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Home My WebLink AboutWQ0037555_CEI_20210728 SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED July 28, 2021 Julie Babcock, POA Assistant Manager Email: jbabcock@trilliumnc.com Trillium Links & Village LLC SUBJECT: Compliance Inspection Report Trillium Links & Village WWTP Non-discharge Permit No. WQ0037555 Jackson County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Trillium Links & Village WWTP on 6/30/2021. This inspection was conducted to determine what steps have been taken to address the items documented in the facility inspection report from 2017 and compliance with current permit requirements. Please carefully review any deficiencies and comments noted in the summary of the attached inspection report. A start-up inspection will be required before the infiltration basin is placed into service. If you should have any questions, please do not hesitate to contact me at 828-296-4686 or via email at mikal.willmer@ncdenr.gov. Sincerely, Mikal Willmer, Environmental Specialist II Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Report Ec: LF Robert Barr, RPB Systems Freddie Boan, POA Manager DocuSign Envelope ID: 70D8E899-3F4B-4427-8A44-707F91448D51 Compliance Inspection Report Permit:WQ0037555 Effective:07/18/17 Expiration:05/31/21 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: WW3,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: 06/30/2021 09:00AM 11:30AM Mikal Willmer 828-296-4686 Stephanie A Williams Facility Status: Permit Inspection Type: Reason for Inspection:Inspection Type: Not CompliantCompliant Routine High Rate Infiltration Compliance Evaluation Question Areas: Treatment Flow Measurement-Effluent Treatment Flow Measurement-Influent Miscellaneous Questions Treatment Flow Measurement-Water Use Records Treatment Treatment Barscreen Record Keeping Treatment Activated Sludge Treatment Disinfection End Use-Infiltration Treatment Flow Measurement Treatment Return pumps Standby Power (See attachment summary) Page 1 of 6 DocuSign Envelope ID: 70D8E899-3F4B-4427-8A44-707F91448D51 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0037555 06/30/2021 Compliance Evaluation Trillium Links & Village LLC Routine Inspection Summary: Mikal Willmer and Stephanie Williams, with the Asheville Regional Office (ARO), conducted a Compliance Evaluation Inspection of the Trillium WWTP on June 30, 2021. This inspection was conducted to determine if the facility is being operated and maintained in compliance with Permit No. WQ0037555. RPB and Trillium staff were present and assisted in the inspection. The new wastewater treatment plant for Trillium was installed in 2016 due to issues with the previously aging package plant. Since the Membrane Bioreactor (MBR) system was installed, staff have attributed difficulty in running the facility to multiple recurring equipment failures. Almost all the previously installed submersible pumps have been replaced with air-lift pumps due to repeated impeller failure, the original blowers failed and were replaced with blowers from the old package plant, which are a higher cfm than plant design requires. The original piping has been replaced due to structural failure. The membranes have torn multiple times since being placed into service. According to staff, the automated CIP system never worked. Chemicals are manually added when backwashing is required, approximately every three months. Trillium has ordered a new set of MBRs, so one set can be retained as a backup. This will allow staff/operators to immediately install in tact membranes and repair the damaged membranes. Membranes are projected to last 5-7 years by the manufacturer; however, they were replaced approximately 2 years ago and need replacement once again. Staff believe debris not captured at the headworks may be causing the tears to the membranes. The ORC reports there are no issues with the existing influent fine screen; however, additional screening and/or grit removal may be necessary to increase the life expectancy of the membranes. The system is computer controlled through proprietary software and cannot be operated in hand mode. It is recommended Trillium continue seeking solutions to the system software as this could potentially render the plant inoperable. The infiltration basin was never placed into operation because the schedules from the previous permit were not completed and items from the startup inspection had not been resolved. The Division received an engineering certification for the facility on May 11, 2021. Please note, the facility description may need to be modified to accurately reflect the equipment that has been replaced since the initial install. After the most recent inspection, the ARO determined GW-1 forms were never filled out or submitted by the driller. The wells were only drilled to a depth of 20’ and not to a depth where groundwater was encountered. Due to additional information obtained recently, the ARO has requested a schedule be placed in the renewed permit requiring the old wells to be permanently and properly abandoned and new wells be sited and drilled. Details will be forthcoming in the draft permit. A complete Operation and Maintenance (O&M) plan has not been submitted (spill response plan, operational functions, safety measures and maintenance schedules). The O&M plan submitted to Permitting on June 13, 2021 only contained equipment information manuals. A schedule will be placed in the new permit requiring submittal of a complete O&M plan. The infiltration basin has a vegetative cover; however, there are significant amounts of weeds and woody vegetation becoming established within the basin. The basin will need to be reseeded with an appropriate and manageable ground cover that allows for easy inspection and even effluent distribution. The spray heads appeared intact but will need to be exercised for functionality before being placed into service. Page 2 of 6 DocuSign Envelope