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HomeMy WebLinkAboutWQCSD0455_Compliance Evaluation Inspection_20181231 North Carolina Department of Environmental Quality | Division of Water Resources 2090 U.S. 70 Highway, Swannanoa, NC 28778 828-296-4500 December 31, 2018 Cody S Jones Cedar Beach Investment Group LLC PO Box 20670 Charleston, SC 29413 SUBJECT: Compliance Inspection Report Cedar Hill WWTP Collection System Permit No. WQCSD0455 Jackson County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Cedar Hill Collection System on 12/17/2018. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in 15A NCAC 02T.0403. Based on the site visit and discussions with RPB Systems staff, the system was determined to be in compliance; however, the following items were noted and need to be addressed.  Spill Response Plan: No formal spill response plan was available at the time of the inspection. A general guidance document with contact numbers and response procedures should be available to all staff.  Grease Education: Examples of Fats, Oils, and Greases (FOGs) educational materials were not available at the time of the inspection. FOGs educational material should be distributed to collection system users bi-annually. North Carolina Department of Environmental Quality | Division of Water Resources 2090 U.S. 70 Highway, Swannanoa, NC 28778 828-296-4500 Additional comments can be found in the attached inspection report. Please review the attached regulations to maintain system compliance. If you should have any questions, please do not hesitate to contact me at 828-296-4500 or via email at mikal.willmer@ncdenr.gov. Sincerely, Mikal Willmer, Environmental Specialist I Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Report 15A NCAC 02T.0403 EC: WQS-ARO Server LF Bob Barr, RPB Systems G:\WR\WQ\Jackson\Collection Systems\Cedar Hill\Inspections\Inspect. Dec. 17, 2018\20181231_WQCSD0455_CEI Compliance Inspection Report Permit:WQCSD0455 Effective:07/29/09 Expiration:Owner :Cedar Beach Investment Group LLC SOC: Contact Person: Region: County: Directions to Facility: Jackson Asheville Cody S Jones Effective:Expiration:Facility:Cedar Hill WWTP Cedar Hill Cashiers NC 28717 Title:Phone:843-224-7260 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: 12/17/2018 09:30AM 10:30AM Mikal Willmer 828-296-4686 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 Performance Standards Operation & Maint Reqmts Records Monitoring & Rpting Reqmts Inspections Pump Station (See attachment summary) Page:1 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCSD0455 12/17/2018 Collection System Inspect Non Sampling Cedar Beach Investment Group LLC Routine Inspection Summary: Inspector Mikal Willmer, with the Asheville Regional Office, conducted a compliance evaluation inspection of the Cedar Hill Development Collection System. This inspection was conducted to determine whether the system is being operated and maintained in compliance with 15A NCAC 02T.0403. Mike Beck, RPB Systems, was present and assisted in the inspection. The flows for this development are under 200,000 gallons per day and therefore fall under the "deemed" collection system regulations (15A NCAC 02T.0403). A copy of the regulations are attached for your reference. A certified ORC is not required. RPB Systems staff maintain the collection system for Cedar Hill. The inoperable pump should be replaced and or repaired as soon as possible. The inflow and infiltration at PS#3 should continue to be monitored and infiltration should be eliminated as much as possible. This can become an issue as homes are connected to the pump station. Based on the site visit and discussions with RPB System staff, the system was determined to be in compliance. The following items were noted and should be addressed. * No formal spill response plan was available at the time of the inspection. A general guidance document with contact numbers and response procedures should be available to all staff. *Grease Education: Examples of Fats, Oils, and Greases (FOGs) educational materials were not available at the time of the inspection. FOGs educational material should be distributed to collection system users bi-annually. Page:2 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCSD0455 12/17/2018 Collection System Inspect Non Sampling Cedar Beach Investment Group LLC Routine Performance Standards Yes No NA NE Is Public Education Program for grease established and documented? What educational tools are used? Only four or five homes are on the collection system. Educational materials in regard to fats, oils and greases needs to be developed and distributed to all homeowners. Is Sewer Use Ordinance/Legal Authority available? Does it appear that the Sewer Use Ordinance is enforced? 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? Does CIP address short term needs and long term \"master plan\" concepts? Does CIP cover three to five year period? Does CIP include Goal Statement? Does CIP include description of project area? Does CIP include description of existing facilities? Does CIP include known deficiencies? Does CIP include forecasted future needs? 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? 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? 