WQCS00158_NOD2023PC0274 & CEI Report_20231128

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

November 28, 2023

Shaun Adams, Mayor
Town of Robbinsville
Email: [e-mail]

SUBJECT: NOTICE OF DEFICIENCY
Tracking Number: NOD-2023-PC-0274
Permit No. WQCS00158
Robbinsville Collection System
Graham County

Dear Permittee:

The North Carolina Division of Water Resources conducted an inspection of the Robbinsville Collection System on
November 13, 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. WQCS00158. 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 was noted during the inspection:
Inspection Area Description of Deficiency _________________________________________________________________________________________________________________________________________________________________________ General (Pump Stations) A Pump Failure Plan has not been created.
_________________________________________________________________________________________________________________________________________________________________________

In addition, the issues below must also be addressed:

Compliance Issue(s):

1. The sewer system map needs updated and the items missing (as noted in the summary of the
report) need to be added.
2. A pump station logbook was not available for the septage receiving pump station and a 24-hour
notification sign needs to be added.

DocuSign Envelope ID: 6370B1CE-D435-4CDA-991A-F613087CDAAB

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 J. Boss, Acting Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ

ATTACHMENTS: Inspection Report

Ec: Laserfiche
Chadd Carpenter (ORC)
DocuSign Envelope ID: 6370B1CE-D435-4CDA-991A-F613087CDAAB
Compliance Inspection Report
Permit:WQCS00158 Effective:06/09/17 Expiration:02/28/25 Owner :Town of Robbinsville
SOC:
Contact Person:
Region:
County:
Directions to Facility:
Graham
Asheville
Michael J Waresak
Effective:Expiration:Facility:Robbinsville Collection System
PO Box 126
Robbinsville NC 287710126
Title:Phone:[phone]Consultant
Secondary ORC(s):
828-479-3250Phone:[phone]Certification:Chadd Ace CarpenterPrimary ORC:
CS1,System Classifications:
On-Site Representative(s):
Related Permits:
NC0025879 Town of Robbinsville - Robbinsville WWTP
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
11/13/2023 10:00AM 01:00PM
Lauren E Armeni 828-296-4500
Mara G Chamlee
Rachel Rose
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: 6370B1CE-D435-4CDA-991A-F613087CDAAB
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00158
11/13/2023 Collection System Inspect Non Sampling
Town of Robbinsville
Routine
Inspection Summary:
Lauren Armeni, Mara Chamlee, and Rachel Rose, with the Asheville Regional Office (ARO), conducted a Compliance
Evaluation Inspection of the Town of Robbinsville's Collection System on November 13, 2023. The inspection was conducted
to determine if the system is being operated and maintained in compliance with Collection System Permit No. WQCS00158.
Chadd Carpenter (ORC) and Michael Morgan (Maintenance Worker/in-training to be BORC) were present and assisted in the
inspection.
General: Mr. Carpenter indicated that they are waiting on easements for replacing terracotta lines on Laurie Street and
Rodney Orr Bypass/Tapoco Road. Roots have been removed from the Rodney Orr manhole. Terracotta lines have been
replaced on Ford Street, Main Street, Circle Street, Dula Street, Millsaps Road, Snider Hill, and Hosanna Street, totaling
approximately 5,800 feet of terracotta line that was replaced. Terracotta lines on East Main Street and Tallulah Road still
need replaced. He also indicated that they found a leaking line near the manhole at the car wash and NC Rural Water is
currently in the process of finding and fixing the leak. At the time of the inspection, a Pump Failure Plan was not available
and this plan needs to be created and kept at the pump stations. Mr. Carpenter did not have a copy of their most recent
permit, but a copy was emailed to him.
Map: The current map is missing several items (pipe type, pipe materials, flow direction, approximate pipe age, and pump
station IDs), therefore it is recommended to update the map. Creating a sewer system map through GIS can be very useful
and is easy to update.
Pump Stations: The Town has now taken over the septage receiving pump station. Mr. Carpenter questioned whether or not
this should be included as a regular pump station and it was confirmed that it should. Mr. Carpenter indicated that this pump
station typically receives septage on Mondays, Wednesdays, and Fridays. It is OK to visit this pump station only on the
days that septage is received. There is no telemetry; however, flow is not constant in this pump station since it's only used
when septage haulers come and it is monitored when they are there. This pump station does not have a generator; however,
if the power does go out the Town will not accept any septage until the power is back on. No other flow enters this pump
station and flow from this station goes to the WWTP. Mr. Carpenter indicated that they would create a pump station logbook
for the septage receiving station. A 24-hour notification sign is also needed for this station, which includes items listed under
"Pump Stations" of this report.
At the time of the inspection, Mr. Carpenter indicated that the plastic teeth on the bar screen conveyor belt for the influent
