WQCS00205_NOD2024PC0162 & CEI REPORT_20240827

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

September 06, 2024

Aaron Haynie, Mayor
Town of Marshall
Email: [e-mail]

SUBJECT: NOTICE OF DEFICIENCY
Tracking Number: NOD-2024-PC-0162
Permit No. WQCS00205
Marshall Collection System
Madison County

Dear Permittee:

The North Carolina Division of Water Resources conducted an inspection of the Marshall Collection System on
August 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. WQCS00205. 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 _____________________________________________________________________________________________________________________________________________________________________________
Sewer and FOG Ordinances An educational FOG program is required to be distributed to both residential and
non-residential customers at least semiannually, see permit section I(4). _________________________________________________________________________________________________________________________________________________________________________
Inspections Records for an annual observation of the entire wastewater collection system are required to
be maintained, see permit sections III(1) and V(3). _________________________________________________________________________________________________________________________________________________________________________

Remedial actions should have already been taken to correct these problems 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 Richard Eguino with the Water Quality
Regional Operations Section in the Asheville Regional Office at 828-296-4500.

Docusign Envelope ID: FF70B041-7B75-490B-B628-DE87298DC19C

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: James O’Neil Chandler, ORC, [e-mail]
Laserfiche
Docusign Envelope ID: FF70B041-7B75-490B-B628-DE87298DC19C
Compliance Inspection Report
Permit:WQCS00205 Effective:07/09/21 Expiration:06/30/29 Owner :Town of Marshall
SOC:
Contact Person:
Region:
County:
Directions to Facility:
Madison
Asheville
Forrest Gilliam
Effective:Expiration:Facility:Marshall Collection System
PO Box 548
Marshall NC 287530548
Title:Phone:[phone]
Secondary ORC(s):
828-649-3031Phone:[phone]Certification:James O'Neal ChandlerPrimary ORC:
CS1,System Classifications:
On-Site Representative(s):
Related Permits:
NC0021733 Town of Marshall - Marshall WWTP
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
08/27/2024 09:54AM 01:07PM
Richard Eguino 828-296-4500
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 8
Docusign Envelope ID: FF70B041-7B75-490B-B628-DE87298DC19C
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00205
08/27/2024 Collection System Inspect Non Sampling
Town of Marshall
Routine
Inspection Summary:
Richard Eguino, with the Asheville Regional Office, conducted a Compliance Evaluation Inspection of the Town of Marshall
Collection System on August 27, 2024. The inspection was conducted to determine if the system is being operated and
maintained in compliance with Collection System Permit No. WQCS00205. James Chandler (ORC) was present and
assisted in the inspection.
General: The subject collection system consists of 10.45 miles of gravity lines and four duplex pump stations. Spare pump
station pumps and parts are kept at the Town’s Maintenance Building located on Main Street.
Sewer Use and FOG Ordinances: The sewer use and FOG ordinances were reviewed and one area for improvement was
noted—the FOG ordinance requires that grease traps be maintained by end users to prevent discharges of grease but does
not specify a minimum pump out/cleaning requirement. It is recommended that the FOG ordinance be amended to include a
minimum pump out/cleaning requirement for grease traps.
An educational FOG program is being distrubted once per year to residential customers and twice per year to non
residential customers. Permit section I(4) requires the distribution at least semiannually to both residential and
non-residential customers.