ID: 70D8E899-3F4B-4427-8A44-707F91448D51 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0037555 06/30/2021 Compliance Evaluation Trillium Links & Village LLC Routine Type Yes No NA NE Single Family Drip Activated Sludge Drip, LR Recycle/Reuse Lagoon Spray, LR Single Family Spray, LR Activated Sludge Spray, HR Reuse (Quality) Activated Sludge Spray, LR Infiltration System Treatment Yes No NA NE Are Treatment facilities consistent with those outlined in the current permit? Do all treatment units appear to be operational? (if no, note below.) The description in permit does not match current equipment. See summary for details.Comment: Treatment Flow Measurement-Influent Yes No NA NE Is flowmeter calibrated annually? Is flowmeter operating properly? Does flowmeter monitor continuously? Does flowmeter record flow? Does flowmeter appear to monitor accurately? Comment: Treatment Flow Measurement-Water Use Records Yes No NA NE Is water use metered? Are the daily average values properly calculated? Comment: Treatment Flow Measurement-Effluent Yes No NA NE Is flowmeter calibrated annually? Is flowmeter operating properly? Does flowmeter monitor continuously? Does flowmeter record flow? Does flowmeter appear to monitor accurately? Comment: Standby Power Yes No NA NE Is automatically activated standby power available? Page 3 of 6 DocuSign Envelope ID: 70D8E899-3F4B-4427-8A44-707F91448D51 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0037555 06/30/2021 Compliance Evaluation Trillium Links & Village LLC Routine Is generator tested weekly by interrupting primary power source? Is generator operable? Does generator have adequate fuel? Comment: Treatment Barscreen Yes No NA NE Is it free of excessive debris? Is disposal of screenings in compliance? Are the bars spaced properly? Is the unit in good condition? Influent fine screen.Comment: Treatment Activated Sludge Yes No NA NE Is the aeration mechanism operable? Is the aeration basin thoroughly mixed? Is the aeration equipment easily accessed? Is Dissolved Oxygen adequate? Are Settleometer results acceptable? Is activated sludge an acceptable color? This is a membrane bioreactor, not a conventional activated sludge facility. SRT is typically higher in this type of system. Comment: Treatment Return pumps Yes No NA NE Are they in place? Are they operational? Comment: Treatment Disinfection Yes No NA NE Is the system working? Do the fecal coliform results indicate proper disinfection? Is there adequate detention time (>=30 minutes)? Is the system properly maintained? If gas, does the cylinder storage appear safe? Is the fan in the chlorine feed room and storage area operable? Is the chlorinator accessible? If tablets, are tablets present? Are the tablets the proper size and type? Is contact chamber free of sludge, solids, and growth? If UV, are extra UV bulbs available? Page 4 of 6 DocuSign Envelope ID: 70D8E899-3F4B-4427-8A44-707F91448D51 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0037555 06/30/2021 Compliance Evaluation Trillium Links & Village LLC Routine If UV, is the UV intensity adequate? # Is it a dual feed system? Does the Stationary Source have more than 2500 lbs of Chlorine (CAS No. 7782-50-5)? If yes, then is there a Risk Management Plan on site? If yes, then what is the EPA twelve digit ID Number? (1000-____-____) If yes, then when was the RMP last updated? Comment: Record Keeping Yes No NA NE Is a copy of current permit available? Are monitoring reports present: NDMR? NDAR? Are flow rates less than of permitted flow? Are flow rates less than of permitted flow? Are application rates adhered to? Is GW monitoring being conducted, if required (GW-59s submitted)? Are all samples analyzed for all required parameters? Are there any 2L GW quality violations? Is GW-59A certification form completed for facility? Is effluent sampled for same parameters as GW? Do effluent concentrations exceed GW standards? Are annual soil reports available? # Are PAN records required? # Did last soil report indicate a need for lime? If so, has it been applied? Are operational logs present? Are lab sheets available for review? Do lab sheets support data reported on NDMR? Do lab sheets support data reported on GW-59s? Are Operational and Maintenance records present? Were Operational and Maintenance records complete? Has permittee been free of public complaints in last 12 months? Is a copy of the SOC readily available? No treatment units bypassed since last inspection? GW-1 Forms were never submitted for the wells. Construction is unknown. Basin has not been placed into use. Comment: End Use-Infiltration Yes No NA NE Page 5 of 6 DocuSign Envelope ID: 70D8E899-3F4B-4427-8A44-707F91448D51 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0037555 06/30/2021 Compliance Evaluation Trillium Links & Village LLC Routine # Is the application High Rate or Low Rate?High Rate Are buffers maintained? Are any supply wells within the CB? Are any supply wells within 250' of the CB? Is municipal water available in the area? Are GW monitoring wells required? Are GW monitoring wells located properly w/ respect to RB and CB? Are GW monitoring wells properly constructed, including screened interval? Is a usable green area maintained? Is the disposal site acceptable? Is the distribution equipment acceptable? Is the disposal site free of ponding? Is the disposal site free of breakout? Are the disposal sites free of solids, algae, etc.? Do the records show that the fields are properly maintained? Are the disposal sites free of vegetation? Do any surface water features appear to be adversely impacted by GW discharge? No chemicals or rototiller used to eliminate vegetation, solids, algae, etc.? Site has a vegetative cover. Since it is grassed, it will need to be maintained without excessive woody vegetiation or weeds. The infilatration basin has not been placed into use. See summary for details. Comment: Page 6 of 6 DocuSign Envelope ID: 70D8E899-3F4B-4427-8A44-707F91448D51