FAQs for Collection System Permittees
General Permitting Questions
Why Is there a Permit Program For System-wide Collection Systems?
This program grew from the realization that collection systems have outlived their useful life without any continual reinvestment for extending the life. This has led to an increase in Sanitary Sewer Overflows (SSOs) that potentially degrade water quality and threaten human health and wildlife. Since the Division implemented enforcement procedures and spill response measures in the late 90's, there have been great strides in the awareness and benefits of operating a collection system in a proactive and preventative way instead of a reactive way. However, the Division has not always issued permits for sewer extensions. Therefore, a permit program, developed through a stake holders group and federal rules, was necessary to encompass entire collection systems that were never permitted and have often gone unmanaged since installation.
Isn't My Collection System Covered Under My NPDES Permit?
There is a proper operation and maintenance clause in your NPDES permit. However, the collection system permit serves as a more defined extension of that clause. These permits are linked together upon issuance and renewal of each.
What Is In This Permit?
The system wide collection system permit contains five sections: performance standards, operation and maintenance, inspections, record keeping and general conditions. The focus is to become proactive and preventative in operating and maintaining the collection system instead of simply reacting to problems. Therefore, there are conditions for grease control, planned reinvestment into the system through a formal Capital Improvement Plan, alarms for pump stations, spare parts, inspections, cleaning, mapping, observation, preventative maintenance and everything needs to be documented through proper record keeping. The main condition for which all others support is the prohibition of sanitary sewer overflows (SSOs). SSOs are not forgiven unless the Permittee submits justification that the SSO was beyond their control. A copy of the permit shell can be downloaded from our applications page.
What Information Is Available That May Help Me With This New Permit?
Our web site (http://portal.ncdenr.org/web/wq/swp/ps/cs/apps) has the permit application (CSA 12-12), the permit shell, record keeping requirements and other information available for download. The Division continues to collect examples of grease ordinances, grease education material, operation and maintenance forms, Capital Improvement Plan guidance, annual reports and other pertinent collection information that will gladly be distributed upon request.
What If I Can't Comply With Everything In The Permit?
The Division realizes that most everyone may not be able to comply with certain permit conditions upon issuance of the permit. Therefore, in certain instances, compliance schedules decided upon by the applicant and agreed to by the Division will be incorporated into the permit to allow for time to acquire resources and develop programs in accordance with the permit conditions. For instance, if a grease educational program has not yet been developed as required in Condition I(4), a compliance date can be put with that particular condition to indicate when the program will be developed and implemented.
How Will Enforcement Work For Collection Systems If The New Permit Eliminates The Point System?
The Division is developing a guidance document for Condition I(2). A link will be posted upon issuance of the guidance document. Basically, with the elimination of the point system, no "good" points will exempt a collection system owner for enforcement on a Sanitary Sewer Overflow (SSO). Enforcement will be based on compliance with the collection system permit through submitted documentation that all preventable measures were taken to prevent the SSO and past compliance problems. It will also include reasonable judgement exercised by the Division regional office.
Is There A Fee Involved For This Permit?
Currently, an annual fee of $1160 will be charged for collection systems designed for less than 1 million gallons per day. Those over will be charged $1760. A bill will be sent by the Division and to be paid within thirty days of receipt. Fees for permits stay in the Division and fund our many water quality programs.
What Can I Expect From A Collection System Inspection?
The inspector will want to look at your record keeping and your comprehensive map as it relates to the permit conditions during the in-office portion. In the field portion, he or she will ask to see some pump stations where you may be asked to pull floats to test alarms or telemetry, open control panels, run pumps, run permanent generators under load, see spare parts and portable pumps and generators, etc. Portions of line will also be inspected so manholes will be popped. This is also an opportunity to look at and discuss any pertinent issues that may not quite fit into compliance with the collection system permit. The Division wants to assist you with compliance and has the resources to recommend potential solutions. Be sure to have your gloves, a manhole pick and any other tools to perform the above tasks.
The Permit Application Asks About Satellite Systems. What Is A Satellite System?
A satellite system is a collection system where wastewater conveyed by that collection system is sent to a nearby wastewater treatment facility owned by another entity (POTW). Typically, and hopefully, a formal agreement is in place that describes the connection points, allowable flow, method of flow monitoring and addresses enforcement if the collection system owner discharges wastewater into the POTW's collection system that causes that POTW to have SSOs or exceed permit limits.
If I Have More Than One Treatment Plant, Do I Need To Submit Separate Applications?
If the collection system is a contiguous system (i.e. in the same general location), only one application is necessary. Report information for the entire collection system as well as combined permitted and current flows. In some instances, a single entity owns collection systems and treatment plants in several locations throughout the state. These collection systems are total separate and has separate personnel involved in the operation and maintenance. Under this scenario, separate permit applications should be submitted. The Division will notify by certified letter as to when an application should be submitted.
