, threaten human health or create nuisance conditions. The Permittee shall keep an inspection log or summary including, at a minimum, the date and time of inspection, observations made, and any maintenance, repairs, or corrective actions taken by the Permittee. Observations: All collection system components have been completely inventoried and inspection and maintenance schedules developed for every component. Completed work order logs are kept as required in the ORC's office. Compliance Status: Compliant. Part V, Paragraph 2: Pump stations without Supervisory Control and Data Acquisition (SCADA) systems or telemetry shall be inspected everyday (i.e. 365 days per year). Pump stations equipped with SCADA systems or telemetry shall be inspected at least once per week. Observations: The Town has six pump stations, and all six have telemetry. All records of the inspections were readily available for inspection, complete and current. Compliance Status: Compliant. Part V, Paragraph 3: A general observation of the entire collection system shall be performed throughout the course of every year. Observations: A general observation of the entire collection system is performed each year. Operators specifically concentrate on those obscure areas of the system that are not normally be seen by either them or the general public during the course of the year. The observations are recorded. Records of these inspections were complete, current and readily available for inspection. Compliance Status: Compliant. Part V, Paragraph 4: Inspections of all high priority lines (i.e. aerial line, sub- waterway crossing, line contacting surface waters, siphon, line positioned parallel to stream banks that are subject to eroding in such a manner that may threaten the sewer line, or line designated as high-priority in a permit) shall be performed at least once per every six month period of time. New high priority lines installed or identified after permit issuance are incorporated by reference and subject to this permit condition until permit renewal where they shall be referenced in writing. • 10 Observations: All high priority lines (HPL) have been identified and are inspected as required. The inspections are recorded as required. Records of the inspections were complete, current and readily available for inspection. Compliance Status: Compliant. 4. Mr. Harmon and the Town of Boone have done an exceptional job of developing and implementing their WWCS program. The Division thanks the Town of Boone for their efforts in managing its collection system and for their part in safeguarding the natural resources of North Carolina for future generations. 6. If you have any questions regarding the inspection or this letter, please call Gary Hudson or me at (336) 776-9800. Thank you for your cooperation in this matter. Sincerely, Sherri V. Knight, P.E. Regional Supervisor Water Quality Regional Operations Division of Water Resources cc: Jack Harmon, ORC WSRO — SWP Central Files PERCS-Unit- 11 Compliance Inspection Report Permit: WQCS00071 Effective: 02/01/16 Expiration: 01/31/24 Owner: Town of Boone SOC: Effective: Expiration: Facility: Boone Collection System County:Watauga 570 W King St Region: Winston-Salem Boone NC 28607 Contact Person: Rick Miller Title: Public Works Director Phone: 828-268-6250 Directions to Facility: System Classifications: CS2, Primary ORC: Jackie Eugene Harmon Certification: 23104 Phone: 828-268-6256 Secondary ORC(s): On-Site Representative(s): Related Permits: NC0020621 Town of Boone-Jimmy Smith WtAJTP Inspection Date: 09/11/2018 Entry Time: 10 00AM Exit Time: 12 00PM Primary Inspector: Gary Hudson Phone: 336-776-9694 Secondary Inspector(s): Reason for Inspection: Routine Inspection Type: Collection System Inspect Non Sampling Permit Inspection Type: Collection system management and operation Facility Status: I. Compliant 0 Not Compliant Question Areas: I. Miscellaneous Questions 111 Performance Standards • Operation&Maint Reqmts • Records • Monitoring&Rpting Reqmts El Inspections • Pump Station (See attachment summary) • Page 1 Permit. WQCS00071 Owner-Facility:Town of Boone ,r Inspection Date: 09/11/2018 Inspection Type:Collection System Inspect Non Sampling Reason for Visit: Routine Inspection Summary • • Page. 2 Permit: WQCS00071 Owner-Facility:Town of Boone Inspection Date: 09/11/2018 Inspection Type:Collection System Inspect Non Sampling Reason for Visit: Routine Performance Standards Yes No NA NE Is Public Education Program for grease established and documented? • ❑ ❑ ❑ What educational tools are used? Is Sewer Use Ordinance/Legal Authority available? • ❑ ❑ ❑ Does it appear that the Sewer Use Ordinance is enforced? • ❑ ❑ ❑ Is Grease Trap Ordinance available? • ❑ ❑ ❑ Is Septic Tank Ordinance available(as applicable, i.e.annexation) • ❑ ❑ ❑ List enforcement actions by permittee,if any,in the last 12 months Has an acceptable Capital Improvement Plan(CIP)been implemented? • ❑ 0 ❑ Does CIP address short term needs and long term\"master plan\"concepts? • ❑ ❑ ❑ Does CIP cover three to five year period'? • ❑ ❑ ❑ Does CIP include Goal Statement? • ❑ ❑ ❑ 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? • ❑ ❑ ❑ Is CIP designated only for wastewater collection and treatment? • ❑ ❑ ❑ Approximate capital improvement budget for collection system? Total annual revenue for wastewater collection and treatment? CIP Comments Is system free of known points of bypass? • 000 If no,describe type of bypass and location Is a 24-hour notification sign posted at ALL pump stations? • ❑ ❑ ❑ #Does the sign include Instructions for notification? • ❑ ❑ ❑ Pump station identifier? • ❑ ❑ ❑ 24-hour contact numbers • ❑ ❑ ❑ If no, list deficient pump stations • #Do ALL pump stations have an"auto polling"feature/SCADA? I -❑ ❑ ❑ Number of pump stations 6 Number of pump stations that have SCADA 0 Number of pump stations that have simple telemetry 6 Page: 3 ❑ W ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ W ❑ ❑ ❑ 00 000000000 a. ❑ a ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ a ❑ ❑ ❑ 00 0000 ■ 0000 a) __ I z° ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ . 000 ❑ ❑ 000000000 a O O ❑ 2 • 1111 •10 • • • • 111 } ■ . . • • 111 • • • 0 • • • • 5 O c o o o 0 a! of C _ a E o r N N c m Z 2 m m E 0. m c E 2 2 r o° in 0 0 gm C O O Q) 3 o m N o r O r E r ' o U c m• N .n C — F T L O O O a N WO d (Q c, T d Vi N m U. C E +N. r N N C m C X CD O E - E- C E E m m0 4_ �S o. 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Qm wc a o a c 2 14 6o ° om •I 2coCl) •I€ C c 0 c y 2 Cl)N m m Co 0 a o86 2 0 ac m c ° ° ma a L. v mmo o Em O LeE um o o m -0 a m o0m ,22i o ai mo ,- m CNU° o o E ymcac 0 ° Ea mL m cr , m aoa > 0 3cuE woaL ' U ' o oa a = .m N in Crv 0 c 0 u a) a . o m tw Q Q U) U) a m E o m - wE o na Q Z oo m o E a m o m p o — m ❑ C in ❑ Op N 2 * 0-t Y Permit: WQCS00071 Owner-Facility:Town of Boone { Inspection Date: 09/11/2018 Inspection Type•Collection System Inspect Non Sampling Reason for Visit: Routine #Is an annual report being prepared in accordance with G S. 143-215.1U? MOOD #Is permittee compliant with all compliance schedules in the oermlts? ❑ 0 II ❑ If no,which one(s)' Comment: Page- 6