WQCS00039_NOVNOI2023PC0210_20230510

Certified Mail # 7022 0410 0002 1249 8927
Return Receipt Requested
May 10, 2023

Gary Caldwell, Mayor
Town of Waynesville
PO Box 100
Waynesville, NC 28786-0100

SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY
Tracking Number: NOV-2023-PC-0210
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
April 11, 2023. 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 Complaint inspection was conducted by Division of Water Resources staff from the Asheville
Regional Office. The following violation(s) were noted during the inspection:

Inspection Area Description of Violation _________________________________________________________________________________________________________________________________________________________________________
Manhole upstream Lack of proper maintenance for manhole rim and lid. Bolts were stripped, bolt ho usings were
of bar screen stripped and broken.
I. Performance Standards 2. The wastewater collection system shall be effectively managed, 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. _________________________________________________________________________________________________________________________________________________________________________
Second Manhole upstream Lack of proper maintenance for manhole structure. Sewage discharge d through seam in
of bar screen the concrete. Manhole lid was secure but rusted in place, preventing inspection of the
interior.
I. Performance Standards 2. The wastewater collection system shall be effectively managed, 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. _________________________________________________________________________________________________________________________________________________________________________
DocuSign Envelope ID: 8FE5617A-C044-4C3F-AC1D-2D171CD0E772

In addition, the issues below must also be addressed:

Compliance Issue(s):

1.Bar screen channel within the collection system overflows periodically.

2. Infrastructure at this location appears inadequate to handle wastewater flows during storm
events.

A Notice of Violation/Intent to Issue Civil Penalty is being issued for the noted violation of North Carolina General
Statute (G.S.) 143-215.1 and the facility’s Collection System Permit. Pursuant to G.S. 143-215.6A, a civil penalty
of not more than twenty-five thousand dollars ($25,000.00) may be assessed against any person who violates
or fails to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S.
143-215.1.

If you wish to provide additional information regarding the noted violation, request technical assistance, or discuss
overall compliance please respond in writing within ten (10) business days after receipt of this Notice. A review of
your response will be considered along with any additional information provided. You will then be notified of any
civil penalties that may be assessed regarding the violations. If no response is received in this Office
within the 10-day period, a civil penalty assessment may be prepared.

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. If the violations are of a continuing nature, not related to operation and/or maintenance problems, and
you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by
Consent.

If you should have any questions, please do not hesitate to contact me 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

