NC0026697_NOVNOI2021LV0867_Response_20211129

ClayCounty
Water & Sewer District
345 Courthouse Drive * P.O. Box 838
Hayesville, North Carolina 28904
* [phone] *
NOV 2 9 2021 4-21
Water Quality Regional Operations
Asheville Regional Office
This letter is to address the Notice of Violation & Intent to Assess Civil Penalty letter I received
on November 22°d, 2021. Our wastewater plant received a large flow amount in August due to
serious inflow and infiltration issues in our collections system. We have been aware of the
issues and recently our District conducted a smoke test of our collections system and was able to
identify some serious problem areas which attributed to excessive flow from rain water which
entered our system through faulty manholes, storm drains and other service areas. We have been
at work addressing these issues and repairing the damaged areas and plans are in place to hire a
contractor to repair the issues that are too big for our department to handle with available
staffing. I have attached the findings of the smoke testing along with a copy of the flow chart
which indicates the amount of rain which lead to the I&I issues resulting in a blown permit at our
wastewater treatment plant. Thank you for your consideration of the provided information and I
look forward to hearing from you as to how we can satisfy the NOV.
Dusty Beal
Clay County Water & Sewer District Director

DocuSign Envelope ID: C6458C25-D10E-4508-B945-6088AFF851AE
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Oircrror
Certified Mail # 7021 0350 0000 1637 6995
Return Receipt Requested
Debbie Mauney, County Manager
Clay County Water & Sewer District
119 Courthouse Dr.
Hayesville, NC 28904
NORTH CAROLINA
Environmental Quality
November 17, 2021
SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY
Tracking Number: NOV-2021-LV-0867
Permit No. NC0026697
Clay County WWTP
Clay County
Dear Permittee:
A review of the August 2021 Discharge Monitoring Report (DMR) for the subject facility revealed the violation
indicated below:
Limit Exceedance Violation:
Sample Limit Reported
Location Parameter Date Value Value Type of Violation
001 Effluent Coliform, Fecal MF, MFC Broth, 8/21/2021 400 1,200 Weekly Geometric Mean Exceeded
44.5 C (31616)
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 NPDES WW 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.
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Hope F. Cupit, CPA
President & CEO
Swynice Hawkins
Board Chair
Southeast Rural Community Assistance Project, Inc.
Clay County Wastewater Collections system
Smoke testing Report 11/17/2021
SERCAP assisted Clay County in smoke testing their system, and
provided a smoke tester and TAP Tony Dvorak to assist and
evaluate testing over a three day period. Upon testing, numerous
clean outs were found to be missing caps and six clean out
laterals were broken. These repairs are being done at this time.
Manholes with infiltration problems and deteriorating vaults
were found at the following sites. Two on Ritter Road, in ditches
that will fill any time it rains. One on the corner of Arlington St.
and Jones St. This one needs extensive rehab or replacement
work, as it is a stacked concrete block vault that is in poor shape
and in danger of collapse. Another manhole in a field just south
of the Riverwalk subdivision, was found to be leaking ground
water constantly at a possible flow of 40 gpm due to no sealing
around the incoming pipes the vault will need to be excavated.
The next problem is due to two storm drains being cross
connected with Clay County's sewer collection system, located at
the intersection of Hiawassee St. and Hwy 64 Bus. Also the
intersection of Hwy 64 Bus. And Hickory St. Calls to NCDOT
were made by D. Beal utilities director on 11/16/2021 and
subsequent site visit with NCDOT will be scheduled including
camera equipment for investigating and SERCAP smoke tester
will remain available to help provide evidence.
Water Is Life
347 Campbell Avenue, SW
Roanoke, VA 2401E
Phone [phone] Fax [phone]
%%ww. southeastrcap .org

ClayCounty
Water & Sewer District
345 Courthouse Drive * P.O. Box 838
Hayesville, North Carolina 28904
* [phone] *
11/22/2021
Nathan Ohle, Chief Executive Officer
Rural Community Assistance Partnership
1725 I St. NW
Suite 225
Washington, DC 20006
Dear Mr. Ohle,
On behalf of the Clay County Water and Sewer system, I strongly support SERCAP's application
to EPA for the "Training and Technical Assistance to Improve Financial and Managerial Capacity
and Enable Small Water Systems to Provide Safe Drinking Water" national priority are. Our system
has benefitted vastly due to receiving assistance from SERCAP this past year, and i feel that their
services would be valuable to many other systems across the country.
Clay County water and sewer system operates as a municipal not for profit system and primarily
serves roughly 1500 population in Hayesville, NC. The water system is in pretty good condition but
growth in our area is continuing at a fast pace and future needs will be a great struggle. As of last
week, SERCAP Technical Assistance provider has held a Class for our operators and others in the
region to complete their contact hours for certification renewals.
Work from smoke testing, again using SERCAP's smoke tester and the assistance of the TAP was
completed these three days of testing and support was quite valuable as it uncovered sewer collection
system I & I (infiltration and inflow).
Clay County utilities is looking forward to making many improvements and rehabilitations to fix
and correct these deficiencies. I am well pleased with SERCAP and their assistance not just now but,
also to help with future concerns, as we are growing at such an amazing rate.
Sincerely,
Dustin Beal %• ���
Utilities Director
Clay County
Water and Sewer District

11/17/21, 2:42 PM
Yahoo Mail - Smoke
Smoke
From: Dustin Beal ([e-mail])
To: [e-mail]
Date: Wednesday, November 17, 2021, 09:26 AM EST
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