NC0022462_Compliance Evaluation Inspection_20220304

DocuSign Envelope ID: 82640A5A-4C5D-485C-B7E7-1B6DB2FD5942
ROY COOPER
Gwemnr
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director Environmental Quality
NORTH CAROLINA
Certified Mail # 7018 2290 0001 8295 5948
Return Receipt Requested
March 29, 2022
Teresa I Schenk
Sherwood Mobile Home Park Associates LP
C/O DRS Realty Company
8255 Cascade Ave, Suite 120
Commerce Township, MI 48382-2217
SUBJECT: NOTICE OF VIOLATION
Tracking Number: NOV-2022-PC-0160
Permit No. NC0022462
Sherwood Mobile Home Park WWTP
Onslow County
Dear Permittee:
The North Carolina Division of Water Resources conducted an inspection of the Sherwood Mobile Home Park
WWTP on March 4, 2022. This inspection was conducted to verify that the facility is operating in compliance
with the conditions and limitations specified in NPDES WW Permit No. NC0022462. A summary of the findings
and comments noted during the inspection are provided in the enclosed copy of the inspection report.
The Compliance Evaluation inspection was conducted by Division of Water Resources staff from the Wilmington
Regional Office. The following violation(s) were noted during the inspection:
Inspection Area Description of Violation
Sand Filters (Low rate)
Sand filters must be evaluated by a 3rd party consultant to determine the amount of
remaining sand present. If more sand is needed to return filter to its designed depth,
then completely rehab one filter at a time so that the underdrain system can be inspected
& repaired if necessary. As part of the evaluation & rehab, the distribution system
should be redesigned and installed accordingly to provide more even distribution across
the surface.
Secondary Clarifier
The baffles and weirs are made of treated wood. All of the wood has now begun to rot
and now need to be replaced. Highly recommend use of materials that will not rot and
can be easily adjusted.
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DocuSign Envelope ID: 82640A5A-4C5D-485C-B7E7-1B6DB2FD5942
Inspection Area Description of Violation
Effluent Sampling
The facility must begin composite sampling after dechlorination which is the last
treatment process and this has been mentioned to do before. It will require the
dechlorination chemical dosing to be relocated to the end of the chlorine contact chamber
and convert to using liquid or gas due to lack of space.
Equalization Basins
The facility's EQ basin must have its missing air headers & diffusers replaced and
returned to service, the on -site audible alarm repaired or replaced, and masonry block
walls resealed on at least the outside due to observed evidence of past seepage.
Sand Filters (Low rate) The on -site audible & visual alarms on the filter dosing basin must be repaired
Additionally, the inspectors investigated a resident's complaint of a damaged & periodically discharging sewer
service which had been corrected between the time of the complaint and site visit a week later. Related the
park's sewer system (operating as an assigned deemed permitted system under WQCSD0578), the inspectors
noted an aerial force main from the main pump station crossing a stormwater drainage ditch near the entrance
to the treatment facility. The force main is PVC which isn't allowed for exposed sewer lines, exposed lines or
those with less than 3 feet of cover are required to be ductile iron pipe with no exposed joints unless using
restrained joints. Thus, the line needs to be replaced accordingly and that location would be classified as a
high -priority line (HPL) that must be inspected & documented for damage at least every 6 months.
To prevent further action, please respond in writing to this office within 30 days upon your receipt of this Notice
of Violation regarding your plans or measures to be taken to address each of the indicated violations and other
identified issues, if applicable. The response should provide a date or timetable to complete each item to be
addressed.
Lastly, the facility's permit expires at the end of June 2022 and the Permittee is required to submit
for renewal on their own six (6) months prior to expiration. To date this has not occurred and must
be received by our Central Office in Raleigh prior to expiration or the facility will likely have to meet
any new requirements that current facility doesn't meet.
If you should have any questions, please do not hesitate to contact Dean Hunkele or myself with the Water Quality
Regional Operations Section in the Wilmington Regional Office at 910-796-7215.
Sincerely,
—DocuSiggned by: .Y
l 0Ati t Y�O.fYln�\On.
"-7F141E73B6F3456...
Tom Tharrington, Asst. Regional Supervisor
Water Quality Regional Operations Section
Wilmington Regional Office
Division of Water Resources, NCDEQ
ATTACHMENT
Cc: WQS Wilmington Regional Office - Hunkele
Upload to Laserfiche
North CaroDna➢epartnem of Environmental Quality 0..1 of Water Resources
Vadrtngte Regional Office I Ri Cardnal Dive Extend. { Wilmington. North Car.. 25105 �

