WQCS00032_NOD2022PC0109 & CEI Report_20220712

SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED.
July 12, 2022
Seth Eckard
Town of Valdese
Email: [e-mail]
SUBJECT: NOTICE OF DEFICIENCY
Tracking Number: NOD-2022-PC-0109
Permit No. WQCS00032
Valdese Collection System
Burke County
Dear Permittee:
The North Carolina Division of Water Resources conducted an inspection of the Valdese Collection System on
June 29, 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. WQCS00032. 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
_________________________________________________________________________________________________________________________________________________________________________
Inspections A list of High Priority Lines and inspection records were not available at the time of the
inspection. Annual inspection documentation was not organized enough to review.
_________________________________________________________________________________________________________________________________________________________________________
Sewer and FOG Ordinances Grease education material is not being sent as required.
_________________________________________________________________________________________________________________________________________________________________________
Lines/Right-of-Ways/Aerial Maintenance on High Priority Lines has not been documented as required. Gravity line
Lines cleaning records were not organized enough to review.
_________________________________________________________________________________________________________________________________________________________________________
DocuSign Envelope ID: F91C537C-B4A3-4C30-A4DD-664A6DFCF5C8

In addition, the issues below must also be addressed:

Compliance Issue(s):

General: The permit expires on 12/31/2022 and no application has been submitted. Per the permit, the application
should be submitted at least six months prior to the expiration date.

Spill Response Action Plan: The Spill Response Plan needs to be updated.

Pump Stations: The wet well at High Meadows PS contained too much grease and should be cleaned.

