WQCS00131_NOV2018PC0029_20180215

State of North Carolina | Environmental Quality | Water Resources
2090 U.S. 70 Highway, Swannanoa, NC 28778
828-296-4500

Certified Mail #7017 2620 0000 9759 5152
Return Receipt Requested

February 15, 2018

Ron Nalley, Town Manager
Town of Lake Lure
PO Box 255
Lake Lure, NC 28746

SUBJECT: NOTICE OF VIOLATION
Tracking Number: NOV-2018-PC-0029
Permit No. WQCS00131
NPDES Permit No. NC0025381
Lake Lure Collection System
Rutherford County, NC

Dear Permittee:

The North Carolina Division of Water Resources conducted an inspection of the Lake Lure Collection System on
January 25, 2018. This inspection was conducted to verify that the facility is operating in compliance with the
conditions and limitations specified in Collection System Permit No. WQCS00131. 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 _________________________________________________________________________________________________________________________________________________________________________
Performance Standards CIP only addresses short-term goals. Documented excessive I&I is not specifically addressed.
2013 NPDES Permit NC0025381 Renewal estimated I&I at 165,000 GPD. The 2017 SOC listed
I&I at 110,000 GPD. Data for 2017 shows a change in average flow of 80,000 GPD from
November to December, at the beginning of the Lake drawn down. Permit Condition II (2)
requires the permittee to establish a plan for addressing problems in the collection
system that are identified during system inspections. Permit Condition I (5) also
recommends creating a long-term plan to address known deficiencies and
forecasted future needs. _________________________________________________________________________________________________________________________________________________________________________
Operation & Maintenance Excessive I&I has caused significant interference of the POTW treatment processes. NPDES
Permit Standard Conditions Part IV(A) defines interferences as, "inhibition or
disruption of the POTW treatment processes; operations; or its sludge process,
DocuSign Envelope ID: 5D4F67BA-E68C-4C72-989F-6045564B9FFC

State of North Carolina | Environmental Quality | Water Resources
2090 U.S. 70 Highway, Swannanoa, NC 28778
828-296-4500

use, or disposal which causes or contributes to a violation of any requirement..." _________________________________________________________________________________________________________________________________________________________________________
Operation & Maintenance The Spill Response Action Plan (SRAP) does not address corrective action for a catastrophic
failure of the main line beneath Lake Lure. The main line beneath the Lake is a 12” cast iron
gravity main with leaded joints which flows into a 20” cast iron line near the Dam. The lines
were installed before the Lake was filled in 1927. The line sits 90’ below the surface in some
parts of the Lake. Pipe wrapping was completed in 2011 and significantly reduced I&I;
however, the life-expectancy is approximately 10 years. Permit Condition I(2) requires
the Permittee to take immediate action, per the Response Action Plan, in the event
that the wastewater collection system fails to perform satisfactorily, including the
creation of nuisance conditions. _________________________________________________________________________________________________________________________________________________________________________
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, please respond in writing to this office within 30 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 Mikal Willmer with the Water Quality
Regional Operations Section in the Asheville Regional Office at 828-296-4500.

