WQ0002838_NOD-2020-PC-0087_20200304

ROY COOPER
Governor
MICHAEL S. REGAN
5emtary
S. DANIEL SMITH
Alrector
Karen Hamilton
YES Companies EXP WFC, LLC
1900 16" Street -Suite 950
Denver, CO 80202
Ms. Hamilton,
NORTH CAROLINA
Environmental Quality
March 4, 2020
Subject: NOTICE OF DEFICIENCY
NOD-2020-PC-0087
Compliance Evaluation Inspection
Deerhurst MHP WWTF
Wastewater Irrigation System
Permit Number WQ0002838
Wake County
On March 4, 2020, Rick Trone of the Raleigh Regional Office conducted a compliance evaluation
inspection of the wastewater irrigation system at Deerhurst Mobile Home Park. The purpose of this
inspection was to ensure compliance with the subject permit. During the inspection, the cooperation and
assistance provided by the Operators in Responsible Charge, Dale and Andy Matthews was helpful and
appreciated. Also present was Frank D'Antonio who operates the irrigation system, and Eric Wysong of
Apex Companies, LLC.
This compliance evaluation inspection consisted of the following:
• Review of the permit;
• Review of the owner/facility information;
• Review of ORC logbooks, calibration documentation, Non -discharge wastewater monitoring
reports (NDMR), Non -discharge application reports (NDAR), Compliance Monitoring Forms
(G W-59) and;
• On -site inspection of treatment components and spray fields
The current permit was issued September 11, 2019 and expires on November 30, 2025.
Components of the wastewater system appeared to be overall well -maintained and operational. The
collection system has no aerial or high -priority sewer lines or pump stations. The influent flowmeter was
last calibrated in December 2019 by Carolina Technical Services. The chlorination equipment appeared to
be in good condition. A representative soil analyses was last conducted in March 2019; however, this test
North Carolina Department of Environmental Quality ! Division or Water Resources
Raleigh Regional Office 13500 Barrett Drive I Raleigh. North Carolina 27609

was a Predictive Home and Garden analyses instead of the permit required Standard Soil Fertility
Analysis. Please ensure in the future that the correct soil analysis is requested. Staff explained that
material regarding fats, oils, and grease is distributed to residents quarterly. Water in the storage lagoon
was free of solids and plenty of freeboard was available at the time of inspection.
The stabilization and polishing pond are experiencing erosion to the lagoon berms. This appears to be
most problematic on the stabilization/storage lagoon. These erosion issues have created large gaps
beneath the fencing on the west side of the lagoon. It is recommended that the facility start investigating
corrective measures to stop and repair this erosion to prevent future problems or a failure of the berm
itself.
NDMR records for 2019 were reviewed. The facility is monitoring the effluent as required. Meritech
analyzes effluent samples. A few random months of lab results were compared to NDMR forms with no
discrepancies noted. Occasionally the facility reports ERROR in the flow column because a problem with
the influent flowmeter prevents an accurate read on some days. Please address this issue with the
flowmeter.
All four monitoring wells were observed and appeared to be in good condition. GW-59 reports for 2018-
2019 were reviewed. The facility should submit lab results for well sampling with each set of GW-59's as
required by the permit. The facility failed to analyze the monitoring wells for Volatile Compounds in
2019. Please ensure these samples are taken as soon as possible and the results submitted with the
GW-59's.
NDAR forms for 2019 were reviewed. No issues were noted with form NDAR. The facility maintains
four spray fields. Mr. D'Antonio explained that field A was not in operation due to some problems with
the equipment. A function check was not performed on the fields during this inspection due to wet
conditions. Spray heads observed appeared to be in good condition. Standing water was observed in low
areas of the irrigation area. This standing water is not believed to be irrigation water, but instead due to
the naturally wet conditions in certain parts of the fields. As discussed, please ensure these wet areas are
not irrigated during wet times of the year.
The following permit condition deficiencies were noted during the March 4, 2020 compliance
inspection and records review:
IV. Monitorine and Renortine Reauirements
Condition 10, which states that, "Monitoring wells shall be sampled at the frequencies and for the
parameters specified in Attachment C." Attachment C requires sampling for Volatile Compounds
annually in November. The facility missed this sampling requirement in 2019. Please ensure wells are
sampled for VOC's during the next round of groundwater sampling. Please submit all groundwater
monitoring lab results with form GW-59.

