WQCSD0287_NOVNOI2018PC0443 & CEI Report_20181128

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

Certified Mail # 7017 2620 0000 9759 1611
Return Receipt Requested

November 28, 2018

Lynne Vasquez
Cliffside Sanitary District
PO Box 122
Cliffside, NC 28024

SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY
Tracking Number: NOV-2018-PC-0443
Permit No. WQCSD0287
Cliffside Sanitary District WWTP
Rutherford County

Dear Permittee:

The North Carolina Division of Water Resources conducted an inspection of the Cliffside Sanitary District WWTP
on November 7 and 7, 2018. This inspection was conducted to verify that the facility is operating in compliance
with the conditions and limitations specified in 15 NCAC 02T.0403. 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 violation(s) were noted during the inspection:

Inspection Area Description of Violation _________________________________________________________________________________________________________________________________________________________________________
Records Inspection records appeared incomplete. Inspectors could not locate comprehensive system
maintenance/repair records. 15NCAC 02T.0403 (a)(10) Documentation of compliance
with Subparagraphs (a)(1) through (a)(9) of this Rule shall be maintained by the
collection system owner for three years. _________________________________________________________________________________________________________________________________________________________________________

North Carolina Department of Environmental Quality | Division of Water Resources
2090 U.S. 70 Highway, Swannanoa, NC 28778
828-296-4500
Inspection Area Description of Violation
_________________________________________________________________________________________________________________________________________________________________________
Inspections Maintenance records and the condition of the system indicate annual observations of the
entire system and high-priority line inspections were not routinely conducted. 15NCAC
02T.0403 (a)(5) High-priority sewers shall be inspected by the permittee or its
representative once every six-months and inspections shall be documented. (a)(6)
A general observation by the permittee or its representative of the entire
collection system shall be conducted once per year. _________________________________________________________________________________________________________________________________________________________________________
Operation & Maintenance The status of the entire collection system is unknown. The collection system is overgrown with
Requirements vegetation. Several manholes observed during the inspection had broken risers and lines,
missing rings and root intrusion. The system experiences significant flow increases due to
Inflow & Infiltration. A spill response plan was not available at the time of the inspection. 15NCAC
02T.0403 (a)(3) An operation and maintenance plan, including pump station
inspection frequency, preventative maintenance schedule, spare parts inventory
and overflow response shall have been developed and implemented. (a)(9) Right-
of-ways and easements shall be maintained in the full easement width for
personnel and equipment accessibility. _________________________________________________________________________________________________________________________________________________________________________
A Notice of Violation/Intent to Issue Civil Penalty is being issued for the noted violation of North Carolina General
Statute (G.S.) 143-215.1 and the facility’s Collection System Permit. Pursuant to G.S. 143-215.6A, a civil penalty
of not more than twenty-five thousand dollars ($25,000.00) may be assessed against any person who violates
or fails to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S.
143-215.1.

If you wish to provide additional information regarding the noted violation, request technical assistance, or discuss
overall compliance please respond in writing (email is acceptable) within ten (10) business days after receipt of
this Notice. A review of your response will be considered along with any additional information provided. You will
then be notified of any civil penalties that may be assessed regarding the violations. If no response is received
in this Office within the 10-day period, a civil penalty assessment may be prepared.

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. If the violations are of a continuing nature, not related to operation and/or maintenance problems, and
you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by
Consent.

