NC0057720_NOV2023PC0069_20230215

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
CERTIFIED MAIL # 7020 3160 0002 0860 8591
RETURN RECEIPT REQUESTED
February 15, 2023
Jones Estate Hidden Lakes, LLC
Attn: Kellen Buss, Director of Site Infrastructure
2310 S Miami Blvd, Suite 238
Durham, NC 27703
Subject: Compliance Evaluation Inspection & Notice of Violation with Intent to Enforce
NOV Tracking #: NOV-2023-PC-0069
Permit No. NCO057720
Hidden Lakes Village Mobile Home Park WWTP
Stokes County
Dear Mr. Buss:
Seren Homer of the North Carolina Division of Water Resources (DWR) Winston-Salem Regional
Office (WSRO) conducted a compliance evaluation inspection of the Hidden Lakes Village
Mobile Home Park Wastewater Treatment Plant on January 19, 2023. Randall Bell, the Operator
in Responsible Charge (ORC), was present for the inspection. The determined permit violations
and items of concern are listed below. Inspection findings are detailed in the attached Water
Compliance Inspection Report.
PERMIT VIOLATIONS
1. There is currently no bar screen installed or operational in the treatment system. Multiple
system components (including diffusers, blowers, chlorinator, and de -chlorinator) are
either not present or insufficient. There is an uncontained leak in the pipe going from the
post -chlorination tank to the meter well. This is in violation of the subject permit condition
Part II, Section C (2.).
2. There are no adequate safeguards (including standby power) to prevent the discharge of
untreated or inadequately treated wastes during electrical power failures for the facility.
This is in violation of the subject permit condition Part II, Section C (7.).
3. Data records prior to July 2022 were not available at the time of inspection. This is in
violation of the subject permit condition Part II, Section D (6.).
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� Qualm
336.776.9800

ITEMS OF CONCERN
1. Records for the flow meter were not available on -site during the inspection. All records,
including those pertaining to installation, calibration, and maintenance, should be retained
and readily available on -site as stipulated in permit condition Part II, Section D (3.) and (6.).
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 respond in writing within ten (10) business days after receipt of this Notice. The 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 are expected to make all the necessary corrective actions to achieve full
compliance within ninety (90) days of receiving this Notice. Failure to do so may result in
enforcement actions. A follow-up site inspection will subsequently be conducted to ensure the
necessary corrective actions have been made.
If you have any questions or concerns, please contact Seren Homer by phone at 336-776-9698 or
via email at seren.homer@ncdenrgov. Thank you in advance for your time and attention to this
matter.
Sincerely,
DocuSigned by:
OD2D3CE3F167456...
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, NCO057720
NORTH CAROLINAD E Q
oeo+ro�.m m F,mro���w n�si�
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

United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040-0057
Water Compliance Inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 IN 1 2 u 3 I NCO057720 I11 121 23/01/19 I17 18I � I 19 I s I 20L]
21111I I I I I I I II I I I I I I I I I I I I I I I I I I I I I I I II I I I I I r6
Inspection
Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved -------------------
67
I 72 I n, I 71 I 74 79 I I I I I I I80
701 I 71 I LL -1 I I
LJ
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES Dermit Number)
09:30AM 23/01/19
22/10/01
Hidden Lakes Village Mobile Home Park WWTP
1020 Twin Lakes Dr
Exit Time/Date
Permit Expiration Date
King NC 27021
11:30AM 23/01/19
27/02/28
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Randall Keith Bel 1/0RC/336-373-7514/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Kellen P Buss,2310 S Miami Blvd Ste 238 Durham NC 27703/Director of Site
I nfranstructure/419-357-9091 / No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit 0 Flow Measurement Operations & Maintenar Records/Reports
Self -Monitoring Progran 0 Sludge Handling Dispo: Facility Site Review 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
Ron Boone Docusignedby: DWR/WSROWQ/336-776-9690/ 2/15/2023
Seren Homeruonoowwr.L DWR/WSRO WQ/336-776-9698/
E51MAF3FBF834CF...
Jesse Barnes DWR/WSRO WQ/336-776-9701/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
DocuSigned by:
DWR/WSRO 336-776-9695 2/15/2023
'--OD2D3CE3F1B7456.-
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

