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HomeMy WebLinkAboutWQCSD0143_NOD-2019-PC-0096_20190411 DocuSign Envelope ID: FF8E6D95-8EC3-477F-90CE-ED24A0605CE8 ROY COOPER c�crrlc+r - A ICHAEL S.PECAN Secretary QLUAM LINDA CULPEPPER NORTH CAROL INA r4wtor Environmental Quality April 16, 2019 Harold C Morton Rock Creek Environmental Company Inc. 308 Country Club Blvd Jacksonville, NC 28540 SUBJECT: NOTICE OF DEFICIENCY Tracking Number: NOD-2019-PC-0096 Permit No. WQCSDO143 Rock Creek Country Club Deemed Collection System Onslow County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Rock Creek Country Club Deemed Collection System on April 11, 2019. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in Collection System Permit No. WQCSD0143. A summary of the findings and comments noted during the inspection are provided in the enclosed copy of the inspection report. The Collection System Non-sampling inspection was conducted by Division of Water Resources staff from the Wilmington Regional Office. The following deficiency(s) was noted during the inspection: Inspection Area Description of Deficiency Operation & Maintenance A general observation of the entire sewer system is not documented at least once a year. Requirements Operation & Maintenance A spill response plan has not been developed and implemented. Requirements Performance Standards Biannual distribution of grease education materials to users of the collection system has not been documented. NorthCawEnsDepsrt rim ntofEnvironmeatalQua?ity I Diuisionof Water Resources Z��P- 1i'drniaVon Reg•3rLa-Dffioe 1 127 CardiaaiDrive Exten son I Wliwaington, NorthCaro-ms2A405 i 8 " 910-796-7215 DocuSign Envelope ID: FF8E6D95-8EC3-477F-90CE-ED24A0605CE8 Remedial actions should have already been taken to correct this problem and prevent further occurrences in the future. The Division of Water Resources may pursue enforcement action for this and any additional violations of State law. To prevent further action, carefully review these deficiencies and address the causes of non-compliance to prevent the recurrence of similar situations. If you should have any questions, please do not hesitate to contact Helen Perez with the Water Quality Regional Operations Section in the Wilmington Regional Office at 910-796-7215. Sincerely, DocuSigned by: E3ABA14AC7DC434... Morelia Sanchez-King, Regional Supervisor Water Quality Regional Operations Section Wilmington Regional Office Division of Water Resources, NCDEQ ATTACHMENTS Cc: Josh Johnson — electronic copy Uploaded to Laserfiche NorthCaroTinaDepartrnentoffnvironmeatadQaadity I Diuisianof Water Resources Wilmington Reg•3reIOffice 1 127 Cardinr lDriveExtension I Wilrn,ngton. North Caro:ma73405 _ eri 910-796-7215 Compliance Inspection Report Permit: WQCSD0143 Effective: 03/01/00 Expiration: Owner: Rock Creek Environmental Company Inc SOC: Effective: Expiration: Facility: Rock Creek Country Club Deemed Collection Syster County: Onslow Region: Wilmington Contact Person: Harold C Morton Title: Phone: 910-324-3023 Directions to Facility: System Classifications: Primary ORC: Joshua Lee Johnson Certification: 989743 Phone: 910-324-3022 Secondary ORC(s): On-Site Representative(s): On-site representative Joshua L Johnson 910-347-5843 Related Permits: NC0062294 Rock Creek Environmental Company Inc-Rock Creek Golf&Country Club WWTP Inspection Date: 04/11/2019 Entry Time: 09:30AM Exit Time: 11:30AM Primary Inspector: Helen I Perez Phone: 910-796-7387 Secondary Inspector(s): 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 Performance Standards Operation&Maint Reqmts Records Inspections Pump Station (See attachment summary) Page 1 of 9 Permit: WQCSDO143 Owner-Facility:Rock Creek Environmental Company Inc Inspection Date: 04/11/2019 Inspection Type:Collection System Inspect Non Sampling Reason for Visit: Routine Inspection