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WQCSD0632_Regional Office Physical File Scan Up To 12/3/2020
G_ NCDENR North Carolina Department.of Environment and Natural Resources" Pat McCrory' Donald R. van der Vaart Governor Secretary June 10, 2015 CERTIFIRED MAIL RETURN RECEIPT REQUESTED 7014 0510 0000 4466 0691 Aubrey L. Deaver A&D Water Service, Inc. PO Box 1407 Pisgah Forest, NC 28768-1407 .SUBJECT: NOTICE OF VIOLATION NOV-2015-PC-0151 Compliance Evaluation Inspection High Vista Falls Collection System Permit No.: WQCSD0632 Henderson County Dear Mr. Deaver: Enclosed please find a copy of the Inspection Report From from the inspection conducted on 2015-05-07. The Collection System Inspection was conducted by Beverly Price of the Asheville Regional Office. .The facility was found to be in violation of Permit WQCSD0632 for the following: Overation.and Maintenance Reciuirements: _. Permit condition 15A NCAC 02T' .0403 Permitting by Regulation (a)(10)' states "Documentation shall be kept for Subparagraphs (a)(1) through (a)(9) of this Rule for a minimum of three years with the exception of the map, which shall be maintained for the life of the system". I have attached a copy of the permit conditions (a)(1), through (a)(9). "On the day of the inspection there were no operatioh/maintenance records available: Iri"addition, there was no confirmation that Grease Control Program materials were distributed bi-annually as required. Please refer to the enclosed inspection report for additional observations and comments. To prevent further action, carefully review these violations and deficiencies and respond in writing to this office within thirty (30) days of receipt of this letter. You should address the causes of noncompliance and all actions taken to prevent the recurrence of similar situations. If you should have any questions, please do not hesitate to contact Bev Price at 828-296-4500. Sincerely, L� P G. Landon Davidson, P:G., Regional Supervisor Water Quality Regional Operations Asheville Regional Office Enc. cc: MSC 1617-Central Files -Basement AR©�Fi1es . CjAWR\WQ\Henderson\Collection Systems\High Vista Falls Collection System\CEI15 NOV-2015-PC-0151.doe Water Quality Regional Operations —Asheville Regional Office 2090 U.S. Highway 70, Swannanoa, North Carolina 28778 ;,,, Phone: 828-296.4500 FAX: 828-299-7043 Internet: http:l/portal.ncdenr.orgAveb/wq/ p.� An Equal Opportunity \ Affirmative Action Employer L v Compliance Inspection -Resort Permit: WQCSD0632 Effective: 06/09/15 Expiration: Owner: Aubrey Lewis Deaver SOC: Effective: Expiration: Facility: High Vista Falls County: Henderson Region: Asheville Contact Person:. .Aubrey Lewis Deaver Title: Phone: 828-884-9772 Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): 24 hour contact name On -site representative Related Permits: Inspection Date: 05/07/2016 Primary Inspector: Beverly Price Secondary Inspector(s): Certification: Phone: Aubrey Lewis Deaver 828-884-9772 Aubrey Lewis Deaver 828-884-9772 Entry Time: 11:30AM Exit Time: 12:30PM Phone: 828-296-4500 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 Performance Standards Operation & Maint Reqmts Records Inspections Manhole (See attachment summary) Page: 1 Permit: WQCSD0632 Owner -Facility: Aubrey Lewis Deaver Inspection Date: 05/07/2015 Inspection Type: Collection System Inspect Non Sampling Reason for Visit: Routine Inspection Summary: Operation/Maintenance Issues: There was no indication that FOG materials were distributed bi-annually as required. There were no maintenance/inspection records available at the time of inspection. An annual observation of the entire system is required annually. Pipe size and material should be added to the map which is dated 6/3/02 - this is the "As -Built" map. Log sheets for documenting compliance with the 2T Rules were provided to Mr. Deaver following the 2014 inspection. The Mills River Health & Rehabilitation Center came on-line in July 2014. Page: 2 Permit: WQCSD0632 Owner -Facility: Aubrey Lewis Deaver Inspection Date: 05/07/2015 Inspection Type: Collection System Inspect Non Sampling Reason for Visit: Routine Performance Standards Is Public Education Program for grease established and documented? What educational tools are used? Mr. "Deaver indicated that flyers are mailed out to customers with their water bills. 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 Has an acceptable Capital Improvement Plan (CIP) been implemented? Does CIP address short term needs and long term 1"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 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? 2-4-hour contact numbers If no, list deficient pump stations # Do ALL pump stations have an "auto polling" feature/SCADA? Number of pump stations Number of pump stations that have SCADA Number of pump stations that have simple telemetry Number of pump stations that have only audible and visual alarms Number of pump stations that do not meet permit requirements # Does the permittee have a root control program? Yes No NA NE ❑ ❑ ❑ ❑ ❑ M ❑ ❑,❑ ■ ❑ ❑❑■❑ ❑ ❑ M ❑ ❑❑■❑ ❑ ❑ M ❑ ❑❑M'❑ 1111 ❑ ❑ ❑ N ❑ ❑❑■❑ Page: 3 Permit: WQCSD0632 Owner - Facility: Aubrey Lewis Deaver Inspection Date: 05/07/2015 ' Inspection Type: Collection System Inspect Non Sampling Reason for Visit: Routine # If yes, date implemented? Describe: Comment: Mr. Deaver was unsure whether FOG materials had been distributed bi-annually. Inspections Yes No NA NE Are maintenance records for sewer lines available? ❑ ❑ ❑ Are records available that document pump station inspections? ❑ ❑ 0 ❑ Are SCADA or telemetry equipped pump stations inspected at least once a week? ❑ ❑ ❑ Are non-SCADA/telemetry equipped pump stations inspected every day? ❑ ❑ M ❑ Are records available that document citizen complaints? ❑ ❑ ❑ # Do you have a system to conduct an annual observation of entire system? El ❑ El # Has there been an observation of remote areas in the last year? DEIN ❑ Are records available that document inspections of high -priority lines? ❑ ❑ ❑ Has there been visual inspections of high -priority lines in last six months? ❑ ❑ 0 ❑ Comment: Maintenance records were not available at the time of inspection. Mr. Deaver was provided with log sheets for documenting compliance,after the 2014 inspection. Operation & Maintenance Requirements Yes No NA NE Are.all log books available? ❑ ❑ ❑ Does supervisor review all log books on a regular basis? ❑ ❑ N ❑ Does the supervisor have plans to address documented short-term problem areas? ❑ 110 ❑ 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? ❑ 0 ❑ ❑ What is the schedule for testing emergency/standby equipment? Do pump station logs include: Inside and outside cleaning and debris removal? ❑ ❑ ❑ Inspecting and exercising all valves? ❑ ❑ N❑ Inspecting and lubricating pumps and other equipment? ❑ ❑ N ❑ Inspecting alarms, telemetry and auxiliary equipment? ❑ 1-10 ❑ Is there at least one spare pump for each pump station w/o pump reliability? ❑ ❑. N ❑ Are maintenance records for right-of-ways available? ❑ E ❑ ❑ Are right-of-ways currently accessible in the event of an emergency? N ❑ ❑ ❑ Are system cleaning records available? ❑ 0 ❑ ❑ Has at,least 10% of system been cleaned annually? ❑ ❑ ❑ What areas are scheduled for cleaning in the next 12 months? Is a Spill Response Action Plan available? 0 ❑ ❑ ❑ Does the plan include: Page: 4 Permit: WQCSD0632 Owner -Facility: Aubrey Lewis Deaver Inspection Date: 05/07/2015 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine 24-hour contact numbers 0❑ ❑ ❑ Response time ❑ ❑ ❑ Equipment list and spare parts inventory 0❑ ❑ ❑ Access to cleaning equipment M ❑ ❑ ❑ Access to construction crews, contractors, and/or engineers, ❑ ❑ ❑ Source of emergency funds ❑ ❑ ❑ Site sanitation and cleanup materials ❑ ❑ ❑ Post-overflow/spill assessment 0 ❑ ❑ ❑ Is a Spill Response Action Plan available for all personnel? 0 ❑ ❑ ❑ Is the spare parts inventory adequate? ❑ ❑ ❑ Comment: Spare parts inventory was not available. 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? ❑ ❑ 0 ❑ Do spill records indicate repeated overflows (2 or more in 12 months) at same location? ❑ ❑ 0 ❑ If yes, is there a corrective action plan? ❑ ❑0 ❑ Is a map of the system available? 0 ❑ ❑ ❑ Does the map include: Pipe sizes ❑ 0 ❑ ❑ Pipe materials ❑ ❑ ❑ Pipe location 0 ❑ ,❑ ❑ Flow direction ❑ M ❑ ❑ 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? ❑ ❑ M ❑ Comment: Pipe size and material should be added to the map. MH#1 PHASE I - Field adjac Manhole Yes No NA NE Is manhole accessible? ❑ ❑ ❑ # Is manhole cover/vent above grade? 0 ❑ ❑ ❑ Is the manhole free of visible signs of overflow? 0 ❑ ❑ ❑ Is the manhole free of sinkholes and depressions? ❑ ❑ ❑ Is manhole cover present? 