WQCS00143_Compliance Evaluation Inspection_20200331

DocuSign Envelope ID: 882F63B8-17AF-44BB-82C9-8C23FAE9ED01
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ROY COOPER
Governor
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Secretary
Secretary
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S. DANIEL SMITH
NORTH CAROLINA
Director
Environmental Quality
Certified Mail # 7019 1640 0000 1354 4078
Return Receipt Reauested
March 30, 2020
Theresa Coletta
Town of Burnsville
PO Box 97
Burnsville, NC 28714
SUBJECT: NOTICE OF VIOLATION
Tracking Number: NOV-2020-PC-0190
Compliance Inspection Report
Burnsville Collection System
Collection System Permit No. WQCS00143
Yancey County
Dear Permittee:
The North Carolina Division of Water Resources conducted an inspection of the Town of Burnsville Collection
System on March 10, 2020. This inspection was conducted to verify that the facility is operating in compliance
with the conditions and limitations specified in Collection System Permit No. WQCS00143. 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 violations were noted during the inspection:
Inspection Area Description of Violation
Performance Standards Documented excessive I&I shall be specifically addressed. Flow data for 2017-2019 shows a
variance in average flow ranging by over 100% of dry weather flow contingent on weather
events. Permit Condition II (2) requires the permittee to establish a plan for
addressing problems in the collection system that are identified during system
inspections. Permit Condition I (5) also recommends creating a long-term plan to
address known deficiencies and forecasted future needs.
Operation & Maintenance Excessive I&I has caused significant interference of the POTW treatment processes. The
current (partially operational) WWTP is not able to fully treat influent flows during rain events.
NPDES Permit Standard Conditions Part IV(A) defines interferences as, "inhibition
or disruption of the POTW treatment processes; operations; or its sludge process,
use, or disposal which causes or contributes to a violation of any requirement..."
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w::•= n 82319fi-4500

DocuSign Envelope ID: 882F63B8-17AF-44BB-82C9-8C23FAE9ED01
Remedial actions should have already been taken to correct these problems 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, please respond in writing to this office within 15 days upon your receipt of
this Notice of Violation regarding your plans or measures to be taken to address the indicated violations and other
identified issues, if applicable.
If you should have any questions, please do not hesitate to contact Tim Heim with the Water Quality
Regional Operations Section in the Asheville Regional Office at 828-296-4500.
Sincerely,
DocuSigned by:
7E617A38285848C...
G. Landon Davidson, P.G., Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS
Ec:
WQS-ARO Server
LF
G:\WR\WQ\Yancey\Collection Systems\Burnsville Collection System\2020 CEI\WQCS00143_CEI Ltr_20200330.Docx
Noah Carofins Department of Environmental QuadBy I DMsion of Water Resources
Ashevdle Regional Office 12090 U.S. 70 31igi ay I Swaaaanoa, North Carolina 23773

DocuSign Envelope ID: 882F63B8-17AF-44BB-82C9-8C23FAE9ED01
Compliance Inspection Report
Permit: WQCS00143 Effective: 09/06/18 Expiratlon: 08/31/26 Owner: Town of Burnsville
SOC: Effective: Expiration: Facility: Burnsville Collection System
County: Yancey PO Box 97
Region: Asheville
Burnsville NC 287140497
Contact Person: Theresa Coletta Title: Mayor Phone: [phone]
Directions to Facility:
System Classifications: CS2,
Primary ORC: Michael Shane Dale
Secondary ORC(s):
On -Site Representative(s):
Certification:996498 Phone: [phone]
Related Permits:
NCO020290 Town of Burnsville - Burnsville WWE-P
Inspection Date: 03/10/2020 Entry Time 10:00AM
Primary Inspector: Timothy H Heim 3/31/2020
Secondary Inspector(s):
Exit Time: 02:00PM
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Collection System Inspect Non Sampling
Permit Inspection Type: Collection system management and operation
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Miscellaneous Questions General Sewer & FOG Ordinances
Capital Improvement Plan Map Spill Response Plan
Lines Manholes Pump Stations
(See attachment summary)
Page 1 of 8

