WQCSD0059_Compliance Evaluation Inspection_20190409

April 09, 2019

Jonathan Cannon
City of Saluda
PO Box
Saluda, NC 28773

SUBJECT: Compliance Inspection Report
City of Saluda Collection System
Collection System Permit No. WQCSD0059
Polk County

Dear Permittee:

The North Carolina Division of Water Resources conducted an inspection of the City of Saluda Collection
System on 4/02/2019. This inspection was conducted to verify that the facility is operating in
compliance with the conditions and limitations specified in 15NCAC 02T.0403. The findings and comments
noted during this inspection are provided in the enclosed copy of the inspection report entitled "Compliance
Inspection Report".

There were no violations of the 02T.0403 regulations noted at the time of the inspection and therefore a
response is not required. The regional office has documented the aging infrastructure that is of concern to the
City and could lead the system to repeat non-compliance, should it fail. Please continue to communicate the
City’s efforts to pursue funding and long-term plans to remove I&I and repair aging infrastructure.

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 or via email at
[e-mail].

Sincerely,

Mikal Willmer, Environmental Specialist I
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS: Inspection Report
EC: WQS-ARO Server
LF
G:\WR\WQ\Polk\Collection Systems\Saluda WQCSD0059\Inspections\Inspect. April 2, 2019\20190409_WQCSD0059_CEI
DocuSign Envelope ID: 59EC5F7C-25D4-4FFB-8FED-239B25AE79D4
Compliance Inspection Report
Permit:WQCSD0059 Effective:03/01/00 Expiration:Owner :City of Saluda
SOC:
Contact Person:
Region:
County:
Directions to Facility:
Polk
Asheville
Kevin Queen
Effective:Expiration:Facility:City of Saluda Collection System
Title:Phone:[phone]Public Works Supervisor
Secondary ORC(s):
Phone:Certification:Primary ORC:
CS1,System Classifications:
On-Site Representative(s):
Related Permits:
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
04/02/2019 09:00AM 12:00PM
Mikal Willmer 828-296-4686
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
(See attachment summary)
Page 1 of 5
DocuSign Envelope ID: 59EC5F7C-25D4-4FFB-8FED-239B25AE79D4
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCSD0059
04/02/2019 Collection System Inspect Non Sampling
City of Saluda
Routine
Inspection Summary:
Mikal Willmer with the Asheville Regional Office conducted a compliance evaluation inspection of the City of Saluda's
Collection system on April 2, 2019. This inspection was conducted in response to repeat overflows at Pearson Falls Rd and
to determine whether the system is being operated and maintained in compliance with the States "deemed" collection
system regulations under 15NCAC 02T.0403. Jonathan Cannon, City Manager, was present and assisted in the inspection.
The City is actively taking steps within their financial means to reduce I&I and repair aging infrastructure. The City was
recently awarded a loan through USDA to replace sections of three lines and to rebuild the 176 LS; however, City staff do
not estimate this will significantly reduce I&I in the system. Additionally, they have developed a good working relationship
with the City of Hendersonville to aid in cleaning, sewer line inspections and pumping when needed. The City of Saluda does
own a jetter and camera and cleans most of the system in-house annually.
City staff are maintaining the collection system as much as the current infrastructure allows. Not all lines can be completely
inspected by camera due to the significant shifting and settling of terracotta lines at joints. Due to compromised
infrastructure and underground channeled streams and stormwater conveyances, foreign debris and I&I are entering the
collection system. This has reached a critical point, contributing excessive flows to the WWTP and foreign debris has begun
to settle in downstream manholes causing back-ups in the shallow Pearson Falls manhole directly next to Joel's Creek.
The major cause of the repeat overflows at Pearson Falls Rd is believed to be the stream channeled through a stone canal
directly beneath main street (suspected of being channeled when the town was founded). The sewer line sits directly above
this stream and due to the old terracotta line settling, it is very likely surface water, ground water and debris are entering the
system at this point. This stream, in addition to extremely wet weather, has caused significant sinking throughout
downtown. This can be seen in recently installed water meters that have dropped approximately three inches. Additionally,
a DOT stormwater conveyance under main street may also be contributing additional flow and debris. The City has received
a cost estimation from McGill and Associates regarding the replacement of this section of line. The City has had
discussions with DWI to explore potential funding options for this project (estimated at ~162,000). Currently they do not
qualify for DWI assistance based on MHI. Saluda’s sewer rates are approximately 50% more than the state median rate.
