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Home My WebLink AboutWQCS00174_NOD2021PC0441 & CEI Report_20210820 August 20, 2021 Don Denton Carolina Water Service Inc of North Carolina 4944 Pwky Plz Blvd Ste 375 Charlotte, NC 28217 SUBJECT: NOTICE OF DEFICIENCY Tracking Number: NOD-2021-PC-0441 Permit No. WQCS00174 Sugar Mountain Collection System Avery County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Sugar Mountain Collection System on August 10, 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. WQCS00174. 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 _________________________________________________________________________________________________________________________________________________________________________ Sewer and FOG Ordinances The pemittee has not developed and implemented a Sewer Use Ordinance or an enforceable FOG program as required per Permit Conditions Part I, Sections 4 and 5. _________________________________________________________________________________________________________________________________________________________________________ DocuSign Envelope ID: F786799A-A288-4989-85DA-3D466E8C4200 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 Stephanie Williams 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 Cody Marlow (ORC) DocuSign Envelope ID: F786799A-A288-4989-85DA-3D466E8C4200 Compliance Inspection Report Permit:WQCS00174 Effective:12/01/13 Expiration:11/30/21 Owner :Carolina Water Service Inc of North Carolina SOC: Contact Person: Region: County: Directions to Facility: Avery Asheville Lane Chilton Effective:Expiration:Facility:Sugar Mountain Collection System PO Drawer 240908 Charlotte NC 28224 Title:Phone:252-723-8953Eastern NC Manager Secondary ORC(s): Phone:Certification:Primary ORC: CS2,System Classifications: On-Site Representative(s): Related Permits: NC0022900 Carolina Water Service Inc of North Carolina - Sugar Mountain WWTP Secondary Inspector(s): Primary Inspector: Inspection Date:Exit Time:Entry Time: Phone: 08/10/2021 10:00AM 12:00PM Stephanie A Williams 828-296-4500 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 Pump Stations (See attachment summary) Page 1 of 7 DocuSign Envelope ID: F786799A-A288-4989-85DA-3D466E8C4200 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCS00174 08/10/2021 Collection System Inspect Non Sampling Carolina Water Service Inc of North Carolina Routine Inspection Summary: Stephanie Williams, with the Asheville Regional Office, conducted a Compliance Evaluation Inspection of the Sugar Mountain Collection System on August 10, 2021. This inspection was conducted to determine if the system is being operated and maintained in compliance with permit no. WQCS00174. Cody Marlow (ORC) and Cody Green (CWS Operator) were present during the inspection. The system is comprised of approximately 7.6 miles of line – 5.6 miles of gravity line and 2 miles of force mains, with 9 duplex pump stations. The system carries an average annual flow of 0.208 MGD which is treated at the Sugar Mountain WWTP. The lines are mostly HDPE or PVC, with ductile iron used for high priority lines. There are no known clay lines in the system. The facility is currently not in compliance because the utility has not developed and implemented a Sewer Use Ordinance or an enforceable FOG program as required by Permit Conditions Part I, Sections 4 and 5. Page 2 of 7 DocuSign Envelope ID: F786799A-A288-4989-85DA-3D466E8C4200 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCS00174 08/10/2021 Collection System Inspect Non Sampling Carolina Water Service Inc of North Carolina 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?Every 2 months # 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? The permit expires 11/30/2021.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? 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 permittee has not developed and implemented a Sewer Use Ordinance or an enforceable FOG program as required per Permit Conditions Part I, Sections 4 and 5. 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? 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? Comment: Map Yes No NA NE Page 3 of 7 DocuSign Envelope ID: F786799A-A288-4989-85DA-3D466E8C4200 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCS00174 08/10/2021 Collection System Inspect Non Sampling Carolina Water Service Inc of North Carolina Routine 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? It is recommended that the map be updated to reflect the line items in this report.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?Website The last reported SSO occurred on 8/4/2019.Comment: Inspections Yes No NA NE 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? 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: Page 4 of 7 DocuSign Envelope ID: F786799A-A288-4989-85DA-3D466E8C4200 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCS00174 08/10/2021 Collection System Inspect Non Sampling Carolina Water Service Inc of North Carolina Routine 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 Does the Permittee appear to respond within 2 hours of first knowledge of a spill? It is recommended that a source of emergency funds be added to the Spill Response Plan.Comment: Spills Yes No NA NE 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? Comment: Lines/Right-of-Ways/Aerial Lines Yes No NA NE Please list the Lines/Right of Ways/Aerial Lines Inspected: Golf Course HPL 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: Below gravel lot that was just paved (#1013), Grandfather receiving manhole (#1024), Grandfather center lift station (no number) 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? Page 5 of 7 DocuSign Envelope ID: F786799A-A288-4989-85DA-3D466E8C4200 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCS00174 08/10/2021 Collection System Inspect Non Sampling Carolina Water Service Inc of North Carolina Routine # 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: Pump Stations Yes No NA NE Please list the Pump Stations Inspected: Sewer Plant Lift Station, Grandfather Village Lift Station # Number of duplex or larger pump stations in system 9 # 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 pump/vacuum stations have: # A two-way "auto polling" communication system (SCADA) installed?0 # A simple one-way telemetry/communication system (auto-dialer) installed?9 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 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? Page 6 of 7 DocuSign Envelope ID: F786799A-A288-4989-85DA-3D466E8C4200 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCS00174 08/10/2021 Collection System Inspect Non Sampling Carolina Water Service Inc of North Carolina Routine 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? There are four lift stations that do not have stationary generators and the Utility has three portable generators. The generators will be deployed to the three stations with the highest flow. Misty Woods Lift Station has several days storage capacity, and generators will be rotated to this lift station as needed. # 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? Valves are submerged in the wet well. It is recommended that signage be modified to include address of pump station and instructions for notification. Comment: Page 7 of 7 DocuSign Envelope ID: F786799A-A288-4989-85DA-3D466E8C4200