24-hour contact numbers If no, list deficient pump stations PS #3, this system is not currently receiving flow. At least two homes will be connected in the next year or two. Recommend adding a pump station identifier and contact information in the event of an overflow. # Do ALL pump stations have an "auto polling" feature/SCADA? Number of pump stations 3 Number of pump stations that have SCADA 0 Number of pump stations that have simple telemetry 3 Number of pump stations that have only audible and visual alarms 3 Page:3 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCSD0455 12/17/2018 Collection System Inspect Non Sampling Cedar Beach Investment Group LLC Routine Number of pump stations that do not meet permit requirements 0 # Does the permittee have a root control program? # If yes, date implemented? Describe: RPB systems maintains the collection system for Cedar Hill. All pump stations are connected to telemetry and inspected daily by RPB systems staff.Comment: Inspections Yes No NA NE Are maintenance records for sewer lines available? Are records available that document pump station inspections? Are SCADA or telemetry equipped pump stations inspected at least once a week? 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? # Has there been an observation of remote areas in the last year? Are records available that document inspections of high-priority lines? Has there been visual inspections of high-priority lines in last six months? PS#3 (does not currently receive wastewater) receives I&I. The aluminum lid reportedly leaks during heavy rain and snowfall events. Mr. Beck stated there was no reported issues with the pumps maintaining an appropriate level within the wetwell. This should be monitored as homes are connected. Comment: Operation & Maintenance Requirements Yes No NA NE Are all log books available? Does supervisor review all log books on a regular basis? Does the supervisor have plans to address documented short-term problem areas? 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?weekly Do pump station logs include: 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? 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? Are system cleaning records available? Page:4 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCSD0455 12/17/2018 Collection System Inspect Non Sampling Cedar Beach Investment Group LLC Routine Has at least 10% of system been cleaned annually? What areas are scheduled for cleaning in the next 12 months? Minimal flow through the system and no major issues with debris in lines. Is a Spill Response Action Plan available? 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 Is a Spill Response Action Plan available for all personnel? Is the spare parts inventory adequate? No formal spill response plan available. Recommend a spill response guidance document be generated for current and future collection system staff. This should include contact information and response procedures after an overflow is documented. Comment: Records Yes No NA NE Are adequate records of all SSOs, spills and complaints available? 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? If yes, is there a corrective action plan? Is a map of the system available? Does the map include: Pipe sizes Pipe materials Pipe location Flow direction Approximate pipe age Number of service taps Pump stations and capacity If no, what percent is complete? List any modifications and extensions that need to be added to the map There is a map maintained at the WWTP of the Cedar Hill development. Current homes connected are listed and the location of pump stations and lines is also listed. # Does the permittee have a copy of their permit? This is a deemed system. 02T.0403 regulations are attached.Comment: Page:5 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQCSD0455 12/17/2018 Collection System Inspect Non Sampling Cedar Beach Investment Group LLC Routine Monitoring and Reporting Requirements Yes No NA NE Are copies of required press releases and distribution lists available? Are public notices and proof of publication available? # Is an annual report being prepared in accordance with G.S. 143-215.1C? # Is permittee compliant with all compliance schedules in the permits? If no, which one(s)? Mr. Beck reports no sewer system overflows.Comment: Page:6 Certificate Of Completion Envelope Id: 95AEF7ABF75D4C69A5DD9763CE8133B8 Status: Completed Subject: Please DocuSign: 20181231_WQCSD0455_CEI.ltr.docx, 20181231_WQSCD0455_CEI.draft.pdf Source Envelope: Document Pages: 8 Signatures: 1 Envelope Originator: Certificate Pages: 1 Initials: 1 Mikal Willmer AutoNav: Disabled EnvelopeId Stamping: Disabled Time Zone: (UTC-05:00) Eastern Time (US & Canada) 217 W. Jones Street Raleigh, NC 27699 Mikal.willmer@ncdenr.gov IP Address: 149.168.204.10 Record Tracking Status: Original Dec 28, 2018 | 14:53 Holder: Mikal Willmer Mikal.willmer@ncdenr.gov Location: DocuSign Signer Events Signature Timestamp Mikal Willmer mikal.willmer@ncdenr.gov Environmental Specialist North Carolina Department of Environmental Quality Security Level: Email, Account Authentication (None) Signature Adoption: Drawn on Device Using IP Address: 149.168.204.10 Sent: Dec 28, 2018 | 14:53 Viewed: Dec 28, 2018 | 14:54 Signed: Dec 28, 2018 | 14:59 Freeform Signing Electronic Record and Signature Disclosure: Not Offered via DocuSign In Person Signer Events Signature Timestamp Editor Delivery Events Status Timestamp Agent Delivery Events Status Timestamp Intermediary Delivery Events Status Timestamp Certified Delivery Events Status Timestamp Carbon Copy Events Status Timestamp Notary Events Signature Timestamp Envelope Summary Events Status Timestamps Envelope Sent Hashed/Encrypted Dec 28, 2018 | 14:53 Certified Delivered Security Checked Dec 28, 2018 | 14:54 Signing Complete Security Checked Dec 28, 2018 | 14:59 Completed Security Checked Dec 28, 2018 | 14:59 Payment Events Status Timestamps