WQCS00217_Compliance Evaluation Inspection_20190702

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
Kathrine Heigel
PO Box 240705
Charlotte, NC 28201
Dear Ms. Heigel,
NORTH CAROLINA
Environmental Quality
July 2, 2019
Subject: Compliance Evaluation Inspection
Carolina Trace Collection System
Permit WQCS00217
Lee County
On Thursday, June 20, 2019, Zach Thomas of the Raleigh Regional Office conducted a
compliance evaluation inspection of the collection system for Carolina Trace. The purpose of
this inspection was to ensure compliance with the subject permit. During the inspection, the
presence and cooperation of Mr. Dean Miller and other staff was helpful and appreciated.
This compliance evaluation inspection consisted of the following:
• Review of the permit;
• Review of the owner/facility information;
• Review of records;
• On -site inspection of the collection system and lift station units
Findings during the inspection and file review were as follows:
I. The permit (WQCS00217) was issued effective on December 1, 2013, and will expire on
November 30, 2021.
2. Many permit affiliations have changed since the last inspection. It was requested that these
be updated and sent to DWR.
3. The system is classified CS-2. As listed in the subject permit, the system contains
approximately 39.7 miles of gravity sewer, 5.3 miles of force main, fi duplex pump stations
and 7 simplex stations.
DNorth Caroiina department of Environmental Quality Division of Water Resaurcrs
E , "A
Raleigh Regional Office 1 3800 Barrett Drive I Raleigh. North Carolina 27609
"►� 919.7914200

4. Jill Strickler is responsible for the Fats, Oil and Grease (FOG) program. Materials are mailed
out two times per year with the utility bills. There is one grease trap located at the country
club. The receiving lift station and line are monitored frequently and they have had no
enforcements in the recent past.
5. The Sewer Use Ordinance was complete and up to date. The HOA implements a Septic Tank
Ordinance that states any home still on septic must be connected to the CS before it is
allowed to be sold to new owners (currently 2 left in the community).
6. The Capital Improvement Plan was complete and detailed a 5-year to 10-year period. There
was approximately $200,000 allotted for line replacement and possible lift station repairs and
upgrades.
7. Maintenance, inspection, and system records are all kept in an online system that is reviewed
weekly and in depth yearly by the management staff. Citizen complaints are handled through
the company's 1-800 number and routed to the appropriate staff.
8. Two of the six duplex stations have permanent generators. The remaining rely on 3 pull
behind generators that connect to on -site hookup. Generators are tested weekly.
9. The map of the system was complete and in compliance with the permit requirements. The
entire system was mapped and evaluated for roots and issues using cameras by Rezone in
2017. Two manholes were found to be low or covered. They were subsequently rechecked
by staff and raised.
10. Right of Way and high priority line inspections were in compliance with the permit
requirements. Right of ways are inspected at the same time as jetting/cleaning and high
priority lines are performed every 6 months (most recently in January and February 2019).
11. Of the approximate 39.7 miles of gravity line, approximately 28,340 feet were cleaned in
2018. This action is typically performed in October of each year.
12. SSO records are kept with the ORC and BIMs shows there have been 2 SSOs since the last
inspection. One occurred during Hurricane Matthew due to flooding. The Spill Response
Plan reviewed was thorough, but needed updated 24-hour contact information and
contained information for the DWR Winston Salem Regional Office. Mr. Miller stated
that they would make these changes immediately.
13. Several lift stations, manholes, and high priority lines were inspected:
a) 3 of the 6 duplex stations were inspected. All stations contain telemetry/mission SCADA
and are visited weekly by staff. The following observations were noted:
i) Woodfield Lift Station had no fence, but was locked and secured. The posted
sign was significantly faded and unreadable. When tested at the control switch,
the audible/visual alarms worked properly. However, when the floats were
pulled only the telemetry alarm worked.
ii) Harbor Creek Lift Station was rehabbed in 2018 and had one pump out for
repair/rebuilding at the time of inspection (due to flooding from Hurricane

