WQCS00200_CEI NOD2024PC0138_20240802

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

August 02, 2024

Chris Ammons, Facilities Maintenance Supervisor
Western Carolina University
Email: [e-mail]

SUBJECT: NOTICE OF DEFICIENCY
Tracking Number: NOD-2024-PC-0138
Permit No. WQCS00200
Western Carolina University Collection System
Jackson County

Dear Permittee:

The North Carolina Division of Water Resources conducted an inspection of the Western Carolina University
Collection System on July 12, 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. WQCS00200. 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 _________________________________________________________________________________________________________________________________________________________________________
Lines/Right-of-Ways/Aerial Linear feet of line cleaned is not documented to assess the percentage of line cleaning, only
the zone cleaned is maintained on file. Per section II.7 of the permit, “At least 10
percent of the gravity wastewater collection system…shall be cleaned each year.” _________________________________________________________________________________________________________________________________________________________________________
Inspections Staff are observing the entire system, but semi-annual high-priority line and annual
inspections are not specifically documented. Per section III.1 of the permit, “Records
shall be maintained to document compliance with Conditions I(4), II(2)-II(4),
II(7)-II(8), IV(3) and V(1)-V(4).” _________________________________________________________________________________________________________________________________________________________________________

Docusign Envelope ID: 71E1C086-BA15-4D9B-83C7-AB7DF01361EC

In addition, the issues below must also be addressed:

Compliance Issue(s):

Capital Improvements Plan (CIP)- a copy of the scheduled capital project for the year was on file; however, the
complete CIP was not available for review. Please reference section I.5 of the permit for CIP requirements and
recommendations.

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 Mikal Willmer with the Water Quality
Regional Operations Section in the Asheville Regional Office at 828-296-4686.

