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Home My WebLink AboutNC0059200_CEI NOD2024PC0131_20240801 SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED August 1, 2024 Julie Babcock Trillium Links & Village LLC Email: jbabcock@trilliumnc.com SUBJECT: NOTICE OF DEFICIENCY Tracking Number: NOD-2024-PC-0131 Permit No. NC0059200 Trillium Links & Village WWTP Jackson County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Trillium Links & Village WWTP on July 11, 2024. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in NPDES WW Permit No. NC0059200. A summary of the findings and comments noted during the inspection are provided in the enclosed copy of the inspection report. The Compliance Evaluation 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 _________________________________________________________________________________________________________________________________________________________________________ Flow Measurement – Effluent A calibration verification is not being conducted annually as required by permit. Part II.D.3 NPDES Standard Conditions: “Flow measurement devices shall be calibrated at a minimum of once per year…” _________________________________________________________________________________________________________________________________________________________________________ Docusign Envelope ID: 9BA164C1-3479-4AC9-B659-60EB74D0044C Remedial actions should have already been taken to correct this problem and prevent further occurrences in the future. The Division of Water Resources may pursue enforcement action for this and any additional violations of State law. To prevent further action, carefully review these deficiencies and address the causes of non-compliance to prevent the recurrence of similar situations. If you should have any questions, please do not hesitate to contact Mikal Willmer with the Water Quality Regional Operations Section in the Asheville Regional Office at 828-296-4686. Sincerely, Daniel Boss, Assistant Regional Supervisor Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Report Ec: LF Docusign Envelope ID: 9BA164C1-3479-4AC9-B659-60EB74D0044C EPA United States Environmental Protection Agency Washington, D.C. 20460 Water Compliance Inspection Report Form Approved. OMB No. 2040-0057 Approval expires 8-31-98 Section A: National Data System Coding (i.e., PCS) Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type 1 N 52 NC0059200 24/07/11 C S31112171819 20 21 66 Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ----------------------Reserved------------------- N67707172 73 74 75 80 Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include POTW name and NPDES permit Number) Trillium Links & Village WWTP 298 Fenly Forest Trl Cashiers NC 28717 Entry Time/Date Permit Effective Date Exit Time/Date Permit Expiration Date 10:00AM 24/07/11 23/02/01 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Kenneth Jason Rummel/ORC/828-785-3769/ Robert P Barr/ORC/828-251-1900/ Other Facility Data 11:30PM 24/07/11 27/10/31 Name, Address of Responsible Official/Title/Phone and Fax Number Dewayne Calven Ward,PO Box 2644 Cashiers NC 28717//828-743-5886/8287430687 Contacted No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit Flow Measurement Operations & Maintenance Records/Reports Self-Monitoring Program Sludge Handling Disposal Facility Site Review Effluent/Receiving Waters Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Name(s) and Signature(s) of Inspector(s)Agency/Office/Phone and Fax Numbers Date Melanie Kemp DWR/ARO WQ/ - - / Mikal Willmer DWR/ARO WQ/828-296-4686/ Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date Daniel J Boss DWR/ARO WQ/828-296-4658/ EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page#1 Docusign Envelope ID: 9BA164C1-3479-4AC9-B659-60EB74D0044C 8/1/2024 8/2/2024 8/2/2024 NPDES yr/mo/day 24/07/11 Inspection Type C3111218 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Mikal Willmer and Melanie Kemp, with the Asheville Regional Office, conducted a Compliance Evaluation Inspection of Trillium's Wastewater Treatment Plant on July 11, 2024. This inspection was conducted to determine whether the facility is being operated and maintained in compliance with NPDES Permit #NC0059200. RPB Systems and Trillium staff were present and assisted in the inspection. The following items were noted during inspection: Operational staff indicate they still have limited ability to alter settings beyond what was originally programmed for the WWTP within the SCADA system. Bar Screen: A 2mm fine screen is installed. Brushes were replaced for the first time in 2023. No reported issues or major