WQCS00039_NOD-2022-PC-0001 & CEI Report_20220103

SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED.

January 03, 2022

Gary Caldwell, Mayor
Town of Waynesville
Email: [e-mail]

SUBJECT: NOTICE OF DEFICIENCY
Tracking Number: NOD-2022-PC-0001
Permit No. WQCS00039
Waynesville Collection System
Haywood County

Dear Permittee:

The North Carolina Division of Water Resources conducted an inspection of the Waynesville Collection System on
December 9, 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. WQCS00039. 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 _________________________________________________________________________________________________________________________________________________________________________
Reporting Requirements Annual Wastewater Performance Reports have not been submitted. _________________________________________________________________________________________________________________________________________________________________________
Lines/Right-of-Ways/Aerial High priority line inspections are not being documented. _________________________________________________________________________________________________________________________________________________________________________

DocuSign Envelope ID: D307D8DC-E267-4E9F-9216-BDDD8EA6AE47

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 Lauren Armeni with the Water Quality
Regional Operations Section in the Asheville Regional Office at 828-296-4667.

Sincerely,

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

ATTACHMENTS: Inspection Report

Ec: Laserfiche
Jeff Stines (Public Services Director/ORC)
Ricky Foster (Assistant Public Works Director)
Wayne Bolin (Water & Sewer Superintendent/ORC in-training)
DocuSign Envelope ID: D307D8DC-E267-4E9F-9216-BDDD8EA6AE47
Compliance Inspection Report
Permit:WQCS00039 Effective:03/17/16 Expiration:11/30/23 Owner :Town of Waynesville
SOC:
Contact Person:
Region:
County:
Directions to Facility:
Haywood
Asheville
Preston Gregg
Effective:Expiration:Facility:Waynesville Collection System
PO Box 100
Waynesville NC 287860100
Title:Phone:[phone]Town Engineer
Secondary ORC(s):
Phone:Certification:Primary ORC:
CS2,System Classifications:
On-Site Representative(s):
Related Permits:
NC0025321 Town of Waynesville - Waynesville WWTP
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
12/09/2021 09:45AM 12:15PM
Lauren E Armeni 828-296-4500
Julia Byrd
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
(See attachment summary)
Page 1 of 6
DocuSign Envelope ID: D307D8DC-E267-4E9F-9216-BDDD8EA6AE47
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00039
12/09/2021 Collection System Inspect Non Sampling
Town of Waynesville
Routine
Inspection Summary:
Lauren Armeni with the Asheville Regional Office and Julia Byrd with the Central Office conducted a Compliance Evaluation
Inspection of the Waynesville Collection System on December 9, 2021. This inspection was conducted to determine if the
system is being operated and maintained in compliance with permit no. WQCS00039. Jeff Stines (ORC), Wayne Bolin (ORC
in-training), and Ricky Foster (Assistant Public Works Director) were present and assisted in the inspection.
The Town of Waynesville is currently under an SOC, which requires I&I mitigation and quarterly reports to document
progress.
Projects:
In 2019 and 2020, McGill and Associates conducted a sewer smoke study for the Town of Waynesville to identify problem
areas of the collection system that may be experiencing I&I. The Town of Waynesville assisted McGill in testing over 10,000
linear feet (LF) of gravity sewer lines. Upon finding problem areas within the system, the Town replaced approximately 1,100
LF of existing terracotta pipe including 4", 6", and 8" pipe.
Internally, the Town has inspected approximately 3,000 LF of sewer lines via CCTV, which has helped them identify areas
that may cause I&I into the collection system, and can be added to the CIP as additional projects.
From December 2020 to June 2021, approximately 4,340 LF of terracotta/clay pipe was replaced, as stated in the SOC
Semi-Annual Progress report dated June 24, 2021. Additional projects are outlined in the 10-Year CIP to mitigate I&I within
the collection system to ultimately reduce the inflow at the WWTP to extend its life, as a new WWTP for the Town is
currently in the bidding process.
Mr. Stines and Mr. Bolin indicated that a large amount of terracotta pipe will need to be replaced at the Waynesville Country
Club and that these lines are contributing to a significant amount of I&I in the system. Upon replacing these lines, there will
be an overall reduction in flow contributions from I&I at downstream lines. This project is a top priority for the Town and
includes eliminating/reducing as much I&I upstream of the fairgrounds as possible.
CIP:
The 10-Year CIP will address specific collection system issues found during the smoke testing conducted by McGill
Associates in 2019 and 2020. Future collection system testing will be conducted to further pinpoint areas of concern. The
Town is also planning on an annual comprehensive inspection and maintenance program to identify and eliminate I&I by
locating manholes that need replaced, root intrusion, and/or broken pipes. Mr. Stines indicated that $300,000 has been
allocated in the budget specifically for I&I mitigation. The CIP outlines the specific subdivisions that the Town will focus on
throughout the next ten years, and additional areas may be added as issues are uncovered.
Reporting Requirements:
The Annual Wastewater Performance Report has not been submitted since at least 2019. An Annual Report is required for
systems with an average annual flow greater than 200,000 gallons per day. This report should summarize the performance of
