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Home My WebLink AboutWQCSD0646_Compliance Evaluation Inspection_20180829 (2) ROY COOPER Governor ; MICHAEL S. REGAN Secretary LINDA CULPEPPER Interim Director August 29, 2018 Matthew Raynor RECEIV'E®1®E14RI"R Nature Trails Association CLP SEP 0 4 2018 524 Meadow Avenue Loop rces Banner Elk,NC 28604 Water ResSection tt ct on permitting 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. Operation 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 Sanitary 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 Mail service Center I Raleigh,North Carolma 27699-1628 919 791-4200 ,;°,-''yFir, !#Me �rn�r- 7ri,,•'y:,t�.'"v}"S'' +,y, w �."`;e",, : t f - ` 'i -r -,a 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 hi-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. Documentation. 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, ,...„5:- ,,,,„ /,,,,,---, ' r 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=966=5939" Directions to Facility: cite- 240- Lre3I 6A4) B2g4- 433- 5b 3 (o) System Classifications: Primary ORC: Certification: Phone: Secondary ORC(s)• On-Site Representative(s): 'y✓)a pAt-t _ . ��r•[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 OOPM Primary Inspector Vanessa E Manuel Phone. X1-8=864'=6392 Secondary Inspector(s): /9- 9/-Jf z S^5- Reason for Inspection: Routine Inspection Type: Collection System Inspect Non Sampling Permit Inspection Type. Deemed permitted collection system management and operation Facility Status• gi Compliant ❑ Not Compliant Question Areas: Miscellaneous Questions 111 Performance Standards Ea Operation&Maint Reqmts Records to Monitoring&Rpting Reqmts Inspections Lines (See attachment summary) • Page 1 \a Permit: WQCSD0646 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? ® ❑ ❑ ❑ 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? ❑ ❑ 0 Does it appear that the Sewer Use Ordinance is enforced'? ❑ ❑ E ❑ Is Grease Trap Ordinance available? ❑ ❑ ❑ Is Septic Tank Ordinance available(as applicable,i.e annexation) ❑ ❑ . ❑ List enforcement actions by permittee,if any,in the last 12 months Has an acceptable Capital Improvement Plan(CIP)been implemented'? 00Z1111 Does CIP address short term needs and long term\"master plan\"concepts? ❑ 000 Does CIP cover three to five year period? 0000 Does CIP include Goal Statement? ❑ ❑ ❑ ❑ Does CIP include description of project area? 0000 Does CIP include description of existing facilities? 0000 Does CIP include known deficiencies? 0000 Does CIP include forecasted future needs'? 0000 Is CIP designated only for wastewater collection and treatment? ❑ ❑ ❑ ❑ 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? • al 000 If no,describe type of bypass and location Is a 24-hour notification sign posted at ALL pump stations? ❑ ❑ ' ❑ . #Does the sign include Instructions for notification'? ❑ ❑ ❑ ❑ Pump station identifier? 0000 24-hour contact numbers 0000 If no,list deficient pump stations #Do ALL pump stations have an"auto polling"feature/SCADA? ❑ ❑ ® ❑ 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? 000 #If yes,date implemented? Describe Comment: Inspections Yes No NA NE Are maintenance records for sewer lines available? 0000 Are records available that document pump station inspections? ❑ ❑ ❑ Are SCADA or telemetry equipped pump stations inspected at least once a week? ❑ 0 ❑ Are non-SCADA/telemetry equipped pump stations inspected every day? ❑ ❑ ❑ Are records available that document citizen complaints? ❑ ❑ ❑ #Do you have a system to conduct an annual observation of entire system? 000 #Has there been an observation of remote areas in the last year? 000 Are records available that document inspections of high-priority lines? ❑ 000 Has there been visual inspections of high-priority lines in last six months? ® 000 Comment: Operation&Maintenance Requirements Yes No NA NE Are all log books available? 0 ❑ ❑ Does supervisor review all log books on a regular basis? ❑ ❑ ❑ ❑ Does the supervisor have plans to address documented short-term problem areas? 0000 What is the schedule for reviewing inspection,maintenance,&operations logs and problem areas? Are maintenance records for equipment available? ❑ ❑ ❑ Is a schedule maintained for testing emergency/standby equipment? ❑ ❑ , ❑ What is the schedule for testing emergency/standby equipment? Do pump station logs include Inside and outside cleaning and debris removal? ❑ ❑ E ❑ Inspecting and exercising all valves? ❑ ❑ ❑ Inspecting and lubricating pumps and other equipment? ❑ ❑ ❑ Inspecting alarms,telemetry and auxiliary equipment? ❑ ❑ E ❑ Is there at least one spare pump for each pump station w/o pump reliability? ❑ ❑ ® ❑ Are maintenance records for right-of-ways available? ❑ ❑ ❑ Are right-of-ways currently accessible in the event of an emergency? E1 ❑ ❑ ❑ Are system cleaning records available? ❑ ❑ Ei ❑ Has at least 10%of system been cleaned annually? 00E10 What areas are scheduled for cleaning in the next 12 months? Is a Spill Response Action Plan available? ❑ rE ❑ ❑ 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 El 0 0 0 Response time 0 El 0 0 Equipment list and spare parts inventory ❑ 0 0 ❑ Access to cleaning equipment 0 0 ❑ ❑ Access to construction crews,contractors,and/or engineers 0 ❑ 0 0 Source of emergency funds El El El ❑ Site sanitation and cleanup materials ❑ 0 0 0 Post-overflow/spill assessment ❑ ❑ ❑ 0 Is a Spill Response Action Plan available for all personnel? ❑ ❑ ❑ ❑ Is the spare parts inventory adequate? 0 ❑ ❑ ❑ Comment The permittee needs to document record-keeping activities. Records Yes No NA NE Are adequate records of all SSOs,spills and complaints available'? El 0 s ❑ Are records of SSOs that are under the reportable threshold available? ❑ 0 ❑ Do spill records indicate repeated overflows(2 or more in 12 months)at same location? ❑ ❑ ® ❑ If yes,is there a corrective action plan? ❑ ❑ 0 0 Is a map of the system available? El El 0 ❑ Does the map include Pipe sizes 0 0 0 Pipe materials 0 ❑ El Pipe location El 0 ❑ ❑ Flow direction 0 ❑ 0 Approximate pipe age ❑ ❑ lid ❑ Number of service taps ❑ 0 EEI ❑ Pump stations and capacity ❑ ❑ E ❑ 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? ❑ ❑ El ❑ Comment. ill7onitorinq and Reporting Requirements Yes No NA NE Are copies of required press releases and distribution lists available'? 0 0 E 0 Are public notices and proof of publication available? 0 ❑ El ❑ #Is an annual report being prepared in accordance with G S.143-215 1C? ❑ ❑ E El #Is permittee'compliant with all compliance schedules in the permits? ❑ ❑ ❑ If no,which one(s)? Comment Page' 5 Permit: WOCSD0646 Owner-Facility:Nature Trails Association CLP Inspection Date• 08/23/2018 Inspection Type Collection System Inspect Non Sampling Reason for Visit. Routine • Page 6