WQCS00227_CEI Report & NOD2021PC0462_20210908

September 08, 2021

Don Denton
Carolina Water Service Inc of North Carolina
4944 Pwky Plz Blvd
Ste 375
Charlotte, NC 28217

SUBJECT: NOTICE OF DEFICIENCY
Tracking Number: NOD-2021-PC-0462
Permit No. WQCS00227
Fairfield Sapphire (form. Jackson Utility) Collection System
Jackson County

Dear Permittee:

The North Carolina Division of Water Resources conducted an inspection of the Fairfield Sapphire (form. Jackson
Utility) Collection System on August 25, 2021. This inspection was conducted to verify that the facility is
operating in compliance with the conditions and limitations specified in Collection System Permit No. WQCS00227.
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
Asheville Regional Office. The following deficiency(s) was noted during the inspection:
Inspection Area Description of Deficiency _________________________________________________________________________________________________________________________________________________________________________
Sewer and FOG Ordinances The permittee has not developed and implemented a Sewer Use Ordinance or an enforceable
FOG program as required per Permit Conditions Part I, Sections 4 and 5. _________________________________________________________________________________________________________________________________________________________________________

DocuSign Envelope ID: D4CF6587-93FA-4AE5-9643-8FC5250DD1C1

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 Stephanie Williams with the Water Quality
Regional Operations Section in the Asheville Regional Office at 828-296-4500.