Sincerely,

G. Landon Davidson, P.G., Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ

ATTACHMENTS: Inspection Report

Ec: WQS ARO Server
PERCS-LF

20180206_WQCS00131_NOV2018PC0029

DocuSign Envelope ID: 5D4F67BA-E68C-4C72-989F-6045564B9FFC
Compliance Inspection Report
Permit:WQCS00131 Effective:06/01/17 Expiration:05/31/25 Owner :Town of Lake Lure
SOC:
Contact Person:
Region:
County:
Directions to Facility:
Rutherford
Asheville
Linda Ward
Effective:Expiration:Facility:Lake Lure Collection System
PO Box 255
Lake Lure NC 287460255
Title:Phone:[phone]
Donnie S McCraw 993525 828-625-9983
Donald G Byers 13128
Secondary ORC(s):
Phone:Certification:Primary ORC:
CS1,System Classifications:
On-Site Representative(s):
Related Permits:
NC0025381 Town of Lake Lure - Lake Lure WWTP
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
01/25/2018 10:00AM 01:00PM
Mikal Willmer 828-296-4686
Timothy H Heim
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 Performance Standards Operation & Maint Reqmts
Records Monitoring & Rpting Reqmts Inspections
Pump Station Manhole Lines
(See attachment summary)
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DocuSign Envelope ID: 5D4F67BA-E68C-4C72-989F-6045564B9FFC
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00131
01/25/2018 Collection System Inspect Non Sampling
Town of Lake Lure
Routine
Inspection Summary:
Inspectors Mikal Willmer and Tim Heim, with the Asheville Regional Office conducted a Compliance Evaluation Inspection of
the Town of Lake Lure's Collection System. This inspection was conducted to determine whether the facility is being
operated and maintained in compliance with CS Permit #WQCS00131. Don Byers (Backup CS ORC), Ron Nalley (Town
Manager), David Arrowood (Public Works Director) and Donnie McCraw (ORC) were present and assisted in the inspection.
The following additional items were noted during the inspection:
Collection system staff are adequately maintaining and monitoring the Lake's perimeter manholes and preventing SSOs.
Staff enforce the sewer use ordinance as necessary to encourage citizens to repair private lines around the lake; however,
not all lines are approved by the town before installation and constant breaks occur. In addition to inadequate private line
installation causing infiltration, the town maintained line below the Lake is not easily accessible for repairs. The pipe wrap
installed in 2011 on the main line below the Lake is reaching the end of its 10-year life expectancy. Additional wrapping is
not a permanent solution. I&I still accounts for about a third of the Lake Lure WWTP (NPDES Permit
No.NC0025381)average flow. The excessive I&I has caused interference with the Town's ability to adequately treat the
incoming wastewater. Interference under the NPDES Permit Standard Conditions Part IV(A).is defined as "inhibition or
disruption of the POTW treatment processes; operations; or its sludge process, use, or disposal which causes or
contributes to a violation of any requirement..." Due to the excessive I&I, the Town's WWTP was converted to
physical/chemical because the influent composition could not sustain biological growth. Additionally, a failure of the main
collection system line under the Lake would inundate the WWTP and potentially wash accumulated solids into the receiving
stream.
The recent CIP only addresses short term goals. The Town plans to prioritize sewer projects after the budgeted water and
sewer study is completed. The previously budgeted Greenline project would have created an interconnect with the Town of
Spindale and removed a NPDES permit, but did not address the excessive I&I. Permit Condition II(2.) requires the permittee
to establish a plan for addressing problems in the collection system that are identified during system inspections. Permit
Condition I(5) also recommends creating a long-term plan to address known deficiencies and forecasted future needs.
SRAP does not currently address a failure of the main line beneath Lake Lure. Permit Condition I.(2.) Requires the Permittee
to take immediate action, per the Response Action Plan, in the event that the wastewater collection system fails to perform
satisfactorily, including the creation of nuisance conditions. The permittee has worked with a diving firm from Charlotte in the
past; however, conditions would be such line replacement would not be feasible at depth. The 90-year-old Dam does not
have a spill-way and the flood gates would not lower the lake adequately to access the pipe. Town staff report there is a 30"
valve on the bottom side of the Dam that could potentially be used to lower the lake; however, it has not been exercised
regularly.
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DocuSign Envelope ID: 5D4F67BA-E68C-4C72-989F-6045564B9FFC
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00131
01/25/2018 Collection System Inspect Non Sampling
Town of Lake Lure
Routine
Performance Standards Yes No NA NE
Is Public Education Program for grease established and documented?
What educational tools are used?
Flyers are available to town residents and oil and grease educational material is available through the
Town's website.
Is Sewer Use Ordinance/Legal Authority available?
Does it appear that the Sewer Use Ordinance is enforced?
Is Grease Trap Ordinance available?
Is Septic Tank Ordinance available (as applicable, i.e. annexation)
List enforcement actions by permittee, if any, in the last 12 months
The SUO was recently updated and is enforced as needed. There is not a separate Septic Tank Ordinance;
however, residences within 200' of the existing collection system are required to tie on. CS staff report having
discussions regularly with citizens about repairing private lines. The Town plans to begin using a Grease
Trap Inspection form moving forward. Restaurants are generally inspected before they reopen for the season.
CS staff report these measures adequately address the related issues.
Has an acceptable Capital Improvement Plan (CIP) been implemented?
Does CIP address short term needs and long term \"master plan\" concepts?
Does CIP cover three to five year period?
Does CIP include Goal Statement?
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?
Is CIP designated only for wastewater collection and treatment?
Approximate capital improvement budget for collection system?$35,000.00
Total annual revenue for wastewater collection and treatment?
CIP Comments
The recently updated CIP (Summer 2017) does not forecast the long-term needs of the Collection System, or
address the current significant issues with I&I. The Town plans to prioritize sewer projects after the budgeted
water and sewer study is completed. The previous CIP covered a long-term goal of creating an interconnect
