WQCSD0459_NOV2024PC0191 & CEI Report_20240319

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

March 19, 2024

Danny Parr, III, Director of Facilities
Wildcat Community Services Inc.
Email: [e-mail]

SUBJECT: NOTICE OF VIOLATION
Tracking Number: NOV-2024-PC-0191
Permit No. WQCSD0459
Wildcat Cliffs WWTP
Macon County

Dear Permittee:

The North Carolina Division of Water Resources conducted an inspection of the Wildcat Cliffs WWTP on March
12, 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. WQCSD0459. 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 violations were noted during the inspection:

Inspection Area Description of Violation _________________________________________________________________________________________________________________________________________________________________________
Inspections The pump stations are currently inspected annually. All pump stations wit hout telemetry
need to be inspected daily, and ones with telemetry need to be inspected weekly per the
deemed-permitted collection system rule 15A NCAC 02T .0403 (a)(4). _________________________________________________________________________________________________________________________________________________________________________
Pump Stations The pump stations are not secure with restricted access, and there are no 24-hour
notification signs. Pump stations have not been inspected the required amount, and
pump station logs have not been kept. The high level audible/visual alarms were not
working at the Clubhouse PS; the high level audible/visual alarms could not be tested at
the Birch PS; and the visual alarms did not work at Woodland Cottages PS #1 and #2. _________________________________________________________________________________________________________________________________________________________________________
DocuSign Envelope ID: 8A3210C4-67CF-4553-90FD-E4C70E7B5567

In addition, the issues below must also be addressed:

Compliance Issue:

1. Manholes: No manholes could be located during the inspection. The manholes need to be located
and pictures of the inside of them should be emailed to Ms. Armeni.

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, please respond in writing to this office within 30 days upon your receipt of this Notice
of Violation regarding your plans or measures to be taken to address the indicated violations and other identified
issues, if applicable.

If you should have any questions, please do not hesitate to contact Lauren Armeni with the Water Quality
Regional Operations Section in the Asheville Regional Office at 828-296-4667.

