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HomeMy WebLinkAboutWQ0035784_NOD-2021-PC-0506_20211025ROY COOPER Governor ELIZABETH S. BISER Secretary S. DANIEL SMITH Director NORTH CAROLINA Environmental Quality October 25, 2021 CERTIFIED MAIL 7018 1130 0000 1612 8922 Return Receipt Requested Mr. Sean Devine Wallace Loft, LLC — The Cottages of Boone 4100 E Mississippi Avenue, Floor 15 Denver, CO 80426 SUBJECT: Notice of Deficiency (NOD-2021-PC-0506) The Cottage of Boone — Wastewater Irrigation System Permit No. WQ0035784 Watauga County Dear Mr. Devine: On October 12, 2021, Division of Water Resources staff Caitlin Caudle conducted a scheduled compliance inspection. DWR staff Lon Snider and Jenny Graznak were present during the review of the deemed collection system (WQCSD0738) and the wastewater treatment facility (WQ0035784). Rose Hernandez of the Cottages of Boone and Don Feller of EnviroLink, Inc. were present during the entire inspection. David Smith and Jacob Tilley were present during the deemed collection system inspection and the majority of the wastewater treatment facility review. A review of the collections system and wastewater treatment facility, records, and irrigation equipment was completed. This review mostly reflects compliance with Permit WQ0035784. The following deficiency was noted- 1 . At the time of inspection, a Spill Plan was not available for review. Per Permit Condition 111.1 a spill response plan is a component of the Operations and Maintenance Plan. Please locate or develop a Spill Response Plan and keep a copy posted within the wastewater treatment plant and apartment clubhouse, ensure that all staff or contractors are aware of the location of the Spill Response Plan, and ensure that all staff that work with the collection system and the wastewater treatment plant are aware of spill response procedures. Please send Ms. Caudle evidence of the Spill Response Plan being posted in the requested locations within thirty (30) days of receipt of this letter. NOATF4 CARo�INA II Dew 8m of �.im�momni auai" North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1 450 West Hanes Mill Road, Suite 300 1 Winston-Salem, North Carolina 27105 336.776.9800 The following items of concerns were noted: A. The 14 day wet weather storage tank had a few small leaks around the second band of metal plates from the bottom of the storage tank. Leaks in the storage tanks were referenced in correspondence from the previous compliance evaluation inspection and follow up inspection. Repairs were made after the previous inspections, and additional repairs were made shortly after DWR staff concluded the subject inspection. Please continue to monitor the storage tanks and make timely repairs as needed. B. Anoxic Tank A (located inside the treatment building) reportedly has two small holes around the drain valve. Mr. Feller stated that he has contacted the manufacturer of the tank and is in the process of determining the most effective and efficient repair. Please repair this tank in a timely manner and notify Ms. Caudle of any developments associated with this repair. C. Trees were visible growing on the mats covering treated effluent in the 5 day upset tank. While on site, Ms. Caudle observed that the trees and other vegetation pulled the cable attached to the freeboard marker, changing the observed freeboard. Based on this observation, it is likely that the trees and other vegetation can alter the observed freeboard to present a false reading. Please consider taking measures to remove the trees and vegetation or take measures to ensure that the freeboard in the 5 day upset storage tank is accurately represented at all times. Further action may be required by the Division if the freeboard marker is consistently impacted by the vegetation. D. Mr. Feller stated that the rain sensor is not operational, and the current operations are to turn the system off when staff are not on site and there is rain in the weather forecast. Mr. Feller stated that he is in the process of acquiring a rain sensor for the system. Please repair the rain sensor in a timely manner and notify Ms. Caudle when the rain sensor is repaired. Please refer to the enclosed collection system and wastewater treatment plant inspection reports for additional comments and observations. Please me mindful of the deadlines stated above. If you have any questions regarding this Notice or inspection