WQCS00186_NOD2023PC0010 & CEI Report_20230111

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

January 10, 2023

Lamar Nix, Director of Public Works
Town of Highlands
Email: [e-mail]

SUBJECT: NOTICE OF DEFICIENCY
Tracking Number: NOD-2023-PC-0010
Permit No. WQCS00186
Highlands Collection System
Macon County

Dear Permittee:

The North Carolina Division of Water Resources conducted an inspection of the Highlands Collection System on
December 15, 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. WQCS00186. 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 _________________________________________________________________________________________________________________________________________________________________________ Sewer and FOG Ordinances A FOG Ordinance that includes an enforceable Grease Trap Program has not been created.
_________________________________________________________________________________________________________________________________________________________________________
Inspections The annual observation of the entire system has not been documented. High priority line
inspections have not been documented. _________________________________________________________________________________________________________________________________________________________________________
Pump Stations Pump station logs do not include the minimum required information.
_________________________________________________________________________________________________________________________________________________________________________

DocuSign Envelope ID: D4CB7422-5209-4ACB-9276-F915BA4FCD0B

In addition, the issues below must also be addressed:

Compliance Issues:

 Update the Capital Improvement Plan.
 Submit the 2021 Annual Wastewater Performance Report.
 Update the Spill Response Action Plan with the items mentioned below.

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
Robert McMahan (ORC)
Brian Tallent (BORC)
Dawn James (WTP Operator)
Dale Wike (WWTP ORC - Environmental Inc.)
DocuSign Envelope ID: D4CB7422-5209-4ACB-9276-F915BA4FCD0B
Compliance Inspection Report
Permit:WQCS00186 Effective:02/01/16 Expiration:01/31/24 Owner :Town of Highlands
SOC:
Contact Person:
Region:
County:
Directions to Facility:
Macon
Asheville
Lamar Nix
Effective:Expiration:Facility:Highlands Collection System
PO Box 563
Title:Phone:[phone]Public Works Director
Secondary ORC(s):
828-526-2960Phone:992303Certification:Robert Alan McMahanPrimary ORC:
CS1,System Classifications:
On-Site Representative(s):
Related Permits:
NC0021407 Town of Highlands - Highlands WWTP
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
12/15/2022 10:30AM 01:00PM
Lauren E Armeni 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: D4CB7422-5209-4ACB-9276-F915BA4FCD0B
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00186
12/15/2022 Collection System Inspect Non Sampling
Town of Highlands
Routine
Inspection Summary:
Lauren Armeni, with the Asheville Regional Office, conducted a Compliance Evaluation Inspection of the Highlands Collection
System on December 15, 2022. This inspection was conducted to determine if the system is being operated and maintained
in compliance with Permit No. WQCS00186. Mr. Brian Tallent (BORC), Mr. Dale Wike (WWTP ORC, Environmental Inc.),
and Ms. Dawn James (Water Treatment Plant Operator) were present during the inspection.
Overall, staff noted that there are not many issues throughout the collection system because all the lines are cleaned on a
semi-annual basis.
Sewer and FOG Ordinances: The Local Health Department inspects the grease traps, but a FOG Ordinance that includes
an enforceable Grease Trap Program has not been created. An example was sent to Ms. James to use for guidance.
Capital Improvement Plan: The Capital Improvement Plan has not been updated since 2012. The most recent budget needs
to be added, as well as upcoming projects and projects that have been completed since 2012. Ms. James indicated that the
pump station on Arnold Road will be replaced in 2023.

