WQCSD0150_NOD2023PC0046 & CEI Report_20230209

February 9, 2023

Elizabeth Blanton, Mayor
Town of Ellenboro
PO Box 456
Ellenboro, NC 28040

SUBJECT: NOTICE OF DEFICIENCY
Tracking Number: NOD-2023-PC-0046
Permit No. WQCSD0150
Ellenboro Collection System
Rutherford County

Dear Permittee:

The North Carolina Division of Water Resources conducted an inspection of the Ellenboro Collection System on
February 1, 2023. This inspection was conducted to verify that the facility is operating in compliance with the
conditions and limitations specified in Collection System Permit No. WQCSD0150. 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 The semi-annual aerial line inspections and annual inspection of the entire collection system
have not been documented. _________________________________________________________________________________________________________________________________________________________________________

DocuSign Envelope ID: D596AF21-74F1-4F5D-98FC-7C4CF9AB887B

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
Reid Guffey (Forest City CS ORC)

DocuSign Envelope ID: D596AF21-74F1-4F5D-98FC-7C4CF9AB887B
Compliance Inspection Report
Permit:WQCSD0150 Effective:03/01/00 Expiration:Owner :Town of Ellenboro
SOC:
Contact Person:
Region:
County:
Directions to Facility:
Rutherford
Asheville
Elizabeth Blanton
Effective:Expiration:Facility:Ellenboro Collection System
Title:Phone:[phone]Mayor
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:
02/01/2023 10:00AM 12:00PM
Lauren E Armeni 828-296-4500
Mara G Chamlee
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: D596AF21-74F1-4F5D-98FC-7C4CF9AB887B
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCSD0150
02/01/2023 Collection System Inspect Non Sampling
Town of Ellenboro
Routine
Inspection Summary:
Lauren Armeni and Mara Chamlee, with the Asheville Regional Office, conducted a Compliance Evaluation Inspection of the
Ellenboro deemed-permitted collection system on February 1, 2023. The inspection was conducted to determine whether
the system is being operated and maintained in compliance with deemed-permitted Collection System Permit No.
WQCSD0150. Reid Guffey (Forest City CS ORC) was present and assisted in the inspection.
The Town of Ellenboro's Collection System is operated and maintained by Forest City Public Works staff under a 2013
Operational Agreement. Mr. Guffey indicated that the 2013 Operational Agreement ends in 2023, and staff is currently
working on a new one.
The following items were noted:
General: It is recommended to add the Ellenboro Collection System sewer lines to the Forest City GIS map, and include the
other information outlined below (pipe sizes, materials, etc.).
Inspections: All inspections are being conducted, but have not been documented. The semi-annual aerial line inspections
and annual inspection of the entire collection system needs to be documented.
Pump Stations: A Pump Station (PS) log is kept at each PS and includes the dates the PS is inspected and maintenance
that needs to be done, but it does not include the following information: inside and outside cleaning & debris removal;
inspecting and exercising all valves; inspecting and lubricating pumps & other equipment; and inspecting alarms, telemetry,
& auxiliary equipment. It is recommended to add these notes to the PS logs as they are done each visit.
Mr. Guffey indicated that there are two pumps down and in repair - one from the Wilson PS and one from the Morningside
PS. He also mentioned that a Godwin pump was purchased by Forest City if needed at the pump stations.
The following deficiency was noted:
1. Inspections: The semi-annual aerial line inspections and annual inspection of the entire collection system have not been
documented.
Page 2 of 6
DocuSign Envelope ID: D596AF21-74F1-4F5D-98FC-7C4CF9AB887B
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCSD0150
02/01/2023 Collection System Inspect Non Sampling
Town of Ellenboro
Routine
General Yes No NA NE
# Is this system a satellite system?
# If Yes, what is system name or permit number?WQCS00050
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?
Forest City maintains the Ellenboro CS map on their GIS map. Forest City recently switched
GIS programs, and the Ellenboro CS lines were not transferred to the new map. These lines
should be added, including the other information above. With the new map, Forest City staff will
be able to add line repair and maintenance information to the map with their tablets.
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 Ellenboro Collection System falls under the Forest City FOG Ordinance. Forest City
WWTP staff deal with all aspects of the Grease Control Program for Forest City and Ellenboro,
including inspecting and enforcing. Mr. Guffey indicated they have some grease issues at
Ellenboro Elementary, but the force main was recently flushed.
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?
Page 3 of 6
DocuSign Envelope ID: D596AF21-74F1-4F5D-98FC-7C4CF9AB887B
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCSD0150
02/01/2023 Collection System Inspect Non Sampling
Town of Ellenboro
Routine
# Are there repeated overflows/problems (2 or more in 12 months) at same location?
# If Yes, is there a corrective action plan?
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 Ellenboro Collection System falls under Forest City's Spill and Response Action Plan.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?
All lines are observed in the system throughout the year, but the annual inspection is not
documented. There is one aerial line in the system. This aerial line is inspected at least every
six months, but the inspections are not 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. Near Kids at Play daycare
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?
Comment:
Manholes Yes No NA NE
Page 4 of 6
DocuSign Envelope ID: D596AF21-74F1-4F5D-98FC-7C4CF9AB887B
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCSD0150
02/01/2023 Collection System Inspect Non Sampling
Town of Ellenboro
Routine
Please list the Manholes Inspected:
1. Owen Street
2. Across from The Wash Tub
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. Ellenboro Elementary
2. Wilson
# Number of duplex or larger pump stations in system 6
# 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?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 telemetry system functional?
Is a 24-hour notification sign posted ?
Does the sign include:
Page 5 of 6
DocuSign Envelope ID: D596AF21-74F1-4F5D-98FC-7C4CF9AB887B
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCSD0150
02/01/2023 Collection System Inspect Non Sampling
Town of Ellenboro
Routine
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?
The Ellenboro Elementary PS has a dedicated connection for a portable generator and the
Wilson PS has a stationary generator. The other pump stations have stationary generators
except Booger Hollow. Mr. Guffey checks the fuel in the generators, and the stationary
generators have an alarm if the fuel gets low. The stationary generators automatically exercise
once a week, and Power Generator maintains them once a year. Forest City has one large
portable generator and other smaller ones. More information should be included in the PS
logs. See summary for details.
Comment:
Page 6 of 6
DocuSign Envelope ID: D596AF21-74F1-4F5D-98FC-7C4CF9AB887B