Inspections: Town personnel visit the entire system throughout the year during routine maintenance and observations;
however, the annual system observation is not specifically documented. Permit section V(3) establishes the requirement for
the annual observation of the entire system and permit section III(1) establishes the requirement to maintain records of it.
Spill Response Action Plan: The Spill Response Action Plan was reviewed and it was noted that a source of emergency
funds was not included as required in permit section II(8).
Lines/Right-of-Ways/Aerial Lines: Line cleaning records show the 10% minimum annual line cleaning requirement is met.
Mr. Chandler explained the Town conducts line cleaning in house with their own jettter.
The collection system includes three high priority lines (HPL) which are inspected by Town personnel every six months. The
Redmon Road Pump Station to WWTP HPL and the Island Road Pump station to WWTP HPL are force mains that were
installed via directional boring beneath the French Broad River. Both these HPLs are not visible due to being below the
streambed. The Hayes Run Road HPL is a gravity line with two aerial stream crossings over Hayes Run. No issues were
observed.
Manholes: Four manholes were inspected and are listed below.
1.Manhole on Main Street, located in front of town hall, is constructed of brick with a clay pipe. Some sand accumulation
was noted but it was not impeding flow. Mr. Chandler explained this will be monitored and cleaned as necessary.
2.Manhole at the intersection of Rollins Road and Hayes Run Road is of concrete construction. No issues noted.
3.Manhole at the intersection of Roberts Hill Road and P Davis Road is of concrete construction. No issues noted.
4.Manhole on Walnut Creek Road, ~100 ft north of Sunset Dr. is of concrete construction. No issues noted.
Pump Stations: The collection system includes four duplex pump stations, which were inspected and are listed below.
1.Rollins Road pump station
2.Baileys Branch pump station
3.Redmon Road pump station
4.Island Road pump station
Each pump station’s float switches, visual and audible alarms, and auto dialer system were tested satisfactorily. Grease
accumulation was minimal in each pump station. Each is equipped with quick connects for the Town’s portable emergency
generator. No issues were noted.
The portable emergency generator is tested twice per month. In the event of an emergency the generator will be used at the
Page 2 of 8
Docusign Envelope ID: FF70B041-7B75-490B-B628-DE87298DC19C
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00205
08/27/2024 Collection System Inspect Non Sampling
Town of Marshall
Routine
pump station determined to have the greatest flow and will be rotated to the other pump stations as needed until support
from MSD and Mike’s Septic arrives. The Town’s response plan indicates that MSD agrees to support the Town with vac
trucks other equipment during emergencies.
Compliance issues:
1. It is recommended that the FOG ordinance be amended to include a minimum pump out/cleaning requirement for grease
traps.
2. An educational FOG program is required to be distributed to both residential and non-residential customers at least
semiannually, see permit section I(4).
3. Records for an annual observation of the entire wastewater collection system are required to be maintained, see permit
sections III(1) and V(3).
4. The Spill Response Action Plan is required to include a source of emergency funds, see permit section II(8).
Page 3 of 8
Docusign Envelope ID: FF70B041-7B75-490B-B628-DE87298DC19C
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00205
08/27/2024 Collection System Inspect Non Sampling
Town of Marshall
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?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?
Baileys Branch sewer line replacement is in the planning stages and is listed in the Capital
Improvement Plan. Island Road pump station has been recently upgraded with anti-corrosion
(stainless) components.
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?Not listed.
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 FOG ordinance does not include a standard grease trap cleaning requirement. The
grease/sewer educational program is distributed one time per year to residential customers.
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?
Page 4 of 8
Docusign Envelope ID: FF70B041-7B75-490B-B628-DE87298DC19C
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00205
08/27/2024 Collection System Inspect Non Sampling
Town of Marshall
Routine
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 system map is in paper form with only one copy available. Mr. Chandler is currently
working with a consultant to create an updated map in 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?
Annual average flow is less than 200K GPD so the annual report is not required in accordance
with NCGS 143-215.1C.
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?
The entire system is being observed on an annual basis but it is not specifically documented.
See summary for details.
Comment:
Page 5 of 8
Docusign Envelope ID: FF70B041-7B75-490B-B628-DE87298DC19C
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00205
08/27/2024 Collection System Inspect Non Sampling
Town of Marshall
Routine
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 did not include a source of emergency funds. See summary for
details.
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?
Comment:
Lines/Right-of-Ways/Aerial Lines Yes No NA NE
Please list the Lines/Right of Ways/Aerial Lines Inspected:
1. Redman Road Pump Station to WWTP, subsurface force main
2. Island Road Pump Station to WWTP, subsurface force main
3. Hayes Run RdFour , aerial gravity line
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?
See summary for details.Comment:
Manholes Yes No NA NE
Please list the Manholes Inspected:
See summary for details.
Page 6 of 8
Docusign Envelope ID: FF70B041-7B75-490B-B628-DE87298DC19C
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00205
08/27/2024 Collection System Inspect Non Sampling
Town of Marshall
Routine
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?
See summary for details.Comment:
Pump Stations Yes No NA NE
Please list the Pump Stations Inspected:
See summary for details.T
# Number of duplex or larger pump stations in system 4
# 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?
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?
Page 7 of 8
Docusign Envelope ID: FF70B041-7B75-490B-B628-DE87298DC19C
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00205
08/27/2024 Collection System Inspect Non Sampling
Town of Marshall
Routine
# 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?
See summary for details.
# 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?
Comment:
Page 8 of 8
Docusign Envelope ID: FF70B041-7B75-490B-B628-DE87298DC19C