DocuSign Envelope ID: 82640A5A-4C5D-485C-B7E7-1B6DB2FD5942
United States Environmental Protection Agency
EPA Washington, D.C. 20460
Water Compliance Inspection Report
Form Approved.
OMB No. 2040-0057
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code
1 IN I 2 IL I
21IIIIII
NPDES yr/mo/day Inspection
3 I NC0022462 111 121 22/03/04 117
Type
1810I
IIIIIIIIIII
Inspector Fac Type
19I S I 2011
IIIIIIIIIIIIIIIIII I IIIIII
P6
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA Reserved
671I 70 I3 I 71 INI 72 I N I 73I 1 74 711
I I 1
I I I I I 180
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
Sherwood Mobile Home Park WWTP
753 Tallman Cir
Midway Park NC 28544
Entry Time/Date
10:45AM 22/03/04
Permit Effective Date
17/07/01
Exit Time/Date
12:30PM 22/03/04
Permit Expiration Date
22/06/30
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Darrell James Covington/ORC/910-451-7190/
Mikel Howard Seely//910-330-8011 /
Mikel Howard Seely/ORC/910-330-8011/
Sheila Covington/ORC/910-467-5034/
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Mikel Howard Seely, /Contract ORC/910-330-8011/
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenar Records/Reports
Self -Monitoring Progran Sludge Handling Dispo: Facility Site Review Compliance Schedules
Effluent/Receiving Wate Laboratory
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Dean Hunkele DWR/WIRO WQ/910-796-7215/ 3/29/2022
Tyler G Benson E,D9290Cao3746E „._oocuSlgnetlby: DWR/WIRO WQ/910-796-7336/ 3/29/2022
t lltr buA,sotn,
'--06DCAE400764466...
Signature of Management
Tom Tharringtor?oµ
Q A Reviewer Agency/Office/Phone and Fax Numbers Date
DocuSigned by:
_n 14/R/WIRO WQ/ - - / 3/29/2022
7F141E73B6F3456...
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page# 1

DocuSign Envelope ID: 82640A5A-4C5D-485C-B7E7-1B6DB2FD5942
3I
NPDES yr/mo/day
N C0022462 I11 121 22/03/04
17
Inspection Type
18LI
(Cont.)
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
The facility's permit expires at the end of June 2022 and the Permittee is required to submit for
renewal on their own six (6) months prior to expiration. To date this has not occurred and must be
received by our Central Office in Raleigh prior to expiration or the facility will likely have to meet any
new requirements that current facility doesn't meet.
The facility continues to operate in a marginal manner due to needed improvements not being made.
Items that must be addressed are listed below and some additional information may be within the
comment section of the main report:
1. The facility's EQ basin must have its missing air headers & diffusers replaced and return to
service, the on -site audible alarm repaired or replaced, and masonry block walls resealed on at least
the outside.
2. The secondary clarifier baffle and weirs must be replaced since current wood ones are rotting out.
3. The on -site audible & visual alarms on the filter dosing basin must be repaired.
4. Sand filters must be evaluated by a 3rd party consultant to determine the amount of remaining
sand present. If more sand is needed to return filter to its designed depth, then completely rehab
one filter at a time so that the underdrain system can be inspected & repaired if necessary. As part
of the evaluation & rehab, the distribution system should be redesigned and installed accordingly to
provide more even distribution across the surface.
5. The facility must begin composite sampling after dechlorination which is the last treatment process
and this has been mentioned to do before. It will require the dechlorination chemical dosing to be
relocated to the end of the chlorine contact chamber and convert to using liquid or gas due to lack of
space.
6. Additionally, the inspectors investigated a resident's complaint of a damaged & periodically
discharging sewer service which had been corrected between the time of the complaint and site visit
a week later. Related the park's sewer system (operating as an assigned deemed permitted system
under WQCSD0578), the inspectors noted an aerial force main from the main pump station crossing
a stormwater drainage ditch near the entrance to the treatment facility. The force main is PVC which
isn't allowed for exposed sewer lines, exposed lines or those with less than 3 feet of cover are rquired
to be ductile iron pipe with no exposed joints unless using restrained joints. Thus, the line needs to
be replaced accordingly and that location would be classified as a high -priority line (HPL) that must
be inspected & documented for damage at least every 6 months.
Page# 2