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: 8A3210C4-67CF-4553-90FD-E4C70E7B5567
Compliance Inspection Report
Permit:WQCSD0459 Effective:06/30/09 Expiration:Owner :Wildcat Community Services Inc
SOC:
Contact Person:
Region:
County:
Directions to Facility:
Macon
Asheville
John Impagliatelli
Effective:Expiration:Facility:Wildcat Cliffs WWTP
Birchwood Dr
Highlands NC 28741
Title:Phone:[phone]
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:
03/12/2024 11:15AM 12:30PM
Lauren E Armeni 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 Manholes
Pump Stations
(See attachment summary)
Page 1 of 7
DocuSign Envelope ID: 8A3210C4-67CF-4553-90FD-E4C70E7B5567
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCSD0459
03/12/2024 Collection System Inspect Non Sampling
Wildcat Community Services Inc
Routine
Inspection Summary:
Lauren Armeni, with the Asheville Regional Office (ARO), conducted a Compliance Evaluation Inspection of Wildcat Cliffs
deemed-permitted collection system on March 12, 2024. The inspection was conducted to determine whether the system is
being operated and maintained in compliance with deemed-permitted Collection System Permit no. WQCSD0459. Danny
Parr (Director of Facilities) and Tyler Easterly (ORC, Environmental Inc.) were present and assisted in the inspection.
The collection system consists of 113 homes with individually owned and operated grinder pumps. The deemed-permitted
collection system rules have been attached for reference.
The following items were noted during the inspection:
1. General: The map reviewed during the inspection was from 1995. It is recommended to update the map and include pipe
sizes & materials and pump station locations. Flow direction and pipe ages could also be included.
2. Spill and Response Action Plan: At the time of the inspection, there was no Spill and Response Action Plan. It is
recommended to create a spill response plan in case of a sanitary sewer overflow.
3. Inspections: Mr. Parr indicated that the four pump stations are being inspected annually. Per the deemed-permitted
collection system rule 15A NCAC 02T .0403 (a)(4), pump stations with telemetry should be inspected weekly and pump
stations without telemetry should be inspected daily.
4. Manholes: No manholes could be located during the inspection. The lines are primarily force mains; however, there are
some gravity lines around the clubhouse, going towards the WWTP. These manholes should be located and pictures of the
inside should be emailed to Ms. Armeni.
5. Pump Stations: All pump stations are not secure with restricted access. The wet wells and control panels all need to
have locks, and each pump station must have a sign that includes everything in the "Pump Station" section below.
Additionally, pump station logs have not been kept. A log book should be kept for each PS. There is no pump station
Operation & Maintenance Plan that includes pump station inspection frequency, preventative maintenance schedule, and a
spare parts inventory. This Operation & Maintenance plan could be included in the Spill and Response Action Plan.
-Clubhouse: Mr. Parr indicated that they will be completely redoing this PS, including installing a new lid, two new pumps,
and a control panel. Currently only one of the pump works. During the inspection, the high level float alarms were not
working. Mr. Parr said that this will also be replaced with the upgrades. They are hoping to get the upgrades done soon, and
Environmental Inc. is set to do them. During these upgrades, the SCADA system will also be repaired. This PS should be
inspected daily; however, when the SCADA is fixed, only weekly inspections will be required.
-Birch: This PS does not use high level floats - the pumps run off of pressure. During the inspection, the high level
visual/audible alarms could not be tested. Please send a video of the audible/visual alarms working to Ms. Armeni. Root
intrusion was visible in the wet well at this PS. The roots should be removed and any cracks in the wet well should be
sealed. This PS does not have working telemetry and should be inspected daily.
-Woodland Cottages #1: This PS had excess grease in the wet well and wastewater in the wet well was stagnant from no
one occupying the homes all winter. The grease should be removed from the wet well before the residences return for the
season. The high level audible alarm worked during the inspection, but the visual did not. This PS does not have working
telemetry and should be inspected daily.
-Woodland Cottages #2: The high level audible alarm worked during the inspection, but the visual did not. This PS does not
have working telemetry and should be inspected daily.
Page 2 of 7
DocuSign Envelope ID: 8A3210C4-67CF-4553-90FD-E4C70E7B5567
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCSD0459
03/12/2024 Collection System Inspect Non Sampling
Wildcat Community Services Inc
Routine
The following violations were noted during the inspection:
1. Inspections: The pump stations are currently inspected annually. All pump stations without telemetry need to be
inspected daily, and ones with telemetry need to be inspected weekly per the deemed-permitted collection system rule 15A
NCAC 02T .0403 (a)(4).
2. Pump Stations: The pump stations are not secure with restricted access, and there are no 24-hour notification signs.
Pump stations have not been inspected the required amount, and pump station logs have not been kept. The high level
audible/visual alarms were not working at the Clubhouse PS; the high level audible/visual alarms could not be tested at the
Birch PS; and the visual alarms did not work at Woodland Cottages PS #1 and #2.
The following compliances issues were noted during the inspection:
1. Manholes: No manholes could be located during the inspection. The manholes need to be located and pictures of the
inside of them should be emailed to Ms. Armeni.
Page 3 of 7
DocuSign Envelope ID: 8A3210C4-67CF-4553-90FD-E4C70E7B5567
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCSD0459
03/12/2024 Collection System Inspect Non Sampling
Wildcat Community Services 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 provided map was from 1995 and only had the pipe locations. See summary for details.Comment:
Grease Control Yes No NA NE
Is grease/sewer education program documented with req'd customer distribution?
# Are other types of education tools used like websites, booths, special meetings, etc?
If Yes, what are they? (This can reduce mailing to annual.)
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?
FOG materials are put out in the monthly publication to customers.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?
Is a Spill Response Action Plan available for all personnel?
Page 4 of 7
DocuSign Envelope ID: 8A3210C4-67CF-4553-90FD-E4C70E7B5567
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCSD0459
03/12/2024 Collection System Inspect Non Sampling
Wildcat Community Services Inc
Routine
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
At the time of the inspection, a Spill and Response Action Plan was not provided. 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?
Mr. Parr indicated that pump stations are being inspected annually. See summary for details.Comment:
Manholes Yes No NA NE
Please list the Manholes Inspected:
N/A
Are manholes accessible?
# Are manhole covers/vents above grade?
Are manholes free of visible signs of overflow?
Are manholes free of sinkholes and depressions?
Are manhole covers present?
# Are manholes properly seated?
# Are manholes in good condition?
# Are inverts in good condition?
Is flow unrestricted in manholes?
Are manholes free of excessive amounts of grease?
Are manholes free of excessive roots?
Are manholes free of excessive sand?
Are manhole vents screened?
Page 5 of 7
DocuSign Envelope ID: 8A3210C4-67CF-4553-90FD-E4C70E7B5567
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCSD0459
03/12/2024 Collection System Inspect Non Sampling
Wildcat Community Services Inc
Routine
Are vents free of submergence?
Are manholes free of bypass structures or pipes?
Manholes could not be located during the inspection. See summary for details.Comment:
Pump Stations Yes No NA NE
Please list the Pump Stations Inspected:
1. Clubhouse
2. Birch
3. Woodland Cottages #1
4. Woodland Cottages #2
# Number of duplex or larger pump stations in system 4
# 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?1
# A simple one-way telemetry/communication system (auto-dialer) installed?
For pump stations inspected:
Are they secure with restricted access?
Were they free of by-pass structures/pipes?
Were wet wells free of excessive grease/debris?
# Do they all have telemetry installed?
Is the telemetry system functional?
Is a 24-hour notification sign posted ?
Does the sign include:
Owner Name?
Pump station identifier?
# Address?
Instructions for notification?
24-hour emergency contact numbers?
Are audio and visual alarms present?
Are audio and visual alarms operable?
# 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?
Page 6 of 7
DocuSign Envelope ID: 8A3210C4-67CF-4553-90FD-E4C70E7B5567
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQCSD0459
03/12/2024 Collection System Inspect Non Sampling
Wildcat Community Services Inc
Routine
# 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?
At the time of the inspection, pump station logs were not being kept and there was no pump
station operation and maintenance plan. See summary for details.
Comment:
Page 7 of 7
DocuSign Envelope ID: 8A3210C4-67CF-4553-90FD-E4C70E7B5567