pump station needed replaced, and they already have a company scheduled to come out. It is recommended to keep the
floats clear of debris. The infuent pump station has one-way telemetry. The influent pump station also has a stationary
generator that automatically exercises weekly.
The pump station log is still missing some information. Ms. Armeni emailed the pump station log template to Mr. Carpenter
to use for both logbooks.
The following compliance issues were noted during the inspection:
1. The sewer system map needs updated and the items missing (as noted above) need to be added.
2. A pump station logbook was not available for the septage receiving pump station and a 24-hour notification sign needs to
be added.
The following deficiency was noted during the inspection:
1. A Pump Failure Plan has not been created.
Page 2 of 7
DocuSign Envelope ID: 6370B1CE-D435-4CDA-991A-F613087CDAAB
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00158
11/13/2023 Collection System Inspect Non Sampling
Town of Robbinsville
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?Other staff review
them three times a
week.
# 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?
At the time of the inspection, a Pump Failure Plan was not available. The most recent permit
was also not available, so a copy of the permit was emailed to Mr. Carpenter. 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?Grease traps
should be
pumped/checked
every 30 days.
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 education is on the website.
The Town checks the grease traps every 30 days. Mr. Carpenter indicated there are
approximately five grease traps throughout the Town, and if the grease trap needs pumped
he'll let the establishment know.
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?
Page 3 of 7
DocuSign Envelope ID: 6370B1CE-D435-4CDA-991A-F613087CDAAB
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00158
11/13/2023 Collection System Inspect Non Sampling
Town of Robbinsville
Routine
Does CIP include description of existing facilities?
Does CIP include known deficiencies?
Does CIP include forecasted future needs?
The CIP was last completed in 2020.Comment:
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 provided map was an older paper map. Mr. Carpenter indicated that there used to be
someone dedicated to updating the map but he no longer works for the Town. It's
recommended to update the paper copy of the map with the missing items indicated above or
create a map through GIS so that it can be more easily updated. See summary for details.
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
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?
Page 4 of 7
DocuSign Envelope ID: 6370B1CE-D435-4CDA-991A-F613087CDAAB
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00158
11/13/2023 Collection System Inspect Non Sampling
Town of Robbinsville
Routine
Are inspections of HPL documented at least every 6 months?
Are new lines being added to the HPL list when found or created?
Comment:
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 is thorough, but the source of emergency funds needs to be
added. If any contacts need updated, be sure to do that and add which numbers are 24-hour
contacts.
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?
All spills are documented, but sewer related issues/complaints are not currently being
documented because the previous admin person left. Mr. Carpenter indicated that
issues/complaints will be documented moving forward.
Comment:
Lines/Right-of-Ways/Aerial Lines Yes No NA NE
Please list the Lines/Right of Ways/Aerial Lines Inspected:
1. Milltown Road
2. Moose Branch Road
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?
Page 5 of 7
DocuSign Envelope ID: 6370B1CE-D435-4CDA-991A-F613087CDAAB
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00158
11/13/2023 Collection System Inspect Non Sampling
Town of Robbinsville
Routine
At the time of the inspection, there were some branches leaning on the Moose Branch Road
aerial line. Mr. Carpenter indicated that they would remove those branches. Mr. Carpenter also
indicated that the aerial lines are checked every time it rains.
Comment:
Manholes Yes No NA NE
Please list the Manholes Inspected:
1. Down from Robbinsville Elementary School
2. Near 635 Milltown Road
3. Next to McDonald's
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. Septage receiving
2. Influent
# Number of duplex or larger pump stations in system 2
# 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?1
For pump stations inspected:
Are they secure with restricted access?
Were they free of by-pass structures/pipes?
Page 6 of 7
DocuSign Envelope ID: 6370B1CE-D435-4CDA-991A-F613087CDAAB
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00158
11/13/2023 Collection System Inspect Non Sampling
Town of Robbinsville
Routine
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?
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 Town took over the septage receiving pump station that was previously managed by the
County and it does not have a generator or a 24-hour notification sign. The influent pump
station has a generator and a sign. See summary for details.
Comment:
Page 7 of 7
DocuSign Envelope ID: 6370B1CE-D435-4CDA-991A-F613087CDAAB