WQCSD0192_Roaring Gap_CEI_20220301

Compliance Inspection Report
Permit: WQCSD0192 Effective: 03/01/00 Expiration:
SOC: Effective: Expiration:
County: Alleghany
Region: Winston-Salem
Owner : Roaring Gap Club Inc
Facility: Roaring Gap Club Collection System
Contact Person: Randy Crouse Title: Facilities Maintenance Manager Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 03/01/2022
Entry Time 10:OOAM Exit Time: 12:OOPM
Primary Inspector: Patricia Lowery Phone: [phone]
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
II Spills/Response Plan
▪ Manholes
(See attachment summary)
▪ General
▪ Inspections
▪ Pump Stations
▪ Grease Control
▪ Lines
Page 1 of 7

Permit: WQCSD0192 Owner - Facility: Roaring Gap Club Inc
Inspection Date: 03/01/2022
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Inspection Summary:
Tricia Lowery of the NC Division of Water Resources, Winston-Salem Regional Office conducted a compliance evaluation
inspection of Roaring Gap collection system (WQCSD0192) on March 1, 2022. Randy Crouse (Facilities Maintenance
Manager) was present for the inspection. Results of the inspection are summarized in the following paragraphs:
15A NCAC 02T .0403 Permitting By Regulation
(a)(1) The collection system shall be effectively maintained and operated at all times to prevent discharge to land or surface
waters and to prevent any contravention of groundwater standards or surface water standards.
Observations: Overall the collection system is well maintained by Mr. Crouse. The only areas of concern were: Lack of
pump station and ROW maintenance logs. All other maintenance records are detailed and comprehensive.
Compliant: Non -compliant
(a)(2) A map of the collection system shall have been developed and shall be maintained.
Observations: Map has not been updated to reflect updates to collection system. The collection system underwent
rehabilitation, replacing all pipes in 2008. Pump stations were installed approximately 5 years ago. Maintenance manager,
Mr. Crouse, does have list of all pipes in the system, which include pipe size and pipe material, but this information is not
listed on map. Map needs to be updated to reflect changes to collection system.
Complaint: Non -compliant
(a)(3) An operation and maintenance plan, including pump station inspection frequency, preventative maintenance schedule,
spare parts inventory, and overflow response shall have been developed and implemented.
Observations: Spill response plan was revised July 2020. Everything is in good order. The O&M plan includes logbooks
documenting the monthly inspection of entire collection system, as well as pump station generator testing, line cleaning and
HPL inspections. Mr. Crouse inspects entire collection and HPLs more frequently than regulation states
(annually/biannually). However, there is no documentation of pump station inspections. Mr. Crouse will begin documenting
these inspections.
Compliant: Overall compliant with exception of pump stations.
(a)(4) Pump stations that are not connected to telemetry system shall be inspected by the permittee or its representative
every day, 365 days per year, unless the permittee demonstrates that the daily inspections are not necessary because the
pump station has sufficient storage capacity, above the elevation at which the pump activates, to justify a longer inspection
interval. In no case shall the inspection interval exceed seven days. Pump stations that are connected to a telemetry
system shall be inspected once per week.
Observations: There is no documentation of pump station inspection.
Compliant: Non -compliant
(a)(5) High -priority sewers shall be inspected by the permittee or its representative once every six months, and inspections
shall be documented.
Observations: Mr. Crouse inspects HPLs every month and has detailed documentation of these inspections.
Compliant: Compliant
(a)(6) A general observation by the permittee or its representative of the entire collection system shall be conducted once
per year.
Observations: Mr. Crouse inspects the entire collection system every month with proper documentation.
Compliant: Compliant
(a)(7) Overflows and bypasses shall be reported to the appropriate Division regional office in accordance with 15A NCAC
02B .0506(a), and public notice shall be provided as required by G.S. 143-215.1 C.
Observations: There have been no overflows or bypasses in the collection system in over three years.
Compliant: Compliant
(a)(8)(B) Grease Control Program shall be in place for private owned collection systems that will include bi-annual
Page 2 of 7

Permit: WQCSD0192 Owner - Facility: Roaring Gap Club Inc
Inspection Date: 03/01/2022
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
distribution of grease education materials to users of the collection system by the permittee or representative.
Observations: This is a small, private community where residential occupancy is on a seasonal basis (Spring and Summer).
Entire collection system is —6000 LF. Only two residents live in the community throughout the year. Only 30 residential
homes are connected to collection system, in addition to a restaurant and country club. The remaining residents have
private septic tank systems. The country club is undergoing renovation and will have a grease trap installed when
renovations are complete. Grease trap already in place at restaurant. The country club and restaurant operate seasonally
as well. Mr. Crouse distributes FOG educational material via community newsletter every May.
Compliant: Compliant
(a)(9) Right-of-ways and easements shall be maintained in the full easement width for personnel and equipment
accessibility.
Observations: Mr. Crouse stated landscaping crews of community maintains ROWs and performs duties approximately 2
weeks. He does not have documentation of maintenance schedule, however of the ROWs inspected, inspector can confirm
maintenance has been conducted.
Compliant: Compliant
(a)(10) Documentation of compliance with Subparagraphs (a)(1) through (a)(9) of this Rule shall be maintained by the
collection system owner for three years with the exception of the map, which shall be maintained for the life of the system.
Observations: All maintenance records are kept >3. Inspector reviewed records going back to 2008. All records are
adequate, detailed, and comprehensive. The only records not kept are pump station and ROW's inspection and
maintenance. Additionally, the map needs to be updated to reflect changes from rehabilitation of collection system. Mr.
Crouse is currently working to remedy this issue.
Compliant: Overall compliant with exception of what is mentioned above.
Page 3 of 7

