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Home My WebLink AboutWQCSD0212_CEI_Letter_NOV2022PC027_20220519ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director Monroe's Mobile Home Park Attn: Thomas L. Monroe, Owner 5111 Mockingbird Rd Greensboro, NC 27406 NORTH CAROLINA Environmental Quality May 19, 2022 SUBJECT: Compliance Evaluation Inspection Notice of Violation with Intent to Issue a Civil Penalty Case #: NOV-2022-PC-0278 Monroe's Mobile Home Park Wastewater Collection System Deemed Permitted Collection System Tracking Number WQCSD0212 Guilford County Dear Mr. Monroe: 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: Requirement Finding 1. Operation & Maintenance (0&M) Non -compliant 2. WWCS Map Compliant 3. O&M and Spill Plan Non -compliant 4. Pump Station PS Inspection Frequency Compliant S. High Priority Sewers (HPS) NotApplicable 6. Annual General Observation (AGO) Compliant 7. Sanitary Sewer Overflow (SSO) Reporting Compliant 8. Grease Control Program Non -compliant 9. Right -of -Ways ROW NotApplicable 10. Documentation I Non -compliant These non-compliance issues have resulted in this Notice of Violation, 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. Monroe's 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. D �� North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105 Moan caaouNn 336.776.9800 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, DocuSiTgned by: %A. l . 5,,. Gr 145B49E225CMEA... 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. Bradley Flynt, 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: 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: 03/23/2022 Entry Time 11:OOAM Primary Inspector: Ron Boone Secondary Inspector(s): Certification: Phone: 336-580-2202 Phone: Exit Time: 12:OOPM Phone: 336-776-9690 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: WQCSD0212 Owner - Facility: Monroe's Mobile Home Park 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. It's also noted that some of the violations are repeat violations from past inspections. Non -compliant — The permittee is considered non -compliant with this requirement for the reasons detailed below. 2. WWCS Map The map shows piping and pump station locations but is very difficult to read due to its age. You should consider having the map redrawn while it is still readable. Compliant — However, consider upgrading the map while it is still readable. 3. O&M and Spill Plan Written O&M and spill plans were not provided during the inspection. This is a repeat finding. 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 — The permittee is considered non -compliant with this requirement for the reasons detailed elsewhere in this letter and report. 4. Pump Station (PS) Inspection Frequency Mr. Boone was informed that the pump station is inspected by the wastewater treatment plant operator whenever he comes to the park to visit the plant. The operator then notes their inspection in the treatment plant logbook. It is highly recommended that a separate logbook be kept for the pump station, or at least for the collection system, in which the pump station, or all collection system inspections and activities, can be annotated. This would make it much easier to verify compliance with CS requirements. It is noted that the pump station has a telemetry system for remote notification, which notifies specific people by telephone when specific station malfunctions occur. The pump station also has audible/visual alarms for local notification. The pump station has two pumps and according to operators, a spare pump is kept in the park's admin/maintenance facility. These PS details are not recorded. These details are the types of information that should be recorded in the park's collection system O&M and Spill Plan. In addition, the telemetry system's notification protocol should also be recorded in the O&M and Spill Plan. The audible/visual alarms and telemetry system should also be tested/inspected regularly to verify operability. Compliant — However, better documentation in the O&M plan and O&M records must be generated and kept by the permittee for a period of no less than three years. 5. High Priority Sewers (HPS) Mr. Boone was informed that there are no HPSs in the collection system. Not Applicable — However, the absence of HPSs in the collection system, and therefore the non -applicability of this requirement, must be documented in the O&M plan. 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. Page 2 of 7 Permit: WQCSD0212 Owner - Facility: Monroe's Mobile Home Park Inspection Date: 03/23/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine 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. 7. Sanitary Sewer Overflow (SSO) ReportingNo SSOs have been reported or recorded. Compliant — No spills have been reported or recorded to date. 8. Grease Control Program There is no documentation of the required semi-annual distributions of grease control materials to all park residents. Mr. Boone was informed in previous inspections, as well as this inspection, that residents are notified by posting grease control materials in common areas where all park residents would encounter it and can read it, such as the mailbox area. This was acceptable to the Division at the time, however, there is no documentation of these activities. Therefore, the park must produce effective grease control materials and distribute them to all park residents at least twice annually, with no less than 180 days between the two distribution events. The distribution events must be documented. This may be accomplished by dating all grease control materials with the dates of distribution and keeping on file copies of the materials distributed for a period of no less than three years. Regardless of how the park decides to comply with the grease education requirements, all