the collection system or treatment works, as well as permit violations within that year.
Lines/Right of Ways/Aerial Lines:
High priority lines are being inspected, but the inspections are not being documented. All inspections need to be
documented, including documentation of gravity sewer cleaning and inspections of high priority lines. The old bridge piers
next to the aerial line across Richland Creek are still there, but staff keep an eye on this area after storms and remove
debris as needed. It was previously discussed that these piers may be removed, but that does not appear to be a priority
right now.
The following deficiencies were noted during the inspection:
1. Annual Wastewater Performance Reports have not been submitted, which are required per NC General Statute
143-215.1C.
2. High priority line inspections are not being documented.
Page 2 of 6
DocuSign Envelope ID: D307D8DC-E267-4E9F-9216-BDDD8EA6AE47
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00039
12/09/2021 Collection System Inspect Non Sampling
Town of Waynesville
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?The Town uses a
work order
program, Public
Works, to log and
review
maintenance. Mr.
Stines makes
annotations of
problem areas
within the system.
Orders are closed
out once resolved.
# 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?
Projects include continuing to replace old terra cotta lines that are significantly contributing to
I&I in the system. See summary for details.
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?See below.
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 Town will be adding grease/sewer education to their website.
There is no specific grease trap cleaning requirement as of right now, but the Town is currently
working with code enforcement to implement cleaning requirements for restaurants with grease
traps and to have them provide a cleaning receipt quarterly.
Comment:
Capital Improvement Plan Yes No NA NE
Has a Capital (CIP) or System Improvement Plan been developed and adopted?
Page 3 of 6
DocuSign Envelope ID: D307D8DC-E267-4E9F-9216-BDDD8EA6AE47
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00039
12/09/2021 Collection System Inspect Non Sampling
Town of Waynesville
Routine
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?
The most recent ten-year CIP was adopted October 2020. The CIP outlines projects that the
Town of Waynesville will complete based on the I&I study performed by McGill Associates in
2019 and 2020. See summary for details.
Comment:
Map Yes No NA NE
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?
The last 10% of the collection system lines have been added to the ArcGIS map.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?
The Town is aware of the new press release requirement and has been abiding by it. The new
Assistant Town Manager, Jesse Fowler, is contacted after a spill to prepare a public notice or
press release within 24 hours. The Town has not been submitting the required Annual
Wastewater Performance Report. See summary for details.
Comment:
Inspections Yes No NA NE
Are adequate maintenance records maintained?
Are pump stations being inspected at the required frequency?
Page 4 of 6
DocuSign Envelope ID: D307D8DC-E267-4E9F-9216-BDDD8EA6AE47
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00039
12/09/2021 Collection System Inspect Non Sampling
Town of Waynesville
Routine
# 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?
All inspections of the system need to be documented, including the annual inspection, high
priority line inspections, and any jetting conducted on the lines. No lift stations are under
Waynesville's CS permit. The Richland Creek pump station, which services JSD, is no longer
being maintained by the Town.
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:
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
Yes No NA NE
Does the Permittee appear to respond within 2 hours of first knowledge of a spill?
Comment: The Spill Response Action Plan was recently revised.
Spills
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?
There were four SSOs at 9 Haywood Office Park in 2020. There has not been an SSO there
since October 2020. Mr. Stines believes the SSOs have stopped at this location as a result of
fixing the surrounding I&I issues.
Comment:
Lines/Right-of-Ways/Aerial Lines Yes No NA NE
Please list the Lines/Right of Ways/Aerial Lines Inspected:
1. Country Club
2. Eagle's Nest Road/Sulphur Springs Road
3. Across Richland Creek
Page 5 of 6
DocuSign Envelope ID: D307D8DC-E267-4E9F-9216-BDDD8EA6AE47
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00039
12/09/2021 Collection System Inspect Non Sampling
Town of Waynesville
Routine
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?
High priority lines are being inspected once every six months and after heavy storms, but these
inspections are not being documented. See summary for details.
Comment:
Manholes Yes No NA NE
Please list the Manholes Inspected:
1. George Street/South Main Street
2. Georgia Avenue/Brown Avenue
3. 129 Will Hyatt Road aboveground and next to an unnamed tributary
4. Eagle's Nest Road/Sulphur Springs Road
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?
# 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?
The manhole at 129 Will Hyatt Road is above ground and next to an unnamed tributary.
Sediment build-up was noted will need to be cleaned out.
The manhole at Eagle's Nest Road/Sulphur Springs Road will need to be cleaned out due to an
excess build-up of toilet paper that's partially obstructing flow. There was an SSO directly
downstream of this manhole in September 2021 that contributed to this build-up.
Comment:
Page 6 of 6
DocuSign Envelope ID: D307D8DC-E267-4E9F-9216-BDDD8EA6AE47