DocuSign Envelope ID: 882F63B8-17AF-44BB-82C9-8C23FAE9ED01
Permit: WQCS00143 Owner - Facility; Town of Burnsville
Inspection Date: 03110/2020 inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Inspection Summary
Tim Heim of the Asheville Regional Office performed a Compliance Evaluation Inspection of the Burnsville Collection System
on March 10, 2020 this was conducted to follow up on concerns about significant flow issues from rain events impacting the
WWTP, which is not currently able to operate at full capacity. M. Shane Date (ORC) and Dillon Lundy (Burnsville Public
Works) were present and assisted with the inspection.
The inspection included a review of all relevant maintenance and operations records, a visit to each pump station. owned and
operated by the town, inspection of manholes and gravity sewers in representative areas of town, and a review of flow data a
the WWTP during rain events.
The system was non -complaint at the time of the inspection due to severe inflow and infiltration (1&1). Several significant
deficiencies related to record keeping were also noted:
The following items shall be addressed to return the collection system to compliance:
According to DRM data and interviews with public works staff, the WWTP experiences severe I&I during rain events,
increasing flow to the WWTP by over 100% in some cases and causing frequent exceedances of the NPDES flow limit. The
town should pursue a comprehensive and aggressive infrastructure assessment and repair program with a qualified
engineering firm to begin addressing this.
A general observation of the entire collection system shall be performed annually. Access right of ways, and high -priority
lines (creek crossings) shall be visually inspected biannually and these processes shall be documented.
Clean and document at least 10% of the collection system on an annual basis, plus problems areas as needed.
Maintain the Spill Response Action Plan (SRAP), Sewer Use Ordinance (SUO) and other relevant information in an easy to
access location that ail public works staff are made aware of.
Complete and submit annual system report (SPAR).
The following additional items were noted:
Primary maintenance and monitoring of the Altec Pump Station (previously operated by the town) has been taken over by
Aitec.
Complete the OMC Pump Station Project as scheduled.
Page 2 of 8

DocuSign Envelope ID: 882F63B8-17AF-44BB-82C9-8C23FAE9ED01
Permit: WQCS00143 Owner - Facllity:Town of Burnsville
Inspection Date: 0311012020 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: 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?
0
❑ ❑ ❑
# What is that frequency?
Weekly
# 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?
0
❑ ❑ ❑
Does plan indicate if pump partslnew pumps are in spare parts/equipment inventory?
0
❑ ❑ ❑
Are new/significantly upgraded pump stations equipped with anti -corrosion materials?
0
❑ ❑ ❑
Does the permittee have a copy cf their permit?
M
❑ ❑ ❑
# Is permit expiring within the next $ months?
❑
0 ❑ ❑
If Yes, has the Permittee applied for renewal?
❑
❑ 0 ❑
Comment:
Sewer and FOG Ordinances
Yes No NA NE
Is Sewer Use Ordinance (SUO) or other Legal Authority available?
0
❑ ❑ ❑
Does it appear that the Sewer Use Ordinance is enforced?
0
❑ ❑ ❑
Is there a, Grease Control Program that legally requires grease control devices?
0
❑ ❑ ❑
What is the standard grease trap cleaning requirement in the FOG ordinance?
Is Grease Control Program enforced via periodic inspections/records review?
M
❑ ❑ ❑
1s action taken against violators?
0
❑ ❑ ❑
# Have satellite systems adopted an equivalent or more stringent ordinance?
❑
❑ ■ ❑
Is grease/sewer education program documented with req'd customer distribution?
0
❑ ❑ ❑
# Are other types of education tools used like websites, booths, special meetings, etc?
0
❑ ❑ ❑
If Yes, what are they? (This can reduce mailing to annual.)
Website and mailings with water bills.
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? 0 ❑ ❑ ❑
Does Cl P cover three to five year period of earmarked improvements? 0 ❑ ❑ ❑
Does CI P include description of project area? 0 ❑ ❑ ❑
Does CI P include description of existing facilities? 0 ❑ ❑ ❑
Does Cl P include known deficiencies? ❑ M ❑ ❑
Does Cl P include forecasted future needs? ■ ❑ ❑ ❑
Page 3 of 8