Summary: A routine compliance inspection of the Rock Creek Golf and Country Club deemed collection system was conducted on 4-11-2019.Josh Johnson, ORC of the Rock Creek WWTP,was present during the inspection. Each connection to the sewer system has a septic tank installed which collects the majority of the solids before wastewater reaches the WWTP. The utility staff is responsible for the coordination of pumping out septic tank waste with septic haulers.The three pump stations are inspected, maintained and documented weekly.The notification sign at PS#3 needs to be reattached and the audio alarm needs to be repaired.The bulb for the visual alarm at PS#2 needs to be replaced. Documentation at this collection system has improved since the last inspection. It appears that the system is well maintained, but there is still some documentation missing that is required under the 02T regulations for deemed collection systems.A Notice of Deficiency will be issued for the following: 1. Biannual distribution and documentation of grease education materials to users of the collection system. 2. Spill response plan developed and implemented. 3. A general observation of the entire sewer system conducted and documented at least once a year. Please review the comment section of the inspection report for more details. Page 2 of 9 Permit: WQCSDO143 Owner-Facility:Rock Creek Environmental Company Inc Inspection Date: 04/11/2019 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? FOG educational information has been added on to the annual report for customers in the past,but the last few years it has been left off the report. Regulations require at least biannual distribution and documentation of grease education materials to the customers. 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? ❑ ❑ ❑ 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? ❑ ❑ ❑ 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 Sign for PS#3 was down but located within the fence. Needs to be reattached to fence. #Do ALL pump stations have an"auto polling"feature/SCADA? ❑ ❑ ❑ Number of pump stations 3 Number of pump stations that have SCADA 0 Number of pump stations that have simple telemetry 3 Number of pump stations that have only audible and visual alarms 0 Page 3 of 9 Permit: WQCSDO143 Owner-Facility:Rock Creek Environmental Company Inc Inspection Date: 04/11/2019 Inspection Type:Collection System Inspect Non Sampling Reason for Visit: Routine Number of pump stations that do not meet permit requirements 0 #Does the permittee have a root control program? ❑ ❑ ❑ #If yes,date implemented? Describe: Comment: The 3 pump stations have simple telemetry which calls, in order, the ORC, BORC and then the utility office. Inspections Yes No NA NE Are maintenance records for sewer lines available? ❑ ❑ ❑ Are records available that document pump station inspections? ❑ ❑ ❑ Are SCADA or telemetry equipped pump stations inspected at least once a week? ❑ ❑ ❑ Are non-SCADA/telemetry equipped pump stations inspected every day? ❑ ❑ ❑ Are records available that document citizen complaints? ❑ ❑ ❑ #Do you have a system to conduct an annual observation of entire system? ❑ ❑ ❑ #Has there been an observation of remote areas in the last year? ❑ ❑ ❑ Are records available that document inspections of high-priority lines? ❑ ❑ ❑ Has there been visual inspections of high-priority lines in last six months? 