WQCSD0210_NOD2022PC0046_20220411

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
T3t Cranbrook LLC
Attn: Robert Kane
1150 Hungry Neck Blvd, Ste 359
Mt Pleasant, SC 29464
NORTH CAROLINA
Environmental Quality
April 11, 2022
SUBJECT: Notice of Deficiency & Compliance Evaluation Inspection
Tracking #: NOD-2022-PC-0046
Cranbrook Village Community Collection System
Deemed Permitted Collection System Tracking #: WQCSD0210
Guilford County
Dear Mr. Kane:
Mr. Ron Boone, of the NC Division of Water Resources (NCDWR), Winston-Salem Regional
Office (WSRO), conducted a compliance evaluation inspection of the Cranbrook Village
Community wastewater collection system, on March 16, 2022. Mr. Boone met with Paul Smith,
Operator in Responsible Charge of the wastewater treatment system, along with Kevin Davidson,
with Agri -Waste Technologies, Inc., and Steve Barry, with AQWA, Inc. Their assistance and
cooperation were greatly appreciated. Inspection findings are detailed in the attached Compliance
Inspection Report and summarized below.
Deemed permitted wastewater collection systems in North Carolina must be operated and
maintained in accordance with NC regulation 15A NCAC 02T .0400. Mr. Smith stated that he is
not under contract to operate and maintain the wastewater collection system and did not know of
anyone who is. No operation and maintenance records or documentation of any type was presented
for evaluation during the inspection, and it appears that none of the required operation and
maintenance has been done. Cranbrook is therefore considered non -compliant with all ten of the
conditions listed under 15A NCAC 02T .0403.
Please be aware that the Division may take enforcement action against any permittee who fails to
comply with any requirement of their permit. Pursuant to NC General Statute (NCGS) 143-215.6A,
a civil penalty of not more than twenty-five thousand dollars ($25,000.00) may be assessed against
any person who violates or fails to act in accordance with the terms, conditions, or requirements
of any permit issued pursuant to G.S. 143-215.1.
GDE
NORTH C CLI JA '
D. mmmr� .orennt o�.i
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105
336.776.9800

If you have any questions or concerns, please do not hesitate to contact Mr. Boone by phone at
336-776-9690, or by email at [e-mail]. Thank you in advance for your time and
attention to this matter.
Sincerely,
DocuSigned by:
0D2D3CE3F 167456
Jennifer F. Graznak, Assistant Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
Attachments:
1. Water Compliance Inspection Report
2. Copy of 15A NCAC .0400 Regulations
cc: 1. Laserfiche
2. Rich CoAngelo, Owner, via email
[e-mail]
D_E
NORTH CARCLINA
gaparMeM of Environment,/quay
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 W. Hanes Mill Rd, Suite 300 I Raleigh, North Carolina 27105
336.776.9800

Compliance Inspection Report
Permit: WQCSD0210 Effective: 03/01/00 Expiration:
SOC: Effective: Expiration:
County: Guilford
Region: Winston-Salem
Contact Person: James W Radford
Directions to Facility:
Owner : NC Land Lease LLC
Facility: Cranbrook Village Collection System
Title: Managing Member Phone: [phone]
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 03/16/2022
Primary Inspector: Ron Boone
Secondary Inspector(s):
Entry Time 10:OOAM
DocuSigned by:
oruriet 13oon.e
B20F8DD5F2A3460...
Exit Time: 11:OOAM
4/11/2022 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
II Spills/Response Plan
▪ Manholes
(See attachment summary)
▪ General
▪ Inspections
▪ Pump Stations
▪ Grease Control
▪ Lines
Page 1 of 7

Permit: WQCSD0210 Owner - Facility: NC Land Lease LLC
Inspection Date: 03/16/2022
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Inspection Summary:
Ron Boone, of the NC Division of Water Resources (DWR), Winston-Salem Regional Office, met with
Paul Smith, Operator in Responsible Charge of the wastewater treatment system, on 3/16/2022, to perform a compliance
evaluation inspection of the Cranbrook wastewater collection system. Below is a summary of the inspection findings.
According to Mr. Smith, he is not operator for the collection system is no operator has been assigned to his knowledge. As
such, none the requirements for the proper operation and maintenance of the wastewater collection system are currently
being met. There are ten primary requirements, which are detailed below:
In accordance with 15A NCAC 02T .0403 PERMITTING BY REGULATION
(1) The collection system shall be effectively maintained and operated at all times to prevent discharge to land or surface
waters and to prevent any contravention of groundwater standards or surface water standards.
Although no wastewater spills have been recorded or reported at Cranbrook, there was no documentation available during th
inspection to show compliance with this condition or the other nine conditions listed below. You are therefore considered
noncompliant with this condition.
(2) A map of the collection system shall have been developed and shall be maintained.
A map of the collection system was not available during the inspection and Mr. Smith was not aware whether one exists.
You are therefore considered noncompliant with this condition.
(3) An operation and maintenance plan, including pump station inspection frequency, preventative maintenance schedule,
spare parts inventory, and overflow response shall have been developed and implemented.
No O&M plan was available during the inspection and Mr. Smith was not aware whether one exists. You are therefore
considered noncompliant with this condition.
(4) Pump stations that are not connected to a telemetry system shall be inspected by the permittee or its representative
every day, 365 days per year, unless the permittee demonstrates that daily inspections are not necessary because the
pump station has sufficient storage capacity, above the elevation at which the pump activates, to justify a longer inspection
interval. In no case shall the inspection interval exceed seven days. Pump stations that are connected to a telemetry
system shall be inspected once per week.
There are several pump stations in the system, one at each step tank, which must be inspected 365 days/year. No O&M
plan or inspection records for the pump stations were available during the inspection and Mr. Smith was not aware whether
any existed. You are therefore considered noncompliant with this condition.
(5) High -priority sewers shall be inspected by the permittee or its representative once every six months, and inspections
shall be documented.
It is unknown whether any HPSs, as defined in 15A NCAC 02T .0402 DEFINITIONS, exist within the collection system.
There were no records of inspections and maintenance of HPSs
(6) A general observation by the permittee or its representative of the entire collection system shall be conducted once per
year.
There were no records of general observations being conducted as required above. You are therefore considered
noncompliant with this condition.
(7) Overflows and bypasses shall be reported to the appropriate Division regional office in accordance with 15A NCAC 02B
Page 2 of 7

