WQCS00140_NOV-2024-PC-0368_CEI_20240610

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

June 10, 2024

Tim Barth, Town Manager
Town of Columbus
Email: [e-mail]

SUBJECT: NOTICE OF VIOLATION
Tracking Number: NOV-2024-PC-0368
Permit No. WQCS00140
Columbus Collection System
Polk County

Dear Permittee:

The North Carolina Division of Water Resources conducted an inspection of the Columbus Collection System on
May 23, 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. WQCS00140. 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 violations were noted during the inspection:

Inspection Area Description of Violation _________________________________________________________________________________________________________________________________________________________________________
Sewer and FOG Ordinance The Town’s FOGs program is not being documented or enforced by CS staff to ensure users
are complying with the Town’s SUO (Permit Condition I.5).
_________________________________________________________________________________________________________________________________________________________________________
Capital Improvement Plan A finalized, complete Capital Improvement Plan was not provided during the
inspection (Permit Condition I.6). _________________________________________________________________________________________________________________________________________________________________________
Pump Stations Neither of the pump stations inspected had a pump station identifier on the sign posted
(Permit Condition I.9). _________________________________________________________________________________________________________________________________________________________________________
Lines/Right-of-Ways/Aerial The CS is not tracking that at least 10% of their lines are cleaned annually (Permit
Lines Condition II.8). _________________________________________________________________________________________________________________________________________________________________________

Inspections An annual inspection process has not been developed and is not being documented (Permit
Condition V.3). _________________________________________________________________________________________________________________________________________________________________________