Florence). It had no fence, but was Iocked and secured. The posted sign was
significantly faded and unreadable. When the floats were pulled the telemetry
alarm worked, but the audible/visual alarms were not operable.
iii) Country Club Lift Station had no fence, but was locked and secured. All alarms
worked properly when floats were pulled. The posted sign was significantly
faded and unreadable.
b) All inspected manholes were found to be in good condition, free of excessive debris and
signs of overflow.
c) The high priority line inspected was in good condition with unobstructed flow entering
from the upstream manhole. Some vegetation was seen growing close to the line and it
was suggested to keep it as clear as possible for access and to prevent any issues from
occurring
Please address items listed under 12 & 13.a.i—13.a.iii and respond to this office within 30
days of receipt of this Ietter.
If you have questions or comments about the inspection, this report or the requirements to take
corrective action (if applicable), please contact:
Zach Thomas at 919-791-4247 or via email at zacharN-.thomas67'-nedenr. ov.
Sincerely,
OcBolich, LG
Assistant Water Quality Regional Supervisor
Raleigh Regional Office
Attachments: EPA Compliance Inspection Report
Cc: Stephen Harrell, ORC (via email: stephen.harrell cr carolinawaterservicenc.com)
Dean Miller, BUORC (via email: [e-mail])
RRO Files
Laserfiche

Compliance Inspection Report
Permit: WOCS00217 Effective: 12/01/13 Expiration: 11/30/21 Owner: Carolina Trace Utilities Inc
SOC: Effective: Expiration: Facility: Carolina Trace Collection System
County: Lee PO Box 240705
Region: Raleigh
Charlotte NC 28201
Contact Person: Bc�rralrJ-5ear6ere itle.-9.�-0 Phone: [phone]
Directions to Facility:
System Classifications: CS2.
Primary ORC: Dean Ray Miller Certification: 997978 Phone: [phone]
Secondary ORCIs):
On -Site Representative(s)-
Related Permits:
NCO038831 Carolina Water Service Inc of North Carolina - Carolina Tra WWTP
Inspection Date: 06/20/2019 Entry Time: 01 OOPM Exit Time: 03:45PM
Primary Inspector: Zachary Thomas Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Collection System Inspect Non Sampling
Permit Inspection Type: Collection system management ar-.d operation
Facility Status: N Compliant ❑ Not Compliant
Question Areas-.
Miscellaneous Questions General Sewer & FOG Ordinances
Capital Improvement Plan Map Reporting Requirements
Inspections Spill Response Plan Spills
Lines Manholes Pump Stations
(See attachment summary)
Page 1 of 8

permit: WOCS00217 owner -Facility: Caroli-a Trace ---lit-es 1-
Inspection Date: 06/20/2019 Inspection Type: Collection System I rspe-1 Non Sampl ng Reason for Visit: Routine
Inspection Summary:
On Thursday June 20, 2019. Zach Thomas of the Raleigh Regional Office conducted a compliance evaluation inspection of
the collection system for Carolina Trace, The purpose of this inspection was to ensure compliance with the subject permit.
During the inspection, the presence and cooperation of Mr. Dean Miller and other staff was helpful and appreciated.
This compliance evaluation inspection consisted of the following
• Review of the permit
• Review of the owner/facility information;
• Review of records:
• On -site inspection of the collection system and lift station units
Findings during the inspection and file review were as follows
1. The permit (WQCS00217) was issued effective on December 1, 2013, and will expire on November 30, 2021.
2. Many permit affiliations have changed since the last inspection. It was requested that these be updated and sent to
DWR
3. The system is classified CS-2. As listed in the subject permit, the system conta.ns approximately 39.7 miles of gravity
sewer, 5.3 miles of force main, 6 duplex pump stations and 7 simplex stations.
4. Jill Strickler is responsible for the Fats, Oil and Grease (FOG) program. Materials are mailed out two times per year
with the utility bills. There is one grease trap located at the country club. The receiving lift station and line are monitored
frequently and they have had no enforcements in the recent past.
5, The Sewer Use Ordinance was complete and up to date. The HOA implements a Septic Tank Ordinance that states any
home still on septic must be connected to the CS before it is allowed to be sold to new owners (currently 2 left in the
community).
6. The Capital Improvement Plan was complete and detailed a 5-year to 10-year period. There was approximately $200,000
allotted for line replacement and possible lift station repairs and upgrades.
7. Maintenance, inspection, and system records are all kept in an online system that is reviewed weekly and in depth
yearly by the management staff. Citizen complaints are handled through the company's 1-800 number and routed to the
appropriate staff.
B. Two of the six duplex stations have permanent generators. The remaining rely on 3 pull behind generators that connect
to on -site hookup. Generators are tested weekly.
9. The map of the system was complete and in compliance with the permit requirements. The entire system was mapped
and evaluated for roots and issues using cameras by Rezone in 2017, Two manholes were found to be low or covered.
They were subsequently rechecked by staff and raised.
10. Right of Way and high priority line inspections were in compliance with the permit requirements. Right of ways are
inspected at the same time as jetting/cleaning and high priority lines are performed every 6 months (most recently in
January and February 2019).
11. Of the approximate 39.7 miles of gravity line, approximately 28,340 feet were cleaned in 2018. This action is typically
performed in October of each year.
12_ SSO records are kept with the ORC and 131Ms shows there have been 2 SSOs since the last inspection. One occurred
during Hurricane Matthew due to flooding. The Spill Response Plan reviewed was thorough, but needed updated 24-hour
Page 2 of 8