0❑ ❑ ❑ Page: 5 permit: WQCSDO632 Owner -Facility: Aubrey Lewis Deaver Inspection Date: 05/07/2015 Inspection Type: Collection System Inspect Non Sampling. Reason for Visit: Routine # Is manhole properly seated? N ❑ ❑ ❑ # Is manhole in good condition? 0 ❑ ❑ ❑ # Is invert in good condition? ❑- ❑ ❑ Is line free -flowing and unrestricted in manhole? ❑ ❑ ❑ Is manhole free of excessive amounts of grease? 0 ❑ ❑ ❑ Is manhole free of excessive roots? N ❑ ❑ ❑ Is manhole free of excessive sand? N ❑ ❑ ❑ Is manhole's extended vent screened? ❑ 1:10 ❑ Are vents free of submergence? ❑ ❑. 0 ❑ Are manholes free of bypass structures or pipes? 0 ❑ ❑ ❑ Comment: This manhole was patched following the 2014 inspection. Very slight amount of I&I on the day of inspection. MH#30 PHASE IV - adjacen Manhole Is manhole accessible? # Is manhole cover/vent above grade? Is the manhole free of visible signs of overflow? Is the manhole free of sinkholes and depressions? Is manhole cover present? # Is manhole properly seated? # Is manhole in good condition? # Is invert in good condition? Is line free -flowing and unrestricted in manhole? Is manhole free of excessive amounts of grease? Is manhole free of excessive roots? . Is manhole free of excessive sand? Is manhole's extended vent screened? Are vents free of submergence? Are manholes free of bypass structures or pipes? - Comment: MH#7 PHASE V - in the stre Manhole Is manhole accessible? # Is manhole cover/vent above grade? Is the manhole free of visible signs of overflow? Is the manhole free of sinkholes and depressions? 0 Yes No NA NE ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ■❑❑❑ ■❑❑❑ ■❑❑❑ ❑ ❑ ❑ ❑ ❑ ❑ ■❑❑❑ ❑ ❑ ❑ ❑ ❑ N ❑ ❑ ❑ N ❑ ■❑❑❑ Yes No NA NE ❑ ❑ ❑ ❑ ❑ ❑ ■❑❑❑ Page: 6 Permit; WQCSD0632 Owner- Facility: Aubrey Lewis Deaver Inspection Date: 05/07/2015 Inspection type: Collection System Inspect Non Sampling Reason for Visit: Routine Is manhole cover present? ❑ # Is manhole properly seated? M ❑ El 0 # Is manhole in good condition? 0 ❑ El El # Is invert in good condition? Q Is line free -flowing and unrestricted in manhole? Is manhole free of excessive amounts of grease? M ❑ Is manhole free of excessiveroots? E 0 El R Is manhole free of excessive sand? M ❑ 0 Is manhole's extended vent screened? Are vents free of submergence? M El Are manholes free of bypass structures or pipes? M El El El Comment: Page: 7 Page 20 of 69 (1) "Collection system" means a public or private sewer system, consisting of sewer lines, force mains, pump stations or, any combination thereof that conveys wastewater to a designated wastewater treatment facility or separately -owned sewer system. For purposes of permitting, the collection system is considered to be any existing or newly installed system extension up to the wastewater treatment facility property or point of connection with a separately -owned sewer system. (2) "High -priority sewer" means any aerial sewer, sewer contacting surface waters, siphon, sewer positioned parallel to streambanks that is subject to erosion that undermines or deteriorates the sewer, or sewer designated as high priority .in a Division issued permit where the sewer does not meet minimum design requirements. History Note: Authority G.S. 143-215.1(a); 143-215.3(a); 143-215.9B, Eff. September 1, 2006. 15A 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 are deemed permitted pursuant to Rule .0113 of this Subchapter provided the system meets the criteria in Rule .0113 of this Subchapter and all specific criteria required in this Rule: (1) The sewer system is effectively maintained and operated at all times to prevent discharge to land or surface waters, and to prevent any contravention'of groundwater standards or surface water standards. (2) A map of the sewer system has been developed and is.actively maintained. (3) An operation and maintenance plan including pump station inspection frequency, preventative maintenance schedule, spare parts inventory and overflow response has been developed and implemented. (4) Pump stations that are not connected to a telemetry system (i.e., remote alarm system) are inspected by the permittee or its representative every day (i.e., 365 days per year). Pump stations .that are connected to a telemetry system are inspected at least once per week. (5) High -priority in are inspected by the permittee or its representative at least once every six -months and inspections are documented. (6) A general observation by the permittee or its representative of the entire sewer system is conducted at least once per year. (7) Overflows and bypasses are reported to the appropriate Division regional office in accordance with 15A NCAC 02B :0506(a), and public notice is provided as required by G.S. 143-215.1C. (8) A Grease Control Program is in place as follows: (A) For publicly owned collection systems, the Grease Control Program shall include at least 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, 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 sewer systems., (B) For privately owned collection systems, the Grease Control Program shall include at least 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 are maintained in the full easement width for personnel and equipment accessibility. (10) Documentation shall be kept for Subparagraphs (a)(1) through (a)(9) of this Rule for a minimum of three years with 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 where the domestic wastewater contribution is less than 200,000 gallons per day shall be deemed permitted. (c) The Director may determine that a collection system should not be deemed to be permitted in accordance with this Rule and Rule .0113 of this Subchapter. This determination shall be made in accordance with Rule .0113 (e) of this Subchapter. History Note: Authority G.S. 143-215. I (a); 143-215.3(a); 143-215.9B; Eff. September 1, 2006. 15A NCAC 02T .0404 MULTIPLE COLLECTION SYSTEMS UNDER COMMON OWNERSHIP If a public entity owns multiple but separate collection systems (i.e., tributary to separate plants) and any one is subject to an individual permit, all collection systems shall be covered under one permit. This shall not be applicable to public utilities authorized to operate by the North Carolina Utilities Commission who own several individual systems within the state.. History Note: Authority G.S. 143-215. 1 (a); 143-215.3(a); 143-215.9B; http://reports. oah.. state.nc.us/ncacltitle%2015 a%20%20environinent%2Oand%2Onatural%o2... 6/9/2015 A & D Water Service, Inc. P.O. Box 1407 Pisgah Forest, NC 28768 June 30, 2014 Linda Wiggs Environmental Senior Specialist Dear Linda, The collection system in High Vista consists of 30,400'of 8" gravity mains and 90 manholes. The 8" pipes are a combination of PVC and Ductile Iron. The FOG materials were sent out once a year. The next mailing_ is due out at the end of July to early August. We will set up a twice per year schedule. I was unaware of the 10% per year inspection requirement or the need to document inspections. I will be using. at the least a log, book to document these inspections in the. future. We have inspected approximately 3,000' of lines & 12 manholes with a camera in the past 2 years. The line paralleling the stream ( Split Creek Ct ) was inspected by camera 2 years ago. No problems were found. A & D purchased the. entire sewer system from NC 4'Cs in 2006.. The ownership name change forms were sent in to Raleigh at that time and a new permit was issued. The manhole we looked for below the Clubhouse does not exist. I was in error. The nearest manhole is located at the intersection below the area we looked over. I have looked in the manhole and have scheduled it to be cleaned. The spill response plane is attached. All other records are available for inspection at my office (46. Colwell Dr., Brevard ). The manhole along 191 has been repaired. June 30, 2014 Please contact me or my office if you have any questions. Aubrey Deaver, President Revised: 01/01/14 A&D WATER SERVICE P. O. Box 1407 PISGAH FOREST, NC 28768 SPILL / BYPASS RESPONSE PLAN Step 1: RECEIVE NOTIFICATION ABOUT SPILL/BYPASS; Step 2: CONTACT A&D and/or OPERATOR; Step 3: A&D and/or OPERATOR GOES TO SPILL SITE TO MAKE AN ASSESSMENT OF THE SPILL; Step 4: A&D or OPERATOR CONTACTS DWQ OFFICE TO ADVISE ABOUT SPILL WITHIN 2 HOURS; Step 5: PEOPLE AND EQUIPMENT ARE GATHERED TO STOP SPILL; Step 6: SPILL/BYPASS IS CONTAINED; Step 7: CLEANUP OF SITE; Step 8: CONTACT DWQ AT REGIONAL OFFICE WITHIN 24 HOURS OF FIRST NOTIFICATION OF THE SPILL; Step 9: FOLLOW-UP WITH WRITTEN REPORT WITHIN 5 DAYS - IF REQUIRED. 