WQCSD0211_CEI_Letter_NOD2022PC0078_20220519

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Jones Estates Bay Country LLC
Attn: Jason Freed, Owner
2310 S. Miami Blvd, Suite 238
Durham, NC 27703
NORTH CAROLINA
Environmental Quality
May 19, 2022
SUBJECT: Compliance Evaluation Inspection and Notice of Deficiency
Case #: NOD-2022-PC-0078
Crown Mobile Home Park Wastewater Collection System
Deemed Permitted Collection System Tracking Number WQCSD0211
Guilford County
Dear Mr. Freed:
Ron Boone, of the NC Division of Water Resources (DWR), Winston-Salem Regional Office (WSRO),
performed a scheduled compliance evaluation inspection (CEI) of the above mentioned deemed
permitted wastewater collection system (WWCS) on March 23, 2022. Hal Young and Bradley Flynt,
who currently operate the park's wastewater treatment plant, were present for the inspection.
Inspection findings are listed below and detailed in the attached compliance inspection report:
Requirement
Finding
1.
Operation & Maintenance 0&M
Non -compliant
2.
WWCS Map
Non -compliant
3.
0&M and Spill Plan
Non -compliant
4.
Pump Station PS Inspection Frequency
Non -compliant
S.
High Priority Sewers (HPS)
Non -compliant
6.
Annual General Observation AGO
Non -compliant
7.
Sanitary Sewer Overflow (SSO) Reporting
Compliant
8.
Grease Control Program
Non -compliant
9.
Right-of-Ways(ROW)
Non -compliant
10.
Documentation
Non -compliant
These non-compliance issues have resulted in this Notice of Deficiency, which you should respond to
and follow up on promptly in order to properly and timely address all identified violations and avoid
any further enforcement actions.
Crown Mobile Home Park must remedy each identified violation fully and properly within 90 days
of receiving this correspondence. Failure to do so may result in this office proceeding with the next
step in our enforcement process. You are reminded that, in accordance with NC General Statute 143-
215.6A., Enforcement Procedures: Civil Penalties, a civil penalty of not more than twenty-five
thousand dollars ($25,000) per violation, per day, may be assessed for the violations detailed above.
DffNorth Carolina Department of Environmental Quality I Division of Water Resources
oan caaouNn
Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105
M336.776.9800
oep.m.m or em�nmen� Qualm,

Thank you for your prompt attention to this matter. If you have any questions or require assistance,
please do not hesitate to contact Mr. Boone, or me, by phone at 336.776.9690, or 336.776.9700,
respectively. You may also contact us by email at ron.boonePncdenr.gov or lon.sniderOncdenr.gov,
respectively.
Sincerely,
DocuSiTG
gned by:
%w. l . cJn Jtr
945B49E225C94EA...
Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
Attachments:
Water Compliance Report
15A NCAC 02T .0400 Deemed Permitted Collection System Rules
cc: 1. Laserfiche
2. Hal Young, via email
REQ� North Carolina Department ofEnvironmental Quality I Division ofWater Resources
Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Raleigh, North Carolina 27105
NORTH CAROLINA 336.776.9800
naparMeM of EmironmanW 9uallly

Permit: WQCSD0211
SOC:
County: Guilford
Region: Winston-Salem
Compliance Inspection Report
Effective: 03/01/00 Expiration: Owner : Jones Estates Bay Country LLC
Effective: Expiration: Facility: Crown MHP Collection System
6201 Jonquil Dr
Contact Person: Jason Freed Title:
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 03/23/2022 Entry Time 12:30PM
Primary Inspector: Ron Boone
Secondary Inspector(s):
Certification:
Greensboro NC 27407
Phone: [phone]
Phone:
Exit Time: 01:30PM
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 7

Permit: WQCSD0211 Owner - Facility: Jones Estates Bay Country LLC
Inspection Date: 03/23/2022 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 (WSRO), performed a scheduled
compliance evaluation inspection (CEI) of the above mentioned deemed permitted wastewater collection system (WWCS) on
March 23, 2022. Bradley Flynt, who currently operates the park's wastewater treatment plant, was present for the
inspection. Inspection findings are listed below and detailed in the attached compliance inspection report:
Requirements & Findings
1. Operation & Maintenance (O&M) - Although no spills have been reported, the park is noncompliant with several of the 02T
rules, as detailed below.
Non -compliant
2. WWCS Map - No system map was presented during the inspection.
Non -compliant
3. O&M and Spill Plan - Written O&M and spill plans were not provided during the inspection. Draft plans were provided by
Mr. Flynt post -inspection, but they need to be fine-tuned in order to be fully compliant. The O&M Plan must detail all
activities the park has implemented to comply with regulatory requirements concerning the collection system map, pump
station O&M and inspection frequency, high priority sewer O&M and inspection frequency, ROW O&M and inspection
frequency, grease control, and annual general system observation. The presence and/or absence of pump stations, high
priority lines, and right-of-ways, in the system, must be recorded in the O&M Plan, i.e., if none of a specific component
exists within the system, this must be annotated in the O&M plan and designated as "Not Applicable".
Non -compliant
4. Pump Station Inspection Frequency - Mr. Boone was informed that the pump stations have telemetry systems, which
requires them to be inspected only once per week. The operators stated they check the stations at least two to three times
weekly. No records of the pump station inspections were presented during the inspection. PS details should be recorded in
the park's O&M plan. Such details include the how many pump stations there are, how many pumps each pump station
has, where it is located, the types of monitoring, alarm, and notification systems the pump stations use along with details of
their programming, such as who they call, in what succession, and whether it repeats indefinitely until alarm conditions are
acknowledged. This list is not all inclusive.
Compliant — Mr. Boone noted no conditions that lead us to believe the pump stations are not being inspected and
maintained as required, however, better documentation of pump station inspections and maintenance, in addition to adding
the necessary pump station information, as discussed above, to the O&M plan, must be generated and kept by the
permittee for a period of no less than three years.
5. High Priority Sewers (HPS) - Details of HPSs and their inspections must be included in the O&M plan. If none exist, the
O&M plan should state this. No records of the inspections and maintenance of high priority lines were provided during the
inspection. Past inspection records indicate there is at least one high priority line (aerial) in the park.
Non -compliant
6. Annual General Observation (AGO) - Mr. Boone documented no reasons that lead us to believe the AGOs are NOT being
done, however, there is no documentation of the AGOs.
Compliant — However, the completion of the AGOs must documented and the procedures the permittee has implemented to
accomplish the task must be detailed in the O&M plan.
Page 2 of 7