Specific Questions Relating to A Permit Condition
Are Manhole Covers Considered Restricted Access?
Yes, but if vandalism becomes a problem, more restricted access such as a lock should be installed.
Are Bollards Required Around Above Ground Manholes And Other Collection System Features?
The Division highly recommends bollards if above ground features are being destroyed by being hit by mowers, equipment, ATV's, etc. The Permittee must do everything possible to prevent SSOs.
What Is The Division's Interpretation Of Telemetry And SCADA?
The Division thinks of telemetry what some term an "auto-dialer" for pump station alarm notification. A system hooked to a land based phone line that is programmed to dial numbers upon an alarm condition. There is no automatic check that communication is intact. SCADA is thought of by the Division as a more advanced alarm, or operating, notification system for pump stations. With SCADA, there is an automatic polling feature that routinely contacts each station to ensure communications are working. Additionally, some SCADA systems can provide remote control features for pump stations from a central location. Data is also logged electronically upon alarm conditions.
Other systems have recently been proposed that are not exactly an auto-dialer and not exactly SCADA. These are radio or cell based telemetry systems that communicate alarm conditions to a central dispatching location owned by the communications company with which a collection system owner hires or one in which the collection system owner is provided Internet access to view system information. In both instances, alarm conditions immediately signal directly to the collection system personnel via telephone, pagers, faxes, E-mails, pop up computer messages, etc. or to a central dispatch location which in turn contacts the collection system personnel. Report logs are stored for a specified amount of time (years) by the communications company which enables quick review and documentation for recurring problems. Typically, there is an installation fee and then a monthly fee involved in these systems. The Division may accept these systems as meeting Condition I(10) of the permit after a review of the manufacturer's information (see What Is The Requirement For Alarms?).
What Is The Requirement For Alarms?
Condition I(10) requires retrofit of audible and visual alarms on pump stations if SCADA is not present and even if an auto-dialer is present. Note that any permits for pump stations issued since the mid '80's required audible and visual alarms. It has been a common misconception that if an auto-dialer is installed, that the alarms can be removed or disabled. If alarms are in your permit, they should be present and functional.
The reason for requiring audible and visual alarms is that it shows that preventative measures are being taken to prevent an overflow, which is this permit program's goal. Secondly, upon review of the Division's spill database, maintained since 1998, it was discovered that spills did occur and were not promptly responded to because the auto-dialer failed. Reasons given for spills include: phone line was out, lightning struck the phone line, the auto-dialer was not functioning, the auto-dialer was disabled, etc. Therefore, the Division does not feel that alarm systems dependent on phone lines are reliable enough to avoid a secondary alarm back up such as the audible and visible alarms.
Note: The alarms do no good if they are not in a conspicuous location where they can't be seen or heard. Be sure they can achieve the benefit they were designed to provide.
My Pump Station Is So Remote That Audible And Visual Alarms Will Do Nothing. Why Do I Have To Install Them?
Are you positive that no one ever goes out there? Is it near an open field, trail, cemetery, land fill, park? If so, at some point, someone could be walking their dog, jogging, remembering a loved one, disposing of trash or participating in a sporting event nearby who may call if they hear and see those alarms (this is coupled with a condition to have emergency numbers and pump station ID's posted). At the very least, do cars drive by where they could see a flashing light? Without getting into the probability as to how often someone is nearby or whether they will call, it shows that you are doing everything you can to prevent an overflow. If it is truly a remote area, one recommendation is to run the alarms up to the beginning of the access road along with your sign. If that is not feasible, submit documentation and pictures to the Division for a variance for that particular pump station. It is beneficial if the pump station has had no overflow violations.
What If My Right Of Ways (Rows) Are Not Owned?
If a sewer line runs through another's property, the Division suggests speaking with the land owner and explaining the need for access in the event of an emergency. Ensure that any items destroyed (fence, grass, bush, etc.) will be replaced at your expense. If the land owner is difficult, it may be necessary to obtain a court order to get to a spill.
If Someone Builds A Permanent Structure In My Right Of Way, Can The Division Require It Be Removed?
Under the collection system permit, Condition II(7) requires accessible right of ways (see What Does Accessibility Mean When Referring to ROWs?). If a permanent structure is built without knowledge or even with knowledge, that impedes accessibility, the Division cannot personally require removal of the structure. The Division can assist in supporting the collection system owner in getting the structure removed by emphasizing the permit condition requirements and the consequences involved if a spill occurs that cannot be quickly noticed and stopped through correspondence with the collection system owner. This correspondence can be presented to the appropriate person(s) as support for why the structure should be removed. In some cases, the collection system owner may have to result in court actions.