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
LF
G:\WR\WQ\Rutherford\Collection Systems\Cliffside Sanitary District WQCSD0287\Inspections\Inspect. Nov 7-8, 2018\20181128_WQCSD0287_NOVNOI2018PC0443
Compliance Inspection Report
Permit:WQCSD0287 Effective:11/08/07 Expiration:Owner :Cliffside Sanitary District
SOC:
Contact Person:
Region:
County:
Directions to Facility:
Rutherford
Asheville
Greg Blake
Effective:Expiration:Facility:Cliffside Sanitary District WWTP
136 Hawkins Loop Rd
Mooresboro NC 28114
Title:Phone:[phone]
Secondary ORC(s):
Phone:Certification:Primary ORC:
System Classifications:
On-Site Representative(s):
Related Permits:
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
11/07/2018 10:00AM 02:00PM
Mikal Willmer 828-296-4686
Daniel J Boss
Facility Status:
Permit Inspection Type:
Reason for Inspection:Inspection Type:
Not CompliantCompliant
Routine
Deemed permitted collection system management and operation
Collection System Inspect Non Sampling
Question Areas:
Miscellaneous Questions Performance Standards Operation & Maint Reqmts
Records Monitoring & Rpting Reqmts Inspections
(See attachment summary)
Page:1
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCSD0287
11/07/2018 Collection System Inspect Non Sampling
Cliffside Sanitary District
Routine
Inspection Summary:
Inspector Mikal Willmer, with the Asheville Regional Office, conducted a Compliance Evaluation Inspection of the Cliffside
Sanitary District's Collection System on November 7th and 8th, 2018. This inspection was conducted to determine whether
the collection system is being operated and maintained in compliance with the State's "Deemed" Collection System
requirements under 15A NCAC 02T.0403. James and James, contract operating firm, was present and assisted in the
inspection. DWR ARO personnel, Landon Davidson and Dan Boss were also present at the time of the inspections.
Cliffside Sanitary District is classified as a "deemed" collection system due to average daily flows less than 200,000 GPD.
The ARO acknowledges Cliffside Sanitary District is taking steps to improve the collection system; however, the system is
currently in gross non-compliance with 15A NCAC 02T.0403. The non-compliances with specific sections of the "deemed"
requirements are listed below.
1)During the inspection, a manhole was noted as having recently overflowed. DWR does not have a record of SSOs from
Cliffside; however, it appears the collection system would be hard to monitor for potential spills in its current state.
2)A map with known manholes and lines is available to current staff; however, the number of manholes and layout of all the
lines is unknown.
3)No operation and maintenance plan was available for the collection system. Inspectors found an O&M manual for the
WWTP created by Cone Mills in the 1990s. Records did not indicate an active maintenance schedule and written Spill
Response Plan were on hand.
5) Several high priority lines were completely covered in vegetation and there were additional lines with unknown locations
(potentially high-priority). Some records were available for line inspections in 2017; however, it did not appear all high-priority
lines had been inspected every 6 months.
6) It did not appear a general observation of the entire system was occurring annually. Much of the collection system was
over grown with vegetation, manhole covers were missing or paved over, manholes were deteriorating or broken and there
appeared to be a significant root problem throughout the system.
7)Unknown if SSOs were recorded or if they occurred, were visible underneath the vegetation.
8)The status of a grease control program or sewer use ordinance is unknown. Educational materials were unavailable at the
time of the inspection.
9) Right-of-ways and easements were not being properly maintained. Several lines and manholes were covered by vegetation
and not accessible at the time of the inspection.
The Cliffside WWTP experiences major increases in flow due to excessive I&I throughout the collection system. Inspectors
noted at least five manholes that had damage to or were missing their rings, missing lids and had damaged or deteriorated
risers. There are an unknown number of manhole covers with holes in the lid. The system still contains numerous brick
manholes in various states of disrepair allowing root intrusion, inflow and infiltration. Several of the terracotta lines have either
broken or sunken joints. There is potential inflow from illegal connections and flow from facilities no longer in use. Not all
manholes and lines within the collection system are accounted for so the status of the entire collection system is unknown.
It is recommended that Cliffside Sanitary District take necessary steps to reduce and eliminate sources of I&I within the
system. Deteriorated or broken manholes and lines should be repaired as soon as possible. Continue to locate and record
additional colleciton system components. Cliffside should also continue to explore and assess potential longterm options for
the ultimate treatment and management of wastewater generated within the District.
Page:2
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCSD0287
11/07/2018 Collection System Inspect Non Sampling
Cliffside Sanitary District
Routine
Performance Standards Yes No NA NE
Is Public Education Program for grease established and documented?
What educational tools are used?
Educational materials were unavailable at the time of the inspection.
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
It is unknown if the district maintains a sewer use ordinance. Paperwork and ordinances were not readily
available at the time of the inspection.
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?
Total annual revenue for wastewater collection and treatment?
CIP Comments
This is a deemed collection system therefore a CIP is not required.
Is system free of known points of bypass?
If no, describe type of bypass and location
Several locations have broken manholes, missing manhole covers, cracked terracotta lines, deteriorating
brick manholes and potentially illegal connections.
Is a 24-hour notification sign posted at ALL pump stations?
# Does the sign include:
Instructions for notification?
Pump station identifier?
24-hour contact numbers
If no, list deficient pump stations
# Do ALL pump stations have an "auto polling" feature/SCADA?
Number of pump stations 2
Number of pump stations that have SCADA 0
Page:3
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCSD0287
11/07/2018 Collection System Inspect Non Sampling
Cliffside Sanitary District
Routine
Number of pump stations that have simple telemetry 0
Number of pump stations that have only audible and visual alarms 2
Number of pump stations that do not meet permit requirements 0
# Does the permittee have a root control program?
# If yes, date implemented?
Describe:
No apparent root control program. Significant root intrusion throughout the system.
Pumps have been restored to working order at the Haynes LS. Currently only one pump can run
at a time at the influent LS due to an issue with the air relief valves. The generator transfer switch
is currently inoperable at the main LS.
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?
Some inspection records of high-priority lines were available; however, it did not appear to cover
or address all high-priority lines. Many rights-of-way were inaccessible . Inspectors were unable
to locate 2018 collection system maintenance records. The ORC logbook indicates there were
daily visit to the lift stations, but there are no apparent records of what the inspections entailed.
The inspection log at the Haynes LS ended in 2007.
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?
Log book information only notates the pump stations were checked, but not what work was performed.
Are maintenance records for equipment available?
Is a schedule maintained for testing emergency/standby equipment?
What is the schedule for testing emergency/standby equipment?no documented
maintenance
schedule
Do pump station logs include:
Inside and outside cleaning and debris removal?
Inspecting and exercising all valves?
Page:4
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCSD0287
11/07/2018 Collection System Inspect Non Sampling
Cliffside Sanitary District
Routine
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?
Some cleanings were noted from last year.
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?
Inspectors were unable to locate a Spill Response Plan. New contract firm is managing the
collection system. Unable to locate a record of SSOs.
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?
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
Page:5
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCSD0287
11/07/2018 Collection System Inspect Non Sampling
Cliffside Sanitary District
Routine
If no, what percent is complete?10
List any modifications and extensions that need to be added to the map
A generic map is available, but the status and location of several of the manholes and lines are unknown.
# Does the permittee have a copy of their permit?
This is a deemed collection system. Provided a copy of the "deemed" collection system
regulations to the new WWTP ORC.
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)?
N/A .
DWR does not have a record of SSOs for the Cliffside CS. Inspectors were unable to determine
if the system experienced overflows under threshold. Many lines and manholes are not intact
and covered in vegetation. Observing and identifying an ongoing spill would be difficult in several
locations due to vegetation.
Comment:
Page:6