Sincerely,

Daniel Boss, Assistant Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ

ATTACHMENTS: Inspection Report

Ec: Laserfiche, Stacy Adcock (Area Manager)
DocuSign Envelope ID: D4CF6587-93FA-4AE5-9643-8FC5250DD1C1
Compliance Inspection Report
Permit:WQCS00227 Effective:12/01/13 Expiration:11/30/21 Owner :Carolina Water Service Inc of North Carolina
SOC:
Contact Person:
Region:
County:
Directions to Facility:
Jackson
Asheville
Tony Konsul
Effective:Expiration:Facility:Fairfield Sapphire (form. Jackson Utility) Collection System
PO Box 240908
Charlotte NC 282240908
Title:Phone:[phone]Regional Manager
Secondary ORC(s):
Phone:Certification:Primary ORC:
CSNC,System Classifications:
On-Site Representative(s):
Related Permits:
NC0022985 Carolina Water Service Inc of North Carolina - Fairfield Sapphire Valley WWTP
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
08/25/2021 10:00AM 02:00PM
Stephanie A Williams 828-296-4500
Facility Status:
Permit Inspection Type:
Reason for Inspection:Inspection Type:
Not CompliantCompliant
Routine
Collection system management and operation
Collection System Inspect Non Sampling
Question Areas:
Miscellaneous Questions General Sewer & FOG Ordinances
Capital Improvement Plan Map Reporting Requirements
Inspections Spill Response Plan Spills
Lines Manholes Pump Stations
(See attachment summary)
Page 1 of 7
DocuSign Envelope ID: D4CF6587-93FA-4AE5-9643-8FC5250DD1C1
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00227
08/25/2021 Collection System Inspect Non Sampling
Carolina Water Service Inc of North Carolina
Routine
Inspection Summary:
Stephanie Williams, with the Asheville Regional Office, conducted a Compliance Evaluation Inspection of the Fairfield
Sapphire Collection System on August 25, 2021. This inspection was conducted to determine if the system is being
operated and maintained in compliance with permit no. WQCS00227. Stacy Adcock (Area Manager) and Flint Plant (ORC)
were present during the inspection.
The Collection System carries an average annual flow of 0.13 MGD and consists of 3 miles of gravity sewer and 6.5 miles of
force main, with 47 lift stations – 46 duplex stations and 1 simplex station which serves one building. Lines are mostly PVC
with ductile iron used for high priority lines. There are plans to break ground on a new single batch reactor wastewater
treatment plant in 2022.
Lift Station 40 was inspected and appears to have limited accessibility, which may present an issue in an event where a
pump truck needs to access the site. Opening the sharp turn by removing one or more trees may alleviate some of these
accessibility issues.
The facility is currently not in compliance because the utility has not developed and implemented a Sewer Use Ordinance or
an enforceable FOG program as required by Permit Conditions Part I, Sections 4 and 5.
Current Projects:
The utility is currently adding approximately 0.5 miles of line at Lonesome Valley.
Lift Stations: There are currently 5 lift stations with stationary generators – LS 8, LS 14, LS 44, LS 45, and LS 46, and 2 lift
stations with existing quick connections – LS 32 and LS 47. The Utility currently has 2 pull behind portable generators for
the system, which must be hard wired for use at the 40 lift stations with no stationary generator or quick connection in
place. Stationary generators are being added at lift stations 40 and 41, and the pumps at lift station 41 are being converted
from dry to submersible pumps. All other lift stations that do not already have a stationary generator or a quick connect will
be affixed with quick connections, and two small portable generators will be purchased.
Collection System Study: The Utility is conducting a study of the Collection System – a camera has been used to identify
problem areas on gravity lines that will be addressed by the end of 2021.
Page 2 of 7
DocuSign Envelope ID: D4CF6587-93FA-4AE5-9643-8FC5250DD1C1
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00227
08/25/2021 Collection System Inspect Non Sampling
Carolina Water Service Inc of North Carolina
Routine
General Yes No NA NE
Is there a properly designated primary ORC and at least one back-up of proper grade?
Are logs being reviewed by the system management or owner on a regular basis?
# What is that frequency?Quarterly
# Are there any issues being addressed currently or any in the planning stages?
Is there a specific pump failure plan available for all pump stations?
Does plan indicate if pump parts/new pumps are in spare parts/equipment inventory?
Are new/significantly upgraded pump stations equipped with anti-corrosion materials?
Does the permittee have a copy of their permit?
# Is permit expiring within the next 6 months?
If Yes, has the Permittee applied for renewal?
Comment:
Sewer and FOG Ordinances Yes No NA NE
Is Sewer Use Ordinance (SUO) or other Legal Authority available?
Does it appear that the Sewer Use Ordinance is enforced?
Is there a Grease Control Program that legally requires grease control devices?
What is the standard grease trap cleaning requirement in the FOG ordinance?
Is Grease Control Program enforced via periodic inspections/records review?
Is action taken against violators?
# Have satellite systems adopted an equivalent or more stringent ordinance?
Is grease/sewer education program documented with req'd customer distribution?
# Are other types of education tools used like websites, booths, special meetings, etc?
If Yes, what are they? (This can reduce mailing to annual.)
The permittee has not developed and implemented a Sewer Use Ordinance or an enforceable
FOG program as required per Permit Conditions Part I, Sections 4 and 5.
Comment:
Capital Improvement Plan Yes No NA NE
Has a Capital (CIP) or System Improvement Plan been developed and adopted?
Is it designated for wastewater only or does it have a dedicated section?
Does CIP cover three to five year period of earmarked improvements?
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?
Comment:
Map Yes No NA NE
Page 3 of 7
DocuSign Envelope ID: D4CF6587-93FA-4AE5-9643-8FC5250DD1C1