NPDES yr/mo/day Inspection Type
NCO057720 I11 12I 23/01 /19 117 18 i c i
(Cont.)
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
On January 19, 2023, Division of Water Resources staff Seren Homer, Ron Boone, and Jesse Barnes
conducted an announced compliance evaluation inspection (CEI) at the above -referenced facility.
Randall Bell, the ORC, was present during the inspection. This CEI consisted of two parts: (1) a
records review of the facility files and self -monitoring data and (2) an on -site inspection of the
treatment facility. The facility was found to be non -compliant with the subject permit. The inspection
findings are detailed below.
1. Permit
The permit renewal was issued on September 1, 2022 and will expire at midnight on February 28,
2027. A copy of the permit was available on -site during the inspection.
2. Record Keeping/Laboratory
Available data records that were evaluated during the inspection appeared consistent with the data
reported on the DMRs. The facility uses a contract lab (Statesville Analytical) for analysis of all
non -field parameters as required by the permit. The chain -of -custody documentation appeared
complete.
Data records prior to July 2022 were not available at the time of the inspection. The ORC stated that
prior records exist, but he has been unable to obtain them from the former operator. Per Permit
Condition Part II Section D (6), all monitoring records must be retained for at least 3 years, except for
records of monitoring information related to sewage sludge use and disposal activities, which shall be
retained for at least 5 years (or longer as required by 40 CFR 503).
3. Bar Screen
There is currently no bar screen installed or operational in the treatment system. The inspection from
July 25, 2018 noted the same issue. A bar screen should be installed as soon as possible, but no
later than ninety (90) days post -receipt of this Notice.
4. Aeration Basin
The aeration basin utilizes a diffused air system. The ORC indicated that the diffusers are not
currently fully operational, but they plan to repair them. The diffusers should be repaired within ninety
(90) days of receipt of this letter to comply with the permit conditions. The aeration basin appeared to
be free of dead spots and the DO level appeared to be acceptable at the time of inspection.
Two blowers are available on -site. Only one is currently connected to the header and in operation. If
the operating blower were to malfunction, the secondary blower would have to be manually
connected. A manifold should be installed to connect the two blowers to the header within ninety (90)
days of receipt of this letter.
5. Secondary Clarifier
The facility has two secondary clarifiers. Only one is currently operational. According to the ORC, one
clarifier is sufficient for the flow at which the facility is currently operating. However, the permit lists
"dual final clarifiers" in the list of treatment components.
A significant amount of vegetation had accumulated over the influent well. The influent well to the
clarifier needs to be cleaned and the vegetation needs to be removed as soon as possible. A screen
or similar device could be installed above the well to prevent vegetation and other debris from
accumulating and potentially restricting the flow into the clarifier.
Significant scum and floating sludge were observed in the clarifier in quantities exceeding typical
levels.
The sludge blanket could not be evaluated as a sludge judge was not available on -site at the time of
the inspection.
6. Disinfection
A chlorinator is not currently installed in the system. A single chlorinator tube was placed against the
wall just below the weirs. The majority of the effluent does not appear to flow through the chlorinator
Page#

Permit: NCO057720
Inspection Date: 01/19/2023
Owner -Facility: Hidden Lakes Village Mobile Home Park)
Inspection Type: Compliance Evaluation
tube, but rather mixes with the chlorine that has leached from the tube as it flows into the contact
chamber.
7. De -chlorination
A de -chlorinator is not currently installed in the system. A single tablet de -chlorinator tube was placed
in the first of three contact chambers approximately 1 to 2 feet from the chlorinator tube. The
de -chlorination system should be placed downstream of the chlorine contact chambers to allow for
sufficient chlorine contact time. The ORC relocated the de -chlorinator tube to a position in the system
after the contact chamber and before the effluent pipe to the outfall.
8. Flow Measurement- Effluent
Calibration records for the flow meter were not available on -site. The ORC stated that the flow meter
is less than 1 year old and has not been calibrated. The ORC indicated he will check the installation
date of new meter and when it needs to be calibrated. Ensure flow meter is calibrated annually.
9. Effluent Pipe
The right-of-way to the outfall appears to be well -maintained. The outfall pipe is partially buried within
the sediment of the receiving stream. Effluent samples are collected at the end of the treatment works
before discharge to the outfall. The water downgradient of the outfall appeared clear and free of
foam and other debris.
10. Standby Power
No standby power is currently available at the facility. A back-up generator or power source should be
installed.
11. Operations & Maintenance
There is an uncontained leak in the pipe going from the post -chlorination tank to the meter well.
Corrosion was observed throughout the system. Holes in the ground were observed around the
system that could impact the integrity of the plant. The leak in the pipe and the holes proximate to the
treatment system should be repaired and stabilized as soon as possible but no later than ninety (90)
days following receipt of this Notice.
Page#