DocuSign Envelope ID: 82640A5A-4C5D-485C-B7E7-1B6DB2FD5942
Permit: NC0022462
Inspection Date: 03/04/2022
Owner - Facility: Sherwood Mobile Home Park WWTP
Inspection Type: Compliance Evaluation
Permit Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new El El El
application?
Is the facility as described in the permit? • El El El
# Are there any special conditions for the permit? El El • El
Is access to the plant site restricted to the general public? • ❑ ❑ ❑
Is the inspector granted access to all areas for inspection? • El El El
Comment: Permittee is past due in applying for renewal and needs to submit it ASAP; must be
received by our Central Office prior to expiration on June 30, 2022. Fencing around
facility should be higher since its only 3-4 feet tall which can be easily climbed over
plus the outfall works are unsecured.
Compliance Schedules
Is there a compliance schedule for this facility?
Is the facility compliant with the permit and conditions for the review period?
Yes No NA NE
Comment: Since last inspection in 2017, the facility has been issued 13 Notices of Violations and
3 civil penalty assessments for limit violations.
Record Keeping Yes No NA NE
Are records kept and maintained as required by the permit? • ❑ ❑ ❑
Is all required information readily available, complete and current? • El El El
Are all records maintained for 3 years (lab. reg. required 5 years)? ❑ ❑ ❑ •
Are analytical results consistent with data reported on DMRs? El El El •
Is the chain -of -custody complete? El El El •
Dates, times and location of sampling El
Name of individual performing the sampling ❑
Results of analysis and calibration ❑
Dates of analysis El
Name of person performing analyses El
Transported COCs ❑
Are DMRs complete: do they include all permit parameters? • El El El
Has the facility submitted its annual compliance report to users and DWQ? El ❑ • ❑
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified El El • El
operator on each shift?
Is the ORC visitation log available and current? • ❑ El El
Is the ORC certified at grade equal to or higher than the facility classification? • El El El
Page# 3

DocuSign Envelope ID: 82640A5A-4C5D-485C-B7E7-1B6DB2FD5942
Permit: NC0022462
Inspection Date: 03/04/2022
Owner - Facility: Sherwood Mobile Home Park WWTP
Inspection Type: Compliance Evaluation
Record Keeping
Is the backup operator certified at one grade less or greater than the facility
classification?
Is a copy of the current NPDES permit available on site?
Facility has copy of previous year's Annual Report on file for review?
Comment:
Laboratory
Are field parameters performed by certified personnel or laboratory?
Are all other parameters(excluding field parameters) performed by a certified lab?
# Is the facility using a contract lab?
# Is proper temperature set for sample storage (kept at less than or equal to 6.0
degrees Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
Comment:
Yes No NA NE
• ❑ ❑ ❑
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
❑ ❑ • ❑
❑ ❑ • ❑
Bar Screens Yes No NA NE
Type of bar screen
a.Manual •
b.Mechanical ❑
Are the bars adequately screening debris? • ❑ ❑ ❑
Is the screen free of excessive debris? ■ ❑ ❑ El
Is disposal of screening in compliance? ❑ • ❑ ❑
Is the unit in good condition? • ❑ ❑ ❑
Comment: Old screenings observed on ground near unit, these need to be placed in a covered
trash can until properly disposed of.
Equalization Basins
Is the basin aerated?
Is the basin free of bypass lines or structures to the natural environment?
Is the basin free of excessive grease?
Are all pumps present?
Are all pumps operable?
Are float controls operable?
Yes No NA NE
• ❑ ❑ ❑
Page# 4