DocuSign Envelope ID: C0C98283-B92E-473D-B03A-8590E30D75EE

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, please respond in writing to this office within 10 business days upon your receipt of
this Notice of Violation regarding your plans or measures to be taken to address the indicated violations and other
identified issues, if applicable.
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 Evaluation Inspection Report
Ec: LF, James Smith (ORC)
DocuSign Envelope ID: C0C98283-B92E-473D-B03A-8590E30D75EE
Compliance Inspection Report
Permit:WQCS00140 Effective:02/01/15 Expiration:01/31/23 Owner :Town of Columbus
SOC:
Contact Person:
Region:
County:
Directions to Facility:
Polk
Asheville
Jonathan Kanipe
Effective:Expiration:Facility:Columbus Collection System
PO Box 146
Columbus NC 287220146
Title:Phone:[phone]
Secondary ORC(s):
828-899-0685Phone:988472Certification:James Richard SmithPrimary ORC:
CS1,System Classifications:
On-Site Representative(s):
Related Permits:
NC0021369 Town of Columbus - Columbus WWTP
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
05/23/2024 10:00AM 12:30PM
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: C0C98283-B92E-473D-B03A-8590E30D75EE
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00140
05/23/2024 Collection System Inspect Non Sampling
Town of Columbus
Routine
Inspection Summary:
Melanie Kemp, with the Asheville Regional Office, conducted a Compliance Evaluation Inspection of the Town of Columbus'
Collection System on May 23, 2024. This inspection was conducted to determine whether the system is being operated and
maintained in compliance with Collection System Permit No. WQCS00140. James Smith (ORC) was present and assisted
with the inspection. The system is comprised of 18 miles of gravity sewer, 1.4 miles of force main, 9 high priority lines, and
5 duplex pump stations.
General: The permittee did not have a copy of their permit, but one was emailed to the ORC during the inspection. The
permit is currently expired, but a renewal application was submitted and is under review.
Sewer and FOG Ordinances: The Town's Sewer Use Ordinance (SUO) outlines rules for regulating and enforcing grease
traps throughout the collection system, although Collection System (CS) staff are not involved in the process of regularly
performing inspections or enforcing SUO requirements that grease traps are inspected and pumped monthly. It is required
that a system be developed to ensure facilities with grease traps provide proof of routine cleaning.
CIP: Town is in the process of finalizing their 10-year Capital Improvement Plan (CIP), which goes through 2029. A draft of
the budget table was provided during the inspection, but the full CIP was not available for review.
Map: Currently the CS map is available on GIS but does not display many features including pipe type, material, flow
direction, pipe age, or pump station information (ID, location, and capacity). It is recommended that this information be
added to the GIS system.
Reporting Requirements: Although the Town is not required to provide an Annual Report unless flows are above 0.2 MGD, it
is recommended that one be developed and posted on the Town’s website.
Spill Response Action Plan: It is recommended that the Spill Response Action Plan be updated (last updated in 2015) to
ensure the contact list, inventory, and contractors available for spill response is accurate. Any spills that are not reportable
to the state go through the Town’s work order system.
Lines/Right-of-Ways/Aerial Lines: Although CS staff are performing required maintenance to the system (line cleaning,
right-of-way maintenance, and HPL inspections), there was no documentation of these activities available for review.
Pump Stations: All pump stations are being checked as required by permit. The Farm and Highwood pump stations were
operable at the time of the inspection. It should be noted that only the Farm and BP pump stations have telemetry installed
(all others have audible and visual high-water alarms and are checked daily). The Highwood pump station has no back-up
power source or quick-connect for a portable generator.
Compliance issues noted during the inspection:
•The Town’s FOGs program is not being documented or enforced by CS staff, to ensure users are complying with the
Town’s SUO (Permit Condition I.5).
•A finalized and complete Capital Improvement Plan was not provided during the inspection (Permit Condition I.6).
•Neither of the pump stations inspected had a pump station identifier on the sign posted (Permit Condition I.9).
•The CS is not tracking that at least 10% of their lines are cleaned annually (Permit Condition II.8).
Page 2 of 7
DocuSign Envelope ID: C0C98283-B92E-473D-B03A-8590E30D75EE
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00140
05/23/2024 Collection System Inspect Non Sampling
Town of Columbus
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?
The permit expired on 1/31/2023 and a renewal application has been submitted.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?inspect monthly,
pump as needed
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.)
Educational material is occasionally mailed out annually and posted on the Town's website.
The SUO outlines grease trap requirements, but CS staff do not perform inspections or require
customers to track when they clean grease graps. It is required that a program be developed
and enforced to ensure compliance with SUO.
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?
Page 3 of 7
DocuSign Envelope ID: C0C98283-B92E-473D-B03A-8590E30D75EE
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00140
05/23/2024 Collection System Inspect Non Sampling
Town of Columbus
Routine
The CIP is still being drafted. A budget table showing funding allocated through 2029 was
provided during the inspection, but the full CIP was not available for review.
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?
Pump stations were displayed on the map, but did not include identifier or capacity. It is
recommended that additional details be added to GIS.
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?
Flows are under 200,000 GPD therefore no annual report is required, although it is strongly
recommended for municipalities.
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?
Page 4 of 7
DocuSign Envelope ID: C0C98283-B92E-473D-B03A-8590E30D75EE
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00140
05/23/2024 Collection System Inspect Non Sampling
Town of Columbus
Routine
The Town manitains 9 HPL's and checks them monthly, although this process is not being
documented. An annual inspection process has not been developed and is not being
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?
The Spill Response Action Plan was last updated in 2015, and may require an update.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?
Spills are tracked using the Town's work order system, but this was not available for review
during the inspection.
Comment:
Lines/Right-of-Ways/Aerial Lines Yes No NA NE
Please list the Lines/Right of Ways/Aerial Lines Inspected:
White Oak Creek crossing by the WWTP and Woodland Rd/Fox Mountain Rd Intersection
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?
CS staff clean lines when necessary, but this is not being tracked or documented to confirm the
length of lines cleaned.
Comment:
Manholes Yes No NA NE
Page 5 of 7
DocuSign Envelope ID: C0C98283-B92E-473D-B03A-8590E30D75EE
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00140
05/23/2024 Collection System Inspect Non Sampling
Town of Columbus
Routine
Please list the Manholes Inspected:
By Farm Pump Station, intersection of Woodland Rd and Fox Mountain Rd, and intersection of Peak St and
Julia St.
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:
Highwood Pump Station and Farm Pump Station
# Number of duplex or larger pump stations in system 5
# 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?2
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:
Page 6 of 7
DocuSign Envelope ID: C0C98283-B92E-473D-B03A-8590E30D75EE
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00140
05/23/2024 Collection System Inspect Non Sampling
Town of Columbus
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 Farm and BP pump stations have an auto-dialer installed, but all other lift stations do not.
All pump stations have a backup generator, except for the Highwood pump station (which has
neither backup or quick connect). The flows are very low at this pump station and CS staff
inspect daily.. A contractor performs checks and maintenance on the backup generator at the
Farm pump station. A pump station identifier was not present on either of the signs, and needs
to be added.
Comment:
Page 7 of 7
DocuSign Envelope ID: C0C98283-B92E-473D-B03A-8590E30D75EE