WQCSD0212_Compliance Evaluation Inspection_20200917

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
Thomas L. Monroe
5111 Mockingbird Rd
Greensboro, NC, 27406
NORTH CAROLINA
Environmental Quality
September 17, 2020
SUBJECT: Compliance Evaluation Inspection & Notice of Deficiency
NOD Tracking #: NOD-2020-PC-0450
Monroe's Mobile Home Park Wastewater Collection System
Non -discharge Permit #WQCSD0212
Guilford County
Dear Mr. Monroe:
Ron Boone, of the NC Division of Water Resources (DWR), Winston-Salem Regional Office (WSRO), visited
the Monroe mobile home park wastewater collection system on August 13th, 2020, to perform a Compliance
Evaluation Inspection (CEI). Your assistance and cooperation, as well as that of Bradley Flynt, Operator in Responsible
Charge (ORC), was greatly appreciated. Details of the inspection are recorded on the attached EPA Water Compliance
Inspection Report.
You're reminded that, in accordance with NC General Statute 143-215.6A, failure to comply with all
conditions of the permit subjects the Town of Beech Mountain to civil penalties not to exceed $25,000.00 per
violation, per day.
As there were some deficiencies that Mr. Boone noted during his inspection, please respond in writing to
this notice within 15 business days of receiving it. Your response should address each issue individually and include
your proposed corrective action with implementation schedule. Your written response will, in part, determine
whether DWR will pursue any further action regarding the noted deficiencies.
If you have any questions or require further assistance, please contact Mr. Boone by phone at 336-776-
9690, or by email at [e-mail]. You may also contact me by phone at 336-776-9700, or by email at
[e-mail].
Sincerely,
D—SiTgned by:
l t�M�ff
on°l�'niff F,"Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
Attachments:
1. EPA Water Compliance Inspection Report
cc: Laserfiche
Bradley Flynt, 8467 Southard Rd, Stokesdale, NC 27357
D � North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105
NOh r H CAROI.IN/+
oep I, 6,1 m �ku­�I o�a� /"� 336.776.9800

Permit: WQCSD0212
SOC:
County: Guilford
Region: Winston-Salem
Compliance Inspection Report
Effective: 03/01/00 Expiration: Owner: Monroe's Mobile Home Park
Effective: Expiration: Facility: Monroe's MHP Collection System
Contact Person: Thomas L Monroe Title:
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 08/13/2020 Entry Time 12:OOPM
Primary Inspector: Ron Boone
Secondary Inspector(s):
Certification:
Phone: [phone]
Phone:
Exit Time: 01:OOPM
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Collection System Inspect Non Sampling
Permit Inspection Type: Deemed permitted collection system management and operation
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Miscellaneous Questions General Grease Control
Spills/Response Plan Inspections Lines
Manholes Pump Stations
(See attachment summary)
Page 1 of 6

Permit: WQCSD0212 Owner - Facility: Monroe's Mobile Home Park
Inspection Date: 08/13/2020 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Inspection Summary:
Lines and right of ways are all in highly traveled common areas where spills and/or breaks would be immediately noticed by
residents and operators. Operators observe the entire park too when they visit the pump station and treatment plant. There
are no high priority lines.
Pump station operations and inspections are done by the treatment plant operators. The inspections are annotated in the
treatment plant logs.
Grease education is accomplished primarily through posting grease education informaton in public common areas such as
the mailboxes. Additional means should be considered, such as a once annual direct mailing and door to door delivery of
grease education material, although no grease related spills have yet been reported or recorded.
There is an old map of the park that does include the sanitary sewer lines, pump station, and treatment plant location. The
owner should consider developing a map that accurately and completely shows the entire collection system and includes
pipe material, pipe size, pump station name and capacity, and number of service taps.
The owner does NOT have an O&M Plan that includes everything required. The owner needs to develop the plan to be
compliant with the 02T regulations.
Page 2 of 6

Permit: WQCSD0212 Owner - Facility: Monroe's Mobile Home Park
Inspection Date: 08/13/2020 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
General
# Is this system a satellite system?
# If Yes, what is system name or permit number?
Is there a overall sewer system map?
Does the map include:
Yes No NA NE
❑■❑❑
■❑❑❑
Pipe sizes ❑ 0 ❑ ❑
Pipe materials (PVC, DIP, etc) ❑0 ❑ ❑
Pipe location ❑ ❑ ❑
# Flow direction ❑ ❑ ❑
# Approximate pipe age ❑ ❑ ❑
# Pump station ID, location and capacity ❑0 ❑ ❑
# Force main air release valve location & type ❑ ❑ ❑
# Location of satellite connections ❑ ❑ ❑
Are system maintenance records maintained? 0 ❑ ❑ ❑
Comment: Very old map. Can be used to estimate age of piping. Map shows pump station location only.
Grease Control Yes No NA NE
Is grease/sewer education program documented with req'd customer distribution? ❑ ❑ ❑
# Are other types of education tools used like websites, booths, special meetings, etc? ❑ ❑ ❑
If Yes, what are they? (This can reduce mailing to annual.)
For public systems, is there a Grease Control Program via an ordinance/agreement? ❑ ❑ ❑
If Yes, does it require grease control devices at applicable locations? ❑ ❑ ❑
Is the Grease Control Program enforced via periodic inspections/records review? ❑ ❑ ❑
Is action taken against violators? ❑ ❑ 0 ❑
Comment: None
Spills and Response Action Plan
Yes No NA NE
# Is system free of known points of bypass?
❑ ❑ ❑
If No, describe type of bypass and location
# Have there been any sewer spills in the past 3 years?
❑
❑ ❑
If Yes, were they reported to the Division if meeting the reportable criteria?
❑
❑ ❑
If applicable, is there documentation of press releases and public notices issued?
❑
❑ ❑
Are all spills or sewer related issues/complaints documented?
❑
❑ ❑
# Are there repeated overflows/problems (2 or more in 12 months) at same location?
❑
❑ ❑
# If Yes, is there a corrective action plan?
❑
❑ ❑
Is a Spill Response Action Plan available?
❑
❑ ❑
Is a Spill Response Action Plan available for all personnel?
❑
❑ ❑
Page 3 of 6