reports, please contact me or Caitlin Caudle at the letter head address or phone number, or by email at caitlin.caudle(a)_ncdenr.gov. Sincerely, EDocu S�igTned by: L uti l . Jn lAts 145B49E225C94EA.. Lon T. Snider Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ-WSRO hFORiH � CAROLINAD E Q� gape qm of E Im...m I qualV\ North Carolina Department of Environmental Quality 1 Division of Water Resources Winston-Salem Regional Office 1 450 West Hanes Mill Road, Suite 3001 Winston-Salem, North Carolina 27105 336.776.9800 enc: Wastewater Treatment Plant Inspection Report Collection System Inspection Report cc: Rose Hernandez (Electronic: rose.hernandez(cb-thecottagesofboone.com) David Smith (Electronic: david.smith(a-_)thecottagesofboone.com) Melissa Vega -Matta (Electronic: melissa.vega-matta(c cardinalgroup.com) Ashley Vargo (Electronic: ashley.vargo@cardinalgroup.com) Wayne Farquharson (Electronic: wayne.farguharson(a mapletree.com.sq) Don Feller, EnviroLink (dfeller envirolinkinc.com) Watauga County Environmental Health (Electronic) DWR Water Quality Laserfiche Permit File WQ0035784 North Carolina Department of Environmental Quality 1 Division of Water Resources Winston-Salem Regional Office 1 450 West Hanes Mill Road, Suite 3001 Winston-Salem, North Carolina 27105 hFORiH CAROLINq i Dore qm m E,�,im�ma,�i u�an� /"� 336.776,9800 Compliance Inspection Report Permit: WQ0035784 Effective: 10/25/17 Expiration: 04/30/22 Owner: Wallace Loft LLC SOC: Effective: Expiration: Facility: The Cottages of Boone WWTP County: Watauga 1002 Fallview Ln Region: Winston-Salem Boone NC 28607 Contact Person: Justin Pellegrino Title: Phone: Directions to Facility: Take 140 BUS W/US-158 W/US-421 N from N Lierty Street. Follow 421 N to E King Street in Boone. Take US 221 S and NC 105 S to Boone Circle System Classifications: SI, WW2, Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): Related Permits: Inspection Date: 10/12/2021 Entry Time 10:01AM Exit Time: 01:04PM Primary Inspector: Caitlin Caudle Phone: 336-776-9699 Secondary Inspector(s): Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Wastewater Irrigation Facility Status: ❑ Compliant Not Compliant Question Areas: Treatment Flow Measurement -Effluent Treatment Flow Measurement -Influent Miscellaneous Questions Treatment Flow Measurement -Water Treatment Treatment Barscreen Use Records Treatment Filters Record Keeping Treatment Activated Sludge End Use -Irrigation Treatment Influent Pump Station Treatment Disinfection Treatment Flow Measurement Storage Standby Power (See attachment summary) Page 1 of 7 Permit: WQ0035784 Owner - Facility: Wallace Loft LLC Inspection Date: 10/12/2021 Inspection Type: Compliance Evaluation Reason for Visit: Routine Inspection Summary: On October 12, 2021, Division of Water Resources Staff Caitlin Caudle conducted a scheduled compliance inspection. DWR staff Lon Snider and Jenny Graznak were present during the review of the deemed collection system (WQCSD0738) and the wastewater treatment facility (WQ0035784). Rose Hernandez of the Cottages of Boone was present during the entire inspection. David Smith and Jacob Tilley were present during the deemed collection system inspection and the majority of the wastewater treatment facility review. Don Feller of EnviroLink was present during the entire inspection. A review of the collections system and wastewater treatment facility, records, and irrigation equipment was completed. This review mostly reflects compliance with Permit WQ0035784. The following items of deficiency was noted: 1. At the time of inspection, a Spill Plan was not available for review. Per Permit Condition 111.1 a spill response plan is a component of the Operations and Maintenance Plan. Please locate or develop a Spill Response Plan and keep a copy posted within the wastewater treatment plant and apartment clubhouse, ensure that all staff or contractors are aware of the location of the Spill Response Plan, and ensure that all staff that work with the collection system and the wastewater treatment plant are aware of spill response procedures. Please send Ms. Caudle evidence of the Spill Response Plan being posted in the requested locations within thirty (30) days of receipt of this letter. The following items of concerns were noted: A. The 14 day wet weather storage tank had a few small leaks around the second band of metal plates from the bottom of the storage tank. Leaks in the storage tanks