DocuSign Envelope ID: 82640A5A-4C5D-485C-B7E7-1B6DB2FD5942
Permit: NC0022462
Inspection Date: 03/04/2022
Owner - Facility: Sherwood Mobile Home Park WWTP
Inspection Type: Compliance Evaluation
Equalization Basins
Are audible and visual alarms operable?
# Is basin size/volume adequate?
Yes No NA NE
❑ • ❑ ❑
Comment: Several of the air header drops have been removed from the basin so the mixing & air
delivery is inconsistent, thus the missing headers & diffusers must be returned to
service. The audible alarm was non-functional and must be repaired. The outside
masonry walls of the basin show signs of seepage from when basin is high, thus the
basin needs to be resealed. It is highly recommended that telemetry be installed on
the basin to notify operator, park manager, or owner of a high level or power failure at
the facility to avoid a spill.
Aeration Basins Yes No NA NE
Mode of operation Ext. Air
Type of aeration system Diffused
Is the basin free of dead spots? • ❑ ❑ ❑
Are surface aerators and mixers operational? El El • El
Are the diffusers operational? • El El El
Is the foam the proper color for the treatment process? • El El El
Does the foam cover less than 25% of the basin's surface? • El El El
Is the DO level acceptable? El El El •
Is the DO level acceptable?(1.0 to 3.0 mg/I) El El El •
Comment: Activated sludge a little dark, but not too bad for this time of year. One of the two
blowers serving half of the aeration was non-functional due to a bad check valve, thus
needs to be repaired ASAP so its available to not only alternate their use but in case
the active one fails.
Nutrient Removal Yes No NA NE
# Is total nitrogen removal required? El ❑ • El
# Is total phosphorous removal required? • El El El
Type Chemical
# Is chemical feed required to sustain process? • ❑ El El
Is nutrient removal process operating properly? ❑ ❑ El •
Comment: Chemical feed was off-line and ORC stated it wasn't needed during winter months to
meet limit.
Secondary Clarifier
Is the clarifier free of black and odorous wastewater?
Is the site free of excessive buildup of solids in center well of circular clarifier?
Yes No NA NE
❑ ❑ • ❑
Page# 5

DocuSign Envelope ID: 82640A5A-4C5D-485C-B7E7-1B6DB2FD5942
Permit: NC0022462
Inspection Date: 03/04/2022
Owner - Facility: Sherwood Mobile Home Park WWTP
Inspection Type: Compliance Evaluation
Secondary Clarifier
Are weirs level?
Is the site free of weir blockage?
Is the site free of evidence of short-circuiting?
Is scum removal adequate?
Is the site free of excessive floating sludge?
Is the drive unit operational?
Is the return rate acceptable (low turbulence)?
Is the overflow clear of excessive solids/pin floc?
Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth)
Yes No NA NE
❑ • ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Comment: The baffles and weirs are made of treated wood; all of the wood has now begun to rot
and now need to be replaced. Highly recommend use of materials that will not rot or
corrode and can be easily adjusted.
Pumps-RAS-WAS
Are pumps in place?
Are pumps operational?
Are there adequate spare parts and supplies on site?
Comment• Uses air lifts
Aerobic Digester
Is the capacity adequate?
Is the mixing adequate?
Is the site free of excessive foaming in the tank?
# Is the odor acceptable?
# Is tankage available for properly waste sludge?
Comment:
Sand Filters (Low rate)
(If pumps are used) Is an audible and visible alarm Present and operational?
Is the distribution box level and watertight?
Is sand filter free of ponding?
Is the sand filter effluent re -circulated at a valid ratio?
# Is the sand filter surface free of algae or excessive vegetation?
# Is the sand filter effluent re -circulated at a valid ratio? (Approximately 3 to 1)
Yes No NA NE
• ❑ ❑ ❑
❑ ❑ • ❑
Yes No NA NE
• ❑ ❑ ❑
❑ ❑ ❑ •
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Yes No NA NE
❑ • ❑ ❑
❑ ❑ • ❑
❑ • ❑ ❑
❑ • ❑ ❑
❑ ❑ • ❑
Page# 6

