WQCSD0248_NOD2022PC0092 & CEI Report_20220610

SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED.

June 10, 2022

Dusty Beal, Director of Water & Sewer
Clay County Water & Sewer District
Email: [e-mail]

SUBJECT: NOTICE OF DEFICIENCY
Tracking Number: NOD-2022-PC-0092
Permit No. WQCSD0246
Clay County Water & Sewer District
Clay County

Dear Permittee:

The North Carolina Division of Water Resources conducted an inspection of the Clay County Water & Sewer
District 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. WQCSD0246. 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 _________________________________________________________________________________________________________________________________________________________________________ Grease Control The Grease Control Program is not being enforced.
_________________________________________________________________________________________________________________________________________________________________________
Inspections The entire system is not being observed annually. A complete HPL list is not available and
semi-annual HPL inspections are not being documented. _________________________________________________________________________________________________________________________________________________________________________

DocuSign Envelope ID: A3D0E939-4143-49C5-A822-C6BF7E7A77CC

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 Lauren Armeni with the Water Quality
Regional Operations Section in the Asheville Regional Office at 828-296-4667.

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: A3D0E939-4143-49C5-A822-C6BF7E7A77CC
Compliance Inspection Report
Permit:WQCSD0246 Effective:02/02/07 Expiration:Owner :Clay County Water & Sewer District
SOC:
Contact Person:
Region:
County:
Directions to Facility:
Clay
Asheville
Dusty Beal
Effective:Expiration:Facility:Clay County Water & Sewer District
Title:Phone:[phone]Director of Water & Sewer
Secondary ORC(s):
Phone:Certification:Primary ORC:
CS2,System Classifications:
On-Site Representative(s):
Related Permits:
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
06/01/2022 10:30AM 12:00PM
Lauren E Armeni 828-296-4500
Facility Status:
Permit Inspection Type:
Reason for Inspection:Inspection Type:
Not CompliantCompliant
Routine
Deemed permitted collection system management and operation
Collection System Inspect Non Sampling
Question Areas:
Miscellaneous Questions General Grease Control
Spills/Response Plan Inspections Lines
Manholes Pump Stations
(See attachment summary)
Page 1 of 6
DocuSign Envelope ID: A3D0E939-4143-49C5-A822-C6BF7E7A77CC
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCSD0246
06/01/2022 Collection System Inspect Non Sampling
Clay County Water & Sewer District
Routine
Inspection Summary:
Lauren Armeni, with the Asheville Regional Office (ARO), conducted a Compliance Evaluation Enspection of Clay County
Water & Sewer District deemed-permitted collection system on May 31, 2022. The inspection was conducted to determine if
the system is being operated and maintained in compliance with deemed-permitted collection system permit no.
WQCSD0246. Ms. Armeni was accompanied by Mr. Dusty Beal (Clay County Water & Sewer Director).
Projects: SERCAP, Inc. conducted smoke testing in 2021 to evaluate I&I issues. Results indicated that several clean outs
were missing caps and six clean out laterals were broken. These repairs have already been completed. Additionally,
manholes with infiltration problems and deteriorating vaults were found at the following sites: two on Ritter Road, one at the
corner of Arlington Street & Jones Street, and one in the field south of the Riverside Subdivision. The last issue they found
was two storm drains cross connected with the collection system. Mr. Beal stated he is currently working with engineers to
use the Fall 2021 ARPA money to replace the manholes with issues. He is working with the DOT to repair the storm drain
cross connection issue. All manholes on Highway 69 have been replaced because of the current DOT project.
Grease Control: A Grease Control Program is in place, but it is not being enforced via inspections of all businesses
containing grease traps. In the past, Mr. Beal said it has been hard getting businesses to provide pumping records. If
businesses are not submitting pumping records or do not have grease traps, the provided Grease Control Program indicates
that they must comply with the requirements of the Program within ten days of receipt of a Notice of Violation.
Grease education is provided on the County's website, therefore the mailout requirement for grease education is reduced to
once per year and should be included with customer's sewer bills.
Spill Response and Action Plan: An Operation and Maintenance Plan that includes a Spill and Response Action Plan was
provided. This plan was dated January 2007, therefore it will need to be updated.
Inspections: A plan is not in place to observe the entire system annually. Moving forward, keep a document that lists what
sections of the collection system were inspected throughout the year.
A complete list of High Priority Lines was not available at the time of the inspection. Mr. Beal wasn't sure if there were other
HPLs besides the Blair Creek aerial line. A complete list of HPLs should be created and updated as needed. Additionally,