If you have any questions about this inspection or this letter, please contact Rick Trone at
rick.troneQncdenr.gov or 919-791-4200.
Sincerely,
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Attachments: EPA Water Compliance Inspection Report
cc:
Central Files
Laserfiche
Dale Matthews, ORC (via email at [e-mail])
Eric Wysong (via email at [e-mail])

Compliance Inspection Report
Permit: W00002838 Effective: 09/11/19 Expiration: 11/30/25 Owner: Yes Companies Exp Wfc LLC
SOC: Effective: Expiration: Facility: Deerhurst MHP WWTF
County: Wake 6200 Privette Rd
Region: Raleigh
Wendell NC 27591
Contact Person: Karen E Hamilton Title: Vice President Phone: [phone]
Directions to Facility:
From US 64 E (Bus) heading toward Wendell, turn left onto NC Hwy 97, make an Immediate left onto Edgemont Road, go
approximately 3 miles and turn left onto Privette Road. Deerhurst MHP is at the end of Privette Road.
System Classifications: Si,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 0310412020 EntryTime: 10 00AM
Primary Inspector: Rick V Trone
Secondary Inspector(s):
Reason for Inspection: Routine
Permit Inspection Type: Wastewater Irrigation
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Miscellaneous Questions Treatment
Treatment Lagoons End Use-Irrigat on
Storage Wells
(See attachment summary)
Exit Time: 11:30AM
Phone: [phone]
Inspection Type: Compliance Evaluation
Record Keeping
Treatment Disinfection
Page 1 of 6

permit; WC100021338 Owner - Facility: Yes Companies Exp Wfc LLC
Inspection Date: 0310412020 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
On March 4, 2020, Rick Trone of the Raleigh Regional Office conducted a compliance evaluation inspection of the
wastewater irrigation system at Deerhurst Mobile Home Park. The purpose of this inspection was to ensure compliance with
the subject permit. During the inspection, the cooperation and assistance provided by the Operators in Responsible Charge,
Dale and Andy Matthews was helpful and appreciated. Also present was Frank D'Antonio who operates the irrigation
system, and Eric Wysong of Apex Companies, LLC.
This compliance evaluation inspection consisted of the following:
-Review of the permit;
-Review of the owner/facility information;
-Review of ORC logbooks, calibration documentation, Non -discharge wastewater monitoring reports (NDMR), Non -discharge
application reports (NDAR), Compliance Monitoring Forms (GW-59) and;
"On -site inspection of treatment components and spray fields
The current permit was issued September 11, 2019 and expires on November 30, 2025
Components of the wastewater system appeared to be overall well -maintained and operational. The collection system has
no aerial or high -priority sewer lines or pump stations. The influent flowmeter was last calibrated in December 2019 by
Carolina Technical Services. The chlorination equipment appeared to be in good condition. A representative soil analyses
was last conducted in March 2019; however, this test was a Predictive Home and Garden analyses instead of the permit
required Standard Soil Fertility Analysis. Please ensure in the future that the correct soil analysis is requested. Staff
explained that material regarding fats, oils, and grease is distributed to residents quarterly. Water in the storage lagoon was
free of solids and plenty of freeboard was available at the time of inspection.
The stabilization and polishing pond are experiencing erosion to the lagoon berms. This appears to be most problematic on
the stabilization/storage lagoon. These erosion issues have created large gaps beneath the fencing on the west side of the
lagoon. It is recommended that the facility start investigating corrective measures to stop and repair this erosion to prevent
future problems or a failure of the berm Itself.
NDMR records for 2019 were reviewed. The facility is monitoring the effluent as required. Meritech analyzes effluent
samples. A few random months of lab results were compared to NDMR forms with no discrepancies noted. Occasionally the
facility reports ERROR in the flow column because a problem with the influent flowmeter prevents an accurate read on some
days. Please address this issue with the flowmeter.
All four monitoring wells were observed and appeared to be in good condition. GW-59 reports for 2018-2019 were reviewed.
The facility should submit lab results for well sampling with each set of GW-59's as required by the permit. The facility failed
to analyze the monitoring wells for Volatile Compounds in 2019. Please ensure these samples are taken as soon as
possible and the results submitted with the GW-59's.
NDAR forms for 2019 were reviewed. No issues were noted with form NDAR. The facility maintains four spray fields. Mr.
D'Antonio explained that field A was not in operation due to some problems with the equipment. A function check was not
performed on the fields during this inspection due to wet conditions. Spray heads observed appeared to be in good condition.
Standing water was observed in low areas of the irrigation area. This standing water is not believed to be irrigation water, but
instead due to the naturally wet conditions in certain parts of the fields. As discussed, please ensure these wet areas are
not irrigated during wet times of the year.
The following permit condition deficiencies were noted during the March 4, 2020 compliance inspection and records review:
IV. Monitoring and Reporting Requirements
Condition 10, which states that, "Monitoring wells shall be sampled at the frequencies and for the parameters specified in
Attachment C." Attachment C requires sampling for Volatile Compounds annually in November. The facility missed this
sampling requirement in 2019. Please ensure wells are sampled for VOC's during the next round of groundwater sampling.
Page 2 of 6

permit: W00002aw Owner - Facility: Yes Companies Exp Wfc LLC
Inspection pate: 0310412020 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Please submit all groundwater monitoring lab results with form GW-59.
Page 3 of 6

