WQCSD0059_CEI_NOD2022PC0039_20220406

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

April 06, 2022

Steven Orr, City Manager
Email: [e-mail]
City of Saluda

SUBJECT: NOTICE OF DEFICIENCY
Tracking Number: NOD-2022-PC-0039
Permit No. WQCSD0059
City of Saluda Collection System
Polk County

Dear Permittee:

The North Carolina Division of Water Resources conducted an inspection of the City of Saluda Collection System
on March 10, 2022. This inspection was conducted to verify that the facility is operating in compliance with the
conditions and limitations specified in Collection System Permit No. WQCSD0059. 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 was noted during the inspection:
Inspection Area Description of Deficiency _________________________________________________________________________________________________________________________________________________________________________
General Inflow and infiltration throughout the collection system significantly inhibit plant performance
during heavy rain events. _________________________________________________________________________________________________________________________________________________________________________

DocuSign Envelope ID: C2ADDC97-743C-49B5-A007-A05EF91594DA

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. The ARO is aware of current actions underway to assess and repair portions of the collection system.
Please continue to keep our office apprised of the status of the AIA work and planned corrective actions once major
areas of concern are identified.
If you should have any questions, please do not hesitate to contact Mikal Willmer with the Water Quality
Regional Operations Section in the Asheville Regional Office at 828-296-4686 or via email at
[e-mail].

Sincerely,

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

ATTACHMENTS: Inspection Report

Ec: LF
DocuSign Envelope ID: C2ADDC97-743C-49B5-A007-A05EF91594DA
Compliance Inspection Report
Permit:WQCSD0059 Effective:03/01/00 Expiration:Owner :City of Saluda
SOC:
Contact Person:
Region:
County:
Directions to Facility:
Polk
Asheville
Kevin Queen
Effective:Expiration:Facility:City of Saluda Collection System
Title:Phone:[phone]Public Works Supervisor
Secondary ORC(s):
Phone:Certification:Primary ORC:
CS1,System Classifications:
On-Site Representative(s):
Related Permits:
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
03/10/2022 10:00AM 11:00AM
Mikal Willmer 828-296-4686
Facility Status:
Permit Inspection Type:
Reason for Inspection:Inspection Type:
Not CompliantCompliant
Routine
Deemed permitted collection system management and operation
Collection System Inspect Non Sampling
Question Areas:
Miscellaneous Questions General Grease Control
Spills/Response Plan
(See attachment summary)
Page 1 of 4
DocuSign Envelope ID: C2ADDC97-743C-49B5-A007-A05EF91594DA
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCSD0059
03/10/2022 Collection System Inspect Non Sampling
City of Saluda
Routine
Inspection Summary:
Mikal Willmer, with the Asheville Regional Office conducted a compliance evaluation inspection of the City of Saluda’s
deemed collection system on March 10, 2022. This inspection primarily focused on current known deficiencies effects on
the WWTP relating to hydraulic loading and current plans moving forward.

The city has demonstrated excess flow at the WWTP is not due to growth but I&I throughout the collection system. The
Town is currently utilizing an AIA grant to digitally map the system and determine the extent and state of the collection
system. Much of the system is terracotta and it is suspected the lines are heavily influenced by stormwater into the system
through cracks and leaks in the pipes. The City is requesting new sewer extension projects have shapefiles so the
upcoming GIS Map can be immediately updated.
The City is attempting to replace as much aging infrastructure in-house as possible under deemed permitted action and
eliminating sections of line that are no longer in use or needed. Flow swings are increasingly common at the WWTP with
less rainfall amounts due to system wide issues. The preliminary engineering report prepared for the City by High Country
Engineering has identified several upgrades to utilize the awarded $160,000 from ARPA funding. The City plans to replace
approximately 600 LF of clay line with 8” PVC from Poplar to Gaffney and a brick manhole along Pace St. and US 176 is
also slated to be replaced with a new precast manhole.
Almost the entire system is cleaned in-house annually and observed at that time. The City has purchased a vac truck since
the TA inspection in 2019.
Laurel Dr. LS has been replaced and previous issues have been resolved. This LS was the site of recurring overflows during
storm events. Two spare pumps are also now available for this lift station.
Forest Creek LS: The City is currently resolving a property issue at this lift station.
Pearson Manhole: Previous overflow issues at this low-lying manhole were due to debris. This appears to have been
resolved according to facility staff. No reported SSOs at this location since 2019.
It was recommended the City apply for the upcoming APRA funding round through DWI as extensive collection system work
is likely required to reduce the hydraulic surges during wet weather. The ADF for 2021 was 0.047 MGD. I&I from the
collection system is inhibiting the proper operation of the WWTP during rain events. The ORC reports rain events as low as
1.5" are now causing issues at the facility. During rain events, the City often reports the blowers have to be shut off to allow
the plant to settle and prevent further visual solids loss.
Page 2 of 4
DocuSign Envelope ID: C2ADDC97-743C-49B5-A007-A05EF91594DA
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCSD0059
03/10/2022 Collection System Inspect Non Sampling
City of Saluda
Routine
General Yes No NA NE
# 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?
This is a deemed permitted collection system. City currently maintains paper maps of the
system. See summary for details.
Comment:
Grease Control Yes No NA NE
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.)
Distributed with bills and posted on 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?
Comment:
Spills and Response Action Plan Yes No NA NE
# Is system free of known points of bypass?
If No, describe type of bypass and location
# 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?
Page 3 of 4
DocuSign Envelope ID: C2ADDC97-743C-49B5-A007-A05EF91594DA
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCSD0059
03/10/2022 Collection System Inspect Non Sampling
City of Saluda
Routine
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
Recommend annually verifying all contact information is up to date. See summary for details.Comment:
Page 4 of 4
DocuSign Envelope ID: C2ADDC97-743C-49B5-A007-A05EF91594DA