semi-annual HPL inspections are not being documented.
Pump Stations (Lift Stations): The ARPA money will also be used to install a permanent generator and upgrade the
telemetlry system at the Riverside Lift Station, which receives the highest flow. The Creekside Lift Station has the biggest
issue with grease, as it is down from several restaurants. Liquid degreaser is used here every few months. Mr. Beal
indicated that an eleventh pump station will be installed as part of the Highway 69 project.
Permanent generators automatically exercise weekly and fuel is also checked weekly. Fuel tanks are filled yearly by Parker
Oil Company, or more frequently if needed. Generators are fully serviced annually by Midway Electric. Mr. Beal stated the
portable generator will be added to the weekly and annual inspections.
The following deficiencies were noted during the inspection:
1. Grease Control: The Grease Control Program is not being enforced.
2. Inspections: The entire system is not being observed annually. A complete HPL list is not available and semi-annual HPL
inspections are not being documented.
Page 2 of 6
DocuSign Envelope ID: A3D0E939-4143-49C5-A822-C6BF7E7A77CC
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCSD0246
06/01/2022 Collection System Inspect Non Sampling
Clay County Water & Sewer District
Routine
General Yes No NA NE
# Is this system a satellite system?
# If Yes, what is system name or permit number?
Is there a overall sewer system map?
Does the map include:
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
Are system maintenance records maintained?
A sewer system map was provided, but the information on it is limited. Mr. Beal stated that a
GIS map will be created with some of the Fall 2021 ARPA money the County received.
Comment:
Grease Control Yes No NA NE
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.)
For public systems, is there a Grease Control Program via an ordinance/agreement?
If Yes, does it require grease control devices at applicable locations?
Is the Grease Control Program enforced via periodic inspections/records review?
Is action taken against violators?
The County has a Grease Control Program but it is not being enforced via periodic
inspections. Mr. Beal stated that Ingles gets their grease trap pumped every two months. See
summary for details.
Comment:
Spills and Response Action Plan Yes No NA NE
# Is system free of known points of bypass?
If No, describe type of bypass and location
# 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?
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?
Page 3 of 6
DocuSign Envelope ID: A3D0E939-4143-49C5-A822-C6BF7E7A77CC
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCSD0246
06/01/2022 Collection System Inspect Non Sampling
Clay County Water & Sewer District
Routine
Is a Spill Response Action Plan available?
Is a Spill Response Action Plan available for all personnel?
Does the plan include:
# 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
The County has an Operation and Maintenance Plan that includes a Spill and Response Action
Plan. See summary for details.
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?
A plan is not in place to observe the entire system annually. High Priority Line inspections are
not documented, and a list of High Priority Lines was not available at the time of the inspection.
See summary for details.
Comment:
Lines/Right-of-Ways/Aerial Lines Yes No NA NE
Please list the Lines/Right of Ways/Aerial Lines Inspected:
1. Blair Creek
Are right-of-ways and easements maintained for the full width for access?
If No, give details on temporary access:
Is maintenance documented?
Were all areas/lines inspected free of issues?
They have had no issues with HPLs, therefore maintenance has not been documented. Please
document HPL maintenance as needed. The bank was stabilized near the Blair Creek aerial
line in 2020.
Comment:
Manholes Yes No NA NE
Page 4 of 6
DocuSign Envelope ID: A3D0E939-4143-49C5-A822-C6BF7E7A77CC
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCSD0246
06/01/2022 Collection System Inspect Non Sampling
Clay County Water & Sewer District
Routine
Please list the Manholes Inspected:
1. Behind Jail
2. Next to Hayesville House - Assisted living
3. Corner of Riverside Drive and Eagle Street
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?
Comment:
Pump Stations Yes No NA NE
Please list the Pump Stations Inspected:
1. Riverside
2. Blair Creek
3. Creekside
4. Hyatt Mill
# Number of duplex or larger pump stations in system 10
# 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?
# A simple one-way telemetry/communication system (auto-dialer) installed?10
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 telemetry system functional?
Page 5 of 6
DocuSign Envelope ID: A3D0E939-4143-49C5-A822-C6BF7E7A77CC
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCSD0246
06/01/2022 Collection System Inspect Non Sampling
Clay County Water & Sewer District
Routine
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-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?
# 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?
Five of the ten lift stations have permanent generators. One portable generator is used for the
remaining five lift stations as needed. See summary for details.
Comment:
Page 6 of 6
DocuSign Envelope ID: A3D0E939-4143-49C5-A822-C6BF7E7A77CC