were referenced in correspondence for the previous compliance evaluation inspection and follow up inspection. Repairs were made after the previous inspections, and additional repairs were made shortly after DWR staff concluded the subject inspection. Please continue to monitor the storage tanks and make timely repairs as needed. B. Anoxic Tank A reportedly has two small holes around the drain valve. Mr. Feller stated that he has contacted the manufacturer of the tank and is in the process of determining the most effective and efficient repair. Please repair this tank in a timely manner and notify Ms. Caudle of any developments associated with this repair. C. Trees were visible growing on the mats covering treated effluent in the 5 day upset tank. While on site Ms. Caudle observed that the trees and other vegetation pulled the cable attached to the freeboard marker, changing the observed freeboard. Based on this observation, it is likely that the trees and other vegetation can alter the observed freeboard to present a false reading. Please consider taking measures to remove the trees and vegetation or take measures to ensure that the freeboard in the 5 day upset storage tank is accurately represented at all times. D. Mr. Feller stated that the rain sensor is not operational, and the current operations are to turn the system off when staff are not on site and there is rain in the weather forecast. Mr. Feller stated that he is in the process of acquiring a rain sensor for the system. Please repair the rain sensor in a timely manner and notify Ms. Caudle when the rain sensor is repaired. Other observations: • All wastewater treatment components after the equalization basin are housed within a metal building with floor drains that lead to the sump pump tank, which pumps back to the EQ basin. • Ms. Hernandez and Mr. Feller were reminded that per Permit Condition 1.1 a permit renewal application must be submitted 6 months before the expiration of the current permit. That date is October 30, 2021. • Ms. Caudle provided Ms. Hernandez with a copy of permit annual fee invoice on 10/13/2021. Per Permit Condition V1.10 the permit annual fee should be paid within 30 days of being billed by the Division. • Ms. Caudle reminded Mr. Feller that an ORC has not been designated since the previous ORCs resigned. Mr. Feller stated that the paperwork should be completed this week as a new ORC is being trained that will stay at this facility permanently. Mr. Feller is based in Ohio. • Mr. Feller started managing the plant on August 14, 2021. • Mr. Feller stated that membrane bioreactor (MBR B) has been replaced, and the necessary parts are in transit to replace MBR A. • Mr. Feller explained that the original pumps in the EQ basin to transfer wastewater from the EQ basin to the rotary brush screen has been replaced by the previous operators. The previous operators installed a "night valve." This is not reflected in the permit description. This will be addressed in the upcoming permit renewal. This valve did have some liquid dripping from it, which could have been effluent, condensation, or rainwater dripping from the insulation around the valve. • Mr. Feller stated that he and his staff are completing small repairs in the drip zones, but larger repairs are being contracted out, such as changing valves or repairing force mains. • All pumps in the treatment plant were in working order. The pumps referenced in the follow up inspection letter dated October 19, 2020, have been replaced by either the previous operators or Mr. Feller and his staff. Page 2 of 7 Permit: WQ0035784 Owner - Facility: Wallace Loft LLC Inspection Date: 10/12/2021 Inspection Type: Compliance Evaluation Reason for Visit: Routine • Storm water erosion above the storage tanks does not appear to have gotten worse since Ms. Caudle's last site visit. A stormwater diversion ditch is diverting water around the 14 day wet weather storage tank. • The previous operators had concerns that residents were entering the drip zones and DWR staff found previous evidenc( of this in the form of trash and a fire pit in the drip zones. The Cottages staff have concerns that residents are still entering the drip zones. Additional signage or educational material in leasing material may be needed to prevent residents from entering the drip zones. • The only way sludge is wasted from the treatment plant is from the MBRs. Flow is diverted from the