HomeMy WebLinkAboutWQCS00071_Compliance Evaluation Inspection_20181017 � STATE4
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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
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NORTH CAROLJNA
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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
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►' 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.
•
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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-
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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
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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:
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