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Home My WebLink AboutWQCS00109_NOD-2019-PC-0104_20190426Rot' COOPER it Ovenior tMICHAEL S. REGAN Secretary LINDA CULPEPPER Director Mr. Matthew Zapp, Town Manager Town of Benson PO Box 69 Benson, NC 27504 Dear Mr. Zapp: �i Z M 'man• NORTH CAROLINA Environmental Quality April 26, 2019 Subject: NPDES Compliance Evaluation Inspection Notice of Deficiency (NOD-2019-PC-0104) City of Benson Wastewater Collection System Permit No. WQCS00109 Johnston County On April 5, 2019, Jason Robinson of the NC Division of Water Resource's Raleigh Regional Office (RRO) conducted a compliance evaluation inspection of the City of Benson's Wastewater Collection System. The assistance of Benson staff Tim Robbins, Jeremy Bryant and Brian Leavitt was appreciated. Please see the inspection report below: Permit Information: A. The most recently issued permit (July 1, 2018) states that The City of Benson operates a wastewater collection system consisting of approximately 32 miles of gravity sewer, approximately 6 miles of forcemain, 11 duplex pump stations and 32 simplex pump stations. The current permit expires on June 30, 2023. A renewal application should be submitted at least 180 days prior to expiration. Operator information: A. The collection system is classified as a CS-2. Jeremy Bryant is the Town's designated Primary Operator in Charge (ORC). Brian Leavitt is the backup Operator in Responsible Charge (bORC). Both are certified CS-2 operators. Ill. Records Documents were reviewed with Town staff at the Benson Public Works facility at 501 N. Market St. Findings are described below: A. Ordinance/Charter: A Sewer Use Ordinance/Charter was available that addresses sewer construction, grease control, septic tank installation and discharge by septic tank service North Carolina Department of E -vironmental ouality IDwsion of Water Resources Raleigh Regional I Offce 11623 Ma I Serv,oe Center Raleigh NC 27699-1628 Phvsical Address 3800 Barrett Owe Raleigh NC 27609 919.791-4200 Town of Benson's Wastewater Collection System Compliance Evaluation NOD-2019-PC-0104 Permit No. WQC500109 companies (Title V: Public Works, Chapter 52: Sewer). B. Fats, Oils and Grease: A Public Education Program for Grease should be implemented that includes distributing education material to residential and non-residential users at least twice Per year Section 1.5 of permit). ii. A Fats Oils and Grease Trap Program for non-residential users should be implemented that includes regular grease traplinterceptor inspections and enforcement a ainst users who have not Properly installed traps or who fail to properly operate and maintain these units. Section 1.5 ofpermit) C. Capital Improvement Plan (CIP): An adequate CIP was available (Section 1.6). D. Collection System Map, A map was available that showed the pipe size, material, flow direction, and pump stations. This ma shall be maintained to be up-to-date, accurate and comprehensive. It is recommended the legend text be edited to describe the Riues as a wastewater collections stem instead of the current) shown "Water" Section 111.3 of Permit), E. High -Priority lines: Documentation should be kept that demonstrates that all high -priority lines are inspected at least twice per year as required by the Permit Section V.4 of ermit . F. Annual Inspection: A program should be im lemented to ensure that the entire system is inspected at least once every year. Records should be kept to demonstrate this (Section V.3 of permit). G. Right -of -Way / Easements: Documentation should be kept that describes all maintenance/clearingmaintenance/clearing of the systems ri ht-of-wa easements Section 11.7 of ermit . H. System Cleaning: The permit requires that at least 10% of the system is cleaned annually, and the entire system is cleaned every 10 years. The Town should implement a program to ensure this is done and documentation should be kept that describes what portion has been cleaned when and when future portions will be cleaned Section 11.8 of the permit). I. Maintenance Records: Records should be kept for all maintenance done to the system see Citizens' complaints