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Home My WebLink AboutWQCSD0453_CEI NOD2024PC0133_20240801 SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED August 1, 2024 Julia Babcock Trillium Links & Village LLC Email: jbabcock@trilliumnc.com SUBJECT: NOTICE OF DEFICIENCY Tracking Number: NOD-2024-PC-0133 Permit No. WQCSD0453 Trillium Links & Village WWTP Jackson County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Trillium Links & Village WWTP on July 11, 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. WQCSD0453. 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 _________________________________________________________________________________________________________________________________________________________________________ Pump Stations Daily visitations not recorded. Per 02T.0403 (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.” _________________________________________________________________________________________________________________________________________________________________________ General Facility does not have a complete overall system map. Per 02T.0403(2), “A map of the collection system shall have been developed and shall be maintained.” _________________________________________________________________________________________________________________________________________________________________________ Pump Stations Permanent weatherproof signs are not installed. Per 02T.0305(h).2, “Pump stations shall have a permanent weatherproof sign stating the pump station identifier, 24 -hour emergency number, and instructions to call in case of emergency.” _________________________________________________________________________________________________________________________________________________________________________ Docusign Envelope ID: 9BA164C1-3479-4AC9-B659-60EB74D0044C 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. 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 Mikal Willmer with the Water Quality Regional Operations Section in the Asheville Regional Office at 828-296-4686. Sincerely, Daniel Boss, Assistant Regional Supervisor Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Report Ec: LF Docusign Envelope ID: 9BA164C1-3479-4AC9-B659-60EB74D0044C Compliance Inspection Report Permit:WQCSD0453 Effective:07/29/09 Expiration:Owner :Trillium Links & Village LLC SOC: Contact Person: Region: County: Directions to Facility: Jackson Asheville Freddie Boan Effective:Expiration:Facility:Trillium Links & Village WWTP 298 Fenly Forest Trl Cashiers NC 28717 Title:Phone:828-743-6161General Manager From the intersection of Hwy 107 & 64 in Cashiers, go N on Hwy 107 to N Norton Rd on left, continue to Fenley Forest Trail on right, WWTP is appx 1 mile on the right. The high-rate infiltation site is located off N Norton Rd. across from New Trillium Way Secondary ORC(s): Phone:Certification:Primary ORC: System Classifications: On-Site Representative(s): Related Permits: NC0059200 Trillium Links & Village LLC - Trillium Links & Village WWTP Secondary Inspector(s): Primary Inspector: Inspection Date:Exit Time:Entry Time: Phone: 07/11/2024 11:00AM 01:00PM 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 General Grease Control Spills/Response Plan Inspections Lines Manholes Pump Stations (See attachment summary) Page 1 of 7 Docusign Envelope ID: 9BA164C1-3479-4AC9-B659-60EB74D0044C Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCSD0453 07/11/2024 Collection System Inspect Non Sampling Trillium Links & Village LLC Routine Inspection Summary: Mikal Willmer and Melanie Kemp, with the Asheville Regional Office, conducted a Compliance Evaluation Inspection of Trillium's Collection System WQCSD0453 on July 11, 2024. This inspection was conducted to determine whether the facility is being operated and maintained in compliance with the permitted by regulation collection system rules, 02T.0403. RPB and Trillium staff were present and assisted in the inspection The following items were noted at the time of the inspection: Map: A general map is available, but it does appear to represent the entire collection system. All collection system lines, lift stations and manholes should be included at a minimum. Grease Education: Trillium has grease educational materials provided by RPB Systems which are sent out via email notifications to residents. Recommend posting this in a designated location of the Trillium website for residents. Staff report that Trillium speaks specifically to residents in areas where there are recurring issues. Spill Response: There are no known or documented overflows from the system to date. Please ensure all staff associated with the collection system have access to the Spill Response Plan. Lift Stations: The system has five lift stations in total. All are numbered; however, weatherproof signs with 24hr contact information are not installed. Trillium staff reported they visit the lift station daily, but it is not recorded. Recommended staff flip the floats to verify operation during the weekly functionality tests. MH on Chapel Hill: invert was clear, and benches appeared free of debris. No signs of overflow. MH Club Lodge Dr: upstream of the #4 LS. Did not have excessive grease and appeared to be free of any root intrusion or significant debris. LS #2: Connected to the secondary generator located at the WWTP. Audio and visual alarms were operable at the time of the inspection. Have