DocuSign Envelope ID: 8FE5617A-C044-4C3F-AC1D-2D171CD0E772
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:
04/11/2023 01:00PM 02:00PM
Daniel J Boss 828-296-4658
Lauren E Armeni
Facility Status:
Permit Inspection Type:
Reason for Inspection:Inspection Type:
Not CompliantCompliant
Routine
Collection system management and operation
Complaint
Question Areas:
Miscellaneous Questions Lines Manholes
(See attachment summary)
Page 1 of 3
DocuSign Envelope ID: 8FE5617A-C044-4C3F-AC1D-2D171CD0E772
5/15/2023
5/15/2023
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00039
04/11/2023 Complaint
Town of Waynesville
Routine
Inspection Summary:
On 4/11/2023, Lauren Armeni and I (Daniel Boss) inspected a portion of the Waynesville Collection System in response to
an anonymous allegation that Waynesville staff have been allowing a discharge of raw sewage to surface water. We met with
Wayne Bolin (CS ORC) and Jeff Evans (WWTP ORC) during this inspection. The specific location of the inspection was a
portion of the collection system at the Evergreen Packaging facility located at 81 Old Howell Mill Rd in Waynesville. At this
site, there is an aerial line that crosses Richland Creek, a bar screen with an open channel on the North side of the creek
crossing, and manholes immediately upstream and downstream of the aerial line.
Both of the manholes immediately upstream and downstream of the aerial line showed substantial evidence of recent
sanitary sewer overflows. The downstream manhole had been bolted down, but three of the four bolts were unscrewed and
lifted about an inch above the top surface of the manhole lid. The washers around the remaining bolt were bent, indicating
that the opposite side of the lid had lifted. There was a mat of rags that began at the rim of the manhole on the unbolted end
and continued directly to Richland Creek. Upon opening the manhole, we could see that one of the bolt housings was
broken and two of the bolt housings had stripped threads. Two of the bolts had stripped threads as well. Wayne Bolin (CS
ORC) indicated that these bolts had held tight just two weeks prior (during our inspection on March 28,2023). The
wastewater level in the manhole was only a couple feet below the manhole rim. We had not received a 24-hour notice of the
SSO at the time of our visit. Mr. Bolin said they discovered evidence of an SSO on 4/10/2023 at about 7pm.
The bar screen channel showed evidence of overflowing. Rags and solids matted the walled in area around the bar screen.
Jeff Evans (WWTP ORC) told us that the bar screen is typically raked daily and that raking the rags off the screen doesn't
alleviate the flooded condition of the bar screen area. For the bar screen area to flood, the wastewater level needs to rise
about 6 feet above the surface of the upstream manhole. This indicates that the problem at this point in the collection
system may be that either the sewer line is undersized or there is too much I&I entering the collection system during rain
events. The log book kept at the bar screen indicates that the bar screen area is observed to flood about 6-12 times per year
depending on rainfall, and sometimes it floods for multiple days. Mr. Evans stated that there are currently no plans to
address the bar screen flooding. For this event, the logbook indicated that the bar screen area was flooded for three days
beginning April 7. According to the National Weather Service (NWS) website, the Waynesville area received about three
inches of rainfall from April 7th to April 9th.
The manhole immediately upstream of the aerial line at Evergreen Packaging had sewage rags scattered around it that had
discharged from the concrete wall of the manhole in all directions. It appeared that the sewage and rags had discharged
from a seam in the concrete. There was not an obvious hole or crack in the concrete seam, but the discharge was apparent
and there was no evidence that it had emerged from the manhole lid or rim. The manhole lid was unable to be removed by
the CS staff. The lid was held down by bolts that appeared to be rusted in place tightly. Manhole lids need to be able to be
removed for inspections, even if they are sealed watertight to prevent SSOs. This manhole appeared to sit substantially
higher than the manhole immediately downstream of the aerial line. This upstream manhole also overflowing sewage
indicates a significant backup in the collection system, which further indicates that the SSO problems at this location may
require an infrastructure change/upgrade.
NWS information indicates that three inches of rainfall over a 48-hour period is below the threshold for a one-year storm for
the Waynesville area. The last reported SSO at this location occurred 7 years ago, and there are only 3 reported SSOs in
this location in the last 20 years. It is improbably that only 3 SSOs occurred since it only took three inches of area rainfall
over 2 days to trigger three days of bar screen flooding, SSOs from two manholes, and enough pressure to burst the lid off of
a bolted down manhole.
Page 2 of 3
DocuSign Envelope ID: 8FE5617A-C044-4C3F-AC1D-2D171CD0E772
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00039
04/11/2023 Complaint
Town of Waynesville
Routine
Lines/Right-of-Ways/Aerial Lines Yes No NA NE
Please list the Lines/Right of Ways/Aerial Lines Inspected:
Aerial crossing at Evergreen Packaging.
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?
Comment:
Manholes Yes No NA NE
Please list the Manholes Inspected:
One immediately upstream of the barscreen at Evergreen Packaging and the next manhole upstream from
that.
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?
One manhole lid couldn't be removed, so we couldn't evaluate conditions inside of it. Both
manholes had evidence of recent SSOs. The manhole immediately upstream of the barscreen
was bolted down but the lid had burst open on one side and three of the four bolts were pulled
out of the manhole lid. A mat of rags extended from the manhole lid to the river. The next
manhole upstream had rags strewn about around the concrete structure of the manhole and
had apparently discharged from a seam in the structure. The manhole lid was bolted down
and the CS staff couldn't remove it for us to inspect the interior.
Comment:
Page 3 of 3
DocuSign Envelope ID: 8FE5617A-C044-4C3F-AC1D-2D171CD0E772