WQCSD0684_Compliance Evaluation Inspection_20190104

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ROY COOPER NORTH CAROLINA
Governor Environmental Quality
MICHAEL S.REGAN
Secretary
LINDA CULPEPPER
Interim Director
January 4, 2019
Foster Apartment Group, LLC Foster Apartment Group, LLC
Attn: Robert Mark Foster, Owner Attn: JD Hamilton, Regional Manager
704 North Madison Street 3501 Plaza Ridge Circle
Tupelo, MS 38804 Winston-Salem, NC 27107
Subject: Compliance Evaluation Inspection
WQCSD0684-Willow Creek Apartments
100 Stagecoach Rd, Winston-Salem, NC 27105
Forsyth County
Dear Mr. Foster& Mr. Hamilton: •
Ron Boone, of the North Carolina Division of Water Resources (DWR or the Division),
Winston-Salem Regional Office (WSRO), conducted a compliance evaluation inspection (CEI) of
the Willow Creek Apartments, hereinafter referred to as Willow Creek, wastewater collection
system on January 4, 2019. Mr. Hamilton's and Lizbeth Herrera's(property manager) cooperation
and assistance during the inspection was greatly appreciated. The attached EPA Water
Compliance Inspection Report shows all areas that were evaluated during the inspection and
Willow Creek's current compliance status in each area.
Overall, Willow Creek Apartments is currently noncompliant with the applicable NC
regulations that govern wastewater collection systems, i.e., 15A NCAC 02T.0400, System Wide
Collection System Permitting. It is acknowledged, however, that they have made significant
progress toward compliance since the last major sanitary sewer overflow (SSO)/pump station
failure, which occurred near the beginning of November, 2018, despite the obstacles presented
by the holiday season and a severe lack of knowledge of the systems concerned. The Division
and the people of NC appreciate your efforts to comply and to help protect the surface waters and
natural resources of the state.
Please note the following areas, for which Willow Creek is currently regarded as
noncompliant:
1. Operation &Maintenance Plan,which includes pump station inspection frequency,
a preventative maintenance schedule, a spare parts inventory, and an overflow
response plan, which describes all spill response and reporting requirements, in
detail, and demonstrates a thorough plan knowledge by all Willow Creek
employees who are assigned responsibility during such events.
2. A satisfactory map of the entire collection system, which should include, at a
minimum, pipe, cleanout, and manhole locations, materials, and size, as
•
NORTH CAROLINA
DI ,,nt of forlIrmenhil ouaum\ , .4
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 Hanes Mill Road,Suite 300 I Winston-Salem,North Carolina 27103
336.776.9800

t
appropriate, as well as all buildings, roads and other natural or manmade
landmarks. The map must be to scale.
3. A pump station inspection plan, to include a pump failure contingency plan.
4. A plan to implement an annual general observation of the entire collection system.
5. A grease control and education program, which shall include, at a minimum, bi-
annual (every six-month period) distribution of fats, oils, and greases (FOG)
educational materials to all Willow Creek residents. Such distribution shall be done
more frequently when necessary to prevent further grease-related SSOs.
6. A documentation scheme directed at completely and thoroughly documenting all
activities undertaken by Willow Creek, it's employees, and/or contractors, who are
commissioned for the proper operation and maintenance of the Willow Creek
collection system and prevention of pump station failures and SSOs. All
documentation must be maintained on site for no less than three years.
Please reply to this letter in writing by February 1, 2019. Your written reply should indicate,
. in detail, your progress toward attaining full compliance in all areas outlined above in items 1
through 6. For those items not thoroughly completed by the above deadline, please provide a
status and estimated completion date. Please also provide justification for any delays which may
be seen as unacceptable or inordinate.
You are again reminded that, pursuant to NC General Statute (NCGS) 143-215.6A,
Enforcement Procedures, Civil Penalties, the Secretary of the NC Department of
Environmental Quality (NCDEQ), may, at her discretion, assess civil penalties of not more the
$25,000 upon any person who violates the terms and conditions of NCGS 143-215.1, Control of
Sources of Water Pollution; Permits Required, or any permits or regulations promulgated to
implement these statutes.
We look forward to hearing from you soon! Please contact us at 336-776-9800 with any
questions or concerns you may have regarding this letter or the requirements therein.
Si cerel
to .
Cer Sherri V. Knight, P.E.
Regional Supervisor
Water Quality Regional Operations
Division of Water Resources
ATTACHMENTS:
EPA Water Compliance Inspection Report
cc: 1. Central Files
2. (PERCS Unit
3. WSRO SWP-Files
4. City of Winston-Salem, Stormwater Division
P.O. Box 2511, Winston-Salem, NC 27102
Page 2 of 2