Permit: WQCSD0211 Owner - Facility: Jones Estates Bay Country LLC
Inspection Date: 03/23/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
7. Sanitary Sewer Overflows (SSO) Reporting - No SSOs have been reported or recorded.
Compliant
8. Grease Control Program - No documentation of a grease control program or grease control activities were presented
during the inspection. Regardless of how the park decides to comply with the grease education requirements, all such
activities should be detailed in the written O&M plan and all records of activities must be kept by the permittee for no less
than three years.
Non -compliant
9. Right -of -Ways (ROW) - Past inspection records indicate the presence of at least one maintainable right-of-way. No
records documenting the inspection and maintenance of ROWs was provided during the insepction. In addition to producing
and keeping on file for a minimum of three years, records of ROW inspection and maintenance, the ROW inspection and
maintenance program should also be detailed in the park's written O&M plan. If, in fact, no maintainable ROWs exist in the
system, the O&M plan should state so.
Non -compliant
10. Documentation - Documentation is insufficient and does NOT comply with regulatory requirements, as detailed above.
Non -compliant
These non-compliance issues have resulted in a Notice of Deficiency, which you should respond to and follow up on
promptly in order to properly and timely address all identified violations and avoid any further enforcement actions.
Crown Mobile Home Park must remedy each identified violation fully and properly within 90 days of receiving this
correspondence. Failure to do so may result in this office proceeding with the next step in our enforcement process. You are
reminded that, in accordance with NC General Statute 143-215.6A., Enforcement Procedures: Civil Penalties, a civil penalty
of not more than twenty-five thousand dollars ($25,000) per violation, per day, may be assessed for the violations detailed
above.
Thank you for your prompt attention to this matter. If you have any questions or require assistance, please do not hesitate to
contact Mr. Boone, or me, by phone at 336.776.9690, or 336.776.9700, respectively. You may also contact us by email at
[e-mail] or [e-mail], respectively.
Page 3 of 7

Permit: WQCSD0211 Owner - Facility: Jones Estates Bay Country LLC
Inspection Date: 03/23/2022 Inspection Type : Collection System Inspect Non Sampling
Reason for Visit: Routine
General
Yes No NA NE
# Is this system a satellite system?
❑
0 ❑ ❑
# 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: No map of system available during inspection
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? ❑ 1:10 ❑
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: No established grease control system that meets requirements. Operators indicated yearly
distribution onlv.
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?
❑
0 ❑ ❑
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?
❑
❑ ❑
Page 4 of 7

Permit: WQCSD0211 Owner - Facility: Jones Estates Bay Country LLC
Inspection Date: 03/23/2022 Inspection Type : Collection System Inspect Non Sampling
Reason for Visit: Routine
Is a Spill Response Action Plan available for all personnel?
❑
0 ❑ ❑
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: No written spill plan provided during the inspection.
Inspections
Yes No NA NE
Are adequate maintenance records maintained? ❑ 0 ❑ ❑
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: Operators indicated the PSs have telemetry and are inspection a few times weekly. No records
for the annual general observation or inspection of high priority lines were presented during
the inspection.
Lines/Right-of-Ways/Aerial Lines Yes No NA NE
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:
Is maintenance documented? ❑ ❑ ❑
Were all areas/lines inspected free of issues? ❑ ❑ On
Comment: No ROW inspection records presented for inspection.
Manholes Yes No NA NE
Please list the Manholes Inspected:
Are manholes accessible? ❑ ❑ ❑
# Are manhole covers/vents above grade? ❑ ❑ ❑
Are manholes free of visible signs of overflow? ❑ ❑ ❑
Are manholes free of sinkholes and depressions? ❑ ❑ ❑
Page 5 of 7

Permit: WQCSD0211 Owner - Facility: Jones Estates Bay Country LLC
Inspection Date: 03/23/2022 Inspection Type : Collection System Inspect Non Sampling
Reason for Visit: Routine
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: No manholes were inspected durinq the inspection.
Pump Stations
Yes No NA NE
Please list the Pump Stations Inspected:
# Number of duplex or larger pump stations in system
3
# 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?
❑
❑ ❑
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?
❑
❑ ❑
Page 6 of 7

Permit: WQCSD0211 Owner - Facility: Jones Estates Bay Country LLC
Inspection Date: 03/23/2022 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?
# 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: Field inspection of collection system was severely hindered by severe weather.
❑❑■❑
❑■❑❑
Page 7 of 7