24 HOUR CONTACT LIST EMERGENCY CONTACT LIST NAME TITLE AREA Aubrey Deaver A&D Any Aubrey Deaver Jr. A&D Any EQUIPMENT LIST Service Trucks (2) Manhole blower Tripods/harness/air packs Lime & chlorine for cleanup Hard hats/gloves/hand tools Test Equipment CELL 828-507-9853 828-243-2562 HOME 828-696-9391 OFFICE 828-884-9772 828-884-9772 Location A&D Office at 46 Colwell Dr., Brevard, NC A&D Office A&D Warehouse A&D Warehouse A&D Warehouse A&D Warehouse Other needed equipment is rented from the City of Hendersonville. Revised: 1/01/14 A&D WATER SERVICE P. O. Box 1407 PISGAH FOREST, NC 28768 WASTEWATER COLLECTION SYSTEM OPERATION & MAINTENANCE PLAN A&D Water Service provides the following services: 1. Maintains qualified staff and/or subcontractors for O&M activities; 1. Provides a 24 hour emergency contact list; 2. Provides necessary equipment and repair parts or have access to same; 4. Provides lift station O&M; Lift stations with telemetry are checked 1/wk.; Lift stations w/o telemetry are checked daily (7/wk.); 5. Maintains a set of system maps; 6. Provides the annual observation inspection, the high priority semi-annual inspection and ospot. inspections as needed; 7. Provides for right-of-way maintenance; 8. Provides I/I evaluation, manhole inspections and sewer line cleaning on an mas needed. basis; 9. Provides a Grease Control Program; Grease education materials are distributed biannually; Non-residential users are inspected as needed; 10. Spills and overflows are reported as required; Public notice is provided if required; 11. Maintains logs and/or records as required to demonstrate compliance; 12. Provides other services as Owner desires. EMERGENCY CONTACT LIST NAME TITLE AREA Aubrey Deaver A&D Any Aubrey Deaver Jr. A&D Any EQUIPMENT LIST Service Trucks (2) Vacuum Truck Manhole blower Tripods/harness/air packs Lime & chlorine for cleanup Hard hats/gloves/hand tools Test Equipment CELL HOME OFFICE 828-507-9853 828-696-9391 828-884-9772 828-243-2562 828-884-9772 Location A&D Office, 46 Colwell Dr., Brevard, NC Contractor A&D Office A&D Warehouse A&D Warehouse A&D Warehouse A&D Warehouse Other needed equipment is rented from the City of Hendersonville. D ONIT E H G S Tie GREASE GOBLIN Cause The GREASE 0613LIN Your drain's worst enemy! Put ila d grease in collection g z, ta, ne rs Remove oil and grease from -kitchen utensils, equipment apd food preparation areas - c r-apers/towels/brooms -ep p .grease out. of wash water dod scraps collection A PTT " Fps , , I rng fl :C N.C.Divis Toll'F ree DO NOT !. Pour oil and grease d1oWl"'I& drains (2) Wash fryers/gridd:le'-spots - pans, a n d plates withwatt until oil and, grease-,,ar6-,.re1.,rr. Use hot water.to i grease off surface Put-food:s& MI.RAW/i J V d.D ER North Carolina Department of Environment arL* Pat McCrory Governor June 13, 2014 Aubrey Lewis Deaver A&D Water Service Inc. PO Box 1407 Pisgah Forest, NC 28768-1407 SUBJECT: Collection System Inspection High Vista Falls Permit No: WQCSD0128 Henderson County Dear Mr. Deaver: Natural Resources John E. Skvarla, III Secretary On May 20, 2014, I conducted a Collection System Inspection of the High Vista Falls system. The system was noncompliant with 15A NCAC 02T.0403. It appears that some of the criteria of this rule are being performed; however there is insufficient documentation to substantiate. Please respond in writing to this office by June 30, 2014, with how you plan to document the operation and maintenance of this system. This collection system is listed as being owned by the development company NC Four C, LLC Robert Duffy. Please also clarify the current ownership of this system. Refer to the enclosed inspection report for observations and comments. If you or your staff have any questions, please call me at 828-2964500. Sincerely, Linda Wiggs Environmental Senior Specialist Asheville Regional Office Enc. Inspection Report cc: MSC 1617-Central Files -Basement Elshevll Fi"'les G:\WR\WQ\Henderson\Collection Systems\High Vista Falls Collection System\CEI. 05.20.14.doc Water Quality Regional Operations —Asheville Regional Office 2090 U.S. Highway 70, Swannanoa, North Carolina 28778 Phone: 828-2964500 FAX: 828-299-7043 Internet: http://portal.ncdenr.org/webtwq An Equal Opportunity 1 Affirmative Action Employer Permit: WQCSD0128 SOC: County: Henderson Region: Asheville Compliance Inspection Report Effective: 03/01/00 Expiration: Owner: NC Four C's, LLC Effective: Expiration: Facility: High Vista Falls Phase V Contact Person: Robert J Duffy Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): Related Permits: Title: Inspection Date: 05/20/2014 Entry Time: 11:00 AM Primary Inspector: Linda S WiggsOhl-I Secondary Inspector(s): Phone: 828-243-4000 Certification: Phone: Exit Time: 01:00 PM Phone: 828-296-4500 Ext.4653 Reason for Inspection: Routine Inspection Type: Collection System Inspect Non Sampling Permit Inspection Type: Deemed permitted collection system management and operation Facility Status: 0 Compliant ® Not Compliant Question Areas: ® Miscellaneous Questions ® Performance Standards ® Operation & Maint Reqmts ® Records ® Monitoring & Rpting ® Inspections ® Manhole Reqmts (See attachment summary) Page: 1 Permit: WQCSDO128 Owner - Facility: NC Four C's, LLC Inspection Date: 05/20/2014 Inspection Type: Collection System Inspect Non Sampling Reason for Visit: Routine Inspection Summary: This collection system (CS) serves the High Vista development, a small industrial park and will soon serve the Mills River Health and Rehabilitation center. A&D Maintenance Inc. operates and maintains the collection system and the wastewater treatment plant. This is the first inspection of the collection system.. Aubrey Deaver with A&D Maintenance was present for the inspection as was Bev Price with DWR. Mr. Deaver stated this was his first collection system inspection and he did not have the required paperwork with him, nor did he send it upon request (email 5/21/14). The Inspector informed him onsite, and in an email (5/21/14), of the required paperwork to document compliance with the 2T rules. It is suggested that the log sheets sent to Mr. Deaver in the email be used to gain compliance. This collection system is small and it is possible that several of the required CS program components are being met, however without the proper documentation this inspection is considered non -compliant. Mr. Deaver stated that mailings for grease (FOG) are sent to residents annually and that work order invoices are used to track work performed on the CS. FOG materials should be sent 2/yr or more often if needed. The owner of this system is listed as NC Four C's, LLC Robert J. Duffy. The LLC could not be found on the Secretary of State website and Mr. Duffy cannot be reached at the phone number supplied. Please clarify the ownership of this system. Written response is required to indicate how compliance will be achieved. Page: 2 Permit: WQCSDO128 Owner - Facility: NC Four C's, LLC Inspection Date: 05/20/2014 Inspection Type: Collection System Inspect Non Sampling Performance Standards Reason for Visit: Routine Yes No NA NE Is Public Education Program for grease established and documented? IN Cl n n What educational tools are used? Mr. Deaver indicated they are using the State suggested form in a yearly mailing. Mailings need to be sent twice a year. He also stated he believed the Clubhouse does have a grease trap and it is pumped 2/yr. We were unable to find the manhole below the Clubhouse to evaluate for grease. He will determine where that manhole is located and evaluate if cleaning is needed. Is Sewer Use Ordinance/Legal Authority available? n ®n n Does it appear that the Sewer Use Ordinance is enforced? n ❑ ® ❑ Is Grease Trap Ordinance available? ❑ ❑ ® n Is Septic Tank Ordinance available (as applicable, i.e. annexation) ❑ ❑ ® ❑ List enforcement actions by permittee, if any, in the last 12 months Has an acceptable Capital Improvement Plan (CIP) been implemented? n n ® n Does CIP address short term needs and long term \"master plant/ concepts? n n ® n Does CIP cover three to five year period? n ❑ ® n Does CIP include Goal Statement? n n ® Cl Does CIP include description of project area? ❑ ❑ ® n Does CIP include description of existing facilities? n n ® n Does CIP include known deficiencies? n n ® n Does CIP include forecasted future needs? ❑ n ® n Is CIP designated'only for wastewater collection and treatment? n n IN n Approximate capital improvement budget for collection system? Total annual revenue for wastewater collection and treatment? CIP Comments A formal CIP is not required for this system. However, reinvestment into this system through sufficient operation and maintenance is required, therefore the development of some semblance of a CIP is suggested. Is system free of known points of bypass? ■ n ❑ If no, describe type of bypass and location Is a 24-hour notification sign posted at ALL pump stations? n 0 ■ n # Does the sign include: Instructions for notification? n ❑ M fl Pump station identifier? n ❑ ® n Page: 3 Permit: WQCSDO128 Owner - Facility: NC Four C's, LLC Inspection Date: 05/20/2014 Inspection Type: Collection System Inspect Non Sampling Reason for Visit: Routine 24-hour contact numbers nn®n If no, list deficient pump stations # Do ALL pump stations have an "auto polling" feature/SCADA? Number of pump stations Number of pump stations that have SCADA Number of pump stations that have simple telemetry Number of pump stations that have only audible and visual alarms Number of pump stations that do not meet permit requirements # Does the permittee have a root control program? # If yes, date implemented? Describe: Comment: See summary for detailed comments. Inspections 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? Comment: See summary for detailed comments. Operation & Maintenance Requirements 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? See summary. Are maintenance records for equipment available? 