Compliance Inspection Report
Permit: WQCSD0684 Effective: 11/07/18 Expiration: Owner: Foster Apartment Group LLC
SOC: Effective: Expiration: Facility: Willow Creek Apartments
100 Stagecoach Rd
County: Forsyth
Region: Winston-Salem
Winston Salem NC 27105
Contact Person: Jd Hamilton Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 01/04/2019 Entry 110 10 00AM Exit Time: 11 OOAM
Primary Inspector: Ron Boone Phone: [phone]
likk• //t//2 / 7
Secondary Inspectors):
Reason for Inspection: Routine Inspection Type: Collection System Inspect Non Sampling
Permit Inspection Type: Deemed permitted collection system management and operation
Facility Status: ❑ Compliant III Not Compliant
Question Areas:
II Miscellaneous Questions 11 Performance Standards Operation&Maint Reqmts
II Records MI Monitoring&Rpting Reqmts El Inspections
1.1 Pump Station • Manhole II Lines
•
(See attachment summary)
Page 1

Permit: WQCSD0684 Owner-Facility:Foster Apartment Group LLC
Inspection Date: 01/04/2019 Inspection Type.Collection System Inspect Non Sampling Reason for Visit: Routine
Inspection Summary- _
Permittee is still in process of developing program and is currently non-compliant for various reasons, i.e, no map,failure to
properly report spills, etc
Conducted inspection today to reiterate requirements and provide guidance on developing and implementing the collection
system program
Permittee has made significant progress towards achieving compliance since the last major spill/pump station failure The
holiday season has somewhat hindered those efforts.The lack of knowledge of these requirements has also been a
significant factor in the permittee's ability to develop and implement the program.
Page 2

Permit: WQCSD0664 Owner-Facility:Foster Apartment Group LLC
Inspection Date: 01/04/2019 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? 0 II 0 0
What educational tools are used?
Is Sewer Use Ordinance/Legal Authority available? 0 ❑ • ❑
Does it appear that the Sewer Use Ordinance is enforced? 0 0 • 0
Is Grease Trap Ordinance available? 0 0 • 0
Is Septic Tank Ordinance available(as applicable,i e annexation) 0 0 • 0
List enforcement actions by permittee,if any,in the last 12 months
Has an acceptable Capital Improvement Plan(CIP)been implemented? 0 0 II 0
Does CIP address short term needs and long term\"master plan\"concepts? 0 ❑ • 0
Does CIP cover three to five year period? 0 0 Ill 0
Does CIP include Goal Statement? 0 0 IN 0
Does CIP include description of project area? 0 0 • 0
Does CIP include description of existing facilities? 0 ❑ 111 0
Does CIP include known deficiencies? ❑ 0 • 0
,
Does CIP include forecasted future needs? El 0 • 0
Is CIP designated only for wastewater collection and treatment? 0 0 • 0
Approximate capital improvement budget for collection system?
Total annual revenue for wastewater collection and treatment?
CIP Comments
None
Is system free of known points of bypass? 111 0 ❑ 0
If no,describe type of bypass and location
Is a 24-hour notification sign posted at ALL pump stations? 0 • 0 0
#Does the sign include
Instructions for notification? 0 0 • ❑
Pump station identifier'? 0 0 • 0
24-hour contact numbers 0 0 • 0
If no,list deficient pump stations
Pump station#1
#Do ALL pump stations have an"auto polling"feature/SCADA? ❑ • 0 0
Number of pump stations 1
Number of pump stations that have SCADA 0
Number of pump stations that have simple telemetry 0
Number of pump stations that have only audible and visual alarms 1
Number of pump stations that do not meet permit requirements I 0
Page 3

Permit: WQCSD0664 Owner-Facility:Foster Apartment Group LLC
Inspection Date: 01/04/2019 Inspection Type:Collection System Inspect Non Sampling Reason for Visit: Routine
#Does the permittee have a root control program'? ❑ • ❑ ❑
#If yes,date implemented?
Describe
Comment None
Inspections Yes No NA NE
Are maintenance records for sewer lines available? El 1111 ❑ El
Are records available that document pump station inspections'? 0 0 ❑
Are SCADA or telemetry equipped pump stations inspected at least once a week'? 0 ❑ II ❑
Are non-SCADA/telemetry equipped pump stations inspected every day? • ❑ El ❑
Are records available that document citizen complaints? El ❑ ❑
#Do you have a system to conduct an annual observation of entire system'? ❑ MI ❑ ❑
#Has there been an observation of remote areas in the last year'? ❑ II El El
Are records available that document inspections of high-priority lines'? ❑ ❑ • El
Has there been visual inspections of high-priority lines in last six months'? El ❑ • El
Comment. None
Operation&Maintenance Requirements
Yes No NA NE
Are all log books available'? • 0 El ❑
Does supervisor review all log books on a regular basis'? ❑ El
Does the supervisor have plans to address documented short-term problem areas'? • 0 ❑ El
What is the schedule for reviewing inspection,maintenance,&operations logs and problem areas'?
As generated.
Are maintenance records for equipment available'? ❑ El ❑
Is a schedule maintained for testing emergency/standby ecuipment? ❑ ❑ MI ❑
What is the schedule for testing emergency/standby equipment?
Do pump station logs include
Inside and outside cleaning and debris removal'? ❑ • El ❑
Inspecting and exercising all valves'? ❑ • El 0
Inspecting and lubricating pumps and other equipment'? ❑ El ❑
Inspecting alarms,telemetry and auxiliary equipment'? El El
Is there at least one spare pump for each pump station w/o pump reliability'? El ❑ • El
Are maintenance records for right-of-ways available'? ❑ MI ❑ ❑
Are right-of-ways currently accessible in the event of an emergency'? • ❑ ❑ ❑
Are system cleaning records available'? El U El El
Has at least 10%of system been cleaned annually'? ❑ ❑ • ❑
What areas are scheduled for cleaning in the next 12 months?
Is a Spill Response Action Plan available? ❑ • ❑ ❑
Page 4