not needed to clean wet well recently. No issues reported. Needs a sign with 24hr contact information. LS #3: Vented and has permanent generator. All alarms were operable and wet well appeared in good condition. Located near several homes. Needs a sign with 24hr contact information. LS #1: Receives most of the system flow. Currently one pump down and awaiting parts for repair. RPB staff reported the part should be arriving soon. The visual alarm was operable, but the audio alarm did not appear to be working at the time of the inspection. Needs a sign with 24hr contact information. LS #4: Staff report they have the most grease near the recently installed town homes along Club Lodge Dr. Wet well appeared to contain more grease than the other wet wells. It is recommended staff have this wet well pumped more frequently to avoid issues with equipment. Needs a sign with 24hr contact information. Deficiencies noted during the inspection: Map: Staff have a general map of the Trillium property, but it does not appear to represent the entire collection system. Per 02T.0403(2), “A map of the collection system shall have been developed and shall be maintained.” LS: Trillium staff reported they visit the lift stations daily, but it is not recorded. Per 02T.0403 (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.” All LS are numbered; however, a weatherproof sign with 24hr contact information shall be installed at the LS for emergency notification. Per 02T.0305(h).2, “Pump stations shall have a permanent weatherproof sign stating the pump station identifier, 24-hour Page 2 of 7 Docusign Envelope ID: 9BA164C1-3479-4AC9-B659-60EB74D0044C Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCSD0453 07/11/2024 Collection System Inspect Non Sampling Trillium Links & Village LLC Routine emergency number, and instructions to call in case of emergency.” Page 3 of 7 Docusign Envelope ID: 9BA164C1-3479-4AC9-B659-60EB74D0044C Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCSD0453 07/11/2024 Collection System Inspect Non Sampling Trillium Links & Village LLC Routine General Yes No NA NE # Is this system a satellite system? # If Yes, what is system name or permit number? Is there a overall sewer system map? Does the map include: 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 Are system maintenance records maintained? See summary for details.Comment: Grease Control Yes No NA NE 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.) See summary for recommendations. For public systems, is there a Grease Control Program via an ordinance/agreement? If Yes, does it require grease control devices at applicable locations? Is the Grease Control Program enforced via periodic inspections/records review? Is action taken against violators? Private collection system. Does not have enforceable grease control program.Comment: Spills and Response Action Plan Yes No NA NE # Is system free of known points of bypass? If No, describe type of bypass and location # 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? 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? Is a Spill Response Action Plan available? Page 4 of 7 Docusign Envelope ID: 9BA164C1-3479-4AC9-B659-60EB74D0044C Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCSD0453 07/11/2024 Collection System Inspect Non Sampling Trillium Links & Village LLC Routine 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 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? ORC test the alarms and pumps, but indicated he was not flipping floats.Comment: Lines/Right-of-Ways/Aerial Lines Yes No NA NE Please list the Lines/Right of Ways/Aerial Lines Inspected: Are right-of-ways and easements maintained for the full width for access? If No, give details on temporary access: Is maintenance documented? Were all areas/lines inspected free of issues? Comment: Manholes Yes No NA NE Please list the Manholes Inspected: MH on Chapel Hill & Club Lodge Dr upstream PS #4 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? Page 5 of 7 Docusign Envelope ID: 9BA164C1-3479-4AC9-B659-60EB74D0044C Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCSD0453 07/11/2024 Collection System Inspect Non Sampling Trillium Links & Village LLC Routine # 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? Comment: Pump Stations Yes No NA NE Please list the Pump Stations Inspected: LS #1, #2, #3, & #4 # Number of duplex or larger pump stations in system 5 # 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?0 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 telemetry system functional? Is a 24-hour notification sign posted ? Does the sign include: Owner Name? Pump station identifier? # Address? Instructions for notification? 24-hour emergency contact numbers? Are audio and visual alarms present? Are audio and visual alarms operable? Page 6 of 7 Docusign Envelope ID: 9BA164C1-3479-4AC9-B659-60EB74D0044C Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCSD0453 07/11/2024 Collection System Inspect Non Sampling Trillium Links & Village LLC Routine # 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? Two of the LS have a dedicated generator. A portable generator is used for the remaining LS. # 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? PS logs include pump run times and pump and alarm operability information. See summary for details and recommendations. Comment: Page 7 of 7 Docusign Envelope ID: 9BA164C1-3479-4AC9-B659-60EB74D0044C