DocuSign Envelope ID: 82640A5A-4C5D-485C-B7E7-1B6DB2FD5942
Permit: NC0022462
Inspection Date: 03/04/2022
Owner - Facility: Sherwood Mobile Home Park WWTP
Inspection Type: Compliance Evaluation
Sand Filters (Low rate) Yes No NA NE
Comment: Alarm system on pump tank feeding filter distribution box were non-functional and
needs to be repaired ASAP. Pump tank had moderate amounts of solids which
operator stated is cleaned out periodically. Need to keep solids level low enough to
avoid sending excessive solids to the filters. Left filter was in full use, was clean, but
ponding on front half as distribution system is still inconsistent; still recommend using
dosing pumps to pressurize distribution lines. A small amount of flow was entering the
right filter which was ponding and surface covered with algae & grass/weeds. The
filters have been in need of rehabilitation for many years as the current depth of sand
is unknown as well as condition of the underdrain system.
Disinfection -Liquid
Is there adequate reserve supply of disinfectant?
(Sodium Hypochlorite) Is pump feed system operational?
Is bulk storage tank containment area adequate? (free of leaks/open drains)
Is the level of chlorine residual acceptable?
Is the contact chamber free of growth, or sludge buildup?
Is there chlorine residual prior to de -chlorination?
Comment:
De -chlorination
Type of system ?
Is the feed ratio proportional to chlorine amount (1 to 1)?
Is storage appropriate for cylinders?
# Is de -chlorination substance stored away from chlorine containers?
Comment:
Are the tablets the proper size and type?
Are tablet de -chlorinators operational?
Number of tubes in use?
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ •
• ❑ ❑ ❑
Yes No NA NE
Tablet
❑ ❑ • ❑
• ❑ ❑ ❑
❑ ❑ ❑ ■
• ❑ ❑ ❑
Comment: It is unclear where TRC is measured since the tablet box is at the end of the outfall
pipe. As has been mentioned before, the facility should use liquid dripped onto the
weir after chlorination prior to composite sampling and with TRC measured at the end
of the outfall pipe.
Flow Measurement - Effluent
# Is flow meter used for reporting?
Is flow meter calibrated annually?
Is the flow meter operational?
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Page# 7

DocuSign Envelope ID: 82640A5A-4C5D-485C-B7E7-1B6DB2FD5942
Permit: NC0022462
Inspection Date: 03/04/2022
Owner - Facility: Sherwood Mobile Home Park WWTP
Inspection Type: Compliance Evaluation
Flow Measurement - Effluent Yes No NA NE
(If units are separated) Does the chart recorder match the flow meter? • ❑ ❑ ❑
Comment: Calibrated 4-30-2021; new meter datalogs flows -- this information should be
downloaded on a monthly basis to avoid loss of the data.
Effluent Sampling Yes No NA NE
Is composite sampling flow proportional? • ❑ ❑ ❑
Is sample collected below all treatment units? ❑ • ❑ ❑
Is proper volume collected? ❑ ❑ ❑ •
Is the tubing clean? • ❑ ❑ ❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 ■ ❑ ❑ ❑
degrees Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type ■ ❑ ❑ ❑
representative)?
Comment: Supposedly flow proportional with new flow meter. Composite samples should be
collected post de -chlorination. Temp at 3 C
Effluent Pipe
Is right of way to the outfall properly maintained?
Are the receiving water free of foam other than trace amounts and other debris?
If effluent (diffuser pipes are required) are they operating properly?
Comment:
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, MODE
and sampling location)?
Comment:
Standby Power
Is automatically activated standby power available?
Is the generator tested by interrupting primary power source?
Is the generator tested under load?
Was generator tested & operational during the inspection?
Do the generator(s) have adequate capacity to operate the entire wastewater site?
Is there an emergency agreement with a fuel vendor for extended run on back-up
power?
Is the generator fuel level monitored?
Yes No NA NE
❑ ❑ • ❑
❑ ❑ • ❑
❑ ❑ • ❑
Page# 8

DocuSign Envelope ID: 82640A5A-4C5D-485C-B7E7-1B6DB2FD5942
Permit: NC0022462
Inspection Date: 03/04/2022
Owner - Facility: Sherwood Mobile Home Park WWTP
Inspection Type: Compliance Evaluation
Standby Power Yes No NA NE
Comment: Owner should consider having back-up power installed to avoid a spill or loss of
viability in the activated sludge due to a power outage lasting longer than a short
period of time.
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? ❑ • ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable DEEM
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: See filter summary
Page# 9