Permit: WOCS00217 Owner-Facllity:carol.na Trace Utilities Inc
Inspection Date: 06120/2019 Inspection Type: collection System Inspect Non Sampling Reason for Visit Routine
contact information and contained information for the DWR Winston Salem Reg onal Office Mr. Miller stated that they
would make these changes immediately.
13. Several lift stations, manholes, and high priority lines were inspected
a) 3 of the 6 duplex stations were inspected. All stations contain telemetry; mission SCADA and are visited weekly by
staff. The following observations were noted:
i) Woodfield Lift Station had no fence, but was locked and secured. The posted sign was significantly faded and
unreadable. When tested at the control switch, the audiblelvisual alarms worked properly.. However, when the floats were
pulled only the telemetry alarm worked,
ii) Harbor Creek Lift Station was rehabbed in 2018 and had one pump out for repair/rebuilding at the time of inspection (due
to flooding from Hurricane Florence). It had no fence, but was locked and secured. The posted sign was significantly faded
and unreadable. When the floats were pulled the telemetry alarm worked but the audible+visual alarms were not operable.
iii) Country Club Lift Station had no fence, but was locked and secured. All alarms worked properly when floats were
pulled. The posted sign was significantly faded and unreadable.
b) All inspected manholes were found to be in good condition, free of excessive debris and signs of overflow.
c) The high priority line inspected was in good condition with unobstructed flow entering from the upstream manhole. Some
vegetation was seen growing close to the line and it was suggested to keep it as clear as possible for access and to prevent
any issues from occurring
Please address items listed under 12 & 13,a,i—13.a.iii and respond to this office w thin 30 days of receipt of this letter.
Page 3 of 8

permit; M VS00217 owner - Facility,. tiaroina Trace Utd ties inc
Inspection Date: 06,7012018 Inspection Type ; Collection System Inspect Non Sampl ng Reason for Visit: R. -hne
General
Yes No NA NE
Is there a properly designated primary ORC and at least one back-up of proper grade?
❑ ❑ ❑
Are logs being reviewed by the system management or owner on a regular basis?
❑ ❑ ❑
# What is that frequency?
Weekly
# Are there any issues being addressed currently or any in the planning stages?
0 ❑ ❑ ❑
Is there a specific pump failure plan available for all pump stat ons?
E ❑ ❑ ❑
Does plan indicate if pump parts/new pumps are in spare partslequipmenl inventory?
❑ ❑ ❑
Are newlsignifrcantly upgraded pump stations equipped with anti -corrosion matenais?
❑ ❑ ❑
Does the pemtittee have a copy of their permit?
0 ❑ ❑ ❑
# is permit expiring within the next 6 months?
❑ 0 ❑ ❑
If Yes has the Permittee applied for renewal?
❑ ❑ M ❑
Comment: Harbor Creek Lift Station had one pump out for „repair on day of inspection.
CIP plans for line replacement and lift rehabs.
Sewer and FOG Ordinances
Yes No NA NE
Is Sewer Use Ordinance (SUO) or other Legal Authority available?
0 ❑ ❑ ❑
Does it appear that the Sewer Use Ordinance is enforced?
■ ❑ ❑ ❑
Is there a Grease Control Program that legally requires grease control devices?
0 ❑ ❑ ❑
What is the standard grease trap cleaning requirement in the FOG ordinance?
Is Grease Control Program enforced via periodic inspectionslrecords review?
❑ ❑ ❑
Is action taken against violators?
❑ ❑ ❑
# Have satellite systems adopted an equivalent or more stringent ordinance?
❑ ❑ 0 ❑
Is greaselsewer education program documented with req'd customer distribution?
M ❑ ❑ ❑
# Are other types of education tools used like websites, booths, special meetings, etc?
M ❑ ❑ ❑
If Yes, what are they? (This can reduce mailing to annual.)
Information is posted on the Carolina Water Service's Website
Comment:
Capital Improvement Plan
Yes No NA NE
Has a Capital (GIP) or System Improvement Plan been developed and adopted?
0 ❑ ❑ ❑
Is it designated for wastewater only or does it have a dedicated section?
0 ❑ ❑ ❑
Does CIP cover three to five year period of earmarked improvements?
0 ❑ ❑ ❑
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?
❑ ❑ ❑
Page 4 of 8