below). J. Spill Response Action Plan: A plan for addressing SSOs was available for review. The plan should be updated to include 24-hour contact numbers response time a list of a ui ment ands are oarts and their location sources of emergency funds and how cleanup and Post - spill assessment shall be conducted Section 11.9 of permit). K. Sanitary Sewer Overflows (SSOs): SSO 5-day reports were available for review. Any press releases and public notices associated with the SSOs should be kept with these records (Section 111.2 & IV-2 of permit). L. Citizens Complaints: Work orders associated with citizens' complaints were available for review. 2of4 Town of Benson's Wastewater Collection System Compliance Evaluation NOD-2019-PC-0104 Permit No. WQCS00109 M. Annual Report: An annual report should be developed at the end of the calendar fiscal year and distributed to users as described in G.S. 143-215.1C Section IV.3 of permit). IV. Collection System Inspection A. High Priority Lines: The Town's permit lists 7 high priority lines. The following High Priority Lines were observed during the inspection: NC Hwy 50 (East Main St.) to Fayetteville Street at Taco Bell ii. Martin Street Aerial line across Driving Branch John Deer Aerial Line to 1-40 Federal Road Lift Station: Please clear the side of this easement closest to the 1-40 Pump station including removing the downed tree for ,_ uick access in the event of an SSO The following lines were found that should be designated as high -priority lines but are not included in the Town's list. These lines should be added to the Town's High Priority Line List and included in the next Permit renewal application. along with any other lines in the system that meet the definition of high priority lines_(Section V.4 ofpermit). Please submit an updated list of hi h- riorit lines: iv. Exposed gravity line in the stormwater ditch across from the Chicopee Pump Station. V. Aerial line 'ust north of the 1-40 Pump station that crosses Stony Fork Creek. B. Pump Stations: The Town has 11 duplex pump stations. The following four were visited during this site inspection, with comments: South Walton Pump Station (#7); This pump station replaced the old Dutch inn Pump Station. This should be ul2dated on the Town's Pump Station List and in the next permit renewal application. Please submit an updated Pump Station List as part of our response to this report. This list should include the name of the Pump station and the numbers that appear on the pump stations' signs. ii. Chicopee Pump Station (#6): The alarms on this system worked, but the audible alarm was very quiet. Please check to see if the volume of this.nump station can be increased. Also the visual alarm is very small. It is recommended that visual alarms installed in the future are larger. Boardwalk Pump Station (#9): There was excessive grease in this pumostation. Grease should be removed from the wet well and the floats. Also the audible alarm did not work. This should be fixed this alarm does not need to be very loud as it is in a neighborhood and in the front yard of a residence . iv. 1-40 Pump Station: As mentioned above, it is recommended that visual alarms installed in the future are larger than the one present at this site. 3of4 Town of Benson's Wastewater Collection System Compliance Evaluation NOD-2019-PC-0104 Permit No. WQCS00109 The following items that are underlined above should be addressed in a written response submitted to this office within 30 days after receiving this Notice of Deficiency: III.B.i-ii III.D-J HIM IV.A.iii-v, IV.B.i-iii. If you have any questions regarding the report or any of the findings, please contact Jason Robinson at: (919) 791- 4200 (or email: Jason.t.robinson ncdenr. ovj. Rick Bolich, L.G., Assistant Regional Supervisor Water Quality Regional Operations Section Raleigh Regional Office Division of Water Resources, NCDEQ ATTACHMENTS Inspection Checklist Cc: Central Files w/attachment Raleigh Regional Office w/attachment Tim Robbins, Public Works/Utilities Director: trobbins(@townofbenson.com 4 of 4 Compliance Inspection Report Permit: VVQCS00109 Effective: ❑F fl 1.