0 ❑ ❑ ❑ Comment: Weekly pump station inspections are recorded on a checklist sheet. High priority line inspections and some maintenance are documented on the checklist. There is no documentation of an annual observation of the entire system. Operation &Maintenance Requirements Yes No NA NE Are all log books available? ❑ ❑ ❑ Does supervisor review all log books on a regular basis? ❑ ❑ ❑ Does the supervisor have plans to address documented short-term problem areas? ❑ ❑ ❑ What is the schedule for reviewing inspection,maintenance,&operations logs and problem areas? Are maintenance records for equipment available? ❑ ❑ ❑ 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? ❑ ❑ ❑ Inspecting and lubricating pumps and other equipment? ❑ ❑ ❑ Inspecting alarms,telemetry and auxiliary equipment? ❑ ❑ ❑ Is there at least one spare pump for each pump station w/o pump reliability? ❑ ❑ ❑ Are maintenance records for right-of-ways available? ❑ ❑ ❑ Are right-of-ways currently accessible in the event of an emergency? ❑ ❑ ❑ Are system cleaning records available? ❑ ❑ ❑ Has at least 10%of system been cleaned annually? ❑ ❑ 0 ❑ Page 4 of 9 Permit: WQCSDO143 Owner-Facility:Rock Creek Environmental Company Inc Inspection Date: 04/11/2019 Inspection Type:Collection System Inspect Non Sampling Reason for Visit: Routine What areas are scheduled for cleaning in the next 12 months? Is a Spill Response Action Plan available? ❑ 0 ❑ ❑ 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 ❑ ❑ ❑ Is a Spill Response Action Plan available for all personnel? ❑ ❑ ❑ Is the spare parts inventory adequate? ❑ ❑ ❑ Comment: Some maintenance is recorded on the PS inspection checklist. ORC created a WWTP log to include documentation of more detailed maintenance performed and generator testing that will be used moving forward. Right-of-ways are maintained, with the golf course staff mowing the right-of ways on the course. A spill response plan needs to be developed. Records Yes No NA NE Are adequate records of all SSOs,spills and complaints available? ❑ ❑ ❑ Are records of SSOs that are under the reportable threshold available? ❑ ❑ ❑ Do spill records indicate repeated overflows(2 or more in 12 months)at same location? ❑ ❑ ❑ If yes, is there a corrective action plan? ❑ ❑ ❑ Is a map of the system available? ❑ ❑ ❑ Does the map include: Pipe sizes ❑ ❑ ❑ Pipe materials ❑ ❑ ❑ Pipe location ❑ ❑ ❑ Flow direction ❑ ❑ ❑ Approximate pipe age ❑ ❑ ❑ Number of service taps ❑ ❑ ❑ ❑ Pump stations and capacity ❑ ❑ ❑ If no,what percent is complete? List any modifications and extensions that need to be added to the map #Does the permittee have a copy of their permit? 0 ❑ ❑ ❑ Comment: No comment. PS#1 - Pump Station Yes No NA NE Page 5 of 9 Permit: WQCSD0143 Owner-Facility:Rock Creek Environmental Company Inc Inspection Date: 04/11/2019 Inspection Type:Collection System Inspect Non Sampling Reason for Visit: Routine Pump station type Duplex Are pump station logs available? 0 ❑ ❑ ❑ Is it accessible in all weather conditions? 0 ❑ ❑ ❑ #Is general housekeeping acceptable? 0 ❑ ❑ ❑ Are all pumps present? 0 ❑ ❑ ❑ Are all pumps operable? 0 ❑ ❑ ❑ Are wet wells free of excessive debris? 0 ❑ ❑ ❑ Are upstream manholes free of excessive debris/signs of overflow? ❑ ❑ ❑ Are floats/controls for pumps/alarms operable? ❑ ❑ ❑ Is"auto polling"feature/SCADA present? ❑ ❑ ❑ Is"auto polling"feature/SCADA operational? ❑ ❑ ❑ Is simple telemetry present? ❑ ❑ ❑ Is simple telemetry operational? ❑ ❑ ❑ Are audio and visual alarms present? ❑ ❑ ❑ Are audio and visual alarms operable? ❑ ❑ ❑ Is the Pump station inspected as required? ❑ ❑ ❑ Are backflow devices in place? ❑ ❑ ❑ Are backflow devices operable? ❑ ❑ ❑ Are air relief valves in place? ❑ ❑ ❑ Are air relief valves operable? ❑ ❑ ❑ # Is an emergency generator available? ❑ ❑ ❑ Can the emergency generator run the pumps? ❑ ❑ ❑ Is the pump station equipped for quick hook-up? ❑ ❑ ❑ Is the generator operable? ❑ ❑ ❑ #Is fuel in tank and sufficient? ❑ ❑ ❑ Is the generator inspected according to their schedule? ❑ ❑ ❑ Is a 24-hour notification sign posted? 0 ❑ ❑ ❑ Does it include: Instructions for notification? 0 ❑ ❑ ❑ Pump station identifier? 