return to the aeration/bioreactor tanks to the sludge tank. • Influent to the plant is roughly measured via water meter readings. Water meters are read 5 days a week. Effluent is measured after UV disinfection. • Mr. Feller has scheduled the irrigation system to be calibrated by the end of the month. • Monitoring report records were not reviewed beyond August 2021 as the previous operators resigned and kept many records electronically. • Two lift stations are present around the apartments. One lift station transfers wastewater to the crest of the ridge where it gravity flows to the main lift station that transfers wastewater to the treatment plant. Two submersible pumps are present in the main lift station. Back up power is present and tested weekly. The highwater float was operational. No back up pumps are on site, but Mr. Feller is in the process of acquiring back up pumps. • The bar screen for the plant is a rotary brush drum screen that removes solids such as wipes and other hygiene products. Most of the solids removed are fine particles that went through the grinder pumps in the collection system. Screened wastewater is transferred to the anoxic tanks when the tank below the rotary brush screen is at 60% capacity and stopped when the tank is at 20% capacity. • Trash and other solids are still present on top of the EQ basin from previous bypasses. The large pipe on the tank is for influent, the middle pipe is the gravity backflow from the storage tanks, and the small pipe is a 4" overflow to the sump pump. • The flow of wastewater through the treatment plant is preanoxic tanks, aeration/bioreactor tanks, postanoxic tank, MBR, disinfection, turbidity, irrigation or storage. There are several locations where wastewater is backwashed or diverted to previous parts of the treatment plant. • Aeration is only present in the preanoxic tanks. • The sludge storage tank is pumped at 70% capacity. It was last pumped on 8/26/2021, 8/27/2021, and 8/31/2021.A total of 21,000 gallons were removed. Mr. Feller stated that the tank is at about 60% capacity due to emptying Anoxic Tank A for repairs. • MBR A and B are the treatment filters for the system. • UV disinfection is used at the treatment plant. One unit was viewed in operation while on site. Two units are present. • A sump tank is present that collects overflow from the EQ basin, floor drains, and decanted liquid from the sludge storage tank. A high water alarm is present and tested while on site. The sump tank is pumped back to the EQ basin. This does not appear to be included in the permit description. This will be addressed in the upcoming permit renewal. • According to engineer drawings provided to the Division, the wet weather storage tank is 27.81' tall and the upset storage tank is 29.33' tall. At the time of inspection, the wet weather storage tank had -14' of freeboard and the upset storage tank had --3' of freeboard. There were no signs of recent overflows from the storage tanks. • Mr. Feller stated that one of the irrigation pumps had recently been repaired. • Zones 1, 3, 4, 5, 6 had "High Flow Warnings" but the system was still operational and dosing while on site. Mr. Feller stated that the system will shut down or skip a zone when a high flow alarm is triggered. The irrigation zones were not reviewed in person during this site visit. • Ms. Caudle requested to be notified when Mr. Feller or his staff sample the monitoring wells. Page 3 of 7 Permit: WQ0035784 Owner - Facility: Wallace Loft LLC Inspection Date: 10/12/2021 Inspection Type: Compliance Evaluation Reason for Visit: Routine Type Yes No NA NE Infiltration System ❑ Reuse (Quality) ❑ Single Family Spray, LR ❑ Lagoon Spray, LR ❑ Activated Sludge Spray, HR ❑ Activated Sludge Spray, LR ❑ Recycle/Reuse ❑ Single Family Drip ❑ Activated Sludge Drip, LR Treatment Yes No NA NE Are Treatment facilities consistent with those outlined in the current permit? ❑ 0 ❑ ❑ Do all treatment units appear to be operational? (if no, note below.) 0 ❑ ❑ ❑ Comment: A sump pump tank collects overflow from the EQ basin and the floor drains in the building. This will be addressed in permit renewal. Treatment Influent Pump Station Yes No NA NE Is the pump station free of bypass lines or structures? ❑ ❑ ❑ Is the general housekeeping acceptable? ❑ ❑ ❑ Are all pumps present? ❑ ❑ ❑ Are all pumps operable? ❑ ❑ ❑ Are floats/controls operable? ❑ ❑ ❑ Are audio and visual alarms available? ❑ ❑ ❑ Are audio and visual alarms operational? ❑ ❑ ❑ # Are SCADA/Telemetry alarms required? ❑ ❑ ❑ Are SCADA/Telemetry available? ❑ ❑ ❑ Are SCADA/Telemetry operational? ❑ ❑ 0 ❑ Comment: Treatment Flow Measurement -Influent Yes No NA NE Is flowmeter calibrated annually? 