Penult: W00002838 Owner - Facility: Yes Companies Exp Wfc LLC
Inspection Date: 03104/2020 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Tvpe
Yes No NA NE
Activated Sludge Spray, HR
❑
Infiltration System
❑
Lagoon Spray, LR
❑
Single Family Spray, LR
❑
Single Family Drip
❑
Activated Sludge Drip, LR
❑
Recycle/Reuse
❑
Reuse (Quality)
❑
Activated Sludge Spray, LR
❑
Treatment Yes No NA NE
Are Treatment facilities consistent with those outlined in the current permit? M ❑ ❑ ❑
Do all treatment units appear to be operational? (if no, note below.) 011130
Comment:
Treatment Disinfection
Yes No NA NE
Is the system working?
M ❑ ❑ ❑
Do the fecal coliform results indicate proper disinfection?
❑ N ❑ ❑
Is there adequate detention time (-30 minutes)?
E ❑ ❑ ❑
Is the system properly maintained?
0 ❑ ❑ ❑
If gas, does the cylinder storage appear safe?
❑ ❑ M ❑
Is the fan in the chlorine feed room and storage area operable?
❑ ❑ N ❑
is the chlorinator accessible?
E ❑ ❑ ❑
If tablets, are tablets present?
E ❑ ❑ ❑
Are the tablets the proper size and type?
0 ❑ ❑ ❑
Is contact chamber free of sludge, solids, and growth?
❑ ❑ ❑ ■
It UV, are extra UV bulbs available?
❑ ❑ 0 ❑
If UV, is the UV intensity adequate?
❑ ❑ N ❑
# Is it a dual feed system?
❑ ❑ 0 ❑
Does the Stationary Source have more than 2500 Ibs of Chlorine (CAS No. 7792-50-5)?
❑ ❑ 0 ❑
If yes, then is there a Risk Management Plan on site?
❑ ❑ 0 ❑
If yes, then what is the EPA twelve digit ID Number? (1000-= _)
If yes, then when was the RMP last updated?
Comment: ORC discussed high fecal counts found during sampling events. The permit
has no limits on
fecal but the ORC is concerned about the high counts and is attempting
to address the problem.
Residual chlorine levels appear to be adequate.
Page 4 of 6

Permit: W00002am Owner - Facility: Yes Companies Exp Wfc LLC
Inspection Date: 03104/2020 Inspection Typo: Compliance Evaluation
Reason for Visit: Routine
Record Keeping
Yes No NA NE
Is a copy of current permit available?
00 0
Are monitoring reports present, NDMR?
NDAR?
0p p p
Are flow rates less than of permitted flow?
Are flow rates less than of permitted flow?
Are application rates adhered to?
0 El 0 El
Is GW monitoring being conducted, if required (GW-59s submitted)?
0 O 00
Are all samples analyzed for all required parameters?
Are there any 2L GW quality violations?
0 0■ o
Is GW-59A certification form completed for facility?
Is effluent sampled for same parameters as GW?
0
Do effluent concentrations exceed GW standards?
Are annual soil reports available?
# Are PAN records required?
❑ 0 0 ❑
# Did last soil report indicate a need for lime?
0 0 ❑ a
If so, has it been applied?
0 ❑ 0
Are operational logs present?
❑
Are tab sheets available for review?
0 0❑
Do lab sheets support data reported on NDMR?
0
Do tab sheets support data reported on GW-59s?
O 0
Are Operational and Maintenance records present?
0❑ Cl ❑
Were Operational and Maintenance records complete?
N❑ 11 ❑
Has permittee been free of public complaints in last 12 months?
■ 0 0 ❑
Is a copy of the SOC readily available?
0 0 ■ 11
No treatment units bypassed since last inspection?
0❑ so
Comment: Facility failed to sample wells for Volatile Compounds in 2019.
End Use -irrigation
Yes No NA NE
Are buffers adequate?
0❑ ❑ ❑
Is the cover crop type specified in permit?
E ❑ 0 71
Is the crop cover acceptable?
N❑ 0
Is the site condition adequate?
E ❑ 1:111
Is the site free of runoff / ponding?
E❑ ❑ ❑
Is the acreage specified in the permit being utilized?
0 ❑ ❑
Is the application equipment present?
0 ❑ 1313
Is the application equipment operational?
0 ❑ ❑ ❑
Page 5 of 6

permit: W00002838 owner - Facility: Yes Companies Esp Wic LLC
Inspection Date: 0310412020 Inspection Type; Compliance Evaluation Reason for Visit: Routine
Is the disposal field free of limiting slopes?
❑ ❑ M ❑
Is access restricted and/or signs posted during active site use?
M ❑ ❑ ❑
Are any supply wells within the C137
❑ ❑ 0 ❑
Are any supply wells within 250' of the CB?
❑ ❑ M ❑
How close is the closest water supply well?
❑ ❑ 0 ❑
Is municipal water available in the area?
❑ ❑ M ❑
# Info only: Does the permit call for monitoring wells?
M ❑ ❑ ❑
Are GW monitoring wells located properly wt respect to RB and CB7
Are GW monitoring wells properly constructed, including screened interval?
Are monitoring welts damaged?
Comment: See summa .
Page 6 of 6