0 ❑ ❑ ❑ Emergency phone number ❑ ❑ ❑ Is public access limited? ❑ ❑ ❑ Is pump station free of overflow piping? ❑ ❑ ❑ Is the pump station free of signs of overflow? ❑ ❑ ❑ Are run times comparable for multiple pumps? Comment: No comment. Page 6 of 9 Permit: WQCSD0143 Owner-Facility:Rock Creek Environmental Company Inc Inspection Date: 04/11/2019 Inspection Type:Collection System Inspect Non Sampling Reason for Visit: Routine PS#2 - Pump Station Yes No NA NE Pump station type Duplex Are pump station logs available? 0 ❑ ❑ ❑ Is it accessible in all weather conditions? 0 ❑ ❑ ❑ #Is general housekeeping acceptable? 0 ❑ ❑ ❑ Are all pumps present? 0 ❑ ❑ ❑ Are all pumps operable? 0 ❑ ❑ ❑ Are wet wells free of excessive debris? 0 ❑ ❑ ❑ Are upstream manholes free of excessive debris/signs of overflow? ❑ ❑ ❑ Are floats/controls for pumps/alarms operable? ❑ ❑ ❑ Is"auto polling"feature/SCADA present? ❑ ❑ ❑ Is"auto polling"feature/SCADA operational? ❑ ❑ ❑ Is simple telemetry present? ❑ ❑ ❑ Is simple telemetry operational? ❑ ❑ ❑ Are audio and visual alarms present? ❑ ❑ ❑ Are audio and visual alarms operable? ❑ ❑ ❑ Is the Pump station inspected as required? ❑ ❑ ❑ Are backflow devices in place? ❑ ❑ ❑ Are backflow devices operable? ❑ ❑ ❑ Are air relief valves in place? ❑ ❑ ❑ Are air relief valves operable? ❑ ❑ ❑ # Is an emergency generator available? ❑ ❑ ❑ Can the emergency generator run the pumps? ❑ ❑ ❑ Is the pump station equipped for quick hook-up? ❑ ❑ ❑ Is the generator operable? ❑ ❑ ❑ #Is fuel in tank and sufficient? ❑ ❑ ❑ Is the generator inspected according to their schedule? ❑ ❑ ❑ Is a 24-hour notification sign posted? ❑ ❑ ❑ Does it include: Instructions for notification? ❑ ❑ ❑ Pump station identifier? ❑ ❑ ❑ Emergency phone number ❑ ❑ ❑ Is public access limited? ❑ ❑ ❑ Is pump station free of overflow piping? ❑ ❑ ❑ Is the pump station free of signs of overflow? ❑ ❑ ❑ Are run times comparable for multiple pumps? Page 7 of 9 Permit: WQCSD0143 Owner-Facility:Rock Creek Environmental Company Inc Inspection Date: 04/11/2019 Inspection Type:Collection System Inspect Non Sampling Reason for Visit: Routine Comment: Bulb needs to be replaced for visual alarm. PS#3 - Pump Station Yes No NA NE Pump station type Duplex Are pump station logs available? 0 ❑ ❑ ❑ Is it accessible in all weather conditions? 0 ❑ ❑ ❑ #Is general housekeeping acceptable? 0 ❑ ❑ ❑ Are all pumps present? 0 ❑ ❑ ❑ Are all pumps operable? 0 ❑ ❑ ❑ Are wet wells free of excessive debris? 0 ❑ ❑ ❑ Are upstream manholes free of excessive debris/signs of overflow? ❑ ❑ ❑ Are floats/controls for pumps/alarms operable? ❑ ❑ ❑ Is"auto polling"feature/SCADA present? ❑ ❑ ❑ Is"auto polling"feature/SCADA operational? ❑ ❑ ❑ Is simple telemetry present? ❑ ❑ ❑ Is simple telemetry operational? ❑ ❑ ❑ Are audio and visual alarms present? ❑ ❑ ❑ Are audio and visual alarms operable? ❑ 0 ❑ ❑ Is the Pump station inspected as required? ❑ ❑ ❑ Are backflow devices in place? ❑ ❑ ❑ Are backflow devices operable? ❑ ❑ ❑ Are air relief valves in place? ❑ ❑ ❑ Are air relief valves operable? ❑ ❑ ❑ # Is an emergency generator available? ❑ ❑ ❑ Can the emergency generator run the pumps? ❑ ❑ ❑ Is the pump station equipped for quick hook-up? ❑ ❑ ❑ Is the generator operable? ❑ ❑ ❑ #Is fuel in tank and sufficient? ❑ ❑ ❑ Is the generator inspected according to their schedule? ❑ ❑ ❑ Is a 24-hour notification sign posted? ❑ ❑ ❑ Does it include: Instructions for notification? ❑ ❑ ❑ Pump station identifier? ❑ ❑ ❑ Emergency phone number ❑ ❑ ❑ Is public access limited? ❑ ❑ ❑ Is pump station free of overflow piping? 0 ❑ ❑ ❑ Page 8 of 9 Permit: WQCSD0143 Owner-Facility:Rock Creek Environmental Company Inc Inspection Date: 04/11/2019 Inspection Type:Collection System Inspect Non Sampling Reason for Visit: Routine Is the pump station free of signs of overflow? 0 ❑ ❑ ❑ Are run times comparable for multiple pumps? Comment: The 24-hour notification sign was down but located within the fence and needs to be reattached. The audi alarm was not working and needs to be repaired. Page 9 of 9