HomeMy WebLinkAboutWQCSD0646_Compliance Evaluation Inspection_20180829 ROY COOPER
Governor
MICHAEL S. REGAN
- - Secretary
LINDA CULPEPPER
Interim Director
August 29, 2018 RECEIVED/DENR/DWR
Matthew Raynor SEP 0 4 2018
Nature Trails Association CLP
524 Meadow Avenue Loop Water Resources
Banner Elk,NC 28604 Permitting Section
Subject: Compliance Evaluation Inspection
Nature Trails Collection System
Deemed Collection System Permit WQCSD0646
Chatham County
Dear Mr. Raynor:
On August 23, 2018, Vanessa Manuel from the Raleigh Regional Office conducted an inspection of the Nature
Trails wastewater collection system to evaluate compliance with North Carolina Administrative Code Section
15A NCAC 02T .0403 (Permitting by Regulation). Your cooperation and assistance during the inspection were
greatly appreciated.
The subject wastewater collection system was identified as a deemed collection system effective March 15,
2016, and consists of approximately 215 homes or service taps, approximately 30 manholes, and 1 high priority
sewer line. The average daily flow of the collection system is 28,000 GPD. The collection system consists of
gravity sewer lines and no force mains or lift stations. Please update this office with the number of miles of
gravity sewer line within the collection system.
The items below show what conditions were noted during the inspection:
1. Sewer Collection System Map.Nature Trails Association CLP, hereinafter referred to as Nature Trails,
has developed a comprehensive map of its sewer collection system. The map includes pipe size,pipe
location, flow direction, and manholes. Please ensure the map is actively maintained and updated.
2. Operatio and Maintenance Plan.Nature Trails is required to develop and implement an operation
and maintenance plan that includes a preventative maintenance schedule, spare parts inventory, and an
overflow response plan. During the inspection, you stated Nature Trails does not have a written
Operation and Maintenance Plan. Within 45-days of receiving this letter,please develop and submit to
this office Nature Trails'written Operation and Maintenance Plan for the subject sewer collection
system.
3. Inspection of High Priority Sewer Lines.Nature Trails is required to inspect all high priority sewer
lines at least once every six-months. Within 45-days of receiving this letter,please provide this office
with a list of all high priority sewer lines, and their locations, within the subject collection system and
ensure the high priority lines are inspected and documented as required.
4. Reported Saitary Sewer Overflows. During the 2-year period ending July 31, 2018, there were no
reported SSOs from the subject collection system.
State of North Carolina I Environmental Quality I Water Resources I Raleigh Regional Office
1628 Mad service Center I Raleigh,North Carolina 27699-1628
919 791-4200
Nature Trails MHP Collection System,WQCSD0646
August 29, 2018
5. Grease Control Program.Nature Trails is required to develop and implement an educational fats, oils
and grease program that includes at least bi-annual distribution of educational material targeted at
residential users. During the inspection, you provided documentation showing an annual notice on
grease control was sent to residential users on November 8, 2017. Please update your grease control
program to meet the bi-annual distribution requirement of the regulation.
6. Right-of-ways and Easements. Please continue to ensure rights-of-way and easements are maintained
in the full easement width for personnel and equipment accessibility surrounding the sewer collection
system.
7. Documentatio . As required by 15A NCAC 02T .0403(a)(10),Nature Trails is required to maintain all
documentation associated with the sewer collection system for a minimum of three years except for the
sewer collection system map, which shall be maintained for the life of the system. Please ensure all
documentation is maintained as required.
The sewer collection system shall be 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.
Within 45-days of receiving this letter, please provide this office with a response to items 2 and 3 above.
If you have questions or comments about this inspection or the requirements to take corrective action if
applicable,please contact Vanessa Manuel at 919-791-4255.
Sincerely, ,
1`
S. Daniel Smith, Supervisor
Water Quality Regional Supervisor
Raleigh Regional Office
Attachment(s): Collection System Inspection Report
Cc: RRO/SWP Files
PERCS Unit
Central Files
Compliance Inspection Report
Permit: WQCSD0646 Effective: 03/15/16 Expiration. Owner: Nature Trails Association CLP
SOC: Effective: Expiration. Facility• Nature Trails MHP
County: Chatham 326 Nature Trl
Region• Raleigh
Chapel Hill NC 27517
Contact Person: Matthew E Raynor Title Phone: 949=965=55739"
Directions to Facility: 919- 240- .hrf331 6N-0
,BZe- 433- 5o2�3 (o)
System Classifications•
Primary ORC. Certification. Phone
Secondary ORC(s):
On-Site Representative(s) �✓�0. �J j'• 12.6,.1d�(o/?�
Related Permits:
NC0043257 Nature Trails Association CLP-Nature Trails Mobile Home Park WWTP
Inspection Date. 08/23/2018 Entry Time• 10 50AM Exit Time 12.00PM
Primary Inspector: Vanessa E Manuel �F—_ Phone -91-8-807-034a2
Secondary Inspector(s): 6?//- 19/-</Z S^�
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
j Records 12 Monitoring&Rpting Reqmts Inspections
Eni Lines
(See attachment summary)
Page 1
Permit. WOCSD0646 Owner-Facility Nature Trails Association CLP
Inspection Date: 08/23/2018 Inspection Type•Collection System Inspect Non Sampling Reason for Visit. Routine
Inspection Summary
See attached Inspection report.
•
Page 2
Permit: WQCSD0646 Owner-Facility.Nature Trails Association CLP
Inspection Date• 08/23/2018 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? ❑ El El
What educational tools are used?