Several other items were noted at the time of inspection.
The channeled stream daylights Northwest of Downtown. There is significant erosion occurring and several sink-holes
forming around several properties. This poses a risk to the structural integrity of the terracotta line that parallels this stream
and may be an additional source of surface and/or groundwater infiltration into the system. The lack of easements, due to
the date of line installation (possibly 1920’s), further complicates the repair/replacement process.
Manholes with vent pick holes: The City’s collection system still contains several manholes with vent pick holes. While this
is probably not the major source of I&I, these should be sealed or changed in the future. Sheet flow and debris can enter the
system at these points causing issues further downstream and further contributing to excessive flow at the WWTP.
SUO: Recommend expanding the sewer use requirements further to clarify the requirements set forth by the Division of
Water Resources when new private laterals transverse neighboring properties. Please note the requirements listed under
15NCAC 02T.0303.
Please continue to keep our office informed of the plans to address these items moving forward.
Page 2 of 5
DocuSign Envelope ID: 59EC5F7C-25D4-4FFB-8FED-239B25AE79D4
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCSD0059
04/02/2019 Collection System Inspect Non Sampling
City of Saluda
Routine
Performance Standards Yes No NA NE
Is Public Education Program for grease established and documented?
What educational tools are used?
Included with bills and posted on the City's Facebook page. Recommend adding this to the City's main
website as well.
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
Recommend clarifying sewer connection criteria when crossing neighboring properties. See summary for
additional details.
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
For FY20 there will be maintenance funding alloted for the collection system; however, the primary
improvements project will be focused on relocating and grading for a new public works building. This has
become a priority due to repeated flooding within the current public works building.
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?
24-hour contact numbers
If no, list deficient pump stations
Signs still need to be updated to reflect the current contact informaiton. Please address this as soon as
possible.
# Do ALL pump stations have an "auto polling" feature/SCADA?
Number of pump stations 4
Page 3 of 5
DocuSign Envelope ID: 59EC5F7C-25D4-4FFB-8FED-239B25AE79D4
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCSD0059
04/02/2019 Collection System Inspect Non Sampling
City of Saluda
Routine
Number of pump stations that have SCADA 0
Number of pump stations that have simple telemetry 0
Number of pump stations that have only audible and visual alarms 4
Number of pump stations that do not meet permit requirements 0
# Does the permittee have a root control program?
# If yes, date implemented?
Describe:
Laurel creek pump station was recently rebuilt. Simple telemtery is available at one station but
the equipment is outdated and will not work. The 176 lift station is being rebuilt and will have
SCADA installed with the ability to connect on more stations once funding is available.
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?
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 for all
generators
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?
Public Works staff are currently maintaining the emergency equipment. The City currently has a contract with
Maybin's for generator maintenance; however, they are currently looking at other options for generator
maitenance. It is still highly recommended the City look into installing quick-connects for portable generators.
Is a Spill Response Action Plan available?
Does the plan include:
24-hour contact numbers
Response time
Equipment list and spare parts inventory
Page 4 of 5
DocuSign Envelope ID: 59EC5F7C-25D4-4FFB-8FED-239B25AE79D4
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCSD0059
04/02/2019 Collection System Inspect Non Sampling
City of Saluda
Routine
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?
Please make sure the spill repsonse plan is updated and available to all personnel. No specific
requirements for an overflow response document listed within the 02T.0403 Rules.
Comment:
Page 5 of 5
DocuSign Envelope ID: 59EC5F7C-25D4-4FFB-8FED-239B25AE79D4
Certificate Of Completion
Envelope Id: 59EC5F7C25D44FFB8FED239B25AE79D4 Status: Completed
Subject: Please DocuSign: 20190409_WQCSD0059_CEI.draft.docx, 20190409_WQCSD0059_Insp.draft.pdf
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217 W. Jones Street
Raleigh, NC 27699
[e-mail]
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Apr 9, 2019 | 10:53
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[e-mail]
Environmental Specialist
North Carolina Department of Environmental Quality
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