•
Permit: WQCSD0684 Owner-Facility:Foster Apartment Group LLC
Inspection Date: 01/04/2019 Inspection Type:Collection System Inspect Non Sampling Reason for Visit: Routine
Does the plan include:
24-hour contact numbers ❑ 0 11 ❑
Response time ❑ 0 • 0
Equipment list and spare parts inventory ❑ ❑ MI ❑
Access to cleaning equipment ❑ 0 U ❑
Access to construction crews,contractors,and/or engineers ❑ ❑ • ❑
Source of emergency funds ❑ ❑ 111 ❑
Site sanitation and cleanup materials 0 ❑ 1 ❑
Post-overflow/spill assessment ❑ 0 • ❑
Is a Spill Response Action Plan available for all personnel? ❑ ❑ II ❑
Is the spare parts inventory adequate'? ❑ 0 • ❑
Comment: None _
Records Yes No NA NE
Are adequate records of all SSOs,spills and complaints available'? ❑ MI 0 El
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'? ❑ E ❑ ❑
If yes,is there a corrective action plan'? ❑ ❑ IN ❑
Is a map of the system available'? ❑ • ❑ ❑
Does the map include
Pipe sizes 0 ❑ 11 ❑
Pipe materials ❑ ❑ 11 ❑
Pipe location ❑ 0 II 0
Flow direction ❑ ❑ II ❑
Approximate pipe age 0 ❑ MI ❑
Number of service taps ❑ 0 • ❑
Pump stations and capacity ❑ ❑ • ❑
If no,what percent is complete'? 0
List any modifications and extensions that need to be added to the map
#Does the permittee have a copy of their permit'? E 0 ❑ ❑
Comment' 02 T.0403 rules.
Monitoring and Reporting Requirements Yes No NA NE
Are copies of required press releases and distribution lists available'? ❑ I ❑ ❑
Are public notices and proof of publication available'? • ❑ • ❑ ❑
#Is an annual report being prepared in accordance with G S 143-215 1C? ❑ ❑ 1M ❑
#Is permittee compliant with all compliance schedules in the permits'? ❑ ❑ • ❑
If no,which one(s)?
Page 5

Permit: WQCSD0684 Owner-Facility:Foster Apartment Group LLC
Inspection Date: 01/04/2019 Inspection Type:Collection System Inspect Non Sampling Reason for Visit: Routine
Comment: None
PUMP STATION#1 - North
Pump Station Yes No NA NE
Pump station type Duplex
Are pump station logs available? • ❑ ❑ El
Is it accessible in all weather conditions? • ❑ ❑ El
#Is general housekeeping acceptable? • ❑ ❑ ❑
Are all pumps present? • ❑ ❑ ❑
Are all pumps operable? • ❑ ❑ ❑
Are wet wells free of excessive debris? • ❑ ❑ ❑
Are upstream manholes free of excessive debris/signs of overflow? El El ❑ •
Are floats/controls for pumps/alarms operable? • ❑ ❑ El
Is"auto polling"feature/SCADA present? ❑ U El ❑
Is"auto polling"feature/SCADA operational? El ❑ MI ❑
Is simple telemetry present? ❑ 1 El El
Is simple telemetry operational? ❑ ❑ • El
Are audio and visual alarms present? • ❑ ❑ El
Are audio and visual alarms operable? ❑ ❑ ❑
Is the Pump station inspected as required? • ❑ ❑ ❑
Are backflow devices in place? • ❑ ❑ ❑
Are backflow devices operable? • ❑ ❑ ❑
Are air relief valves in place? II El ❑ ❑
Are air relief valves operable? ❑ ❑ ❑
# Is an emergency generator available? ❑ II El ❑
Can the emergency generator run the pumps? ❑ ❑ I ❑
Is the pump station equipped for quick hook-up? ❑ El • ❑
Is the generator operable? El El U ❑
#Is fuel in tank and sufficient? El El • ❑
Is the generator inspected according to their schedule'? ❑ ❑ III ❑
Is a 24-hour notification sign posted? ❑ II ❑ ❑
Does it include.
Instructions for notification? • El ❑ ❑
Pump station identifier? II ❑ El ❑
Emergency phone number • ❑ ❑ ❑
Is public access limited'? • ❑ ❑ ❑
Is pump station free of overflow piping? • ❑ ❑ ❑
Page. 6

•
Permit: W4CSD0684 Owner-Facility:Foster Apartment Group LLC
Inspection Date: 01/04/2019 Inspection Type:Collection System Inspect Non Sampling Reason for Visit: Routine
Is the pump station free of signs of overflow • ❑ ❑ ❑
Are run times comparable for multiple pumps? Not evaluated
Comment- None
•
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