WQCS00323_NOD-2024-PC-0053_20240322

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

March 22, 2024

Bill Carroll
Town of Drexel
Email: [e-mail]

SUBJECT: NOTICE OF DEFICIENCY
Tracking Number: NOD-2024-PC-0053
Permit No. WQCS00323
Drexel Collection System
Burke County

Dear Permittee:

The North Carolina Division of Water Resources conducted an inspection of the Drexel Collection System on
February 27, 2024. This inspection was conducted to verify that the facility is operating in compliance with the
conditions and limitations specified in Collection System Permit No. WQCS00323. 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 _________________________________________________________________________________________________________________________________________________________________________ Pump Stations The pump station ID and address needs to be added to the gate sign. _________________________________________________________________________________________________________________________________________________________________________
Reporting Requirements The Town has not been preparing and submitting Annual Wastewater Performance Reports.
These need to be submitted to the division and shared with customers annually. _________________________________________________________________________________________________________________________________________________________________________

DocuSign Envelope ID: EE1C8C01-C7CE-470B-AED9-4D3082FDDC57

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 Melanie Kemp 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: Compliance Inspection Report

Ec: Laserfiche, Roger Burleson (Public Works Director)

DocuSign Envelope ID: EE1C8C01-C7CE-470B-AED9-4D3082FDDC57
Compliance Inspection Report
Permit:WQCS00323 Effective:06/11/18 Expiration:04/30/26 Owner :Town of Drexel
SOC:
Contact Person:
Region:
County:
Directions to Facility:
Burke
Asheville
Donald L Barker
Effective:Expiration:Facility:Drexel Collection System
Title:Phone:[phone]Distribution Operator
Secondary ORC(s):
828-437-7421Phone:[phone]Certification:Donald L BarkerPrimary 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:
02/27/2024 10:00AM 11:45AM
Melanie Kemp
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: EE1C8C01-C7CE-470B-AED9-4D3082FDDC57
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00323
02/27/2024 Collection System Inspect Non Sampling
Town of Drexel
Routine
Inspection Summary:
Melanie Kemp, with the Asheville Regional Office, performed a Compliance Evaluation Inspection on February 27, 2024, of
the Drexel Collection System. The inspection was conducted to determine if the system is being operated and maintained in
compliance with Collection System Permit No. WQCS00323. Don Barker (CS ORC) and Roger Burleson (CS BORC) were
present and assisted with the inspection.
The Drexel CS consists of approximately 24 miles of gravity sewer, 1 duplex pump station, and 12 high priority aerial lines.
Overall, the system appears to be well maintained and operated, and record keeping was thorough and up to date.
CS staff are working with a contractor to continue monitoring the aerial line across Reece Creek. Eventually, this line will
need to be redesigned and replaced. The streambank is slowly eroding, causing ongoing exposure of this line.
The Old Drexel Heritage Industrial Site Project continues to undergo cleanup. Once a plan has been established for
redevelopment, the Town plans to replace approximately 1200’ of lines adjacent to/under the site.
The following deficiencies were noted during the inspection:
•The Town has not been submitting Annual Wastewater Performance Reports for the CS. These reports need to be
prepared and submitted to the state and shared with Town customers annually.
•The sign posted at the pump station needs to include the pump station identifier and address.
Page 2 of 7
DocuSign Envelope ID: EE1C8C01-C7CE-470B-AED9-4D3082FDDC57
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00323
02/27/2024 Collection System Inspect Non Sampling
Town of Drexel
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?as needed
# 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?
Permit expires in 2026.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?No discharge of
grease allowed,
cleaning
procedure not
outlined
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.)
The Town generates and distributes educational material regarding FOGs at the Public Works office, on their
website, and at local events.
At the moment, there are currently no restaurants or buisnesses in town that maintain or use a
grease trap.
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?
Page 3 of 7
DocuSign Envelope ID: EE1C8C01-C7CE-470B-AED9-4D3082FDDC57
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00323
02/27/2024 Collection System Inspect Non Sampling
Town of Drexel
Routine
Does CIP include known deficiencies?
Does CIP include forecasted future needs?
All wastewater from the CS goes to the Town of Valdese WWTP. The CIP budget has 20 years
of budgetary allocation to the CS and goes through 2039.
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?
There is only one pump station within the CS, which is not specifically displayed on the GIS
map. It is easily identifiable, as it is located within the old wastewater treatment plant.
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?N/A
The Town has not been preparing and submitting Annual Wastewater Performance Reports.
See summary for details. The Town of Drexel CS is a satellite system to the Town of Valdese
WWTP.
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?
Page 4 of 7
DocuSign Envelope ID: EE1C8C01-C7CE-470B-AED9-4D3082FDDC57
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00323
02/27/2024 Collection System Inspect Non Sampling
Town of Drexel
Routine
Are new lines being added to the HPL list when found or created?
There is no written plan for annual inspections, but inspections of right-of-way's and aerial lines
and cleaning of lines are being performed and documented.
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?
Source of emergency funds is not documented in the Spill Response Action Plan, but staff are
aware of the process for locating funds for emergencies.
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 complaints are documented via work orders and were avaialble for review.Comment:
Lines/Right-of-Ways/Aerial Lines Yes No NA NE
Please list the Lines/Right of Ways/Aerial Lines Inspected:
Aerial line across a creek adjacent to Reed St., and across Howard Creek at the Bryant Rd Pump Station.
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?
There are 128,146 ft. of gravity sewer, and at least 10% of that is being cleaned annually.Comment:
Manholes Yes No NA NE
Page 5 of 7
DocuSign Envelope ID: EE1C8C01-C7CE-470B-AED9-4D3082FDDC57
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00323
02/27/2024 Collection System Inspect Non Sampling
Town of Drexel
Routine
Please list the Manholes Inspected:
Manholes 341B and 341A were inspected (along Garrison Dr.)
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?
Manholes inspected were in good condition.Comment:
Pump Stations Yes No NA NE
Please list the Pump Stations Inspected:
Bryant Rd. Pump Station
# Number of duplex or larger pump stations in system 1
# 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?1
# A simple one-way telemetry/communication system (auto-dialer) installed?0
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?
Page 6 of 7
DocuSign Envelope ID: EE1C8C01-C7CE-470B-AED9-4D3082FDDC57
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00323
02/27/2024 Collection System Inspect Non Sampling
Town of Drexel
Routine
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?
During high-flow events, a pump is preemtively set up to divert flow to the old clarifier to
prevent overflows at the pump station. The generators are managed by CS staff and
automatically exercise weekly. The pump station ID and address need to be added to the
posted sign.
Comment:
Page 7 of 7
DocuSign Envelope ID: EE1C8C01-C7CE-470B-AED9-4D3082FDDC57