0000 11 Yes No NA NE n®nn n®nn nn■n nn®n 0 M 0 0 n®nn n®nn n®nn n®nn Yes No NA NE n ® n n Page: 4 Permit: WQCSDO128 Owner - Facility: NC Four C's, LLC Inspection Date: 05/20/2014 Inspection Type: Collection System Inspect Non Sampling Is a schedule maintained for testing emergency/standby equipment? What is the schedule for testing emergency/standby equipment? Do pump station logs include: Inside and outside cleaning and debris removal? Reason for Visit: Routine 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? Mr. Deaver stated they are doing camera work instead of cleaning. Camera work in concert with cleaning should be performed. See summary. 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? Comment: See summary. Records Are adequate records of all SSOs, spills and complaints available? Are records of SSOs that are under the reportable threshold available? nnffn nn®n nn®n nn®n nn®n ❑ ❑ 6 0 n®nn 0 N 0 0 n®nn n®nn 0 U 0 0 Yes No NA NE 0 w 0 0 nMnn Page: 5 Permit: WQCSD0128 Owner - Facility: NC Four C's, LLC Inspection Date: 05/20/2014 Inspection Type: Collection System Inspect Non Sampling Reason for Visit: Routine Do spill records indicate repeated overflows (2 or more in 12 months) at same location? n ® n Cl If yes, is there a corrective action plan? n ON ❑ El Is a map of the system available? W 0 n n Does the map include: Pipe sizes ❑ ®n Pipe materials n ® n n Pipe location ® n n n Flow direction n ® n n Approximate pipe age n ® n n Number of service taps n ® n n . Pump stations and capacity n n ® ri If no, what percent is complete? List any modifications and extensions that need to be added to the map Ths system is small and fairly young 1990's; the age and pipe material is similar. The map is the original Engineer plan sheet, so the pertinent information is there. # Does the permittee have a copy of their permit? ❑ ❑ a ❑ Comment: Deemed system. 2T Rule has been given to Mr. Deaver for assistance. Monitoring and Reporting Requirements Yes No NA NE Are copies of required press releases and distribution lists available? Cl n ® n Are public notices and proof of publication available? n n ® n # Is an annual report being prepared in accordance with G.S. 143-215.1C? n n ■ n # Is permittee compliant with all compliance schedules in the permits? n n n If no, which one(s)? Comment: Refer to summary. MH - Manhole Yes No NA NE Is manhole accessible? ■ n n n # Is manhole cover/vent above grade? ® n n n Is the manhole free of visible signs of overflow? ® n n n Is the manhole free of sinkholes and depressions? ■ n n n Page: 6 Permit: WQCSD0128 Owner - Facility: NC Four C's, LLC Inspection Date: 05/20/2014 Inspection Type: Collection System Inspect Non Sampling Reason for Visit: Routine Is manhole cover present? ®❑ D fl # Is manhole properly seated? ® D D D # Is manhole in good condition? ® D D D # Is invert in good condition? D D D Is line free -flowing and unrestricted in manhole? ® Cl D D Is manhole free of excessive amounts of grease? ® D D D Is manhole free of excessive roots? D D D Is manhole free of excessive sand? ® D D D Is manhole's extended vent screened? D D ® D Are vents free of submergence? D Are manholes free of bypass structures or pipes? ® D D D Comment: There were several manholes inspected. As noted above, the one by the clubhouse was not found during the inspection. Further conversation with Mr. Deaver revealed he found the downstream manhole associated with the clubhouse. Upon inspection he determined that line will need cleaning. Two manholes (Split Crk Ct.) along the creek were inspected, they appeared ok. It was suggested lines along the creek be considered for camera inspection to make sure I&I is not ocurring. The manhole by Hwy 191 did have some issues. This manhole will receive flows from the Mills River Health Center. This manhole sits in a wetland and did have signs of I&I. Since it was noted the WWTP receives elevated flows with rain events, remediating sources of I&I should be a priority. Page: 7 I L North Carolina Department of Environment and Natural Resources Pat McCrory John E. Skvarla, III Governor Secretary June 13, 2014 Aubrey Lewis Deaver A&D Water Service Inc. PO Box 1407 Pisgah Forest, NC 28768-1407 SUBJECT: Collection System Inspection High Vista Falls Permit No: WQCSDO128 Henderson County Dear Mr. Deaver: On May 20, 2014, I conducted a Collection System Inspection of the High Vista Falls system. The system was noncompliant with 15A NCAC 02T.0403. It appears that some of the criteria of this rule are being performed; however there is insufficient documentation to substantiate. Please respond in writing to this office by June 30, 2014, with how you plan to document the operation and maintenance of this system. This collection system is listed as being owned by the development company NC Four C, LLC Robert Duffy. Please also clarify the current ownership of this system. Refer to the enclosed inspection report for observations and comments. If you or your staff have any questions, please call me at 828-2964500. Sincerely, Linda Wiggs Environmental Senior Specialist Asheville Regional Office Enc. Inspection Report cc: MSC 1617-Central_ Files -Basement Asheville Files =4 G:\WR\WQ\Henderson\Collection Systems\High Vista Falls Collection System\CEI. 05.20.14.doe Water Quality Regional Operations — Asheville Regional Office 2090 U.S. Highway 70, Swannanoa, North Carolina 28778 Phone: 828-296-4500 FAX: 828-299-7043 Internet: hUp.1/portal.nedenr.org/web/wq An Equal Opportunity 1 Affirmative Acton Employer Compliance Inspection Report Permit:. WQCSDO128 Effective: 03/01/00 Expiration: Owner: NC. Four Cs, LLC SOC: Effective: Expiration: Facility: High Vista Falls Phase V County: Henderson Region: Asheville Contact Person: Robert J Duffy Title: Phone: 828-M-4000 Directions to Facility; System Classifications: Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): Related Permits: Inspection Date: 05/20/2014 Entry Time: 11:00 AM Exit Time: 01:00 PM Primary Inspector: Linda S Wiggs Phone: 82846534500 Ext.Secondary Inspectors): Reason for Inspection: Routine Inspection Type: Collection System Inspect Non Sampling Permit Inspection Type: Deemed permitted collection system management and operation Facility Status: ❑ Compliant IN Not Compliant Question Areas: ® Miscellaneous Questions Performance Standards Operation & Maint Reqmts ® Records ® Monitoring & Rpting ®Inspections Manhole Reqmts (See attachment summary) Page: 1 Permit: WQCSDO128 Owner - Facility: NC Four C's, LLC Inspection Date: 05/20/2014 Inspection Type: Collection System Inspect Non Sampling Reason for Visit: Routine Inspection Summary: This collection system (CS) serves the High Vista development, a small industrial park and will soon serve the Mills River Health and Rehabilitation center. A&D Maintenance Inc. operates and maintains the collection system and the wastewater treatment plant. This is the first inspection of the collection system.. Aubrey Deaver with A&D Maintenance was present for the inspection as was Bev Price with DWR. Mr. Deaver stated this was his first collection system inspection and he did not have the required paperwork with him, nor did he send it upon request (email 5/21/14). The Inspector informed him onsite, and in an email �5/21/14); of the required paperwork to document compliance with the 2T rules. It is suggested that the log sheets sent to Mr. Deaver in the email be used to gain compliance. This collection system is small and it is possible that several of the required CS program components are being met, however without the proper documentation this inspection is considered non -compliant. Mr. Deaver stated that mailings for grease (FOG) are sent to residents annually and that work order invoices are used to track work performed on the CS. FOG materials should be sent 2/yr or more often if needed. The owner of this system is listed as