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00227
08/25/2021 Collection System Inspect Non Sampling
Carolina Water Service Inc of North Carolina
Routine
Is there a overall sewer system map?
Does the map include:
Pipe Type (GS/FM)
Pipe sizes
Pipe materials (PVC, DIP, etc)
Pipe location
Flow direction
Approximate pipe age
Pump station ID, location and capacity
# Force main air release valve location & type
# Location of satellite connections
Is the map being updated for changes/additions within 1 year of activation?
Comment:
Reporting Requirements Yes No NA NE
# Have there been any sewer spills in the past 3 years?
If Yes, were they reported to the Division if meeting the reportable criteria?
If applicable, is there documentation of press releases and public notices issued?
Is an Annual Wastewater Performance Report being filed with the Division, if required?
Is the report being made available to all its sewer customers?
# How is it being made available?Website
Comment:
Inspections Yes No NA NE
Are adequate maintenance records maintained?
Are pump stations being inspected at the required frequency?
# Is at least one complete functionality test conducted weekly per pump station?
Is there a system or plan in place to observe the entire system annually?
Is the annual inspection documented?
# Does the system have any high-priority lines/locations?
Are inspections of HPL documented at least every 6 months?
Are new lines being added to the HPL list when found or created?
Comment:
Spill Response Action Plan Yes No NA NE
Is a Spill Response Action Plan available?
Is a Spill Response Action Plan available for all personnel?
Does the plan include:
Page 4 of 7
DocuSign Envelope ID: D4CF6587-93FA-4AE5-9643-8FC5250DD1C1
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00227
08/25/2021 Collection System Inspect Non Sampling
Carolina Water Service Inc of North Carolina
Routine
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
Does the Permittee appear to respond within 2 hours of first knowledge of a spill?
It is recommended that a source of emergency funds be added to the Spill Response Plan.Comment:
Spills Yes No NA NE
Is system free of known points of bypass?
If No, describe type of bypass and location
Are all spills or sewer related issues/complaints documented?
# Are there repeated overflows/problems (2 or more in 12 months) at same location?
# If Yes, is there a corrective action plan?
Comment:
Lines/Right-of-Ways/Aerial Lines Yes No NA NE
Please list the Lines/Right of Ways/Aerial Lines Inspected:
Lonesome Valley Rd, East Valley Rd
Are right-of-ways/easements maintained for full width for access by staff/equipment?
If No, give details on temporary access:
Is maintenance documented?
Are gravity sewer cleaning records available?
Has at least 10% of lines older than 5 yrs been cleaned annually?
Were all areas/lines inspected free of issues?
At the time of the inspection, the Utility was waiting on results from the line inspections.Comment:
Manholes Yes No NA NE
Please list the Manholes Inspected:
MH 41, MH 77
Are manholes accessible?
# Are manhole covers/vents above grade?
Are manholes free of visible signs of overflow?
Are manholes free of sinkholes and depressions?
Are manhole covers present?
# Are manholes properly seated?
Page 5 of 7
DocuSign Envelope ID: D4CF6587-93FA-4AE5-9643-8FC5250DD1C1
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00227
08/25/2021 Collection System Inspect Non Sampling
Carolina Water Service Inc of North Carolina
Routine
# Are manholes in good condition?
# Are inverts in good condition?
Is flow unrestricted in manholes?
Are manholes free of excessive amounts of grease?
Are manholes free of excessive roots?
Are manholes free of excessive sand?
Are manhole vents screened?
Are vents free of submergence?
Are manholes free of bypass structures or pipes?
Comment:
Pump Stations Yes No NA NE
Please list the Pump Stations Inspected:
Lift Station 8, LS 40, LS 41
# Number of duplex or larger pump stations in system 46
# Number of vacuum stations in system 0
# Number of simplex pump stations in system 1
# Number of simplex pump stations in system serving more than one building 0
How many pump/vacuum stations have:
# A two-way "auto polling" communication system (SCADA) installed?47
# A simple one-way telemetry/communication system (auto-dialer) installed?0
For pump stations inspected:
Are they secure with restricted access?
Were they free of by-pass structures/pipes?
Were wet wells free of excessive grease/debris?
# Do they all have telemetry installed?
Is the communication system functional?
Is a 24-hour notification sign posted ?
Does the sign include:
Owner Name?
Pump station identifier?
# Address?
Instructions for notification?
24-hour emergency contact numbers?
Are audio and visual alarms present?
Are audio and visual alarms operable?
# Is there a backup generator or bypass pump connected?
Page 6 of 7
DocuSign Envelope ID: D4CF6587-93FA-4AE5-9643-8FC5250DD1C1
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00227
08/25/2021 Collection System Inspect Non Sampling
Carolina Water Service Inc of North Carolina
Routine
If tested during inspection, did it function properly?
Is the back-up system tested at least bi-annually under normal operating conditions?
# Does it have a dedicated connection for a portable generator?
# Is the owner relying on portable units in the event of a power outage?
# If Yes, is there a distribution plan?
If Yes, what resources (Units/Staff/Vehicles/etc) are included in Plan?
# Does Permittee have the approved percentage of replacement simplex pumps?
Is recordkeeping of pump station inspection and maintenance program adequate?
Do pump station logs include at a minimum:
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?
Pump lubrication is only required at lift station 41 and is completed by a contractor because the
pumps are located in a confined space. The pumps at this lift station will be replaced by the
end of 2021 and will no longer require lubrication. See summary for details.
Comment:
Page 7 of 7
DocuSign Envelope ID: D4CF6587-93FA-4AE5-9643-8FC5250DD1C1