WQCSD0255_NOV2022PC0646_20221013

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
BV Belk Properties, Inc.
Attn: BV Belk, Jr., President
204 West Woodlawn Rd, Unit C
Charlotte, NC 28217
NORTH CAROLINA
Environmental Quality
October 13th, 2022
Subject: Compliance Evaluation Inspection & Notice of Violation
NOV Tracking #: NOV-2022-PC-0646
Holden Crossing Shopping Center Wastewater Collection System
Deemed Permitted Wastewater Collection System Tracking #: WQCSD0255
Guilford County
Dear Mr. Belk:
Ron Boone of the North Carolina Division of Water Resources (NCDWR), Winston-Salem Regional
Office (WSRO), conducted a compliance evaluation inspection of the Holden Crossing Shopping
Center Wastewater Collection System on September 14th, 2022. Noah Belk was present for the
inspection. The inspection findings and violations are listed below and are detailed in the
attached Compliance Inspection Report.
REGULATION CITATION
VIOLATION DESCRIPTION
15A NCAC 02T .0403(a)(1)
Collection system not effectively operated or
maintained.
15A NCAC 02T .0403(a)(2)
No collection system map available during the
inspection.
15A NCAC 02T .0403(a)(3)
No written operation & maintenance plan or
spill plan.
15A NCAC 02T .0403(a)(4)
Pump station inspections not performed as
required.
15A NCAC 02T .0403(a)(5)
High priority lines not inspected as required.
15A NCAC 02T .0403(a)(6)
Annual general observation not being
conducted as required.
15A NCAC 02T .0403(a)(7)
Spills not reported as required.
15A NCAC 02T .0403(a)(8)
Fats, oils, and grease not properly managed.
15A NCAC 02T .0403(a)(9)
Right-of-ways not properly identified or
maintained as required.
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
NoanicaaouNn
oep.m.m or em�nmen� ouaim,
336.776.9800

15A NCAC 02T .0403(a)(10) Not all of the required documentation has
been generated or maintained as required.
Please be aware that the Division may take enforcement action against any individual who fails
to comply with the requirements of all applicable permits, regulations, and/or statutes. 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, or applicable regulations, issued
pursuant to G.S. 143-215.1.
Please reply, in writing, to this notice of violation, with 10 days of receiving it. Your written
response must address each violation listed above and in the attached compliance inspection
report and provide your intended remedial actions, with estimated completion dates, for each
violation. You will then be expected to make all the necessary corrective actions to achieve full
compliance within 90 days of receiving the notice. Failure to do so will result in further
enforcement actions.
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,
DocuSiiggned by:
145B49E225CMEA...
Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
Attachments:
1. Compliance Inspection Report, WQCSD0255
NORTH CAROLINAD E Q
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North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Raleigh, North Carolina 27105
336.776.9800

Permit: WQCSD0255
SOC:
County: Guilford
Region: Winston-Salem
Contact Person: B V Belk
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Compliance Inspection Report
Effective: 03/01/00 Expiration: Owner: Bvb Properties Inc
Effective: Expiration: Facility: Holden Crossing Shopping Center Collection S,.
Title:
Inspection Date: 09/14/2022 Entry Time 10:OOAM
Primary Inspector: Ron Boone DocuSigned by:
Secondary Inspector(s): ,O~Vu B°Of'e,
620F8DD5F2A3460...
Certification:
Phone: [phone]
Phone:
Exit Time: 11:OOAM
Phone: [phone]
10/13/2022
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
(See attachment summary)
Page 1 of 4

Permit: WQCSD0255 Owner - Facility: Bvb Properties Inc
Inspection Date: 09/14/2022 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), conducted a
compliance evaluation inspection of the Holden Crossing Shopping Center's wastewater collection system on September
14th, 2022. Noah Belk, property manager, was present for the inspection.
The Holden Crossing Shopping Center's collection system is deemed permitted. Deemed permitted collection systems in
NC are regulated under NC regulations 15A NCAC 02T .0400 - 0405. The primary requirements of these regulations are
enumerated below along with Holden Crossing's compliance status for each:
(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.
The shopping center's pump station has had overflows over the past several years due to inadequate operation and
maintenance. This indicates the system is NOT being operated and maintained effectively at all times.
(2) A map of the collection system shall have been developed and shall be maintained.
Mr. Belk did not present a map of the system during the inspection.
(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.
Mr. Belk did not provide a written plan that meets the above requirements during the inspection.
(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.
Mr. Belk was not familiar with the pump station or its operation and maintenance. It does have local audible and visible
alarms but it is unknown if it is operational. It is unknown whether the pumpstation has telemetry or SCADA systems or how
often it is maintained and inspected. There is a permanent backup generator sitting right next to the pumpstation, so, it is
assumed the generator powers the pumpstation upon loss of commercial power.
(5) High -priority sewers shall be inspected by the permittee or its representative once every six -months, and inspections
shall be documented.
Mr. Belk presented no inspection or maintenance records for high priority sewers (HPS). It is unknown whether there are any
HPSs in the collection system.
(6) A general observation by the permittee or its representative of the entire collection system shall be conducted once per
year.
Mr. Belk presented no documentation of such observations during the inspection.
(7) Overflows and bypasses shall be reported to the appropriate Division regional office in accordance with 15A NCAC 02B
.0506(a), and public notice shall be provided as required by G.S. 143-215.1C.
As stated above, the system has experienced overflows at the pumpstation over the past several years that were NOT
reported by the responsible party. The overflows were reported anonymously.
Page 2 of 4

Permit: WQCSD0255 Owner - Facility: Bvb Properties Inc
Inspection Date: 09/14/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
(8) A Grease Control Program shall be in place as follows: For privately owned collection systems, the Grease Control
Program shall include bi-annual distribution of grease education materials to users of the collection system by the permittee
or its representative.
Mr. Belk presented no documentation for this requirement.
(9) Right-of-ways and easements shall be maintained in the full easement width for personnel and equipment accessibility.
Mr. Belk presented no documentation for this requirement. It is unknown whether there are any maintainable right-of-ways in
the collection system.
(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.
As reflected above, none of the required documentation is being generated or maintained.
Page 3 of 4

Permit: WQCSD0255 Owner - Facility: Bvb Properties Inc
Inspection Date: 09/14/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Page 4 of 4