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Home My WebLink AboutWQCS00201_NOD2022PC0091 & CEI Report_20220608 June 08, 2022 John L Chandler, Mayor Town of Mars Hill PO Box 368 Mars Hill, NC 28754-0368 SUBJECT: NOTICE OF DEFICIENCY Tracking Number: NOD-2022-PC-0091 Permit No. WQCS00201 Mars Hill Collection System Madison County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Mars Hill Collection System on June 1, 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. WQCS00201. 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 deficiencies were noted during the inspection: Inspection Area Description of Deficiency _________________________________________________________________________________________________________________________________________________________________________ Inspections The annual observation is not being documented. _________________________________________________________________________________________________________________________________________________________________________ Capital Improvement Plan The Capital Improvement Plan is out of date. _________________________________________________________________________________________________________________________________________________________________________ Sewer and FOG Ordinances The grease ordinance is not enforced by inspections and grease education materials are not being provided to customers as required. _________________________________________________________________________________________________________________________________________________________________________ DocuSign Envelope ID: 1AFE2163-811E-4EFE-A09E-A03D4B3FA669 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, Nathan Bennett (Town Manager), Jason Riddle (BORC) DocuSign Envelope ID: 1AFE2163-811E-4EFE-A09E-A03D4B3FA669 Compliance Inspection Report Permit:WQCS00201 Effective:05/01/18 Expiration:04/30/26 Owner :Town of Mars Hill SOC: Contact Person: Region: County: Directions to Facility: Madison Asheville Jason Riddle Effective:Expiration:Facility:Mars Hill Collection System PO Box 368 Title:Phone:828-206-6479Wastewater Superintendent Secondary ORC(s): Phone:Certification:Primary ORC: CS2,System Classifications: On-Site Representative(s): Related Permits: NC0057151 Town of Mars Hill - Mars Hill WWTP Secondary Inspector(s): Primary Inspector: Inspection Date:Exit Time:Entry Time: Phone: 06/01/2022 09:30AM 01:30PM 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: 1AFE2163-811E-4EFE-A09E-A03D4B3FA669 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCS00201 06/01/2022 Collection System Inspect Non Sampling Town of Mars Hill Routine Inspection Summary: Stephanie Williams, with the Asheville Regional Office, conducted a Compliance Evaluation Inspection of the Mars Hill Collection System on June 1, 2022. This inspection was conducted to determine if the system is being operated and maintained in compliance with permit no. WQCS00201. Tommy Worley (Maintenance) was present during the inspection. Mr. Worley is currently training to take over as ORC for the Collection System. When this change occurs, an ORC Designation Form should be submitted accordingly. Sewer and FOG Ordinances: The FOG Ordinance does not appear to be enforced and grease trap inspections are not being conducted. The last grease trap inspection or enforcement on record is from 2007. Additionally, grease education materials are not being sent as required. During the inspection, Ms. Williams discussed this requirement with the Town Manager, Mr. Nathan Bennett. Please note that providing the information on the Town’s website reduces the mailout requirement to once per year. Including this information in the newsletter that is mailed with the bill is sufficient, so long as the newsletter is mailed to all customers. The Division recommends including information regarding flushable wipes as well. Capital Improvement Plan: The latest Capital Improvement Plan (CIP) that was available during the inspection is from 2009. The 2018 inspection report states that the CIP was set to expire in 2019. It is recommended that the Town locate this CIP and update it to reflect a period of three to five years as required by section I. 5 in the permit. Upcoming projects: The Town is in the beginning stages of planning the replacement for the Woodhaven Pump Station, which is 38 years old. Inspections: The annual inspection is being conducted but is not being documented as required. Mr. Worley stated that he would begin to document the inspection moving forward. Pump Stations: Pump station logs should include exercising valves. It is recommended that this be added to the notes as it is completed. Sprinkle Creek lift station services the I-26 North Carolina Welcome Center and shares a building with the drinking water booster station. It appears that the sewer wet well has an overflow pipe to prevent overflow into the drinking water pump station. An attempt was made to locate the outlet of this pipe during the inspection but was unsuccessful. However, there is no development near this pump station and the direction of the pipe inside the wet well indicates that it likely discharges on the side of a nearby bank and into a creek. The following deficiencies were noted during the inspection: 1. Sewer and FOG Ordinance: The grease ordinance is not enforced by inspections and grease education materials are not being provided to customers as required. 2. Capital Improvement Plan: The Capital Improvement Plan is out of date. 3. Inspections: The annual observation is not being documented. Page 2 of 7 DocuSign Envelope ID: 1AFE2163-811E-4EFE-A09E-A03D4B3FA669 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCS00201 06/01/2022 Collection System Inspect Non Sampling Town of Mars Hill 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?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? 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? 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?Not Specified 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 FOG Ordinance is not enforced and grease education materials are not being sent as required. See summary for details. 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? The CIP reviewed during the inspection is from 2009. See summary for details.Comment: Map Yes No NA NE Page 3 of 7 DocuSign Envelope ID: 1AFE2163-811E-4EFE-A09E-A03D4B3FA669 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCS00201 06/01/2022 Collection System Inspect Non Sampling Town of Mars Hill 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? The map should be updated for changes and additions within 1 year of activation.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? The only sewer spills that have occurred in the last three years did not meet reportable criteria.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? The annual inspection is not being documented. See summary for details.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: 1AFE2163-811E-4EFE-A09E-A03D4B3FA669 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCS00201 06/01/2022 Collection System Inspect Non Sampling Town of Mars Hill 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? 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: Cascade Street 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: S. Main St., Anderson St. 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: 1AFE2163-811E-4EFE-A09E-A03D4B3FA669 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCS00201 06/01/2022 Collection System Inspect Non Sampling Town of Mars Hill 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: Carl Eller, Sprinkle Creek # Number of duplex or larger pump stations in system 7 # 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?7 # A simple one-way telemetry/communication system (auto-dialer) installed?0 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: 1AFE2163-811E-4EFE-A09E-A03D4B3FA669 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCS00201 06/01/2022 Collection System Inspect Non Sampling Town of Mars Hill 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? The Town owns a pump truck and a portable generator # 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? Pump logs should be modified to include exercising valves. See summary for details.Comment: Page 7 of 7 DocuSign Envelope ID: 1AFE2163-811E-4EFE-A09E-A03D4B3FA669