NC Four C's, LLC Robert J. Duffy. The LLC could not be found on the Secretary of State website and Mr. Duffy cannot be reached at the phone number supplied. Please clarify the ownership of this system. Written response is required to indicate how compliance will be achieved. Page: 2 Permit: WQCSDO128 Owner - Facility: NC Four C's, LLC Inspection Date: 05/20/2014 Inspection Type: Collection System Inspect Non Sampling Reason for Visit: Routine Performance Standards Yes No NA NE Is Public Education Program for grease established and documented? ® n n n What educational tools are used? Mr. Deaver indicated they are using the State suggested form in a yearly mailing. Mailings need to be sent twice a year. He also stated he believed the Clubhouse does have a grease trap and it is_pumped 21yr. We were unable to find the manhole below the Clubhouse to evaluate for grease. He will determine where that manhole is located and evaluate if cleaning is needed. Is Sewer Use Ordinance/Legal Authority available? n ® n n Does it appear that the Sewer Use Ordinance is enforced? n n ( n Is Grease Trap Ordinance available? n n ® n Is Septic Tank Ordinance available (as applicable, i.e. annexation) n n ® n List enforcement actions by permittee, if any, in the last 12 months Has an acceptable Capital Improvement Plan (CIP) been implemented? n Cl ® n Does CIP address short term needs and long term \"master plant/ concepts? n n ® n Does CIP cover three to five year period? nn®n. Does CIP include Goal Statement? n n im n Does CIP include description of project area? n n IN n Does CIP include description of existing facilities? n n ® n Does CIP include known deficiencies? n n ® n Does CIP include forecasted future needs? n n IN n Is CIP designated' only for wastewater collection and treatment? n n ® n Approximate capital improvement budget for collection system? Total annual revenue for wastewater collection and treatment? CIP Comments A formal CIP is not required for this system. However, reinvestment into this systemthrough sufficient operation and maintenance is required, therefore the development of some semblance of a. CIP is suggested. Is system free of known points of bypass? ®n n n If no, describe type of bypass and location Is a 24-hour notification sign posted at ALL pump stations? n n ® n # Does the sign include: Instructions for notification? nn®n Pump station identifier? n n ® n Page: 3 Permit: WQCSDO128 Owner - Facility: NC Four C's, LLC Inspection Date: 05/20/2014 Inspection Type: Collection System Inspect Non Sampling Reason for Visit: Routine 24-hour contact numbers n n n If no, list deficient pump stations # Do ALL pump stations have an "auto polling" feature/SCADA? Number of pump stations Number of pump stations that have SCADA Number of pump stations that have simple telemetry Number of pump stations that have only audible and visual alarms Number of pump stations that do not meet permit requirements # Does the permittee have a root control program? # If yes, date implemented? Describe: Comment: See summary for detailed comments. Inspections 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? Comment: See summary for detailed comments. Operation & Maintenance Requirements 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? See summary. Are maintenance records for equipment available? nnEgn 0 0INnn onion n®nn nn®n 0 0 M 0 n®nn 0 a 0 0 0 M 0 0 OW00 nminn Yes No NA NE n Oil nn nnIMn nnEMn n®nn Page: 4 Permit: WQCSDO128 Owner - Facility: NC Four C's, LLC Inspection Date: 05/20/2014 Inspection Type: Collection System•lnspect Non Sampling Reason for Visit: Routine Is a schedule maintained for testing emergency/standby equipment? n n ®fl What is the schedule for testing emergency/standby equipment? Do pump station logs include: Inside and outside cleaning and debris removal? n n ® n Inspecting and exercising all valves? rl n ® n Inspecting and lubricating pumps and other equipment? n Cl w n Inspecting alarms, telemetry and auxiliary equipment? n n ® n Is there -at least one spare pump for each pump station w/o pump reliability? n n ® n Are maintenance records for right-of-ways available? n ®n Are right-of-ways currently accessible in the event of an emergency? n ®n n Are system cleaning records available? n ® n n Has at least 10% of system been cleaned annually? rll ® n n What areas are scheduled for cleaning in the next 12 months? Mr. Deaver stated they are doing camera work instead of cleaning. Camera work in concert with cleaning should be performed. See summary. Is a Spill Response Action Plan available? n P1 0 n Does the plan include: 24-hour contact numbers n ® n n Response time ❑ ® n n Equipment list and spare parts inventory ❑ ■ Access to cleaning equipment n ® n n Access to construction crews, contractors, and/or engineers In ® n n Source of emergency funds n ® n n Site sanitation and cleanup materials n ® nl n Post-overflow/spill assessment ❑ N 0 n Is a Spill Response Action Plan available for all personnel? n IN n n Is the spare parts inventory adequate? Cl ®❑ 0 Comment: See summary. Records Yes No NA NE Are adequate records of all SSOs, spills and complaints available? n ❑ n Are records of SSOs that are under the reportable threshold available? 0 ■ El fl Page: 5 Permit: WQCSD0128 Owner - Facility: NC Four C's, LLC Inspection Date: 05/20/2014 Inspection Type: Collection System Inspect Non Sampling Reason for Visit: Routine Do spill records indicate repeated overflows (2 or more in 12 months) at same location? n ® n Cl If yes, is there a corrective action plan? n 1W n n Is a map of the system available? is Cl n n Does the map include: Pipe sizes n ® n n Pipe materials n ®n n Pipe location Ng n n n Flow direction n ® o o Approximate pipe age n E n n Number of service taps n lm n n Pump stations and capacity n n ® n If no, what percent is complete? .List any modifications and extensions that need to be added to the map Ths system is small and fairly young 1990's; the age and pipe material is similar. The map is the original Engineer plan sheet, so the pertinent information is there. # Does the permittee have a copy of their permit? n Cl IN ❑ Comment: Deemed system. 2T Rule has been given to Mr. Deaver for assistance. Monitoring and Reporting Requirements Yes No NA NE Are copies of required press releases and distribution lists available? n n ® n Are public notices and proof of publication available? n n ® n # Is an annual report being prepared in accordance with G.S. 143-215.1 C? n n ® n # Is permittee compliant with all compliance schedules in the permits? n n ® n If no, which one(s)? Comment: Refer to summary. MIH o Manhole Yes No NA NE Is manhole accessible? ® n n n # Is manhole cover/vent above grade? ® n n n Is the manhole free of visible signs of overflow? n n n Is the manhole free of sinkholes and depressions? n n n Page: 6 Permit: WQCSD0128 Owner - Facility: NC Four C's, LLC Inspection Date: 05/20/2014 Inspection Type: Collection System Inspect Non Sampling Reason for Visit: Routine Is manhole cover present? o ❑ n # Is manhole properly seated? 0 n n # Is manhole in good condition? pffi ❑ n Q # Is invert in good condition? ® n ❑ n Is line free -flowing and unrestricted in manhole? 9 ❑ 0 ❑ Is manhole free of excessive amounts of grease? 00 n Is manhole free of excessive roots? n n n Is manhole free of excessive sand? IN 00 n Is manhole's extended vent screened? n 00 n Are vents free of submergence? n n ® n Are manholes free of bypass structures or pipes? ❑ 0 Comment: There were several manholes inspected. As noted above, the one by the clubhouse was not found during the inspection. Further conversation with Mr. Deaver revealed he found the downstream manhole associated with the clubhouse. Upon 'inspection he determined that line will need cleaning. Two manholes (Split Crk Ct.) along the creek were inspected, they appeared ok. It was suggested lines along the creek be considered for camera inspection to make sure I&I is not ocurring. The manhole by Hwy 191 did have some issues. This manhole will receive flows from the Mills River Health Center. This manhole sits in a wetland and did have signs of I&I. Since if was noted the WWTP receives elevated flows with rain events, remediating sources of,l&I should be a priority. Page: 7 Compliance Inspection Report PermEffective: 03/01/00 Expiration: Owner: NC Four C's, LLC SOC: Effective: Expiration: Facility Hielh UisMIts Phas- County: Henderson Region: Asheville Contact Person: Robert J Duffy Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): Related Permits: Inspection Date: 05/16/2014 Primary Inspector: Linda S Wiggs Secondary Inspector(s): Title: Certification: Entry Time: 11:00 AM Exit Time: 01:00 PM Phone: 828-243-4000 Phone: Phone: 828-296-4500 Ext.4653 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 