0 ❑ ❑ ❑ Is flowmeter operating properly? ❑ ❑ ❑ Does flowmeter monitor continuously? ❑ ❑ ❑ Does flowmeter record flow? ❑ ❑ ❑ Does flowmeter appear to monitor accurately? 0 ❑ ❑ ❑ Comment: Inlfuent flow is measured from wells providing water to the complex. Page 4 of 7 Permit: WQ0035784 Owner - Facility: Wallace Loft LLC Inspection Date: 10/12/2021 Inspection Type: Compliance Evaluation Reason for Visit: Routine Treatment Flow Measurement -Water Use Records Yes No NA NE Is water use metered? 0 ❑ ❑ ❑ Are the daily average values properly calculated? ❑ ❑ 0 ❑ Comment: Treatment Flow Measurement -Effluent Yes No NA NE Is flowmeter calibrated annually? ❑ ❑ ❑ Is flowmeter operating properly? ❑ ❑ ❑ Does flowmeter monitor continuously? ❑ ❑ ❑ Does flowmeter record flow? ❑ ❑ ❑ Does flowmeter appear to monitor accurately? ❑ ❑ ❑ Comment: Flowmeter is installed after turbidimeter Standby Power Yes No NA NE Is automatically activated standby power available? ❑ ❑ ❑ Is generator tested weekly by interrupting primary power source? ❑ ❑ ❑ Is generator operable? ❑ ❑ ❑ Does generator have adequate fuel? 0 ❑ ❑ ❑ Comment: Treatment Barscreen Yes No NA NE Is it free of excessive debris? 0 ❑ ❑ ❑ Is disposal of screenings in compliance? 0 ❑ ❑ ❑ Are the bars spaced properly? ❑ ❑ 0 ❑ Is the unit in good condition? 0 ❑ ❑ ❑ Comment: A rotary brush screen is used after the EQ basin. Screenings are disposed of in a dumpster. Treatment Activated Sludge Yes No NA NE Is the aeration mechanism operable? ❑ ❑ ❑ Is the aeration basin thoroughly mixed? ❑ ❑ ❑ Is the aeration equipment easily accessed? ❑ ❑ ❑ Is Dissolved Oxygen adequate? ❑ ❑ 0 ❑ Are Settleometer results acceptable? ❑ ❑ 0 ❑ Is activated sludge an acceptable color? 0 ❑ ❑ ❑ Comment: Treatment Filters Yes No NA NE Is the filter media present? 0 ❑ ❑ ❑ Is the filter media the correct size and type? ❑ ❑ ❑ Is the air scour operational? ❑ ❑ ❑ Page 5 of 7 Permit: WQ0035784 Owner - Facility: Wallace Loft LLC Inspection Date: 10/12/2021 Inspection Type: Compliance Evaluation Reason for Visit: Routine Is the scouring acceptable? ❑ ❑ 0 ❑ Is the clear well free of excessive solids? ❑ ❑ 0 ❑ Is the mud well free of excessive solids and filter media? ❑ ❑ 0 ❑ Does backwashing frequency appear adequate? 0 ❑ ❑ ❑ Comment: Treatment filters are membrane bioreactors A and B. Treatment Disinfection Yes No NA NE Is the system working? ❑ ❑ ❑ Do the fecal coliform results indicate proper disinfection? ❑ ❑ ❑ Is there adequate detention time (-30 minutes)? ❑ ❑ ❑ Is the system properly maintained? ❑ ❑ ❑ If gas, does the cylinder storage appear safe? ❑ ❑ ❑ Is the fan in the chlorine feed room and storage area operable? ❑ ❑ 0 ❑ Is the chlorinator accessible? ❑ ❑ ❑ If tablets, are tablets present? ❑ ❑ ❑ Are the tablets the proper size and type? ❑ ❑ ❑ Is contact chamber free of sludge, solids, and growth? ❑ ❑ ❑ If UV, are extra UV bulbs available? ❑ ❑ ❑ If UV, is the UV intensity adequate? ❑ ❑ ❑ # Is it a dual feed system? ❑ ❑ ❑ Does the Stationary Source have more than 2500 Ibs of Chlorine (CAS No. 7782-50-5)? ❑ ❑ ❑ If yes, then is there a Risk Management Plan on site? ❑ ❑ ❑ If yes, then what is the EPA twelve digit ID Number? (1000- If yes, then when was the RMP last updated? Comment: Record Keeping Yes No NA NE Is a copy of current permit available? 0 ❑ ❑ ❑ Are monitoring reports present: NDMR? ❑ ❑ ❑ NDAR? ❑ ❑ ❑ Are flow rates less than of permitted flow? ❑ ❑ ❑ Are flow rates less than of permitted flow? ❑ ❑ ❑ Are application rates adhered to? ❑ ❑ ❑ Is GW monitoring being conducted, if required (GW-59s submitted)? ❑ ❑ ❑ Are all samples analyzed for all required parameters? ❑ ❑ ❑ Are there any 2L GW quality violations? ❑0 ❑ ❑ Is GW-59A certification form completed for facility? ❑ ❑ ❑ Is effluent sampled for same parameters as GW? ❑ ❑ ❑ Page 6 of 7 Permit: WQ0035784 Owner - Facility: Wallace Loft LLC Inspection Date: 10/12/2021 Inspection Type: Compliance Evaluation Reason for Visit: Routine Do effluent concentrations exceed GW standards? ❑ 0 ❑ ❑ Are annual soil reports available? ❑ 0 ❑ ❑ # Are PAN records required? ❑ 0 ❑ ❑ # Did last soil report indicate a need for lime? ❑ ❑ 0 ❑ If so, has it been applied? ❑ ❑ 0 ❑ Are operational logs present? 