-15 Expiration: 06130123 Owner : Town of Benson SOC: Effective: Expiration: Facility: Benson Collection System County: Johnston PO Box fig Region: Raleigh Benson NC 275040069 Contact Person: Don H -'r.hnscn Tilfe: Phone: 919-894-9508 Directions to Facility: System Classifications; CS2 Primary ORC: Jeremy Alan Bryant Certification: IO03457 Phone_ 919-894-2373 Secondary ORC(s): Bran Peter Leavitt 1003433 919-894-2373 On -Site Representative(s): Related Permits: NCO020389 Town of Benson - Benson VAMP Inspection Date: 04/11/2019 Entry Time: 01 COPM1 Exit Time: 03 30Pb1 Primary Inspector: Jason T Robinson /f� ylZSI1� Phone: +�l �� 7p/- WO 0 Secondary Inspector(s): 7 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 Performance Standards Operation & Mamt Reqmts Records Mlonitoring & Rpting Reqmts Inspections (See attachment summary) Page 1 of 7 Permit: WOCSO0109 Owner - Facility: Town of Benson Inspection Date: 04111 i2019 Inspection Type : Ccllectmn System I-spect Non Sampling Reason for Visit: Routine Inspection Summary I Permit Information A. The most recently issued permit (July 1, 2018? states that The City of Benson operates a wastewater collection system consisting of approximately 32 miles of gravity sewer. approximately 6 miles of forcemain, 11 duplex pump stations and 32 simplex pump stations The current permit expires on June 30. 2023. A renewal application should be submitted at least 180 days prior to expiration. Operator information A The collect on system is classified as a CS-2 Jeremy Bryant is the Tawn's designated Primary Operator in Charge (ORC). Brian Leavitt is the backup Operator in Respcm!sible Charge (bORC). Both are certTed CS-2 operators. III Records Documents were reviewed with Town staff at the Benson Public Works facility at 501 N. Markel St. Findings are described below A. Ordinance;Charter: A Sewer Use Ordinance+Chatter was available that addresses sewer construct on, grease control. sept,c tank installation and discharge by septic lank servlGe companies (T Ile V: Public Works, Chapter 52 Sewer). B. Fats, Oils and Grease i. A Public Education Program for Grease should be implemented that includes distrbuling education material to residential and non-residential users at least twice per year (Section 1.5 of permit). ii. A Fats, Oils and Grease Trap Program for non-residential users should be implemented that includes regular grease trap interceptor inspections and enforcement against users who have not properly installed traps or who fa I to properly operate and maintain these units. {Section 1.5 of permit) C. Capital Improvement Plan {CIP). An adequate GIP was available (Section 1.6). D- Collection System Map A map was available that showed the pipe size. material, flow direction and pump stations. Thas map shall be maintained to be up-to-date. accurate and comprehensive. It is recommended the legend text be edited to describe the pipes as a wastewater collection system -nstead of the currently shown 'Water' (Section 1113 of permit). E. High -Priority lines Documentation should be kept that demonstrates that all high-prority lines are inspected at least twice per year as required by the permit (Section VA of permit). F. Annual Inspection: A program should be implemented to ensure that the entire system is inspected at least once every year. Records should be kept to demonstrate this (Section V.3 of permit). G Right-cf-Way 1 Easements Documentation should be kept that descr bes all maintenancelclear'.ng of the systems righ t-of-wayfea se ments (Section 11.7 of permit). H- System Cleaning The permit requires that at least 10% of the system is cleaned annually. and the entire system is cleaned every 10 years, The Town should implement a program to ensure this is done. and documentation should be kept that describes what portion has been cleaned, when and when future portions will be cleaned (Section 11.8 of the permit). I. Maintenance Records: Records should be kept for all maintenance done to the system (see Citizens' complaints below). Page 2 of 7 Permit: WOCS00159 Owner -Facility: Town of Benson Inspection Date: 04!