Performance Standards Operation & Maint Reqmts Records ■ Monitoring & Rpting ■ Inspections Pump Station Manhole Reqmts Lines �f f, (See attachment summary) �`7 �'�� � ' VVI/Ij ems, UH/cH-11YA,1 Page: 1 Permit: WQCSD0128 Owner -Facility: NC Four C's, LLC Inspection Date: 05/16/2014 Inspection Type: Collection System Inspect Non Sampling Reason for Visit: Routine Inspection Summary: Page: 2 Permit: WQCSDO128 Owner - Facility: NC Four C's, LLC Inspection Date: 05/16/2014 Inspection Type: Collection System Inspect Non Sampling Reason for Visit: Routine Performance Standards f - 6 ,J�r—� Is Public Education Program for grease established and documented? ` /q1 What educational tools are used? CIL Is Sewer Use Ordinance/Legal Authority available? Does it appear that the Sewer Use Ordinance is enforced? Is Grease Trap Ordinance available? r Is Septic Tank Ordinance available (as applicable, i.e. annexation) NA List enforcement actions by permittee, if any, in the last 12 months 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 Is system free of known points of bypass? y 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 Yes No NA NE nnnn n n n n nnnn n n n n nnnn nnnn nnnn n n n n nnnn n n n n nnnn n n n n nnnn n n n n n n n n nnnn n n n n n n n n n n n n Page: 3 Permit: WQCSDO128 Owner - Facility: NC Four C's, LLC Inspection Date: 05/16/2014 Inspection Type: Collection System Inspect Non Sampling Reason for Visit: Routine # Do ALL pump stations have an "auto polling" feature/SCADA? Number of pump stations Number of pump stations that have SCADA Number of pump stations that have simple telemetry Number of pump stations that have only audible and visual alarms Number of pump stations that do not meet permit requirements # Does the permittee have a root control program? # If yes, date implemented? Describe: Comment: Inspections C� 5 ►''^ Are maintenance records for sewer lines available? Are records available that document pump station inspections?/V-A Are SCADA or telemetry equipped pump stations inspected at least once a week? Are non-SCADA/telemetry equipped pump stations inspected every day? IYA Are records available that document citizen complaints? /t/OIV1°-1 # 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? y Are records available that document inspections of high -priority lines? /✓A Has there been visual inspections of high -priority lines in last six months? Comment: C2 Operation & Maintenance Requirements Are all log books available? i Cs2 Does supervisor review all log books on a regular basis? 07 IILI ° 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? IVA What is the schedule for testing emergency/standby equipment? n n n n nnnn Yes No NA NE n n n n n n n n n n n n nnnn n n n n nnnn Yes No NA NE n n n n nnnn n n n n n n n n nnnn Page: 4 Permit: WQCSDO128 Owner - Facility: NC Four C's, LLC Inspection Date: 05/16/2014 Inspection Type: Collection System Inspect Non Sampling Reason for Visit: Routine Do pump station logs include: naidoutside cleaning a d debris removal? �nsp:cting-and ❑ n n n ❑ n n ndeexercising all valves. 'cating n n n n Inspecting and lub pumps and other e ipment? Inspecting alarms, teleme , and auxiliary equipment. ❑ Is there at least one spare pump fore pump station w/o pump reliability? n n n n Are maintenance records for right-of-ways ava�table? n n n n Are right-of-ways currently accessible in the event of an emergency? n n n n Are system cleaning records available? /4/0 n n n n Has at least 10% of system been cleaned annually? /1/0 n n n n What areas are scheduled for cleaning in the next 12 months? Is a Spill Response Action Plan available? n n n n Does the plan include: 24-hour contact numbers n n n n Response time n n n n Equipment list and spare parts inventory n n n n Access to cleaning equipment n n n n Access to construction crews, contractors; and/or engineers n n n n Source of emergency funds n n n In Site sanitation and cleanup materials ❑ n Post-overflow/spill assessment n n n n Is a Spill Response Action Plan available for all personnel? n n n n Is the spare parts inventory adequate? n n n n Comment: i�'tG ' " — LWJYes Records �'�� No NA NE Are adequate records of all SSOs, spills and complaints available? Are records of SSOs that are under the reportable threshold available? n n n n Do spill records indicate repeated overflows (2 or more in 12 months) at same location? n n n In If yes, is there a corrective action plan? n n n n Is a map of the system available? n n n n Page: 5 Permit: WQCSD0128 Owner - Facility: NC Four C's, LLC Inspection Date: 05/16/2014 Inspection Type: Collection System Inspect Non Sampling Reason for Visit: Routine 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? /P14 Comment: Monitoring and Reporting Requirements Are copies of required press releases and distribution lists available? Are public notices and proof of publication available? /'1A # Is an annual report being prepared in accordance with G.S. 143-215.1 C? # Is permittee compliant with all compliance schedules in the permits? If no, which one(s)? Comment: 1- Pump Station Pump station type VA Are pump station logs available? Is it accessible in all weather conditions? # Is general housekeeping acceptable? Are all pumps present? Are all pumps operable? Are wet wells free of excessive debris? Are upstream manholes free of excessive debris/signs of overflow? n n n n n n n n nnnn. n n n n nnnn Yes No NA NE Yes No NA NE nnnn nnnn nnnn nnnn nnnn nnnn n n n n Page: 6 Permit: WQCSD0128 Owner - Facility: NC Four C's, LLC Inspection Date: 05/16/2014 Inspection Type: • Collection System Inspect Non Sampling Reason for Visit: Routine Are floats/controls for pumps/alarms operable? n n n n Is "auto polling" feature/SCADA present? n n n n Is "auto pollin " feature/SCADA operational? n n n n Is simple telemetry present? n n Is simple telemetry'operational? n n n n Are audio and visual alarms present? n n n n Are audio and visual alai,Ts operable? n n n ❑ Is the Pump station inspected as required? n n n n Are backflow, devices in place,? n n n n Are backflow devices operable? n n n n z Are it relief Ives in place? n n o o Are air relief valve operable? ti n n n n # Is an emergency � enerator available? n n n n Can the emergency ge erator run; the pumps? 1� o n n n 1 Is`the pump station equip ed for quick hook-up? n ❑ n n Is the generator operable? n n n n # Is fuel in tank and sufficient? n n n n Is the ge�erator inspected according t, t eir schedule? n n n n Is a 24-ho, r notification sign posted? n n n n Does it i cticlude: Instruons for notification? n n n n Pump station identifier? n n n n Emergency phone number n n n n Is public accessl_limited? n n ❑ n Is pump station free of overflow piping? n n n n Is the pump station free of signs of overflow? n n n n Are run times comparable for multiple pumps? Comment: MAIN - Lines/Right-of-Ways/Aeriel Lines Yes No NA NE Page: 7 Permit: WQCSD0128 Owner - Facility: NC Four C's, LLC / Inspection Date: 05/16/2014 Inspection Type: Collection System Inspect Non Sampling Reason for Visit: Routine Is right-of-way accessible for emergency? n n n n Is right-of-way free of sinkholes or depressions? n n n n ` Is line/right-of-way free of evidence of leakage? n n n n # Are there areas of exposed line? n n n n # Is any exposed line constructed of ductile iron or other approved material? n n n n Are water crossing and supports in good condition? n n n n # Is right-of-way free of non -utility motorized traffic? n n n n Is line free of visible damage? n n n n # Are there siphons in this system? n n If yes, are they maintained and documented? Comment: ��� MH -' !r✓� / / Manhole c-- 'I C_k es No YL NA NE Is manhole accessible? Y � n n n n # Is manhole cover/ventabove grade? 1 d"— 1 n n n n Is the manhole free of visible signs of overflow? j� n n n n Is the manhole free of sinkholes and depressions? / y o o n. n Is manhole cover present?Y n n o o # Is manhole properly seated? 0 �" "� I ,./ �e tee/ M N )'/ SJ` F� l /J 1/�' n n n n # Is manhole in good condition?�64-z- CLL_ n n n n # Is invert in good condition? "��l 4V�� MIAr�—�v '� J n o n n Is line free -flowing and unrestricted in manhole? Y n n n n Is manhole free of excessive amounts of grease?y d�J �v �� n n n n Is manhole free of excessive roots?