with Spindale; however, this is no longer forecasted in the most recent CIP and it does not address the
current I&I issue from the Town's line under the lake and all private laterals around the perimeter of the lake,
or the regular non-compliance issues from the wastewater plant. The Town has indicated verbally that they
may pursue installation of a low-pressure system. This would ultimately allow removal of the lines under the
lake. Current CIP does not address known significant system deficiencies.
Is system free of known points of bypass?
If no, describe type of bypass and location
Is a 24-hour notification sign posted at ALL pump stations?
# Does the sign include:
Instructions for notification?
Pump station identifier?
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DocuSign Envelope ID: 5D4F67BA-E68C-4C72-989F-6045564B9FFC
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00131
01/25/2018 Collection System Inspect Non Sampling
Town of Lake Lure
Routine
24-hour contact numbers
If no, list deficient pump stations
The system only contains one pump station immediately downstream of the dam.
# Do ALL pump stations have an "auto polling" feature/SCADA?
Number of pump stations 1
Number of pump stations that have SCADA 0
Number of pump stations that have simple telemetry 1
Number of pump stations that have only audible and visual alarms 0
Number of pump stations that do not meet permit requirements 0
# Does the permittee have a root control program?
# If yes, date implemented?
Describe:
ORC reports no major issues due to root intrusion. System is flushed regularly with infltration
from the Lake. Additionally, flush valves have been installed in each quadrant of the Lake.
Comment:
Inspections Yes No NA NE
Are maintenance records for sewer lines available?
Are records available that document pump station inspections?
Are SCADA or telemetry equipped pump stations inspected at least once a week?
Are non-SCADA/telemetry equipped pump stations inspected every day?
Are records available that document citizen complaints?
# Do you have a system to conduct an annual observation of entire system?
# Has there been an observation of remote areas in the last year?
Are records available that document inspections of high-priority lines?
Has there been visual inspections of high-priority lines in last six months?
CS staff have checked all 65 perimeter manholes since the lake level is down. Staff are unable
to visually inspect the main line under lake without divers. Staff use hydrophones to detect the
presence of leaks.
Comment:
Operation & Maintenance Requirements Yes No NA NE
Are all log books available?
Does supervisor review all log books on a regular basis?
Does the supervisor have plans to address documented short-term problem areas?
What is the schedule for reviewing inspection, maintenance, & operations logs and problem areas?
Issues in perimeter manholes and around the lake are addressed seasonally when the lake is lowered. CS
staff keep excellent records of each area of the Lake. The Town has a boat available to easily inspect the
Lake under low level conditions.
Are maintenance records for equipment available?
Is a schedule maintained for testing emergency/standby equipment?
What is the schedule for testing emergency/standby equipment?weekly/monthly
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DocuSign Envelope ID: 5D4F67BA-E68C-4C72-989F-6045564B9FFC
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00131
01/25/2018 Collection System Inspect Non Sampling
Town of Lake Lure
Routine
Do pump station logs include:
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?
Is there at least one spare pump for each pump station w/o pump reliability?
Are maintenance records for right-of-ways available?
Are right-of-ways currently accessible in the event of an emergency?
Are system cleaning records available?
Has at least 10% of system been cleaned annually?
What areas are scheduled for cleaning in the next 12 months?
Gorman-Rupp is responsible for pump repair and maintenance. Nixon power conducts annual maintenance
on the dam's generator. The generator is automatically tested every Sunday. Lines are cleaned regularly from
infiltration. Flush valves can also be used if needed.
Is a Spill Response Action Plan available?
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
Is a Spill Response Action Plan available for all personnel?
Is the spare parts inventory adequate?
SRAP does not currently address a failure of the main sewer line beneath Lake Lure. The
permittee has worked with a diving firm from Charlotte in the past; however, conditions could be
such line repair would not be feasible at depth. The 90-year-old Dam does not have a spill-way
and the flood gates would not lower the lake adequately to access the pipe. Town staff report
there is a 30" valve on the bottom side of the Dam that could potentially be used to lower the
lake; however, it has not been exercised regularly and its operational status is unknown. The
current pipe wrap is over half-way through its ten-year life expectancy. Currently staff use
hydrophones to listen for leaks. The Town does not maintain a spare -parts inventory. All parts
are obtained from suppliers as needed. Source of emergency funds is not listed within the
SRAP.
Comment:
Records Yes No NA NE
Are adequate records of all SSOs, spills and complaints available?
Are records of SSOs that are under the reportable threshold available?
Do spill records indicate repeated overflows (2 or more in 12 months) at same location?
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DocuSign Envelope ID: 5D4F67BA-E68C-4C72-989F-6045564B9FFC
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCS00131
01/25/2018 Collection System Inspect Non Sampling
Town of Lake Lure
Routine
If yes, is there a corrective action plan?
Is a map of the system available?
Does the map include:
Pipe sizes
Pipe materials
Pipe location
Flow direction
Approximate pipe age
Number of service taps
Pump stations and capacity
If no, what percent is complete?
List any modifications and extensions that need to be added to the map
# Does the permittee have a copy of their permit?
Comment:
Monitoring and Reporting Requirements Yes No NA NE
Are copies of required press releases and distribution lists available?
Are public notices and proof of publication available?
# Is an annual report being prepared in accordance with G.S. 143-215.1C?
# Is permittee compliant with all compliance schedules in the permits?
If no, which one(s)?
An annual report has not been prepared for the previous year. Don Byers, WWTP ORC and CS
Backup ORC is in the process of preparing one for last year.
Comment:
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DocuSign Envelope ID: 5D4F67BA-E68C-4C72-989F-6045564B9FFC