Permit: WOCS00217 Owner -Facility: Carolina Trace lltd ties Ins -
Inspection Cate: 0612012019 Inspection Type : Collection System Inspect Non $ampl ng Reason for Visit: Routine
Comment: There was approximately $200 000 allotted for line replacement and possible lift station re airs
and upgrades.
Man
Yes No NA NE
Is there a overall sewer system map? M 11 ❑
Does the map Include -
Pipe Type (GSIFM) ❑
Pipe sizes
Pipe materials (PVC, DIP, etc) ❑ El
Pipe location .
Flow direction
Approximate pipe age
Pump station ID, location and capacity 1:1 El
# Force main air release valve location 8, type ❑ ❑ ❑
# Location of satellite connections ❑ El El M
Is the map being updated for changestadditions within 1 year of activation? E ❑ ❑ ❑
Comment: The system was mapped, evaluated and videoed by Redzone in 2017.
Reporting Requirements Yes No NA NE
# Have there been any sewer spills in the past 3 years? 0 ❑ ❑ ❑
If Yes, were they reported to the Division if meeting the reportable criteria? E ❑ ❑ ❑
If applicable, is there documentation of press releases and public notices issued? M ❑ ❑ ❑
Is an Annual Wastewater Performance Report being tiled with the Division, if required? M ❑ ❑ ❑
Is the report being made available to all its sewer customers? M ❑ ❑ 13
# How is it being made available? Websiie
Comment:
Inspections
Yes Na NA NE
Are adequate maintenance records maintained? M❑ El ❑
Are pump stations being inspected at the required frequency? []
# Is at least one complete functionality test conducted weekly per pump station?
Is there a system or plan in place to observe the entire system annually?
Is the annual inspection documented?
# Does the system have any high -priority lines/locations? 0 ❑
Are inspections of HPL documented at least every 6 months?
Are new lines being added to the HPL list when found or created?
Comment:
Spill Response Action Plan Yes No NA NE
Page 5 of 8

permit: WOCS00217 owner - Facility: Carolina Trace Utilities Inc
Inspection Date: 06120/2019 Inspection Type : Collection System Inspect Non Sampli-g Reason for Visit Routine
Is a Spill Response Action Plan available?
E ❑ ❑ ❑
Is a Spill Response Action Plan available for all personnel?
0 ❑ ❑ ❑
Does the plan include:
24-hour contact numbers
E ❑ ❑ ❑
Response time
N ❑ ❑ ❑
Equipment list and spare parts inventory
E ❑ ❑ ❑
Access to cleaning equipment
N ❑ ❑ ❑
Access to construction crews, contractors, and/or engineers
0 ❑ ❑ ❑
Source of emergency funds
N ❑ ❑ ❑
Site sanitation and cleanup materials
0 ❑ ❑ ❑
Post-overflow/spill assessment
0 ❑ ❑ ❑
Does the Permiltee appear to respond within 2 hours of first knowledge of a spith
0 ❑ ❑ ❑
Comment. It was noted that the Plan needed updated 24-hour contact information and contained information
for the DWR Winston Salem Regional Office rather than the Raleiclh Regional Office. Mr. Miller
stated it would be changed immediately.
5pi119 Yes No NA NE
Is system free of known points of bypass? N ❑ ❑ ❑
If No. describe type of bypass and location
Are all spills or sewer related issues/complaints documented? 0 ❑ ❑ ❑
# Are there repeated overflows/problems (2 or more in 12 months) at same location? ❑ E ❑ ❑
# If Yes. is there a corrective action plan? ❑ ❑ 0 ❑
Comment: No repeat problems.
LineslRight-of-Ways/Aerial Lines Yes No NA NE
Please list the Lines/Right of WayslAerial Lines Inspected
One aeriallHP line was inspected and looked in good condition. Some vegetation was growing around it, but
did not limit access.
Are right-of-waysleasements maintained for full width for access by stafilequipment? ❑ ❑ ❑
If No, give details on temporary access.
Is maintenance documented? E ❑ ❑ ❑
Are gravity sewer cleaning records available? N ❑ ❑ ❑
Has at least 10% of lines older than 5 yrs been cleaned annually? E ❑ ❑ ❑
Were all areasitines inspected free of issues? ❑ ❑ ❑
Comment:
Manholes Yes No NA NE
Please list the Manholes Inspected.
Multiple manholes were observed and all had unobstructed flow and appeared in good condition.
Are manholes accessible? 0 ❑ ❑ ❑
Page 6 of 8