Permit: WQCSD0192 Owner - Facility: Roaring Gap Club Inc
Inspection Date: 03/01/2022
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
General
# Is this system a satellite system?
# If Yes, what is system name or permit number?
Is there a overall sewer system map?
Does the map include:
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
Are system maintenance records maintained?
Yes No NA NE
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Comment: Map has not been updated reflecting changes to collection system. The collection system
underwent rehabilitation, replacing all pipes in 2008. Pump stations were installed
approximately 5 years ago. Maintenance manager, Mr. Crouse, does have list of all pipes in
the system, which include pipe size and pipe material, but this information is not listed on map.
Map needs to be updated to reflect changes to collection system.
Grease Control
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.)
Note: Mr. Crouse will begin to include FOG educational materials on community website.
For public systems, is there a Grease Control Program via an ordinance/agreement?
If Yes, does it require grease control devices at applicable locations?
Is the Grease Control Program enforced via periodic inspections/records review?
Is action taken against violators?
Yes No NA NE
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Comment: This is a small, private community where residential occupancy is on a seasonal basis (Spring
and Summer). Only two residents live in the community throughout the year. Only 30
residential homes are connected to collection system, in addition to a restaurant and country
club. The remaining residents have private septic tank systems. The country club is
undergoing renovation and will have a grease trap installed when renovations are complete.
Grease trap already in place at restaurant. The country club and restaurant operate
seasonally as well.
Spills and Response Action Plan
# Is system free of known points of bypass?
If No, describe type of bypass and location
Yes No NA NE
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Page4of7

Permit: WQCSD0192 Owner - Facility: Roaring Gap Club Inc
Inspection Date: 03/01/2022
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
# 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?
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?
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
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Comment: Spill response plan was revised July 2020. Everything is in good order, however, need to
update phone number for WSRO. Mr. Crouse was notified of the updated regional office
number.
Inspections
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?
Yes No NA NE
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Comment: The only maintenance records absent are pump station maintenance/inspections. Mr. Crouse
has not implemented logbooks specific to pump stations, but will work to complete. All other
maintenance records are adequate. He inspects entire collection system monthly with
documentation and jets entire collection system annually with proper documentation. All HPLs
are inspected monthly with proper documentation.
**It is important to note, pump stations are inspected monthly when Mr. Crouse inspects entire
collection system, but no documentation specific to pump stations inspections are kept. Again,
Mr. Crouse will correct.
Lines/Right-of-Ways/Aerial Lines
Yes No NA NE
Page5of7

Permit: WQCSD0192 Owner - Facility: Roaring Gap Club Inc
Inspection Date: 03/01/2022
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Please list the Lines/Right of Ways/Aerial Lines Inspected:
1. Over creek between manhole 32-33
2. Over gulley at 42
Are right-of-ways and easements maintained for the full width for access?
If No, give details on temporary access:
Is maintenance documented?
Were all areas/lines inspected free of issues?
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Comment: Mr. Crouse stated landscaping crews of community maintains ROWs and performs duties
approximately 2 weeks. He does not have documentation of maintenance schedule, however
of the ROWs inspected, inspector can confirm maintenance has been conducted.
Manholes
Please list the Manholes Inspected:
#32, #33
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?
Comment: Manholes and vents are in good condition.
Pump Stations
Please list the Pump Stations Inspected:
1. Lake pump station
2. Lodge pump station
# Number of duplex or larger pump stations in system
# Number of vacuum stations in system
# Number of simplex pump stations in system
# Number of simplex pump stations in system serving more than one building
How many pump/vacuum stations have:
Yes No NA NE
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Yes No NA NE
2
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Page6of7

Permit: WQCSD0192 Owner - Facility: Roaring Gap Club Inc
Inspection Date: 03/01/2022
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
# A two-way "auto polling" communication system (SCADA) installed?
# A simple one-way telemetry/communication system (auto -dialer) installed?
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 telemetry 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?
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?
Due to the small infrastructure of collection system, propane back up generators are located at pump station
and tested every Tuesday (running for 15 mins) and is documented.
# 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?
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Comment: As stated previously, there are no records specific to pump station inspection/maintenance.
Mr. Crouse will begin keeping records of pump station inspection/maintenance.
Page 7 of 7