DocuSign Envelope ID: 882F63B8-17AF-44BB-82C9-8C23FAE9ED01
Permit: WQCS00143 owner - Facility - Town of Bumsville
Inspection Date: 03/10=20 Inspection Type: Collection System Inspect Non Sampling Reason for Visit: Routine
Comment: Documented excessive Al shall be specifically addressed:
Flow data for 2017-2019 shows a variance in average flow ranoino by over 100% of dry weather
flow contingent on weather events. Permit Condition II (2) requires the permittee to establish a
plan for addressing problems in the collection system that are identified during system .
inspections. Permit Condition 1 (5) also recommends creating a long-term plan to address
known deficiencies and forecasted future needs.
Map
Yes No NA NE
Is there a.overall sewer system map?
0 ❑ ❑ ❑
Does the map include:
Pipe Type (GS/FM)
0 ❑ ❑ ❑
Pipe sizes
0 ❑ ❑ ❑
Pipe materials (PVC, DIP, etc)
■ ❑ ❑ ❑
Pipe location
0 ❑ ❑ ❑
Flow direction
0 ❑ ❑ ❑
Approximate pipe age
❑ 0 ❑ ❑
Pump station ID, location and capacity
■ ❑ ❑ ❑
# Force main air release valve location & type
0 ❑ ❑ ❑
# Location of satellite connections
M ❑ ❑ ❑
Is the map being updated for changes/additions within 1 year of activation?
0 ❑ ❑ ❑ .
Comment: Update map as necessa
Spill Response Action Plan
Yes No NA NE
Is a Spill Response Action Plan available?
0
❑ ❑ ❑
Is a Spill Response Action Plan available for all personnel?
0
❑ ❑ ❑
Does the plan include:
24-hour contact numbers
0
❑ ❑ ❑
Response time
0
❑ ❑ ❑
Equipment list and spare parts inventory
M
❑ ❑ ❑
Access to cleaning equipment
M
❑ ❑ ❑
Access to construction crews, contractors, and/or engineers
0
❑ ❑ ❑
Source of emergency funds
■
❑ ❑ ❑
Site sanitation and cleanup materials
M
❑ ❑ ❑
Post-overflow/spill assessment
M
❑ ❑ ❑
Does the Permittee appear to respond within 2 hours of first knowledge of a spill?
❑
❑ ❑ ■
Comment:
LineslRight-of-Ways/Aerial Lines Yes No NA NE
Please list the Lines/Right of Ways/Aerial Lines Inspected:
Creek crossings, document inspection process.
Page 4 of 8

DocuSign Envelope ID: 882F63B8-17AF-44BB-82C9-8C23FAE9ED01
Permit: VVQCSC0143 Owner - FaclIIty: Town of Burnsville
Inspection Date: 03/10/2020 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Are right-of-waysleasements maintained for full width for access by staff/equipment? 0 ❑ ❑ ❑
If No, give details on temporary access:
Document inspection process.
Is maintenance documented? ❑ N ❑ ❑
Are gravity sewer cleaning records available? N ❑ ❑ ❑
Has at least 10% of lines older than 5 yrs been cleaned annually? ❑ 0 ❑ ❑
Were all areas/lines inspected free of issues? ■ ❑ ❑ ❑
Comment: Document annual line cleaning.
Manholes
Yes No NA NE
Please list the Manholes Inspected:
Are manholes accessible?
■
❑ ❑ ❑
# Are manhole covers/vents above grade?
0
❑ ❑ ❑
Are manholes free of visible signs of overflow?
0
❑ ❑ ❑
Are manholes free of sinkholes and depressions?
0
❑ ❑ ❑
Are manhole covers present?
0
❑ ❑ ❑
# Are manholes properly seated?
0
❑ ❑ ❑
# Are manholes in good condition?
0
❑ ❑ ❑
# Are inverts in good condition?
0
❑ ❑ ❑
Is flow unrestricted in manholes?
❑ ❑ ❑
Are manholes free of excessive amounts of grease?
0
❑ ❑ ❑
Are manholes free of excessive roots?
0
❑ ❑ ❑
Are manholes free of excessive sand?
0
❑ ❑ ❑
Are manhole vents screened?
0
❑ ❑ ❑
Are vents free of submergence?
0
❑ ❑ ❑
Are manholes free of bypass structures or pipes?
0
❑ E] []
Comment
Pump Stations Yes No NA NE
Please list the Pump Stations Inspected:
OMC, and the two smaller pump stations.
# Number of duplex or larger pump stations in system 3
# Number of vacuum stations in system 0
# Number of simplex pump stations In system 0
# Number of simplex pump stations In system serving more than one building 0
How many pumpfvacuum stations have:
# A two-way "auto polling" communication system (SCADA) installed? 3
# A simple one-way telemetry/communication system (auto -dialer) installed? 0
For pump stations inspected:
Page 5 of 8

DocuSign Envelope ID: 882F63B8-17AF-44BB-82C9-8C23FAE9ED01
Permit: WQCS00143 Owner - Feel IIty:Tawn of Burnsville
Inspection Date: 03/10/2020 inspection Type: Collection System inspect Non Sampling Reason for Visit: Routine
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?
If tested during inspection, did it function properly? .
Is the back-up system tested at least bi-annuaily under normal operating conditions?
# Does it have a dedicated connection far. 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/Vehiclesletc) 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?
Comment:
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