What If A Line Is Under Wetlands Or A Lake Or On A Mountain Side?
Condition I(2) of the permit indicates that everything must be done to prevent an SSO. The Division realizes that it is difficult to get access to lines that are under water, wetlands or on steep slopes. In these worst case scenarios, the portions of these lines can be included in the permit.
What Does "Accessibility" Mean When Referring To Rows?
The intent is that all lines can be accessed with the equipment necessary to promptly clean up a spill or simply perform maintenance and/or repair of a sewer line. Heavy brush that cannot be walked through is not considered accessible. However, the Division does not require clear cutting of areas either. It is the Permittee's best judgement whether lines are accessible and what steps need taken to make them accessible such as removal of trees, etc.
What Is A High Priority Line?
According to the definition in 15A NCAC 02T.0402, a “High-priority sewer” means any aerial sewer, sewer contacting surface waters, siphons, sewer positioned parallel to streambanks that is subject to erosion that undermines or deteriorates the sewer, or sewer designated as a high priority line in a Division-issued permit (or Division-approved variance in accordance with 15A NCAC 02T.0105(n)) if the sewer does not meet minimum design requirements. A list of high priority lines should be submitted with your permit application. The permit upon issuance will include this list as part of the permit.
Is Sanitizing The Stream After A Spill Proper Procedure?
No. Adding anything to the stream except for clean water can potentially cause more harm and violate stream standards, resulting in further violations.
What Is An Acceptable Grease Education Program?
An acceptable grease education program is one in which information about why grease is bad for the collection system is prepared in a concise manner, distributed to residential and commercial customers and the distribution is documented. There are several methods of preparing and distributing grease information: flyers, door hangers, bill stuffers, newspaper publications, web site postings, brochures and posters posted in public areas such as the library, town hall, utility department billing office, grocery stores, etc. Some collection system owners have available funds to spot television advertisements, develop a grease "mascot" and paint information on buses and utility vehicles. These methods represent a range of solutions, some economical and some more costly. The Division expects each collection system owner to develop an effective grease education program within their budget. Documentation must be kept for a minimum of three years as to when and where this information was distributed.
We Don't Have A Grease Problem. Why All The Emphasis On Grease?
The Division hears this a lot. If you have had a spill due to a grease blockage, you have a grease problem whether it is major or minor. Nine times out of ten, the facilities reporting no grease problem have reported spills due to grease blockages. Part of being proactive and showing permit compliance is to have your program in place. In case something does occur, you'll have the documentation necessary to show that everything possible was done to prevent that spill.
We Have A Yearly Budget. Why Do We Need A Formal Capital Improvement Plan?
To properly operate and maintain your collection system, one needs to know where the deficiencies are, identify them and designate funding to correct those deficiencies for the long term in a formal, organized manner. Once these deficiencies are corrected, the collection system should have constant reinvestment simply to maintain and extend its useful life. One reason for the collection system permit program is that historically, collection systems are "out of sight, out of mind". Often the monies for collection systems are lumped together with the water system and wastewater treatment plant. Sometimes funds are not available for the collection system because it has been spent on these other items. If you bought a new car, would you never get an oil change or rotate your tires? Of course not. It is your investment and you want it to last as long as possible. Your collection system is an important investment that your employer and your customers pay. To exercise good stewardship, it should be properly maintained not only because money has been spent fixing it up, but also because proper O&M will make it last while protecting the environment, keeping user rates down and avoiding enforcement for water quality violations. The Capital Improvement Plan is a valuable tool for organizing and planning for your current and future investments.
Does My Comprehensive Map Need To Be Computerized?
The comprehensive map does not need to be computerized. Although, it would be a goal to plan for in the future due to the capabilities and benefits of computerized mapping. The intent of the comprehensive map is not that it fits all on one sheet, but that the collection system and all information associated with it (size, approx. age, flow direction, pipe material, approximate taps into line segments, pump station locations, names, capacities, etc.) is available in one central location. This will enable not only the current collection system personnel to quickly view information about the system to make decisions about line cleaning, ROW maintenance, rehabilitation needs, capacity issues, connection points for new flows, etc., but that someone in the future can come in and quickly become familiar with the system. The Division is not wanting to see a stack of unorganized as-built plans collecting dust in the corner or scattered between several locations as proper collection system O&M depends on knowledge of the entire system as a whole.
What Record Keeping Is Required For The Permit?
The Division does not dictate how these records are to be maintained, but the intent is that the information is quickly available by your collection system personnel and by the Division during an inspection. Proper planning when developing a record keeping system should be employed.