/v n n n n Is manhole free of excessive sand? y n n n n Is manhole's extended vent screened? /f i n n n n Are vents free of submergence? /U� n n n n Are manholes free of bypass structures or pipes? /v Comment: n n n n Page: 8 Wiggs, Linda From: Wiggs, Linda Sent: Wednesday, May 21, 2014 3:52 PM To: admaint@comporium.net Subject: items needed High Vista . Attachments: WWCS_Operational_Logs_Package 1206.xlsx HI Aubrey, I will wait to write up the inspection reports if you will get me the following items by Friday May 30th please. These items are documentation needed to complete the inspection. WWTP *ORC designation form -this has not been received in Raleigh or Asheville, please resend the form with the ORC and BORC. Send the form to the address in Raleigh, but also send me a copy. *A copy of the Operator Log book entries for the last month; April 215Y thru May 21't. I contacted Vince to get this and he is on vacation. This poses another question; who will be operating that WWTP in his absence? *Flow meter calibration proof; work order. *You stated two week ago Carolina Energy worked on the Generator; please send proof of this work ... you said you should be receiving a bill that will show their visit. CS *Educational material for FOG. *Spill Response Plan *.Revenue collected for the wastewater and monies reinvested back into the system for 2013. For Example: Say if you received $100,000 in -tap fees; that would be the revenue number. And if you had to make repairs to 25 feet of line and/or had three days of laborers and equipment working on the system to clean, video, or smoke the lines; that would be a reinvestment number. Do not include in the reinvestment workers' salaries for the year'or maintenance you did on the WWTP, that is s separate line item and not what 1 am looking for here. The above items can be sent to me electronically by May 30th. The items below will be incorporated into the inspection report and will required a response as well. That response will be 15 days after the date on the inspection report letter will go ahead and provide you a bullet list so you can plan for those items and response. WWTP: *litter on the ground from bar screen *operational issues -I will talk with Vince once he is back to get some clarification on this but it will be mentioned in the report so I will include it here. ** process controls, lack of blanket in clarifier, solids beyond clarifier, composite sampler (aliquot, location, method), Chlorine dosing/tubing, flow recorder etc. *EQ alarm *Flow meter chart, solids in float chamber, calibration *standby generator remedy *paper trail CS: *documentation -O&M, inspections *find Manhole (MH) by clubhouse *fix I&I at MH by road *may need to visit industries regarding their wasteflow/type to WWTP. I have attached the collection system logs for your use. There are colored tabs along the bottom of the spreadsheet that bring you to the different log sheets. There are many, you do not have to use all of these for your system. However, there are several you should seriously consider using as they are laid out for proper documentation requirements and are not difficult to use, i.e. FOG Log, ROW Log, Line, Cleaning, High Priority Insp/Maint. The Line Cleaning log can be modified to document your video and smoke testing, the PS Gen Insp Log can be modified to use at the WWTP for that generator. Give me a call if you have any questions. Thanks, iQ" Linda.Wiggs@ncdenr.gov Environmental Senior Specialist North Carolina Dept. of Environment and Natural Resources Asheville Regional Office Division of Water Resources - Water quality Regional Operations 2090 U.S. 70 Highway Swannanoa, NC 28778 Tel: 828-296-4500 Fax: 828-299-7043 Link to Division of Water Resources Home Page http://Porta I.ncde nr.or/web/wq Notice: E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and therefore may be disclosed to third parties. Wiggs, Linda To: admaint@comporium.net Subject: collection system info Attachments: May2014 WQCSD0128.pdf; WWCS_Operational_Logs_Package 1206.xlsx; WQ0020700.pdf Hi Aubrey, To assist you with the collection system (CS) inspections I have attached the following: *A blank'inspection check list (May 2014 WQCSD0128). You will receive a completed copy of this with the inspection letter. *An excel spreadsheet of collection system logs (WWCS... ). There are colored tabs along the bottom that bring you to many different log sheets; I believe there are 16 in total. *The CS permit for High Vista (WQ0020700). This is actually referred to as a Fast Track Sewer'Extension Permit. With regard to the permit, it is the only one I could find easily. I can put in a request to Raleigh if you would like to look for others, but the older ones may be in Central Files. And they would basically be the same information which is what I wanted you to see. I know Kathy said she gave you the 2T rules related to deemed systems. So that rule and this permit language lets you see the legal citations regulating these systems. With regard to the inspection report and the log sheets, these are designed to be all encompassing, so they cover material for very large systems as well. Since your systems are smaller there may be areas you don't have to concern yourself with. It is not required that you use these log sheets, however, they were created by a DWQ staffer and do cover all the basis with regard to what we look for and expect to be presented to us during an inspection. It is your call whether you don't use them , use them or manipulate them to suit your preference. If nothing else definitely go through them thoroughly so you get a feel for what ,we want to see for documentation requirements. b } Finally, the inspection check list is horribly laid out, it drives me crazy but I cannot change it. So bear with it being all over the place. But go through it too. Once you look at it and the logs sheets you may decide it is easier to use those logs instead of having to pull together work orders etc. I say this because I have found that some folks that use work orders do not have enough detail listed on those work orders to properly document the job done; i.e. a work order might just say cleared right of way (ROW) or cleaned lines. That would not be enough information because it would not tell the inspector where the ROW was performed or which lines and how many feet of lines were cleaned. Anyhow feel free to give me a call with questions, !Q" owo- Linda.Wiggs@ncdenr.gov Environmental Senior Specialist North Carolina Dept. of Environment and Natural Resources Asheville Regional Office Division of Water Resources - Water Quality Regional Operations 2090 U.S. 70'Highway Swannanoa, NC 28778 Tel: 828-296-4500 Fax: 828-299-7.043 Link to Division of Water. Resources Home Page http://Porta1.ncdenr.org/web/wq Betty Roberts 44 La Vista Drive Mills River, NC 28759-2619 A V�TS�TA VJI'L ACrE CQI 1D(L31VI1NIiJ=IvLASSo'Ic 99 La Vista Drive, Mills River, NC 28759 26 September2010 Mr. Audrey Deaver A & D Water Service, Inc. P.O. Box 1407 Pisgah Forest, NC 28788 Dear Mr. Deaver, Our association recently had our lift station professionally inspected. There were several deficiencies and/or defects found. The most notable were: (1) The telephone alarm system was inoperable. In addition to the Telephone line having been cut, AT&T had disconnected service. We are in the process of ascertaining when that occurred. (2) One pump is operating below capacity, the second is not functioning - and is being replaced. (3) The generator has not been servicedtsin�3 2003 and the timer was notl set. W� CST��7e�8 In light of the situation you are advised that we have retained James & James Environmental Management, Inc. To maintain and service our lift station. We have also transferred all the applicable accounts into the name of La Vista Village Condominium Association. CC: N.C. Utilities. Commission, Chief Clerk Bruce -Vaughn, Engineer, Public Staff, Roy Davis, NCDENR, Western Regional Office t! Very truly yours, La Vista Village Condominium Association Betty C. R�rts,x President , E V SE P 2 8 2010 ' 1 WATER QUALITY SECTION jfl,L Dr d\, V 1 7� �,v 1 . ,p CL VIA` U ` 11 W 6021 52L Ld�- 29i-�/3ol 2 �� �,o rry) �7P= 4 VVAT�C Michael F. Easley, Governor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Coleen H. Sullins, Director Division'of Water Quality SURFACE WATER PROTECTION SECTION September 6, 2007 Mr. Duffy NC Four C's, LLC 81 Avondale Cir Arden, NC 28704 SUBJECT: Wastewater Collection System Owner & Operator Requirements High Vista Falls Phase V Wi jCtS, .R,)-@ I 2i Henderson County Dear Mr. Duffy: I would like to take this opportunity to discuss the requirements for sewerage collection systems that were first established in 15 NCAC .02H .0200 in March 2000 and are now found in 15 NCAC 2T .0403, Waste Not Discharged to Surface Waters, which became effective September 1, 2006. These Regulations place significant operation, maintenance and reporting requirements on those entities that own or operate a wastewater collection system with average daily flows of less than 200,000 gallons per day. These regulations are applicable to your facility. This letter is provided as guidance to assist you in complying with the new reporting and operations and