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, Greg Padgett (ORC, [e-mail])
DocuSign Envelope ID: F91C537C-B4A3-4C30-A4DD-664A6DFCF5C8
Compliance Inspection Report
Permit:WQCS00032 Effective:01/01/15 Expiration:12/31/22 Owner :Town of Valdese
SOC:
Contact Person:
Region:
County:
Directions to Facility:
Burke
Asheville
Bryan Duckworth
Effective:Expiration:Facility:Valdese Collection System
PO Box 339
Valdese NC 286900339
Title:Phone:[phone]
Secondary ORC(s):
Phone:Certification:Primary ORC:
CS2,System Classifications:
On-Site Representative(s):
Related Permits:
NC0041696 Town of Valdese - Lake Rhodhiss WWTP
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
06/29/2022 11:15AM 02:15PM
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 8
DocuSign Envelope ID: F91C537C-B4A3-4C30-A4DD-664A6DFCF5C8
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00032
06/29/2022 Collection System Inspect Non Sampling
Town of Valdese
Routine
Inspection Summary:
Stephanie Williams, with the Asheville Regional Office, conducted a Compliance Evaluation Inspection of the Valdese
Collection System on June 29, 2022. This inspection was conducted to determine if the system is being operated and
maintained in compliance with permit no. WQCS00032. Greg Padgett (ORC), Allen Hudson (Public Works Director), Alex
Garrison (Maintenance Supervisor), and Terry Stillwell (Maintenance) were present during the inspection.
The Collection System is 64.4 miles total, with 61.3 miles of gravity line and 3.1 miles of force main. The system includes 5
pump stations and 15 high priority lines. There are three satellite systems connected to the Collection System – Drexel,
Rutherford College, and a portion of the Burke County Collection System.
Overall, records and documentation were poorly organized. Ms. Williams sent a blank report which outlined all required
documentation with ample time for preparation prior to the inspection. Staff were having difficulty finding the requested
documentation during the inspection. The Town allocates Collection System maintenance responsibilities between
Collection System and Distribution System staff. Collection System staff maintain the lift stations and Distribution System
staff maintain manholes, gravity lines, force mains, and high priority lines. This may be a contributing factor to the issue of
files being disorganized. Additionally, the permit expires on 12/31/2022 and no application has been submitted. The
permittee should submit a permit renewal application promptly to avoid noncompliance due to an expired permit.
Sewer and FOG Ordinances: The Town has not been mailing grease education materials as required by the permit. There is
education information posted on the Town website, which reduces the mailing requirement from twice to once annually.
Education materials still need to be sent at least once per year.
Inspections: The annual inspection is documented through work orders and was presented at the time of the inspection as
an unorganized 100-page document with work dating back more than ten years. Please present this information in a
reasonably organized manner that is clear for the inspector to review and understand. High Priority Line inspection records
were not available at the time of the inspection.
Spill Response Action Plan: The Spill Response Plan is outdated and needs to be updated. At the time of the inspection,
staff did not have an easily accessible copy of the Spill Response Plan. An updated Plan should be always accessible to all
staff.
Lines/Right-of-Ways/Aerial Lines: Maintenance on High Priority Lines has not been documented as required. Gravity line
cleaning records were presented in a 50-page document of unorganized work orders dating back more than ten years. The
information presented during the inspection did not include length of line cleaned. This information is necessary to calculate
the percentage of the system that has been cleaned. In the future, please present this information in a reasonably organized
manner that is clear for the inspector to review and understand.
Pump Stations:
High Meadows: The wet well at the High Meadows Pump Station had approximately 75% grease coverage. The grease
should be pumped and kept at coverage of 25% or less. In addition to the annual grease educational material mailing
requirement, targeted education materials or door hangers can be used in an effort to prevent grease from entering the
system. At the time of the inspection, the audio alarm was disabled due to a complaint from a neighbor. Staff reconnected
the alarm following the inspection and it is now operational. The 2019 inspection indicated that the rail on pump 1 was
corroded. The rail has since been replaced. This lift station does not have a permanent generator or quick connections for a
portable generator; however, staff stated that the wet well retains two days of typical flow. In the event of a power outage,
pump trucks would be used as needed.
Morgan Trace: At the time of the inspection, the visual alarm at the Morgan Trace Pump Station was not functioning.
Following the inspection, Collection System staff ordered a sensor to fix the alarm. Staff will repair the visual alarm upon
delivery of this part. Collection System staff stated that work will begin within the next month to redo this pump station.
Cline: Staff stated that rags are an issue at this lift station. It is recommended that information regarding rags be included in
Page 2 of 8
DocuSign Envelope ID: F91C537C-B4A3-4C30-A4DD-664A6DFCF5C8
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00032
06/29/2022 Collection System Inspect Non Sampling
Town of Valdese
Routine
the grease education materials and targeted educational materials can be distributed in problem areas as needed. Staff
stated that flow is higher than what should be expected at this lift station.
The following deficiencies were noted during the inspection:
1. Sewer and FOG Ordinances: Grease education material is not being sent as required.
2. Inspections: A list of High Priority Lines and inspection records were not available at the time of the inspection. Annual
inspection documentation was not organized enough to review.
3. Lines/Right-of-Ways/Aerial Lines: Maintenance on High Priority Lines has not been documented as required. Gravity line
cleaning records were not organized enough to review.
Additional Compliance Issues:
General: The permit expires on 12/31/2022 and no application has been submitted. Per the permit, the application should be
submitted at least six months prior to the expiration date.
Spill Response Action Plan: The Spill Response Plan needs to be updated.
Pump Stations: The wet well at High Meadows PS contained too much grease and should be cleaned.
Page 3 of 8
DocuSign Envelope ID: F91C537C-B4A3-4C30-A4DD-664A6DFCF5C8
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00032
06/29/2022 Collection System Inspect Non Sampling
Town of Valdese
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?Twice yearly
# 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 on 12/31/2022 and no application has been submitted. Per the permit, the
application should be submitted at least six months prior to the expiration date. See summary
for details.
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?6 months
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.)
Town website
Grease education material is 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 Capital Improvement Plan is thorough and is updated yearly.Comment:
Page 4 of 8
DocuSign Envelope ID: F91C537C-B4A3-4C30-A4DD-664A6DFCF5C8
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00032
06/29/2022 Collection System Inspect Non Sampling
Town of Valdese
Routine
Map Yes No NA NE
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?
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?Town website
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 list of High Priority Lines and inspection records were not available at the time of the
inspection. Annual inspection documentation was not organized enough to review. See
summary for details.
Comment:
Spill Response Action Plan Yes No NA NE
Is a Spill Response Action Plan available?
Page 5 of 8
DocuSign Envelope ID: F91C537C-B4A3-4C30-A4DD-664A6DFCF5C8
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00032
06/29/2022 Collection System Inspect Non Sampling
Town of Valdese
Routine
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
Does the Permittee appear to respond within 2 hours of first knowledge of a spill?
The Spill Response Plan needs to be updated. The current plan was not immediately available.
The updated plan should be available to all personnel. See summary for details.
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?
Mr. Padgett stated that there have not been any non-reportable spills or complaints.Comment:
Lines/Right-of-Ways/Aerial Lines Yes No NA NE
Please list the Lines/Right of Ways/Aerial Lines Inspected:
Lake Rhodhiss Drive NE
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?
Maintenance on High Priority Lines has not been documented as required. Gravity line
cleaning records were not organized enough to review. See summary for details.
Comment:
Manholes Yes No NA NE
Please list the Manholes Inspected:
Cline Street, Sterling Street SW
Are manholes accessible?
# Are manhole covers/vents above grade?
Are manholes free of visible signs of overflow?
Page 6 of 8
DocuSign Envelope ID: F91C537C-B4A3-4C30-A4DD-664A6DFCF5C8
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00032
06/29/2022 Collection System Inspect Non Sampling
Town of Valdese
Routine
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:
High Meadows, Morgan Trace, Cline
# Number of duplex or larger pump stations in system 5
# 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?5
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?
Page 7 of 8
DocuSign Envelope ID: F91C537C-B4A3-4C30-A4DD-664A6DFCF5C8
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00032
06/29/2022 Collection System Inspect Non Sampling
Town of Valdese
Routine
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?
Pump truck
# 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?
The audio alarm at High Meadows PS and the visual alarm at Morgan Trace PS were not
functional at the time of the inspection. Audio at High Meadows has been reconnected and a
part has been ordered to repair visual at Morgan Trace. The wet well at High Meadows PS
contained too much grease and should be cleaned. See summary for details. Generators are
exercised under load quarterly and automatically exercise weekly.
Comment:
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DocuSign Envelope ID: F91C537C-B4A3-4C30-A4DD-664A6DFCF5C8