Permit: VMCS00217 Owner - Facility: Carolina Trace Utilities Inc
Inspection bale: 0612012019 Inspection Type : Collection System Inspect Non Sampling
Reason for Visit: Routine
# Are manhole coverslvenis above grade?
❑ rl
Are manholes free of visible signs of overflow?
Are manholes free of sinkholes and depressions?
0 El ❑ El
Are manhole covers present?
.
# Are manholes properly seated?
# Are manholes in good condition?
M El El El
# Are inverts in good condition?
Is flow unrestricted in manholes?
Are manholes free of excessive amounts of grease?
Are manholes free of excessive roots?
0 El El F1
Are manholes free of excessive sand?
Are manhole vents screened?
❑ ❑ ❑ .
Are vents free of submergence?
❑ ❑ 0 M
Are manholes free of bypass structures or pipes?
0
Comment: During the 2017 mapping and videoino by Re zone. 2 manholes were found to be low or
covered. They were rechecked and raised to proper specs.
Pump Stations
Yes No NA NE
Please list the Pump Stations Inspected
3 of the 6 duplex stations were observed. Woodfield, Harbor Creek. and Country Club.
# Number of duplex or larger pump stations in system
5
# Number of vacuum stations in system
# Number of simplex pump stations In system
7
# Number of simplex pump stations in system serving more than one building
How many pump/vacuum stations have-
# A two-way "auto polling" communication system (SCAOA) installed?
# A simple one-way telemetry/communication system (auto -dialer) installed?
For pump stations inspected.
Are they secure with restricted access?
❑ ❑
Were they free of by-pass structures/pipes?
. ❑ ❑ ❑
Were wet wells free of excessive grease/debris?
❑
# Do they all have telemetry installed?
W❑ ❑
Is the communication system functional?
❑11❑
Is a 24-hour notification sign posted ?
❑ ❑ ❑
Does the sign include
Owner Name?
❑ ❑
Pump station identifier?
11 11■ El
# Address?
■ El
Page 7 of 8

Pe,,it• WOCS00217 Owner - Facility: zarolina Trace Utilsties Inc
Inspection Date: 0612012019 Inspection Type: valWtion System Inspect Non Sampling Reason for Visit: Routine
Instructions for notification?
24-hour emergency contact numbers?
Are audio and visual alarms present?
Are audio and visual alarms operable?
# Is there a backup generator or bypass pump connected?
If tested during inspection, did it function property?
Is the back-up system tested at least bi-annually under normal operating Condit ons?
# Does it have a dedicated connection for a portable generator?
# is the owner relying on portable units in the event of a power outage?
# If Yes, is there a distribution plan?
It Yes. what resources (Units/StaffNehiciesletc) are included in Plan?
There are 3 portable units that can be pulled to ear:h station and can ut lize a "quick connect"_
# Does Permittee have the approved percentage of replacement simplex pumps?
Is recordkeeping of pump station inspection and maintenance program adequate?
Do pump station logs Include at a minimum:
❑❑■❑
❑ ❑ ❑
M ❑ ❑ ❑
❑ M ❑ ❑
■❑❑❑
❑ ❑ N ❑
■❑❑❑
M ❑ ❑ ❑
M ❑ ❑ ❑
■❑❑❑
Inside and outside cleaning and debris removal? ❑ ❑ ❑
Inspecting and exercising all valves? ❑ ❑ ❑
Inspecting and lubricating pumps and other equipment? 00110
Inspecting alarms, telemetry and auxiliary equipment? 0 ❑ ❑ ❑
Comment: All visited stations were in need of new si na a due to fading. All stations had working telemetry
alarms. Woodland and Harbor Creek audible/visual alarms did not work when floats were pulled.
Staff were to address the issue immediately.
Page 8 of 8