+ 112019 Inspection Type: Collection System Inspect Non Sampl ng Reason for Visit: Routine J. Spilt Response Action Plan A plan for address ng SSOs was ava table for review The plan should be updated to include 24-hour contact numbers response time, a I.st of equipment and spare parts and their location source(s) of emergency funds and how cleanup and post -spill assessment shall be condur--ted (Section 11.9 of perm t). K. Sanitary Sewer Overflows (SSOs) SSO 5-day reports were available for review Any press releases and public notices associated with the SSOs should be kept with these records (Section 111.2 & IV 2 of permit) L. Citizens Compla.nts Work orders associated with citizens' compla nts were available for review M. Annual Report. An annual report should be developed at the end of the calendar,fiscal year and distributed to users, as described in G.S. 143-215.1C (Section IV.3 of permit} IV. Collection System Inspection A. High Priority Lines The Towns permit I sts 7 high priority lines. The following High Priority Lines were observed during the inspection i. NC Hwy 50 (East Main St.) to Fayetteville Street at Taco Bell ii, Martin Street Aerial line across Driving Branch iii. John Deer Aerial Lane to 140 Federal Road Lift Station Please clear the s de of this easement closest to the 140 pump station, including remov ng the downed tree for qu•ck access ,n the event of an SSO. The following lines were found that should be designated as high -prior ty lines but are not included in the Town's list. These lines should be added to the Towns H gh Priority Line List and included in the next permit renewal application. along with any other lines in the system that meet the definition of h gh priority Ines ? Section V 4 of permit) Please submit an updated list of high -priority lines: iv, Exposed gravity line in the stormwater ditch across from the Chicopee Pump Station. v. Aerial line just north of the 1-40 Pump station that crosses Stony Fork Creek, B. Pump Stations: The Town has 11 duplex pump stations. The following four were visited during this site inspection. with comments: i. South Walton Pump Station (#7): This pump station replaced the old Dutch Inn Pump Station, This should be updated on the Town's Pump Station List and in the next permit renewal application. Please submit an updated Pump Station List as part of your response to this report. This list should include the name of the pump station and the numbers that appear on the pump stations' signs. ii. Chicopee Pump Station (#6): The alarms on this system worked, but the audible alarm was very quiet. Please check to see if the volume of this pump station can be increased. Also, the visual alarm is very small. It is recommended that visual alarms installed in the future are larger. iii, Boardwalk Pump Station (#9): There was excessive grease in this pump station. Grease should be removed from the wet well and the floats. Also, the audible alarm did not work. This should be fixed (this alarm does not need to be very loud. as it is in a neighborhood and in the front yard of a residence). iv. 1-40 Pump Station: As mentioned above, it is recommended that visual alarms installed in the future are larger than the one present at this site. Page 3 of 7 Permit: VVQCSO0109 Owner • Facility: Town of Benson Inspection Date: 0411112019 Inspection Type: Collection System Inspect Non Sampling Reason for Visit: R auune Performance Standards Is Public Education Program for grease established and documented? What educational tools are used? Material should be developed and distributed to users at least twice per year 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 permiltee, 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 Vmaster 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 $9 3 mil budget through 2027. Is system free of known points of bypass? It 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 9 Do ALL pump stations have an "auto polling" featureiSCADA? Number of pump stations Number of pump stations that have SCADA Number of pump stations that have simple telemetry Yes No NA NE ❑■❑❑ ■❑❑❑ E ❑ ❑ ❑ ■❑❑❑ ❑ ❑ E ❑ • ❑ 110 • ❑ ❑ ❑ ■ ❑❑❑ ❑ ❑ ❑ ❑ ❑ ❑ * ❑ ❑ ❑ ❑ ❑ ❑ M ❑ ❑ ❑ ❑ 110 $930 000 00 11010101 ❑ ❑ ❑ ❑ 1111 • ❑ ❑ ❑ • ❑ ❑ ❑ Page 4 