Sincerely,

Daniel Boss, Assistant Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ

ATTACHMENTS: Inspection Report

Ec: LF
Docusign Envelope ID: 71E1C086-BA15-4D9B-83C7-AB7DF01361EC
Compliance Inspection Report
Permit:WQCS00200 Effective:06/24/24 Expiration:05/31/32 Owner :Western Carolina University
SOC:
Contact Person:
Region:
County:
Directions to Facility:
Jackson
Asheville
Lee Smith
Effective:Expiration:Facility:Western Carolina University Collection System
Physical Plant
Cullowhee NC 28723
Title:Phone:[phone]Director of Operations and Maintenance
Secondary ORC(s):
828-227-2988Phone:[phone]Certification:Bradford Eugene MorganPrimary ORC:
CS2,System Classifications:
On-Site Representative(s):
Related Permits:
NC0020214 Tuckaseigee Water and Sewer Authority - TWSA WWTP#2
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
07/12/2024 01:30PM 03:30PM
Mikal Willmer 828-296-4686
Richard Eguino
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
(See attachment summary)
Page 1 of 7
Docusign Envelope ID: 71E1C086-BA15-4D9B-83C7-AB7DF01361EC
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00200
07/12/2024 Collection System Inspect Non Sampling
Western Carolina University
Routine
Inspection Summary:
Mikal Willmer and Richard Eguino, with the Asheville Regional Office, conducted a compliance evaluation inspection of
Western Carolina University’s (WCU) collection system on July 12, 2024. This inspection was conducted to determine
whether the system is being operated and maintained in compliance with collection system permit #WQCS00200. Chris
Ammons, Brad Morgan, and Mike Burnett, with WCU, were present and assisted in the inspection.
The following items were noted at the time of the inspection:
The WCU collection system is managed and owned by Western Carolina University. There are no private users connected
to the system. WCU staff report ARAMARK manages several of the food service establishments on campus, but all other
users are predominantly students, faculty or staff associated with the university. WCU is a satellite system to Tuckaseigee
Water and Sewer Authority’s (TWSA) #1 collection system. A memorandum of understanding is maintained with TWSA for
assistance related to water and sewer.
General: WCU utilizes the TMA System for maintenance tracking, which is reviewed daily, and any maintenance requests
are tracked within the system.
Sewer Use Ordinance: WCU contracts Wind River Environmental to quarterly inspect and clean the grease traps around
campus. These inspections are retained on file for review. If one of the food service establishments onsite managed by
ARAMARK requires more frequent pumping, then the costs would be passed on to ARAMARK. FOG educational material
is provided to students at orientation and to residence hall directors regularly. Placards are also used. Recommend adding
this information to WCUs website so it is easily accessible to all students, faculty and staff.
Capital Improvements Plan (CIP): WCU maintenance staff have a copy of the capital improvement project scheduled for this
fiscal year on file; however, a copy of the University’s overall budget and capital improvement plan was not available for
review. A CIP is required per Section I.5 of the permit to show funds are being placed towards the continued and future
operation, management and improvement of the collection system.
CS Map: WCU has 8x11 engineering drawings of each of the seven (7) zones of the collection system. It’s recommended
the university continue to pursue a GIS map for their sewer system for facility staff to utilize.
Reporting: No reported SSOs within the past three years. Based on WCU’s 2023 annual average daily flow (approximately
147,263 GPD), an annual performance report to customers is not currently required. The Division would still recommend
posting a performance report on the University's website along with any other information pertaining to the collection and
distribution system.
Inspections:Staff visit the entire system throughout the year during routine maintenance and observation; however, the
semi-annual high-priority line (HPL) and annual system inspection are not specifically documented. High-priority line and
annual system inspections shall be documented. As discussed during the inspection, these can be documented on the
forms that are currently used for system work and maintenance.
Lines/Right-of-ways: All rights-of-way are maintained by the grounds crew of WCU. There are no remote areas within the
system. WCU staff indicated they clean by zone so at least 10% is cleaned annually. Please note, WCU needs to
document the linear feet of line cleaned and/or document each zone’s total linear feet so the percentage cleaned annually
can be easily reviewed. Division records indicate there are approximately four (4) miles of sewer line.
Manholes (MH): All manholes had minimal flow due to school being on break for the summer.
Village MH: this section of line was jetted this year.
Apodaca Science Building MH: brick manhole & vitrified clay pipe (VCP). Staff report the manhole has backed up in the
past; however, it has not overflowed due to depth of manhole.
Page 2 of 7
Docusign Envelope ID: 71E1C086-BA15-4D9B-83C7-AB7DF01361EC
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00200
07/12/2024 Collection System Inspect Non Sampling
Western Carolina University
Routine
MH behind University Auditorium Building: Brick manhole coated with concrete. Invert in good condition. No signs of overflow
or root intrusion.
HPLs: DWR staff visited all four high-priority lines. All lines are subaqueous but visible for routine inspection. Recommend
staff camera these lines to verify there are no cracks or issues near the joints.
Deficiencies: semi-annual high-priority line inspections, annual system inspections and system cleaning are being
completed but are not fully documented. Per. Section III.1 of the permit, “Records shall be maintained to document
compliance with conditions I(4), II(2)-II(4), II(7)-II(8), IV(3) and V(1)-V(4).”
Compliance Issue: A copy of the complete CIP pertaining to WCU needs to be kept on file for review. Please see the
sections in the permit and inspection report pertaining to the required and recommended items for the CIP.
Page 3 of 7
Docusign Envelope ID: 71E1C086-BA15-4D9B-83C7-AB7DF01361EC
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00200
07/12/2024 Collection System Inspect Non Sampling
Western Carolina University
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?daily/weekly
# 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?
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?Quarterly
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.)
Provided at orientation.
See summary for details.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?
The current year's capital project was available for review. See summary for details.Comment:
Map Yes No NA NE
Page 4 of 7
Docusign Envelope ID: 71E1C086-BA15-4D9B-83C7-AB7DF01361EC
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00200
07/12/2024 Collection System Inspect Non Sampling
Western Carolina University
Routine
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?
Paper maps are used.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?
Annual report not currently required based on average annual flows. See summary for details.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?
Observing entire system, but semi-annual and annual inspections are not specifically
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:
Page 5 of 7
Docusign Envelope ID: 71E1C086-BA15-4D9B-83C7-AB7DF01361EC
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00200
07/12/2024 Collection System Inspect Non Sampling
Western Carolina University
Routine
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?
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?
Complaints/issues on campus are addressed and documented within maintenance logs
retained on file.
Comment:
Lines/Right-of-Ways/Aerial Lines Yes No NA NE
Please list the Lines/Right of Ways/Aerial Lines Inspected:
Baseball field, Cordelia Camp Annex, Softball field and Picnic Area.
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?
Right-of-way maintenance is handled by the grounds crew. The permit does not require
right-of-way maintenance to be documented.
Comment:
Manholes Yes No NA NE
Please list the Manholes Inspected:
Apodaca Science Building MH, University Auditorium Building MH and Village MH.
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?
Page 6 of 7
Docusign Envelope ID: 71E1C086-BA15-4D9B-83C7-AB7DF01361EC
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00200
07/12/2024 Collection System Inspect Non Sampling
Western Carolina University
Routine
# 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:
Page 7 of 7
Docusign Envelope ID: 71E1C086-BA15-4D9B-83C7-AB7DF01361EC