pass-through debris noted. EQ Basin: A pressure transducer is used to monitor the level in the EQ basin, which is connected to SCADA. Any alarms triggered will call Trillium staff who will contact RPB systems. ORC states he can pull the transducer up and down to determine if it is reading the liquid level accurately. Oxic and Anoxic Basins: The ORC checked the DO and MLSS with field meters at the time of the inspection. DO read 0.72 mg/L and the MLSS was showing approximately 10,000 mg/L. The ORC indicated the MBR literature states the membranes can handle a higher solid content but based on his experience with the facility, there are issues with running the solids at the manufacturer suggested levels. MBRs: Membranes were replaced in November of 2021 and there have been no tears noted to the membranes since they were installed. Staff indicated if there is too much suction detected on the membranes, the pumps will shut down to prevent damage. When the clean alarm sounds, staff will perform a filter wash. The ORC performs a chlorine wash once a quarter and washes with just water monthly. The original clean in place (CIP) system is still inoperable. DWR still recommends staff attempt to fix or alter this system so the ORC does not need to climb to the top of the building to feed cleaning chemicals. Blower Motors: It should be noted the EQ basin and membranes tanks share blower motors, which limits how much the ORC can adjust the power to the motors depending on the season. The old motors are retained onsite as spares in case there are any issues with the motors in operation. Solids: ORC reports Mike’s septic pumps the facility monthly in the peak season. Solids were most recently removed on June 9, 2024. Flow meter: Facility utilizes a mag meter and was previously verifying effluent mag meter flow readings by measuring volume/time and comparing to the mag meter reading. At the time of the inspection, the ORC reported the meter was not being calibrated/verified to be within 10% of true value annually. Please note, per Part II.D.3 of the NPDES Standard Conditions this must be done, at a minimum, annually. Due to the nature and placement of the mag meter, staff can verify the reading is accurate by checking discharge volume/time and, if possible, checking any diagnostics for the meter within the SCADA system set by the manufacturer. Please notify the ARO, once the calibration verification has occurred and the associated percentage error. Should the percentage error exceed 10%, the permittee will need to replace or send off the mag meter for calibration. Trillium should also reach out to the mag meter manufacturer (IFM) to see if they have any recommendations for in-situ calibration verifications. Inline turbidimeter: An inline turbidimeter is installed. The ORC stated he relies on turbidity samples taken as he is unsure of the accuracy of the inline turbidimeter. Please note, if/when the infiltration NC0059200 17 (Cont.) Page#2 Docusign Envelope ID: 9BA164C1-3479-4AC9-B659-60EB74D0044C Permit:NC0059200 Inspection Date:07/11/2024 Owner - Facility: Inspection Type: Trillium Links & Village WWTP Compliance Evaluation basin is placed into service, the inline turbidimeter will need to be calibrated annually per permit #WQ0037555 since continuous readings are required. Generator: Onsite generator tests underload daily at approximately 1330. Blossman gas refills the propane tank onsite and Trillium maintains a contract with a local company to service all the generators. The propane tank was reading 80% full at the time of the inspection. Outfall- Trillium staff maintain the path to the outfall near well #7. Recommend the outfall location be marked for future facility staff to easily locate. US/DS: ORC reports no issues accessing the sampling location 100’ upstream and of the outfall and at the mouth of the UT to Thorpe Lake. Noted Deficiencies: Flow Measurement: A calibration verification is not being conducted annually as required by permit. Part II.D.3 NPDES Standard Conditions: “Flow measurement devices shall be calibrated at a minimum of once per year…” Page#3 Docusign Envelope ID: 9BA164C1-3479-4AC9-B659-60EB74D0044C Permit:NC0059200 Inspection Date:07/11/2024 Owner - Facility: Inspection Type: Trillium Links & Village WWTP Compliance Evaluation Record Keeping Yes No NA NE Are records kept and maintained as required by the permit? Is all required information readily available, complete and current? Are all records maintained for 3 years (lab. reg. required 5 years)? Are analytical results consistent with data reported on DMRs? Is the chain-of-custody complete? Dates, times and location of sampling