0 ❑ ❑ ❑ Are lab sheets available for review? 0 ❑ ❑ ❑ Do lab sheets support data reported on NDMR? 0 ❑ ❑ ❑ Do lab sheets support data reported on GW-59s? 0 ❑ ❑ ❑ Are Operational and Maintenance records present? 0 ❑ ❑ ❑ Were Operational and Maintenance records complete? 0 ❑ ❑ ❑ Has permittee been free of public complaints in last 12 months? ❑ 0 ❑ ❑ Is a copy of the SOC readily available? ❑ ❑ 0 ❑ No treatment units bypassed since last inspection? ❑ 0 ❑ ❑ Comment: There are no groundwater standard violations. Soil reports were not available. The permittee has not been free of comDlaints in the Dast 12 months. End Use -Irrigation Yes No NA NE Are buffers adequate? ❑ ❑ ❑ Is the cover crop type specified in permit? ❑ ❑ ❑ Is the crop cover acceptable? ❑ ❑ ❑ Is the site condition adequate? ❑ ❑ ❑ Is the site free of runoff / ponding? ❑ ❑ ❑ Is the acreage specified in the permit being utilized? ❑ ❑ ❑ Is the application equipment present? ❑ ❑ ❑ Is the application equipment operational? ❑ ❑ ❑ Is the disposal field free of limiting slopes? ❑ ❑ ❑ Is access restricted and/or signs posted during active site use? ❑ ❑ ❑ Are any supply wells within the CB? ❑ ❑ ❑ Are any supply wells within 250' of the CB? ❑ ❑ ❑ How close is the closest water supply well? ❑ ❑ ❑ Is municipal water available in the area? ❑ ❑ ❑ # Info only: Does the permit call for monitoring wells? ❑ ❑ ❑ Are GW monitoring wells located properly w/ respect to RB and CB? ❑ ❑ ❑ Are GW monitoring wells properly constructed, including screened interval? ❑ ❑ ❑ Are monitoring wells damaged? ❑ ❑ ❑ Comment: The drip zones and monitoring wells were not evaluated during this inspection. Page 7 of 7 Permit: WQCSD0738 SOC: County: Watauga Region: Winston-Salem Compliance Inspection Report Effective: 10/04/21 Expiration: Owner: Wallace Loft LLC Effective: Expiration: Facility: Cottages of Boone WWCS 1002 Fallview Ln Contact Person: Justin Pellegrino Title: Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): Related Permits: Inspection Date: 10/12/2021 Entry Time 10:01AM Primary Inspector: Caitlin Caudle Secondary Inspector(s): Certification: Boone NC 28607 Phone: Phone: Exit Time: 01:04PM Phone: 336-776-9699 Reason for Inspection: Routine Inspection Type: Collection System Inspect Non Sampling Permit Inspection Type: Deemed permitted collection system management and operation Facility Status: Compliant ❑ Not Compliant Question Areas: Miscellaneous Questions (See attachment summary) Page 1 of 4 Permit: WQCSD0738 Owner - Facility: Wallace Loft LLC Inspection Date: 10/12/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Inspection Summary: On October 12, 2021, Division of Water Resources Staff Caitlin Caudle conducted a scheduled compliance inspection. DWR staff Lon Snider and Jenny Graznak were present during the review of the deemed collection system (WQCSD0738) and the wastewater treatment facility (WQ0035784). Rose Hernandez of the Cottages of Boone was present during the entire inspection. David Smith and Jacob Tilley were present during the deemed collection system inspection and the majority of the wastewater treatment facility review. Don Feller of EnviroLink was present during the entire inspection. A review of the collections system and wastewater treatment facility, records, and irrigation equipment was completed. This review reflected compliance with the deemed collection system regulations. This deemed permit was created in response to a sanitary sewer overflow that resulted from faulty equipment at a grinder pump station (#7). The response to the SSO was reviewed and was appropriate for the situation. The grinder pump was replaced, wastewater and contaminated soil was removed, and lime was applied to stabilize the area. The collection system consists of 22 grinder pump stations that serve two buildings each. These grinder pumps send wastewater to the main sewer line, that gravity feeds to the secondary lift station. This lift station then sends wastewater towards the main lift station. The rest of the buildings can gravity feed to the main lift station. This separation is determined by the topography, and lines up roughly with the clubhouse. The maintenance staff at The Cottages manages the collection system. Mr. Smith stated that thy have a regular maintenance and inspection schedule, but it is not written down. Ms. Caudle recommended that The Cottages create an Operation and Maintenance