WQCSD0455_NOD2024PC0035 & CEI Report_20240306

SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED.

March 6, 2024

Brian Dorry, Director of Operations
IPM Management
Email: [e-mail]

SUBJECT: NOTICE OF DEFICIENCY
Tracking Number: NOD-2024-PC-0035
Permit No. WQCSD0455
Cedar Hill WWTP
Jackson County

Dear Permittee:

The North Carolina Division of Water Resources conducted an inspection of the Cedar Hill Collection System on
February 29, 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. WQCSD0455. 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 _________________________________________________________________________________________________________________________________________________________________________ Spills and Response Action Plan A Spill Response and Action Plan is required to be made available to all staff.
_________________________________________________________________________________________________________________________________________________________________________
Pump Stations Pump stations are required to have 24-hour notification signs posted with the following
information: owner name, pump station identifier, address, instructions for notification, and
24-hour contact numbers. _________________________________________________________________________________________________________________________________________________________________________
Pump Stations Pump stations that do not have operable telemetry service are required to be visited every
day until telemetry service is restored at each pump station. _________________________________________________________________________________________________________________________________________________________________________
DocuSign Envelope ID: 90079035-F428-4BA4-B088-358166A8BD87

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 Daniel Boss with the Water Quality
Regional Operations Section in the Asheville Regional Office at 828-296-4500.

Sincerely,

Daniel Boss, Assistant Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ

ATTACHMENTS: Inspection Report

Ec: Laserfiche
DocuSign Envelope ID: 90079035-F428-4BA4-B088-358166A8BD87
Compliance Inspection Report
Permit:WQCSD0455 Effective:07/29/09 Expiration:Owner :Cedar Hill Property Owners Association Inc
SOC:
Contact Person:
Region:
County:
Directions to Facility:
Jackson
Asheville
Jerry Honea
Effective:Expiration:Facility:Cedar Hill WWTP
1820 US Hwy 64
Cashiers NC 28717
Title:Phone:[phone]
The entrance to Cedar Hill is on the left approximately 1000' past Cedar Creek Rd. Once you enter the development, take the first
road on your left. The entrance to the WWTP is 330' down the road. Please note a gate code may be needed to access this site
Secondary ORC(s):
Phone:Certification:Primary ORC:
System Classifications:
On-Site Representative(s):
Related Permits:
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
02/29/2024 11:00AM 12:00PM
Mara G Chamlee 828-296-4500
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 Pump Stations
(See attachment summary)
Page 1 of 5
DocuSign Envelope ID: 90079035-F428-4BA4-B088-358166A8BD87
3/6/2024
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCSD0455
02/29/2024 Collection System Inspect Non Sampling
Cedar Hill Property Owners Association Inc
Routine
Inspection Summary:
Mara Chamlee, with the Asheville Regional Office, conducted a Compliance Evaluation Inspection of the Cedar Hill Property
Owners Association deemed-permitted collection system on February 29, 2024. The inspection was conducted to determine
whether the system is being operated and maintained in compliance with deemed-permitted collection system permit
number WQCSD0455. Mr. Jeffrey Moore (Collection System Operator, RPB Systems), Mr. Kenneth Rummel (WWTP ORC,
RPB Systems), and Mr. Bob Barr (Owner, RPB Systems) were present and assisted with the inspection.
RPB Systems maintains the collection system which includes 3 pump stations and no manholes.
The following items were noted during the inspection:
1) Pump Stations: Each of the three pump stations were inspected. At the time of the inspection, pump #2 was down at
Pump Station #1 and pump #1 was down at Pump Station #2. Mr. Moore noted that new replacement pumps for each of
these inoperable pumps have been ordered. The pump station control panels and wet wells did contain locks but they were
not fenced in. The pump stations did not have 24-hour notification signs posted. These signs should be added and need to
include: owner name, pump station identifier, address, instructions for notification, and 24-hour notification numbers.
Telemetry: Telemetry is available at each pump station; however it was not in service at these stations. It is required to visit
pump stations daily where telemetry is not operable.
2) Spill Response and Action Plan: Mr. Barr indicated that they did not have a formal Spill Response Action Plan created.
He did note, however, that they do have accessible lists of 24-hour contact numbers, equipment list and spare parts
inventory, access to construction crews/contractors, and site sanitation and cleanup materials. It is required that this
information be compiled into a Spill Response Action Plan that is available for all staff members.
The following deficiencies were noted during the inspection:
1) 15A NCAC 02T .0403 (4) states that: "Pump stations that are not connected to a telemetry system shall be inspected by
the permittee or its representative every day, 365 days per year, unless the permittee demonstrates that daily inspections
are not necessary because the pump station has sufficient storage capacity, above the elevation at which the pump
activates, to justify a longer inspection interval. In no case shall the inspection interval exceed seven days. Pump stations
that are connected to a telemetry system shall be inspected once per week."
The telemetry service was not available at the pump stations and at the time of the inspection, pump stations were being
visited twice per week. It is required that pump stations be visited daily until telemetry service is restored to the pump
stations.
2) The pump stations did not have 24-hour notification signs. The pump stations should include 24-hour notification signs
with the required information as follows: owner name, pump station identifier, address, instructions for notification, and
24-hour contact numbers.
3) A Spill Response and Action Plan is required to be made available to all staff members.
Page 2 of 5
DocuSign Envelope ID: 90079035-F428-4BA4-B088-358166A8BD87
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCSD0455
02/29/2024 Collection System Inspect Non Sampling
Cedar Hill Property Owners Association Inc
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?
The collection system services approximately 20-30 houses in a subdivision.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.)
Grease education materials are distributed bi-annually in the form of a flyer through the POA.
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?
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 3 of 5
DocuSign Envelope ID: 90079035-F428-4BA4-B088-358166A8BD87
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCSD0455
02/29/2024 Collection System Inspect Non Sampling
Cedar Hill Property Owners Association Inc
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
Mr. Barr indicated that they did not have a formal Spill Response and Action Plan created. He
did note, however, that they do have accessible lists of 24-hour contact numbers, equipment
list and spare parts inventory, access to construction crews/contractors, and site sanitation and
cleanup materials. See summary for details.
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?
The system does not have any HPL lines or locations. The annual inspection is documented
properly in the operator's log.
Comment:
Pump Stations Yes No NA NE
Please list the Pump Stations Inspected:
There are three pump stations in this system. Pump stations inspected included stations #1, #2, and #3 -
each are labeled on the panel box.
# Number of duplex or larger pump stations in system 3
# 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?3
For pump stations inspected:
Are they secure with restricted access?
Page 4 of 5
DocuSign Envelope ID: 90079035-F428-4BA4-B088-358166A8BD87
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCSD0455
02/29/2024 Collection System Inspect Non Sampling
Cedar Hill Property Owners Association Inc
Routine
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?
# 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?
# 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?
The pump station logs include visitation and includes above listed activities performed. It
documents any issues and maintenance performed or needed. Telemetry is connected at each
pump station, however at the time of the inspection it was not functional. The pump stations
were not fenced in, but the wet wells and control panels did contain locks. There were no signs
at each pump station. See summary for details.
Comment:
Page 5 of 5
DocuSign Envelope ID: 90079035-F428-4BA4-B088-358166A8BD87