WQCSD0337_NOD2022PC0143 & CEI Report_20220919

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

September 19, 2022

Zelerie Rogers, Town Administrator
Town of Fontana Dam
Email: [e-mail]

SUBJECT: NOTICE OF DEFICIENCY
Tracking Number: NOD-2022-PC-0143
Permit No. WQCSD0337
Town of Fontana Dam WWTP
Graham County

Dear Permittee:

The North Carolina Division of Water Resources conducted an inspection of the Town of Fontana Dam WWTP
on September 13, 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. WQCSD0337. 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 _________________________________________________________________________________________________________________________________________________________________________ Spills and Response A Spill Response Action Plan has not been created. Action Plan
_________________________________________________________________________________________________________________________________________________________________________
Inspections The aerial line inspections and annual inspection of the entire collection system have not
been documented. _________________________________________________________________________________________________________________________________________________________________________

DocuSign Envelope ID: 40663603-7905-4BBD-9E1B-D587F8A0283F

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
Daniel Pilkington (WWTP ORC)
DocuSign Envelope ID: 40663603-7905-4BBD-9E1B-D587F8A0283F
Compliance Inspection Report
Permit:WQCSD0337 Effective:07/30/08 Expiration:Owner :Town of Fontana Dam
SOC:
Contact Person:
Region:
County:
Directions to Facility:
Graham
Asheville
Zelerie Rogers
Effective:Expiration:Facility:Town of Fontana Dam WWTP
Fontana Village Resort
Fontana Dam NC 28733
Title:Phone:[phone]Town Administrator
Secondary ORC(s):
Phone:Certification:Primary ORC:
System Classifications:
On-Site Representative(s):
Related Permits:
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
09/13/2022 10:00AM 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
(See attachment summary)
Page 1 of 5
DocuSign Envelope ID: 40663603-7905-4BBD-9E1B-D587F8A0283F
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCSD0337
09/13/2022 Collection System Inspect Non Sampling
Town of Fontana Dam
Routine
Inspection Summary:
Lauren Armeni, with the Asheville Regional Office, conducted a Compliance Evaluation Inspection of the Town of Fontana
Dam deemed-permitted collection system on September 13, 2022. The inspection was conducted to determine whether the
system is being operated and maintained in compliance with deemed-permitted collection system permit no. WQCSD0337.
Dennis Pilkington (WWTP ORC) was present and assisted in the inspection.
Approximately two miles of the main gravity line along Highway 28 was replaced from November 2021 through
January/February 2022. The Town hasn't had any more issues since the line was replaced. Forty-five feet of line was
replaced along Woods Road in August 2022. I&I issues will be addressed and lines will be jetted in October/November 2022.
Mr. Pilkington stated that sections of the collection system will be cut out and lines will be plugged where cabins have been
torn down, which should decrease I&I in the system.
Grease Control: There are currently two grease traps in place at the restaurants and one is not being used because the
restaurant is currently closed. The grease trap at the Bistro was pumped four months ago. The only grease issues the Town
has had is with Wildwood Grill, and they are in the process of installing a grease trap which should eliminate these issues.
Spills and Response Action Plan: The Town does not currently have a Spill and Response Action Plan, but Ms. Zelerie
Rogers (Administrator/Clerk) is in the process of creating one.
Inspections: The HPL inspections and annual inspection of the entire collection system has not been documented.
Lines/Right-of-Ways/Aerial Lines: The Welch Road aerial line consists of a 6" PVC pipe going into an 8" iron pipe. At the
time of the inspection, this pipe was slowly leaking at the joint. Mr. Pilkington said he would fix it the same day. On
September14, 2022, Mr. Pilkington sent pictures confirming the repair had been made and the aerial line is no longer
leaking.
The following deficiencies were noted during the inspection:
1. Spills and Response Action Plan: A Spill Response Action Plan has not been created.
2. Inspections: The aerial line inspections and annual inspection of the entire collection system have not been documented.
Page 2 of 5
DocuSign Envelope ID: 40663603-7905-4BBD-9E1B-D587F8A0283F
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCSD0337
09/13/2022 Collection System Inspect Non Sampling
Town of Fontana Dam
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?
Mr. Pilkington indicated that the main sewer lines are concrete and the lines from the cabins
are terra cotta.
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?
Mr. Pilkington indicated that the restaurants periodically check the grease traps and they are
pumped as needed. 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 5
DocuSign Envelope ID: 40663603-7905-4BBD-9E1B-D587F8A0283F
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCSD0337
09/13/2022 Collection System Inspect Non Sampling
Town of Fontana Dam
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
At the time of the inspection, a Spill Response Action Plan was not available. Ms. Rogers is in
the process of creating one. 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?
Mr. Pilkington is conducting the inspections of the high priority line, but is not documenting
them. All lines are being inspected annually but are not being documented. 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. Welch Road
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?
The Welch Road aerial line was leaking at the time of the inspection. See summary for details.Comment:
Manholes Yes No NA NE
Please list the Manholes Inspected:
1. Main gravity line near WWTP
2. Main convergence to gravity line at Fontana Road West (next to General Store)
Are manholes accessible?
Page 4 of 5
DocuSign Envelope ID: 40663603-7905-4BBD-9E1B-D587F8A0283F
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCSD0337
09/13/2022 Collection System Inspect Non Sampling
Town of Fontana Dam
Routine
# 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?
Manholes from the Pitstop Gas Station and down have been refurbished.Comment:
Page 5 of 5
DocuSign Envelope ID: 40663603-7905-4BBD-9E1B-D587F8A0283F