activities should be detailed in the written O&M plan. Non -compliant 9. Right -of -Ways (ROW) Mr. Boone was informed that there are no ROWs in the collection system that require maintenance beyond that which is already accomplished through normal landscaping maintenance activities by both residents and park maintenance personnel. This should also be detailed in a written O&M plan. Not Applicable — However, the absence of ROWs in the collection system, and therefore the non -applicability of this requirement, must be documented in the O&M plan. 10. Documentation Documentation is insufficient and does NOT comply with regulatory requirements, as detailed above elsewhere in this letter and report. Non -compliant These non-compliance issues have resulted in a Notice of Violation, 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. Monroe's 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 ron.boone@ncdenr.gov or lon.snider@ncdenr.gov, respectively. Page 3 of 7 Permit: WQCSD0212 Owner - Facility: Monroe's Mobile Home Park 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? ❑ 0 ❑ ❑ Comment: Required records are minimal. Mr. Bradley Flynt, operator for the wastewater treatment system, was interviewed for the inspection of the collection system. Mr. Flynt stated that he checks the pump station every day when he drives by it on his way to the plant, and records his observations in his plant operations logbook. However, he does NOT visit the plant every day and it is unknown whether the backup operator does the same. Furthermore, he did NOT present any of the documentation for evaluation during the inspection. The pump station does have a telemetry system so it only has to be inspected a minimum of once per week. 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? ❑ ❑ ❑ ❑ Comment: No documentation for the grease control program was presented for evaluation durinq the inspection. 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? ❑ ❑ ❑ Page 4 of 7 Permit: WQCSD0212 Owner - Facility: Monroe's Mobile Home Park Inspection Date: 03/23/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine 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? 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: A written spill response plan was not presented for evaluation during the inspection. 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? Yes No NA NE ❑❑❑■ ❑■❑❑ ❑■❑❑ ❑❑❑■ ❑❑❑■ ❑❑❑■ Comment: No records were presented for evaluation durinq the inspection. With the current system configuration, required records would include pump station inspection records, grease control records, annual general observation records, a written O&M plan, and a written spill plan. Mr. Flynt has indicated there are no high priority sewers or right-of-ways but this needs to be verified with the park owner and then fully documented in a written O&M plan. Lines/Right-of-Ways/Aerial Lines Please list the Lines/Right of Ways/Aerial Lines Inspected: None Are right-of-ways and easements maintained for the full width for access? If No, give details on temporary access: According to Mr. Flynt, no right-of-ways exist that would require additional maintenance beyond what is already done by park maintenance personnel and park residents. But this should also be verified with the park owner and then fully documented in a written O&M plan. Is maintenance documented? Were all areas/lines inspected free of issues? Yes No NA NE ❑❑■❑ ❑❑❑■ ■❑❑❑ Page 5 of 7 Permit: WQCSD0212 Owner - Facility: Monroe's Mobile Home Park Inspection Date: 03/23/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Comment: None 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? ❑ ❑ ❑ Are manholes free of sinkholes and depressions? ❑ ❑ ❑ Are manhole covers present? ❑ ❑ ❑ # 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: There are no manholes in the system Pump Stations Yes No NA NE Please list the Pump Stations Inspected: Main # 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? ❑ ❑ ❑ # Do they all have telemetry installed? 0 ❑ ❑ ❑ Is the telemetry system functional? ❑ ❑ ❑ Is a 24-hour notification sign posted ? ❑ 0 ❑ ❑ Page 6 of 7 Permit: WQCSD0212 Owner - Facility: Monroe's Mobile Home Park Inspection Date: 03/23/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Does the sign include: Owner Name? ❑ 0 ❑ ❑ Pump station identifier? ❑ 0 ❑ ❑ # Address? ❑ 0 ❑ ❑ Instructions for notification? ❑ 0 ❑ ❑ 24-hour emergency contact numbers? ❑ 0 ❑ ❑ Are audio and visual alarms present? 0 ❑ ❑ ❑ Are audio and visual alarms operable? ❑ ❑ ❑ # Is there a backup generator or bypass pump connected? ❑ 0 ❑ ❑ If tested during inspection, did it function properly? ❑ ❑ 0 ❑ Is the back-up system tested at least bi-annually under normal operating conditions? ❑ ❑ ❑ # Does it have a dedicated connection for a portable generator? ❑ 0 ❑ ❑ # Is the owner relying on portable units in the event of a power outage? ❑ 0 ❑ ❑ # If Yes, is there a distribution plan? ❑ ❑ 0 ❑ If Yes, what resources (Units/Staff/Vehicles/etc) are included in Plan? # Does Permittee have the approved percentage of replacement simplex pumps? ❑ ❑ 0 ❑ Is recordkeeping of pump station inspection and maintenance program adequate? ❑ 0 ❑ ❑ Do pump station logs include at a minimum: Inside and outside cleaning and debris removal? ❑ 0 ❑ ❑ Inspecting and exercising all valves? ❑ 0 ❑ ❑ Inspecting and lubricating pumps and other equipment? ❑ 0 ❑ ❑ Inspecting alarms, telemetry and auxiliary equipment? ❑ 0 ❑ ❑ Comment: Mr. Flynt stated that he checks the pump station every day when he drives by it on his way to the plant, and records his observations in his plant operations logbook. However, he does NOT visit the plant every day and it is unknown whether the backup operator does the same. Furthermore, he did NOT present any of the documentation for evaluation during the inspection. Page 7 of 7