Reporting Requirements: The 2021 Annual Wastewater Performance Report was not submitted. The previous ORC left in
December 2021 and had not completed this report. Ms. James is in the process of gathering this information and compiling
the 2021 Annual Wastewater Performance Report.
Inspections: The annual observation of the entire system is conducted (when lines are cleaned semi-annually), but has not
been documented. The Mill Creek High Priority Line (HPL) is being inspected at least once every six months, but these
inspections are not documented.
Spill Response Action Plan: This plan has not been updated for several years. The 24-hour contact numbers, response time,
and equipment list & spare parts inventory need to be added. Any outdated information should be updated.
Pump Stations:
-The previous inspection report mentioned checking the integrity of the concrete at the Mill Creek pump station. Mr. Wike
indicated that no leaks have been observed there. Hydrogen peroxide is used at the Mill Creek pump station to increase the
dissolved oxygen of the wastewater prior to entering the WWTP. The hydrogen peroxide barrel is sitting on the ground and
should be placed on secondary containment since surface water is nearby.
-Audio and visual alarms were not checked during the inspection because there were no gloves; however, Mr. Wike indicated
that these alarms are checked regularly.
-The simplex pump stations are privately owned; however, the Town maintains them if any need replaced or have issues.
-The minimum required information is not included in the Pump Station log books. The Pump Station log template was
emailed to Ms. James and outlines what is required.
The following compliance issues were noted during the inspection:
1. The 2021 Annual Wastewater Performance Report was not submitted.
2. The Capital Improvement Plan needs to be updated.
3. The Spill Response Action Plan needs to be updated with the items listed in the report.
The following deficiencies were noted during the inspection:
1. Sewer and FOG Ordinances: A FOG Ordinance that includes an enforceable Grease Trap Program has not been created.
2. Inspections: The annual observation of the entire system has not been documented. High priority line inspections have not
been documented.
3. Pump Stations: Pump station logs do not include the minimum required information.
Page 2 of 7
DocuSign Envelope ID: D4CB7422-5209-4ACB-9276-F915BA4FCD0B
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00186
12/15/2022 Collection System Inspect Non Sampling
Town of Highlands
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?
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.)
Grease/sewer education is on the Town's website and on the bulletin board in Town Hall.
The Local Health Department inspects grease traps. An enforceable Grease Control Program
was not available at the time of the inspection. 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 hasn't been updated since 2012. See summary for details.Comment:
Page 3 of 7
DocuSign Envelope ID: D4CB7422-5209-4ACB-9276-F915BA4FCD0B
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00186
12/15/2022 Collection System Inspect Non Sampling
Town of Highlands
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?
The map is maintained in the Town's GIS system. Ms. James indicated that the employee who
updates this map will add the pipe types.
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's website
The 2020 Annual Wastewater Performance Report was submitted, but the 2021 report was not.
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?
W & S Maintenance Unlimited, Inc. jets all the lines twice a year. During this time, the entire
system is observed; however, this observation is not being documented. There is one High
Priority Line in the system that is inspected semi-annually, but the inspections are not being
documented. See summary for details.
Comment:
Page 4 of 7
DocuSign Envelope ID: D4CB7422-5209-4ACB-9276-F915BA4FCD0B
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00186
12/15/2022 Collection System Inspect Non Sampling
Town of Highlands
Routine
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:
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 Action Plan has not been updated for several years. 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?
Comment:
Lines/Right-of-Ways/Aerial Lines Yes No NA NE
Please list the Lines/Right of Ways/Aerial Lines Inspected:
1. Mill Creek
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?
W & S Maintenance Unlimited, Inc. jets all lines twice a year. Since the last inspection, no
maintenance has been done on the line, but maintenance will be documented as necessary.
Comment:
Manholes Yes No NA NE
Please list the Manholes Inspected:
1. Highlands School - near Holly Tree Road
2. Mountain Fresh Grocery - Main Street
3. Near Courtyard Cafe - Oak Street
Page 5 of 7
DocuSign Envelope ID: D4CB7422-5209-4ACB-9276-F915BA4FCD0B
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00186
12/15/2022 Collection System Inspect Non Sampling
Town of Highlands
Routine
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. Mill Creek
2. Lower Brushy Face
# Number of duplex or larger pump stations in system 6
# Number of vacuum stations in system 2
# Number of simplex pump stations in system 13
# 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?6
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?
Page 6 of 7
DocuSign Envelope ID: D4CB7422-5209-4ACB-9276-F915BA4FCD0B
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00186
12/15/2022 Collection System Inspect Non Sampling
Town of Highlands
Routine
# 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?
Mr. Wike is in charge of inspecting and maintaining the pump stations. The pump station logs
should include more detail, as indicated above and in the Pump Station Log template that was
emailed to Ms. James. The Lower Brushy Face Pump Station generator fuel tank was low and
Mr. Wike indicated it would be put on the list to refuel. See summary for details.
Comment:
Page 7 of 7
DocuSign Envelope ID: D4CB7422-5209-4ACB-9276-F915BA4FCD0B