Permit: NCO057720 Owner -Facility: Hidden Lakes Village Mobile Home Park)
Inspection Date: 01/19/2023 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
❑
❑
■
❑
application?
Is the facility as described in the permit?
❑
■
❑
❑
# Are there any special conditions for the permit?
❑
■
❑
❑
Is access to the plant site restricted to the general public?
❑
■
❑
❑
Is the inspector granted access to all areas for inspection?
■
❑
❑
❑
Comment: Facility does not currently have a bar screen.
Security fence needs improvement to restrict public access.
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?
❑
■
❑
❑
Are all records maintained for 3 years (lab. reg. required 5 years)?
❑
■
❑
❑
Are analytical results consistent with data reported on DMRs?
■
❑
❑
❑
Is the chain -of -custody complete?
■
❑
❑
❑
Dates, times and location of sampling
■
Name of individual performing the sampling
■
Results of analysis and calibration
■
Dates of analysis
■
Name of person performing analyses
■
Transported COCs
■
Are DMRs complete: do they include all permit parameters?
■
❑
❑
❑
Has the facility submitted its annual compliance report to users and DWQ?
❑
❑
■
❑
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified
❑
❑
■
❑
operator on each shift?
Is the ORC visitation log available and current?
■
❑
❑
❑
Is the ORC certified at grade equal to or higher than the facility classification?
■
❑
❑
❑
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: ORC only had data records for July 2022 to present at the inspection.
Laboratory Yes No NA NE
Page# 4

Permit: NCO057720 Owner -Facility: Hidden Lakes Village Mobile Home Park)
Inspection Date: 01/19/2023 Inspection Type: Compliance Evaluation
Laboratory
Yes
No
NA
NE
Are field parameters performed by certified personnel or laboratory?
0
❑
❑
❑
Are all other parameters(excluding field parameters) performed by a certified lab?
0
❑
❑
❑
# 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: Contract lab is Statesville Analytical.
Effluent Sampling
Yes
No
NA
NE
Is composite sampling flow proportional?
❑
❑
0
❑
Is sample collected below all treatment units?
0
❑
❑
❑
Is proper volume collected?
■
❑
❑
❑
Is the tubing clean?
❑
❑
0
❑
# 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:
Bar Screens
Yes
No
NA NE
Type of bar screen
a.Manual
❑
b.Mechanical
❑
Are the bars adequately screening debris?
❑
0
❑
❑
Is the screen free of excessive debris?
❑
0
❑
❑
Is disposal of screening in compliance?
❑
■
❑
❑
Is the unit in good condition?
❑
0
❑
❑
Comment: No bar screen currently in system.
Aeration Basins Yes No NA NE
Mode of operation Ext. Air
Type of aeration system Diffused
Is the basin free of dead spots? 0 ❑ ❑ ❑
Page# 5

Permit: NCO057720 Owner -Facility:
Inspection Date: 01/19/2023 Inspection Type:
Hidden Lakes Village Mobile Home Park)
Compliance Evaluation
Aeration Basins
Yes
No
NA
NE
Are surface aerators and mixers operational?
❑
❑
0
❑
Are the diffusers operational?
0
❑
❑
❑
Is the foam the proper color for the treatment process?
■
❑
❑
❑
Does the foam cover less than 25% of the basin's surface?
0
❑
❑
❑
Is the DO level acceptable?
0
❑
❑
❑
Is the DO level acceptable?(1.0 to 3.0 mg/1)
0
❑
❑
❑
Comment: Diffusers are operational but not sufficient.
Blower output pipes should be plumbed together into the header pipe.
Secondary Clarifier
Yes
No
NA
NE
Is the clarifier free of black and odorous wastewater?
0
❑
❑
❑
Is the site free of excessive buildup of solids in center well of circular clarifier?
❑
❑
0
❑
Are weirs level?
0
❑
❑
❑
Is the site free of weir blockage?
0
❑
❑
❑
Is the site free of evidence of short-circuiting?
■
❑
❑
❑
Is scum removal adequate?
❑
0
❑
❑
Is the site free of excessive floating sludge?
❑
0
❑
❑
Is the drive unit operational?
❑
❑
0
❑
Is the return rate acceptable (low turbulence)?
■
❑
❑
❑
Is the overflow clear of excessive solids/pin floc?
0
❑
❑
❑
Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth)
❑
❑
❑
Comment: Scum and floating sludge should be cleaned regularly.
The influent well to the clarifier needs to be cleaned and veaetation needs to be
removed.
Sludge blanket was not evaluated because operator did not have sludge judge onsite.
Disinfection -Tablet Yes No NA NE
Are tablet chlorinators operational? ❑ ❑ 0 ❑
Are the tablets the proper size and type? ■ ❑ ❑ ❑
Number of tubes in use? 1
Is the level of chlorine residual acceptable? ❑ ❑ ❑
Is the contact chamber free of growth, or sludge buildup? ❑ 0 ❑ ❑
Is there chlorine residual prior to de -chlorination? ❑ ❑ ❑
Page# 6