maintenance (O&M) requirements and to advise you that you are subject to system review, inspections and possible enforcement, if the system is not in compliance with the regulation. For your convenience and easy reference, a highlight of these requirements and the following guidance are offered (see enclosed). You may find the regulations using the following web site: http://h2o.enr.state.nc.us/peres/Collection%2OSystems/CollectionSystemsHome.html The Asheville Regional Office will be increasing the level of oversight, compliance activities and enforcement relating to collections systems, therefore, we wanted to be sure you are aware of the requirements for these systems. We will be performing NPDES Wastewater Collection System inspections sometime in the near future. NorthCarolina Naturally North Carolina Division of Water Quality 2090 US Hwy 70; Swannanoa, NC 28778 Phone (828) 296-4500 Internet: www..ncwaterquality.org Customer Service 1-877-623-6748 FAX (828) 299-7043 An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper September 6, 2007 Page 2 of 2 If this Office has not previously inspected your wastewater collection system and records of same, you should be prepared to demonstrate compliance with all criteria listed above. Enclosed, is an inspection form that you can use to assemble your records prior to an inspection by the staff of this Office. This Office has a Wastewater Treatment Plant Consultant on staff to offer assistance to you in complying with the requirements of these regulations. Should you have questions or need additional information regarding this issue, please contact Don Price at (828) 296-4500. Should you have any other questions concerning this correspondence or the requirements relating to collection systems, please contact Roy Davis or Keith Haynes at 828- 296-4500. Sincerely, Roger C. Edwards, Supervisor Surface Water Protection Section cc: Deborah Gore - PERCS Unit_- w/out enclosures_ _ ��bwifle-Regional=Office-fac�l'ity-fiPe= w%out enclosures} DWQ - SWPS - Central Office Files - w/out enclosures Jul 12 04 03:23p MR*MRS HARRY JAMES 8286969738 James & James Environmental Management, Inc. PO Box 1354, Mountain Hume, NC 28758 Office: (828) 697-0063 Fax: (828) 697-0065 Recipient.--E�ef Company: Fax Number: ;2C7q - -705�3 Voice Number: c�l 0 Date: q 1 tZ *1 (54 Tltne: 17 2D p m Total No. Pages (includes cover). Subject: q vj�ja Sent By. .) lart-'-4a - Caaus Message: n = M m � <C D m C7 m n m oM a r„ r c7 O —j T O M m p.1 i Jul 12 04 03:23p MR*MRS HARRY JAMES 8.286969738 p.2 5ECEWE AI J U L 12 2004 . 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[tarraaeanittg arrd fr�eaionseuerue�t d atah��torti+��uyre,�tousw�,aenr�s� �,�i t,�CJNr,�r� AM l ��-11111�' 114 —OpAkr,Ouduru, edtetaetanal materialsbetrrg � and, ea Pry lirtttr@sirtlr�lt Odd iPlt;kw" and a oft NOW shotid be aya&d;b Uf7w teg!Lea i Despib� eq aor aVMbb etafkftpmbrarrr? ❑• t*ONPa If Yes ftvk*r: monotboim fyreP*ed,►dratec&mwwataMto9mwthe SSW impact of the Corttmeafs: For DWQ Use t3ri1V: MQ RMOSM an AdMMI VAOM Report: OY"CI NOOKA O NE tfYes. Wh&AddkWW tfrkaration ls'Meedett: Cammanft ram WOUDOW H. zUUj pw Jul 12 04 03a24p MR*MRS HARRY JAMES 8286969738 p.5 W ioe t . t tftat she infamy d in is we accrrate Wthe A Y1C Lo YrLLC} iOWPhOMMUMbe r I�zs - tool `I •ColoE � ��awh�tt�r�be�r seaar�appaopc�ett�+aattv�aa� ss canpam, tcsmetie it c numt�er is antra whin snag a nos forrst r CSSSO FOM QcWbW9. 2W3 Section 8: SSO Enforcement Guidance EXHIBIT B: SSO EVALUATION FACTORS Incident #: a Q Q 1f0 ! � Permittee:"v- Date of Incident: ( ARE ANY OF THESE FACTORS A BASIS FOR PROCEEDING WITH FURTHER ACTION? FACTOR YES NO COMMENTS Volume/Duration Surface Water • Sensitive/High Priority SA / ORW / WS, etc. Damage , • Fish Kill • Property • Public Health Concerns Weather Conditions and other Uncontrollable Factors • Severe Natural Condition (hurricane, tornado, etc.) • Vandalism/Third Party • Other Repetitiveness Same Location (past 24 mo Repetitiveness Same Cause (past 24 mo C.� Preventability • Proper O&M • Storm Preparation System -wide Compliance (past 24 mo) • Similar causes multiple instances • Previous actions like NOVs / Enforcements • Failure to react to Technical Assistance from Division Response to Spill Adequate time & cleanup)t� Proactiveness • Active programs for III, grease, roots, etc. • CIP program CONCLUSION: Does overall evaluation or o Action ❑ Action any one single factor result in the need to Sta this to report NOV SOC Pending proceed with action? File Enforcement Moratorium Close out incident in BIMS No Action Additional Comments: Form completed by Date 7 h (0 Page 9 of 9 10/03 Section 8: SSO Enforcement Guidance EXHIBIT B: SSO EVALUATION FACTORS Incident#: i�t� i7�-j-C� 1+3 Permittee: 1 3 Fcp,� Date of Incident: ARE ANY OF THESE FACTORS A BASIS FOR PROCEEDING WITH FURTHER ACTION? FACTOR YES NO COMMENTS Volume/Duration Surface Water • Sensitive/High Priority SA / ORW / WS, etc. t/ Damage • Fish Kill Cl • Property • Public Health Concerns Weather Conditions and other Uncontrollable Factors / • Severe Natural Condition (hurricane, (O tornado, etc.) • Vandalism/Third Party • Other Repetitiveness Same Location tl (past 24 mo Repetitiveness Same Cause (past 24 mo Preventability • Proper O&M • Storm Preparation System -wide Compliance (past 24 mo) • Similar causes multiple instances • Previous actions like NOVs / Enforcements • Failure to react to Technical Assistance from Division Response to Spill Adequate time & cleanup)C/ Proactiveness • Active programs for 1/I, grease, roots, etc. • CIP program CONCLUSION: Does overall evbluation or lNo Action ❑ Action any one single factor result in the need to Staple this to report NOV SOC Pending proceed with action? File Enforcement Moratorium Close out incident in BIMS No Action Additional Comments: ,. Form completed by �) Date Page 9 of 9 10/03 ■ Co lete items 1, 2, and 3. Also complete A. Sig t e it if Restricted Delivery is desired. X JW ■ P our name and address on the reverse so that we can return the card to you. B. eceived by (rinte ame): ■ Attach this card to the back of the mailpiece, _ or on the front if space permits. North Carolina Department �i�f�ot;,te elry Environment and Natural Resou d S ss ,�fF18 Division of Water Reso s Water Quality Regional Operations, gga�s io 2090 U.S. Highway,70, Swannanoa, NC 287 81 NCD "' NR Aubrey. Lewis Deaver finegist is Type A & D Water Service, Inc. ertrtted Mail® Priorityy Post office Box 1407i�'Led \�'.8etum Ri�+c, Pisgah Forest, NC 28768-1407 ❑ Insured ai �❑ olJec Sn l III didileee1eee1Hen1nr111en1IRestrictedDelivery? tra:V ) ❑ Agent ❑ Addressee Date of Deliver) 1? ❑ Yes ❑ No ❑ Yes 7014 05100000, 4466 0691, MTV-a2t115_ P� o�,�� PS` Fora 3811. Julv20y3 1 1 11 1 Domestic Return Receipt UNITED STATES POSTALSER=E" ,.,.,fI�,,•,,,,,,, •',,,,„,,,. -first-ClassNtail 1.I I I P P stage & Fees 4 G�5 Permit o. G-14 • Serider:• 1dase print your name, addre 8,V- 1 ZIP+4kjn this bob• o � MS. BEVERLY P ICE �:• NCDENR-DWR-WQROS aJ , 2090 U.S. HIGHWAY 70 SWANNANOA NC 28778 ■ Complete items 1, 2, and 3. Also complete A. Signature item 4 if Restricted Delivery is desired. X ■ Print your name and address on the reverse so that we can return the card to you. B. Received by ■ Attach this card to the back of the mailpiece, or_on the f[ont_itspace permits. ,,.y:t--.ram-f' _.._rCir;-• ;..' a;;� ! ' IL� z:-+ _v. .. •ail• ..+� i_ `�d; �q+-��•+--...:r!l.u' Kjq 0 Insured 4. Restricted ❑ Agent Eftddre rted Name) C.. to rix ifferent" item 1 e addre Below: c 10 clu ■ cr) 0 o N a � .0 mail RetmRi erchan,O.D. ar Yes 70' ;11187b Ibob13 10$17N123�'� 1 11 11 111 [ 11 1 1 Sw PS Form 381.1. February 2004 Domestic Return RecelDt' 102595-02-M-154 UNITED STATES POSTAL SERVFiCst-6lass.Mai�l <v �' Posxage _&Fees Paid =gp Pe r—m it rva�rte� • Sender: Please print, `}c u !ref%, add ress,-q-irTfit -ir+ LINDA WIGGS - -- _ NCDENR-DWq-SWP 2090 U.S. HIGHWAY 70 1 SWANNANOA NC 28778 ill. Th-lill,lilli)-+hil ■ Complete items 1, 2, and 3. Also complete A 6 item 4 if Restricted Delivery Is desired.Z ❑ Agent ■ Print your name and address on the reverse X ❑ Addresse( so that we can return the card to you. B, Re road by ( •nted Name) C. Deliver) ■ Attach this card to the back of the mailpiece, or on the front if space permits. _- - -- - - - iffen nt from item 17• ❑ es addreelow: c N 80 Oil Abr vo - se loweTAM ,v CerM del•-'13 E rM m i Regt red , ,��um Rer-i r Merchandise O Insu Mail 4 O.D. C .• Restrict (EXtrd'Fee) A ❑Yes 71310 1100100R$11'267 121322 S� Ps Form 3811, February 2004 Domestic Retum Receipt 102e95-02-Mll5a UNITED STATES POSTALSE L� qi� a PM 28 JAN • Sender: Please prime, add LINDA WIGGS R- NCDENDWq-SWP 2090 U.S. HIGHWAY 70 SWANNANOA NC 28778 iililil9ijlllllilliililiitliiijiiiiilillip!Jim 1111i1filipIli! .ills .