Permit: WQCSD0210 Owner - Facility: NC Land Lease LLC
Inspection Date: 03/16/2022
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
.0506(a), and public notice shall be provided as required by G.S. 143215.1 C.
As mentioned above, no wastewater spills have been recorded or reported at Cranbrook.
(8) A Grease Control Program shall be in place as follows: (B) For privately owned collection systems, which Cranbrook is,
the Grease Control Program shall include biannual distribution of grease education materials to users of the collection
system by the permittee or its representative. (C) Grease education materials shall be distributed more often than required in
Part (B) of this Subparagraph if necessary to prevent grease -related sanitary sewer overflows.
No grease education documentation was availabe during the inspection. It appears this requirement is NOT being
accomplished. You are therefore considered noncompliant with this condition.
(9) Right-of-ways and easements shall be maintained in the full easement width for personnel and equipment accessibility.
There is no record of whether any such right-of-ways exist in the system and there are no records of the required
maintenance. You are therefore considered noncompliant with this condition.
(10) Documentation of compliance with Subparagraphs (a)(1) through (a)(9) of this Rule shall be maintained by the collection
system owner for three years with the exception of the map, which shall be maintained for the life of the system.
No such documentation was presented during the inspection and Mr. Smith was unsure whether any such documentation
exists. You are therefore considered noncompliant with this condition.
Page 3 of 7

Permit: WQCSD0210 Owner - Facility: NC Land Lease LLC
Inspection Date: 03/16/2022
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:
Pipe sizes
Pipe materials (PVC, DIP, etc)
Pipe location
# Flow direction
# Approximate pipe age
# Pump station ID, location and capacity
# Force main air release valve location & type
# Location of satellite connections
Are system maintenance records maintained?
Comment: None
Grease Control
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.)
None
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?
Comment: None
Spills and Response Action Plan
# Is system free of known points of bypass?
# 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?
Yes No NA NE
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Yes No NA NE
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Yes No NA NE
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Page4of7

Permit: WQCSD0210 Owner - Facility: NC Land Lease LLC
Inspection Date: 03/16/2022
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
Comment: None.
Inspections
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?
# 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?
Comment: None
Lines/Right-of-Ways/Aerial Lines
Please list the Lines/Right of Ways/Aerial Lines Inspected:
Are right-of-ways and easements maintained for the full width for access?
If No, give details on temporary access:
None
Is maintenance documented?
Were all areas/lines inspected free of issues?
Comment: None
Manholes
Please list the Manholes Inspected:
None
Are manholes accessible?
# Are manhole covers/vents above grade?
Are manholes free of visible signs of overflow?
Are manholes free of sinkholes and depressions?
Are manhole covers present?
Yes No NA NE
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Yes No NA NE
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Yes No NA NE
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Page5of7

Permit: WQCSD0210 Owner - Facility: NC Land Lease LLC
Inspection Date: 03/16/2022
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
# Are manholes properly seated?
# Are manholes in good condition?
# Are inverts in good condition?
Is flow unrestricted in manholes?
Are manholes free of excessive amounts of grease?
Are manholes free of excessive roots?
Are manholes free of excessive sand?
Are manhole vents screened?
Are vents free of submergence?
Are manholes free of bypass structures or pipes?
Comment: No known manholes exist in system. There is no system map.
Pump Stations
Please list the Pump Stations Inspected:
The one furthest west.
# Number of duplex or larger pump stations in system
# Number of vacuum stations in system
# Number of simplex pump stations in system
# 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 (SCADA) 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?
Is the telemetry system functional?
Is a 24-hour notification sign posted ?
Does the sign include:
Owner Name?
Pump station identifier?
# Address?
Instructions for notification?
24-hour emergency contact numbers?
Are audio and visual alarms present?
Are audio and visual alarms operable?
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Yes No NA NE
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Page6of7

Permit: WQCSD0210 Owner - Facility: NC Land Lease LLC
Inspection Date: 03/16/2022
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
# 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?
N/A
# 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 7 of 7