Permit: NCO057720
Inspection Date: 01/19/2023
Owner -Facility: Hidden Lakes Village Mobile Home Park)
Inspection Type: Compliance Evaluation
Disinfection -Tablet Yes No NA NE
Comment: Chlorinator is not installed. The operator uses a single chlorinator tube to apply
chlorine to the clarifier effluent.
Contact chamber contains typical growth, but does not appear to negatively affect
._,.,,+V.. --4-
De-chlorination
Yes No
NA
NE
Type of system ?
Tablet
Is the feed ratio proportional to chlorine amount (1 to 1)?
❑ ❑
0
❑
Is storage appropriate for cylinders?
❑ ❑
0
❑
# Is de -chlorination substance stored away from chlorine containers?
0 ❑
❑
❑
Comment:
Are the tablets the proper size and type? 0 ❑ ❑ ❑
Are tablet de -chlorinators operational? ❑ ❑ 0 ❑
Number of tubes in use? 1
Comment: Dechlorinator is not installed. The operator uses a single dechlorinator tube to
dechlorinate effluent.
Flow Measurement - Effluent
Yes
No
NA NE
# Is flow meter used for reporting?
0
❑
❑
❑
Is flow meter calibrated annually?
❑
0
❑
❑
Is the flow meter operational?
0
❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
❑
❑
0
❑
Comment: Operator is checking installation date of new meter and when it needs to be calibrated.
Effluent Pipe
Yes
No
NA
NE
Is right of way to the outfall properly maintained?
0
❑
❑
❑
Are the receiving water free of foam other than trace amounts and other debris?
■
❑
❑
❑
If effluent (diffuser pipes are required) are they operating properly?
❑
❑
0
❑
Comment: Outfall pipe is underwater and partially buried in stream substrate. Effluent samples are
therefore taken at effluent v-notch.
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, 0 ❑ ❑ ❑
and sampling location)?
Comment:
Page# 7

Permit: NCO057720
Inspection Date: 01/19/2023
Owner -Facility: Hidden Lakes Village Mobile Home Park)
Inspection Type: Compliance Evaluation
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? ❑ 0 ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: Corrosion was observed throuqhout the system. Holes in the qround were observed
around the system that could impact the integrity of the plant. There is an uncontained
leak in the pipe going from the post -chlorination tank to the meter well.
The lines are joined together using temporary couplings. These joints should be
welded or otherwise made permanent.
Discarded materials are present around the perimeter of the plant posing potential
safety concerns.
Standby Power
Yes
No
NA
NE
Is automatically activated standby power available?
❑
■
❑
❑
Is the generator tested by interrupting primary power source?
❑
0
❑
❑
Is the generator tested under load?
❑
0
❑
❑
Was generator tested & operational during the inspection?
❑
0
❑
❑
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
❑
0
❑
❑
power?
Is the generator fuel level monitored?
❑
0
❑
❑
Comment: No standby power source is located on -site. A back-up qenerator or power source
should be installed.
Pumps-RAS-WAS
Yes
No
NA
NE
Are pumps in place?
0
❑
❑
❑
Are pumps operational?
0
❑
❑
❑
Are there adequate spare parts and supplies on site?
❑
❑
■
❑
Comment:
Page# 8