WQCS00182_NOV2024PC0177_RESP_20240325

Junaluska Sanitary District
• P.O. Box 35
Lake Junaluska, NC 28745
828-452-1178
www.jsdwater.org
Daniel Boss, Assistant Regional Supervisor
Lauren Armeni, Environmental Specialist
NCDEQ Asheville Regional Office
March 25, 2024
Subject: Response to NOV dated 3/13/24 and Inspection dated 2/27/24
Tracking #: NOV-2024-PC-0177
Dear Daniel and Lauren,
The Junaluska Sanitary District (JSD) is responding to the Notice of Violation letter dated 3/13/24.
The letter states there were three violations and two compliance issues noted. Please find our
responses to these below.
Notice of Violation Item:
1) Reporting Requirements — The Annual Wastewater Performance reports have not been
done.
• JSD Response: Please find enclosed JSD's Annual Sewer Performance Report 2023. We do
understand that this report was not completed by the inspection dated 2/27/24.
However, all the details of this report were complete as noted in our Sewer system
inspection book, we just had not summarized it yet in our annual report. Furthermore, in
previous years' inspections by Tim Heim there was some uncertainty on what this report
should consist of and who it should be sent to. We did in fact send a summary report to
Mr. Heim but never received any confirmation or follow-up. The work is being completed
and it is being documented. Lauren did send us a copy of a performance report and we
have updated our system as seen in the attached.
2) Inspections — A complete High Priority Line list has not been created and semi-annual HPL
inspections have not been documented.
• JSD Response: The complete HPL list is on our permit, and it has been created (see
attached, page 11 of the PDF in the permit). JSD's 2023 HPL's are Hospital Line, Daniel
lane, Birchwood and Spicewood. In addition, these lines are notated as High Priority in
our GPS mapping system as well as identified in our inspection record books. These lines
have been inspected and recorded in our inspection book.
3) Pump Stations —Audible Alarm not working at Liner Cv PS and Audible/Visual alarms not
working at RCPS and 209 PS.
• JSD Response: During 2023, JSD started an implementation of a SCADA project for our
entire system (Water and Sewer). In this process we have converted all 3 pump stations
to this new SCADA system in order to allow our ORC and crew to remotely monitor the
stations 24 hours a day through our cell phones and Ipdad's. When any alarm goes off or

if the SCADA system goes down, it automatically sends an alert to our ORC and on -call
crew member. With this new SCADA system, JSD adopted a operations procedure that
the on -call person must visit the site when the alarm goes off. We do understand per
the regulations these audible and visual alarms still need to be in place. Through the
implementation of the new SCADA system, we have run into some issues with our
electrical set up (switches and transfers) to allow for both to take place. We have been
and are working on rectifying this and have ordered the additional components to
accommodate both SCADA and visual/audible. Our electrician is working with the
SCADA software engineer on the installation once these components come in. We are
currently waiting for the material and hope to have it all in place in April (as soon as
possible). Furthermore, I understand this might not have been fully explained to Lauren
during the on -site inspection.
Compliance Issues:
1) Inspections —The annual inspection of the entire system is not being documented.
• JSD Response: As noted in Reporting Requirements above, JSD has documented our
inspection of the entire system and it is recorded in our Sewer System Inspection book.
Per the GS, regulations and our permit, at least 10% of the gravity wastewater collection
system shall be appropriately cleaned. A general observation of the entire wastewater
collection system shall be conducted at least once per year. In 2023, JSD has cleaned
approximately 4.5 miles of sewer line (more than 10% of our system). Furthermore, JSD
was awarded an AIA Grant through the State Revolving Fund for GIS mapping of our entire
system. Throughout the year, JSD has inspected, observed, and documented our entire
sewer system in order to record location, material, depth and pertinent information of all
our MH's and lines. During this process for each item (MH's and Lines) that needed work,
repair or cleaning we generated work orders. The crew came behind the inspection and
performed the work for our entire system. This information was recorded in our Sewer
System record books.
2) Manholes — There were several issues with some of the manholes inspected (see above),
including excessive rags & grease.
• JSD Response: Per the Inspection summary of the report, the manholes that were called
out were two at Paragon Parkway near Tractor Supply and a third at Birchwood. It should
be noted that these manholes and lines were inspected during 2023 (see attached
inspection records). Since the annual inspection on 2/27/24, JSD has revisited these and
made repairs. Please see attached photos. We assume there might be some confusion on
the rags and grease comments in the manhole at Birchwood. In fact, it was not grease but
it was full of solid waste. During the inspection our ORC pulled some of this to prove it
was not grease.
In summary, JSD would respectively request that the Notice of Violation to be rescinded. All
inspections are being documented and we had and have a plan in place to fix the visual/audible
alarms in our Pump station as soon as the material is received. I am copying a photo of our annual
inspection book (too large to scan in and email) as a reference. Due to our GIS mapping project,
in 2023 we have thoroughly inspected and recorded our entire system, not just observed. We
were required to in order to appropriately complete the GIS mapping. Furthermore, following
the inspection with Lauren, we have made a new inspection book with our High Priority lines.
These were always in the main inspection book but have now made copies to have a separate
book just on these as well as recording in our GIS system. If the documentation should be in a
different format or any improvements need to take place, we would hope that NCDEQ would

help and inform JSD to make these improvements instead of issuing a violation because in fact
they are being done.
Sincerely,
M-
Jo Nickol
General Manager/Finance Officer
Junaluska Sanitary District.