Plan. Replacement grinder pumps are available on site. Each grinder pump station has an audible and visual alarm and is connected to telemetry to notify maintenance staff. A map of the collection system is available at the clubhouse. Grease Education Material is provided to the renters with the leasing material. Ms. Caudle requested that a copy of the material be provided to her. Ms. Caudle also requested that a few random inspection logs be provided to her by the end of the following week. Ms. Hernandez stated that The Cottages is looking to install low flow features in all apartments and water meters on each unit. Additional measures may need to be taken to restrict resident's access to the collection system. A sign is posted on a gate to the access road for the section of the collection system with grinder pumps. Per 15 NCAC 02T .0403 Permitting by Regulation: A. Collection systems having an actual permitted or Division -approved average daily flow less than 200,000 gallons per day shall be deemed permitted, pursuant to Rule .0113 of this Subchapter if the system meets the criteria in Rule .0113 of this Subchapter and all criteria required in this Rule: 1) The collection system shall be effectively maintained and operated at all times to prevent discharge to land surface or surface waters and to prevent any contravention of groundwater standards or surface water standards. 2) A map of the collection system shall have been developed and shall be maintained. 3) An operation and maintenance plan, including pump station inspections frequency, preventative maintenance schedule, spare parts inventory, and overflow response shall have been developed and implemented. 4) Pump stations that are not connected to a telemetry system shall be inspected by the permittee or its representative every day, 365 days per year, unless the permittee demonstrates that daily inspections are not necessary because the pump station has sufficient storage capacity, above the elevation at which the pump activates, to justify a longer inspection interval. In no case shall the inspection interval exceed seven days. Pump stations that are connected to a telemetry system shall be inspected once per week. Page 2 of 4 Permit: WQCSD0738 Owner - Facility: Wallace Loft LLC Inspection Date: 10/12/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine 5) High -priority sewers shall be inspected by the permittee or its representative once every six -months, and inspections shall be documented. 6) A general observation by the permittee or its representative of the entire collection system shall be conducted once per year. 7) Overflows and bypasses shall be reported to the appropriate Division regional office in accordance with 15A NCAC 02B .0506(a), and public notice shall be provided as required by G.S. 143-215.1C. 8) A Grease Control Program shall be in place as follows: a. For publicly owned collection systems, the Grease Control Program shall include bi-annual distribution of educational materials for both commercial and residential users and the legal means to require grease interceptors for new construction and retrofit and if necessary, of grease interceptors at existing establishments. The plan shall also include legal means for inspections of the grease interceptors, enforcement for violators and the legal means to control grease entering the system from other public and private satellite collection systems. b. For privately owned collection systems, the Grease Control Program shall include bi-annual distribution of grease education materials to users of the collection system by the permittee or its representative. c. Grease education materials shall be distributed more often than required in Parts (A) and (B) of this Subparagraph if necessary to prevent grease -related sanitary sewer overflows. 9) Right-of-ways and easements shall be maintained in the full easement width for personnel and equipment accessibility. 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 with the exception of the map, which shall be maintained for the life of the system. B. Private collection systems on a single property serving an industrial facility from which the domestic wastewater contribution is less than 200,000 gallons per day shall be deemed permitted. Page 3 of 4 Permit: WQCSD0738 Owner - Facility: Wallace Loft LLC Inspection Date: 10/12/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Page 4 of 4