Name of individual performing the sampling Results of analysis and calibration Dates of analysis Name of person performing analyses Transported COCs Are DMRs complete: do they include all permit parameters? Has the facility submitted its annual compliance report to users and DWQ? (If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift? Is the ORC visitation log available and current? Is the ORC certified at grade equal to or higher than the facility classification? Is the backup operator certified at one grade less or greater than the facility classification? Is a copy of the current NPDES permit available on site? Facility has copy of previous year's Annual Report on file for review? Facility flows range from 15,000 to 40,000 during the peak season.Comment: Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge Judge, and other that are applicable? ORC checks solids, ammonia and DO as needed.Comment: Permit Yes No NA NE (If the present permit expires in 6 months or less). Has the permittee submitted a new application? Is the facility as described in the permit? # Are there any special conditions for the permit? Page#4 Docusign Envelope ID: 9BA164C1-3479-4AC9-B659-60EB74D0044C Permit:NC0059200 Inspection Date:07/11/2024 Owner - Facility: Inspection Type: Trillium Links & Village WWTP Compliance Evaluation Permit Yes No NA NE Is access to the plant site restricted to the general public? Is the inspector granted access to all areas for inspection? Trillium should verify components are accurate during next permit renewal. Permit mentions 12 MBRs; however, this was originally for the complete build out. Comment: Bar Screens Yes No NA NE Type of bar screen a.Manual b.Mechanical Are the bars adequately screening debris? Is the screen free of excessive debris? Is disposal of screening in compliance? Is the unit in good condition? Fine screen at headworks. See summary for details.Comment: Equalization Basins Yes No NA NE Is the basin aerated? Is the basin free of bypass lines or structures to the natural environment? Is the basin free of excessive grease? Are all pumps present? Are all pumps operable? Are float controls operable? Are audible and visual alarms operable? # Is basin size/volume adequate? EQ basins are interconnected. See summary for details.Comment: Aerobic Digester Yes No NA NE Is the capacity adequate? Is the mixing adequate? Is the site free of excessive foaming in the tank? # Is the odor acceptable? # Is tankage available for properly waste sludge? Comment: Page#5 Docusign Envelope ID: 9BA164C1-3479-4AC9-B659-60EB74D0044C Permit:NC0059200 Inspection Date:07/11/2024 Owner - Facility: Inspection Type: Trillium Links & Village WWTP Compliance Evaluation Disinfection - UV Yes No NA NE Are extra UV bulbs available on site? Are UV bulbs clean? Is UV intensity adequate? Is transmittance at or above designed level? Is there a backup system on site? Is effluent clear and free of solids? Two UV banks in control room. See summary for details.Comment: Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? Is flow meter calibrated annually? Is the flow meter operational? (If units are separated) Does the chart recorder match the flow meter? Mag meter has not been calibrated annually. See summary for details.Comment: Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? Are the receiving water free of foam other than trace amounts and other debris? If effluent (diffuser pipes are required) are they operating properly? Path to the effluent pipe is maintained by Trillium staff. See summary for details.Comment: Effluent Sampling Yes No NA NE Is composite sampling flow proportional? Is sample collected below all treatment units? Is proper volume collected? Is the tubing clean? # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type representative)? Comment: Upstream / Downstream Sampling Yes No NA NE Page#6 Docusign Envelope ID: 9BA164C1-3479-4AC9-B659-60EB74D0044C Permit:NC0059200 Inspection Date:07/11/2024 Owner - Facility: Inspection Type: Trillium Links & Village WWTP Compliance Evaluation Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? Comment: Standby Power Yes No NA NE Is automatically activated standby power available? Is the generator tested by interrupting primary power source? Is the generator tested under load? Was generator tested & operational during the inspection? Do the generator(s) have adequate capacity to operate the entire wastewater site? Is there an emergency agreement with a fuel vendor for extended run on back-up power? Is the generator fuel level monitored? See summary for details.Comment: Page#7 Docusign Envelope ID: 9BA164C1-3479-4AC9-B659-60EB74D0044C