Grease control notice included in billing annually. Regulation requires at least bi-annual distribution of
grease education materials
Is Sewer Use Ordinance/Legal Authority available? ❑ El 0
Does it appear that the Sewer Use Ordinance is enforced'? 0 0 ❑
Is Grease Trap Ordinance available'? El ❑ ❑
Is Septic Tank Ordinance available(as applicable,i e annexation) ❑ El El
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 plant"concepts'? 0 0 El 0
Does CIP cover three to five year period? El ❑ 0 ❑
Does CIP include Goal Statement'? ❑ 0 El ❑
Does CIP include description of project area'? 0 0 0 ❑
Does CIP include description of existing facilities? 0 0 ❑ ❑
•
Does CIP include known deficiencies'? ❑ 0 0 Cl
Does CIP include forecasted future needs'? 0000
Is CIP designated only for wastewater collection and treatment? ❑ ❑ ❑ El
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'? 0 ❑ 0
If no,describe type of bypass and location
Is a 24-hour notification sign posted at ALL pump stations? El ❑ ❑
#Does the sign include
Instructions for notification'? ❑ 0 El ❑
Pump station identifier? 0 ❑ ❑ ❑
24-hour contact numbers El ❑ 0 0
If no,list deficient pump stations
#Do ALL pump stations have an"auto polling"feature/SCADA? 01=1E10
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
Page 3
Permit WQCSD0646 Owner-Facility.Nature Trails Association CLP
Inspection Date. 08/23/2018 Inspection Type.Collection System Inspect Non Sampling Reason for Visit: Routine
#Does the permittee have a root control program? ❑ El ❑
#If yes,date implemented?
Describe
Comment.
Inspections Yes No NA NE
Are maintenance records for sewer lines available? El ❑ 0 El
Are records available that document pump station inspections? ❑ El ❑
Are SCADA or telemetry equipped pump stations inspected at least once a week? ❑ ❑ 0
Are non-SCADA/telemetry equipped pump stations inspected every day? ❑ ❑ 'a El
Are records available that document citizen complaints? ❑ El ❑
#Do you have a system to conduct an annual observation of entire system? ❑ ❑ 0
#Has there been an observation of remote areas in the last year? El ❑ 0
Are records available that document inspections of high-priority lines? ❑ 0 0 0
Has there been visual inspections of high-priority lines in last six months'? ❑ El El
Comment
Operation&Maintenance Requirements Yes No NA NE
Are all log books available'? ❑ ❑ ❑
Does supervisor review all log books on a regular basis'? ❑ El El ❑
Does the supervisor have plans to address documented short-term problem areas'? ❑ ❑ El ❑
What is the schedule for reviewing inspection,maintenance,&operations logs and problem areas'?
Are maintenance records for equipment available'? ❑ 0 12 ❑
Is a schedule maintained for testing emergency/standby equipment'? 0 El El ❑
What is the schedule for testing emergency/standby equipment?
Do pump station logs include
Inside and outside cleaning and debris removal? ❑ ❑ a ❑
Inspecting and exercising all valves'? ❑ ❑ El ❑
Inspecting and lubricating pumps and other equipment'? El ❑ Ffl El
Inspecting alarms,telemetry and auxiliary equipment? ❑ ❑ E El
Is there at least one spare pump for each pump station w/o pump reliability'? ❑ ❑ iN ❑
Are maintenance records for right-of-ways available'? ❑ M ❑ ❑
Are right-of-ways currently accessible in the event of an emergency'? Et3 El 0 El
Are system cleaning records available'? ❑ ❑ E ❑
Has at least 10%of system been cleaned annually'? ❑ ❑ 11 ❑
What areas are scheduled for cleaning in the next 12 months'?
Is a Spill Response Action Plan available'? El El ❑
Does the plan include
Page. 4
Permit WOCSD0646 Owner-Facility.Nature Trails Association CLP
Inspection Date 08/23/2018 Inspection Type Collection System Inspect Non Sampling Reason for Visit. Routine
24-hour contact numbers 0 ❑ ❑ 0
Response time ❑ ❑ ❑ ❑
Equipment list and spare parts inventory 0000
Access to cleaning equipment 0000
Access to construction crews,contractors,and/or engineers 0000
Source of emergency funds 0000
Site sanitation and cleanup materials 0000
Post-overflow/spill assessment 100010
Is a Spill Response Action Plan available for all personnel? 0000
Is the spare parts inventory adequate? 0000
Comment The permittee needs to document record-keepinq activities
Records
Yes No NA NE
Are adequate records of all SSOs,spills and complaints available? ❑ ❑ 0
Are records of SSOs that are under the reportable threshold available? ❑ ❑ ® ❑
Do spill records indicate repeated overflows(2 or more in 12 months)at same location? ❑ ❑ J ❑
If yes,is there a corrective action plan? 0000
Is a map of the system available? 000
Does the map include
Pipe sizes ® ❑ ❑ ❑
Pipe materials 01 ❑ ❑ ❑
Pipe location ❑ ❑ ❑
Flow direction 10 ❑ ❑ ❑
Approximate pipe age ❑ ❑ ❑
Number of service taps ❑ ❑ E ❑
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? ❑ ❑ 01 ❑
Comment
iVionitorinq and Reporting Requirements
Yes No NA NE
Are copies of required press releases and distribution lists available'? ❑ ❑ 12 0
Are public notices and proof of publication available? ❑ ❑ PE ❑
#Is an annual report being prepared in accordance with G S 143-215.1C? ❑ ❑ EE ❑
#Is permittee-compliant with all compliance schedules in the permits'? 00 .' 0
If no,which one(s)?
Comment'
Page 5
Permit: WQCSD0646 Owner•Facility.Nature Trails Association CLP
Inspection Date: 08/23/2018 Inspection Type Collection System Inspect Non Sampling Reason for Visit. Routine
Page 6