of 7 Permit: W00500109 Owner - Facility: Town of Benson Inspection Date: 0411112019 Inspection Type - Collection system nspe_t No• 5ar.plm9 Reason for Visit Routine Number of pump stations that have only audible and visual alarms 0 Number of pump stations that do not meet permit requirements 0 # Does the permitlee have a root control program? ❑ ❑ ❑ # If yes date implemented? Describe - Roots addressed as needed. Comment: Inspections Yes No NA NE Are maintenance records for sewer lines available? ❑ ❑ ❑ Are records available that document pump station nspections7 ❑ ❑ ❑ Are SCADA or telemetry equipped pump stations nspected at least once a week? ❑ ❑ Are non-SCADAItelemetry equipped pump stations mspe :trd every day? ❑ ❑ 0 ❑ Are records available that document citizen complaints? ❑ ❑ ❑ # Do you have a system to conduct an annual observation of enl re system? ❑ ■ 0 ❑ # Has there been an observation of remote areas in the last year? ❑ Are records available that document inspections of high -prior ly lines? ❑ . ❑ ❑ Has there been visual inspections of high -priority lines to last six months? M ❑ ❑ ❑ Comment: Need to start keeping explicit records showing entire system has been inspected annually. high phoiEty lines have been insl2ected every, 6 months. etc. 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, ma nlenance> & operations logs and problem areas? Town to start keeping log books for all inspect ons that will be reviewed by the supervisor on a regular basin. Are maintenance records for equipment available? Is a schedule maintained for testing emergencylstandby 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 w10 pump reliability? Are maintenance records for right-of-ways available Are righl-of-ways currently accessible in the event of an emergency? ❑ ❑ ❑ ❑ ❑ ❑ At least twice a month M ❑ ❑ ❑ ■❑❑❑ ■❑❑❑ ■❑❑❑ ■❑❑❑ ❑ M ❑ ❑ ■❑❑❑ Page 5 of 7 Permit WQCS00109 Owner • Facility: Town of Benson Inspection Date: 04711+2019 Inspection Type: Collection System Inspect Non Sampl ng Reason for Visit: Routine Are system cleaning records available') 0 ❑ ❑ ❑ Has at least 10% of system been cleaned annually? M ❑ ❑ Cl 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 ❑ 0 ❑ ❑ Response time ❑ M ❑ ❑ Equipment list and spare parts nventory ❑ M ❑ ❑ Access to cleaning equipment M ❑ ❑ ❑ Access to construction crews. contractors. and/or engineers ❑ M ❑ ❑ Source of emergency funds ❑ 0 ❑ ❑ Site sanitation and cleanup maler als ❑ ❑ ❑ Post-overflowlspill assessment ❑ ❑ ❑ Is a Spill Response Action Plan available for all personnel? ❑ 0 ❑ ❑ Is the spare parts inventory adequate? M ❑ ❑ ❑ Comment. Spill Response plan was available but needs some additions and should be distributed to all staff. Records Yes No NA NE Are adequate records of all SSOs, spills and compla nts available? M ❑ ❑ ❑ Are records of SSOs that are under the reportable threshold available? ❑ ❑ M ❑ Do spill records indicate repeated overflows (2 or more in 12 months) at same location? M ❑ ❑ ❑ If yes. is there a corrective action plan? ❑ ❑ M ❑ Is a map of the system available? 0 ❑ ❑ ❑ Does the map include: Pipe sizes 0 ❑ ❑ ❑ Pipe materials 0 ❑ ❑ ❑ Pipe location 0 ❑ ❑ ❑ Flow direction M ❑ ❑ ❑ Approximate pipe age ❑ 0 ❑ ❑ Number of service taps ❑ M ❑ ❑ Pump stations and capacity M ❑ ❑ ❑ If no what percent is complete? List any modifications and extensions that need to be added to the map Chage "water lines" to "sewer lines" in map legend A Does the permiltee have a copy of their permit? 0 ❑ ❑ ❑ Comment: Page 6 of 7 Permit: W4csoolo9 Owner -Facility: Town of Benson Inspection Date: 04111/2019 Inspection Type: Collection System Inspect Non Sampling Reason for Visit: R,W;,no Monitoring and Reporting Requirements Are copies of required press releases and distribution lists available? Are public notices and proof of publication available? # Is an annual report being prepared in accordance with G.S. 143-215 1C? # Is permittee compliant with all compliance schedules in the permits? If no, which one(s)? Keep 5-day reports for SSOs and press releases 1 pubbic notices. Prepare an annual report at end of calendar or fiscal year. Comment: Yes No NA NE ❑ ❑ ❑ ❑ ❑ ❑ Page 7 of 7