Permit: WQCSD0212 Owner - Facility: Monroe's Mobile Home Park
Inspection Date: 08/13/2020 Inspection Type : Collection System Inspect Non Sampling
Reason for Visit: Routine
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
❑
❑ 0 ❑
Comment: Permittee should write a spill action plan and post it in an area readily
available to himself and th
operator, Bradley Flynt.
Inspections Yes No NA NE
Are adequate maintenance records maintained? ❑ ❑ ❑
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? 0 ❑ ❑ ❑
# Does the system have any high -priority lines/locations? ❑ ❑ ❑
Are inspections of HPL documented at least every 6 months? ❑ ❑ ❑
Are new lines being added to the HPL list when found or created? ❑ ❑ 0 ❑
Comment: Operator annotates his system checks and maintenance in the plant records.
Lines/Right-of-Ways/Aerial Lines Yes No NA NE
Please list the Lines/Right of Ways/Aerial Lines Inspected:
All of system observeable along route traveled during inspection to the plant, then to the pump station, then to
the main office. There are no visible HPLs. No issues with below ground lines or ROWS noted.
Are right-of-ways and easements maintained for the full width for access? 0 ❑ ❑ ❑
If No, give details on temporary access:
Is maintenance documented? ❑ ❑ ❑
Were all areas/lines inspected free of issues? 0 ❑ ❑ ❑
Comment: All piping runs within common areas maintained by residents or park manager/owner. No
problems were noted during the inspection.
Manholes Yes No NA NE
Please list the Manholes Inspected:
There are no manholes in the system.
Are manholes accessible? ❑ ❑ ❑
# Are manhole covers/vents above grade? ❑ ❑ ❑
Are manholes free of visible signs of overflow? ❑ ❑ ❑
Page 4 of 6

Permit: WQCSD0212 Owner - Facility: Monroe's Mobile Home Park
Inspection Date: 08/13/2020 Inspection Type : Collection System Inspect Non Sampling
Reason for Visit: Routine
Are manholes free of sinkholes and depressions?
❑
❑ 0 ❑
Are manhole covers present?
❑
❑ 0 ❑
# Are manholes properly seated?
❑
❑ 0 ❑
# Are manholes in good condition?
❑
❑ 0 ❑
# Are inverts in good condition?
❑
❑ 0 ❑
Is flow unrestricted in manholes?
❑
❑ 0 ❑
Are manholes free of excessive amounts of grease?
❑
❑ 0 ❑
Are manholes free of excessive roots?
❑
❑ 0 ❑
Are manholes free of excessive sand?
❑
❑ 0 ❑
Are manhole vents screened?
❑
❑ 0 ❑
Are vents free of submergence?
❑
❑ 0 ❑
Are manholes free of bypass structures or pipes?
❑
❑ 0 ❑
Comment: None
Pump Stations
Yes No NA NE
Please list the Pump Stations Inspected:
Main (only PS in system).
# Number of duplex or larger pump stations in system
1
# Number of vacuum stations in system
0
# Number of simplex pump stations in system
0
# Number of simplex pump stations in system serving more than one building
0
How many pump/vacuum stations have:
# A two-way "auto polling" communication system (SCADA) installed?
0
# A simple one-way telemetry/communication system (auto -dialer) installed?
1
For pump stations inspected:
Are they secure with restricted access?
0
❑ ❑ ❑
Were they free of by-pass structures/pipes?
0
❑ ❑ ❑
Were wet wells free of excessive grease/debris?
0
❑ ❑ ❑
# Do they all have telemetry installed?
0
❑ ❑ ❑
Is the telemetry system functional?
0
❑ ❑ ❑
Is a 24-hour notification sign posted ?
❑
0 ❑ ❑
Does the sign include:
Owner Name?
❑
❑ 0 ❑
Pump station identifier?
❑
❑ 0 ❑
# Address?
❑
❑ 0 ❑
Instructions for notification?
❑
❑ 0 ❑
24-hour emergency contact numbers?
❑
❑ 0 ❑
Page 5 of 6

Permit: WQCSD0212 Owner - Facility: Monroe's Mobile Home Park
Inspection Date: 08/13/2020 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
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 properly?
Is the back-up system tested at least bi-annually under normal operating conditions?
# 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?
If Yes, what resources (Units/Staff/Vehicles/etc) are included in Plan?
# 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:
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?
Comment: None
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Page 6 of 6