NC0057720_NOI_NOV2023PC0069_20230629

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
June 29, 2023
CERTIFIED MAIL # 7020 3160 0002 0860 6184
RETURN RECEIPT REQUESTED
Jones Estate Hidden Lakes, LLC
Attn: Kellen Buss, Director of Site Infrastructure
2310 Miami Blvd, Suite 238
Durham, NC 27703
Subject: NOTICE OF CONTINUING & ADDITIONAL VIOLATIONS and
RECOMMENDATION FOR ENFORCEMENT
NOV Tracking #: NOV-2023-PC-0069
Hidden Lakes Village Mobile Home Park WWTP
NPDES Permit #: NCO057720
Stokes County
Dear Mr. Buss:
On January 19, 2023, Division of Water Resources/Winston-Salem Regional Office (NCDWR/WSRO) staff
inspected the Hidden Lakes Village Mobile Home Park Wastewater Treatment Plant. This inspection
resulted in several violations as detailed in the table below:
PERMIT
VIOLATIONS:
1.
There is currently no bar screen installed or operational in the treatment system. Multiple system
components (including diffusers, blowers, chlorinator, and dechlorinator) 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 11, Section C, Paragraph 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 11, Section C, Paragraph 7.
3.
Data records prior to July 2022 were not available at the time of inspection. This is in violation of
Part 11, Section D, Paragraph 6.
4.
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 conditions Part 11, Section D, Paragraphs 3 and 6.
On May 22, 2023, NCDWR/WSRO staff conducted a follow-up inspection. This inspection reflected
continuing non-compliance, in addition to new violations, as detailed in the table below:
e:!ar::f NORTH CAROLINAD QI
�
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
336.776.9800

PERMIT
VIOLATIONS:
1.
The bar screen, chlorinator, and dechlorinator are all still missing from the plant. Removal of these
processes, without adequate equivalent replacements, capable of providing comparable
treatment, was not authorized by the NCDWR as required by Part 11, Section E, Paragraph 2, of the
permit, as well as NC General Statute (NCGS) 143-215.1(a)(3). Furthermore, as noted in the
January 2023 inspection, it is also a violation of Part 11, Section C, Paragraph 2, of the permit. The
operator uses a single tube each for chlorination and dechlorination that is only leaning against the
wall of the component it has been placed in.
2.
There are still no adequate safeguards (including standby power) to prevent the discharge of
untreated or inadequately treated wastes during electrical power failures for the facility, in
violation of Part 11, Section C, Paragraph 7.
3.
Data records prior to July 2022 were still not available at the time of inspection, in violation of Part
11, Section D, Paragraph 6.
4.
The flow meter was installed in early 2022. The meter has been installed longer than a year and
still has not been calibrated. The operator stated that they cannot find someone to calibrate it. This
violates Part 11, Section D. Paragraph 3.
5.
Corrosion and disrepair of treatment units is a violation of Part 11, Section C, Paragraph 2, of the
permit, as detailed below:
a. The aeration basin has severe corrosion.
b. The air header and laterals are in very poor condition and were observed to provide insufficient
air diffusion throughout the tank.
c. The clarifiers have severe corrosion. The inlet/scum box on the southern clarifier is so
overgrown with weeds that have taken root in the scum layer that you cannot see the box. The
northern clarifier's inlet/scum box is visible but only about 50 percent of the original structure
remains due to corrosion, allowing the scum to flow right back into the clarifier.
d. The sludge holding tank has two large open holes in it just above the level of the current inlet
pipe. Sludge could flow out onto the ground, and possibly to the stream, if it reaches the level
of these holes.
You are reminded that in accordance with NC General Statute 143-215.6A, a civil penalty of not more than
twenty-five thousand dollars ($25,000) may be assessed by the Secretary of the Division of Water
Resources against any person who is required but fails to apply for or to secure a permit required by NCGS
143-215.1, or who violates or fails to act in accordance with the terms, conditions, ore requirements of
such permit.
As such you must take immediate steps to correct the violations noted above. Please reply in writing to
this notice within 10 days of receiving it. Your written response should detail the corrective actions you
have taken and/or plan to take to correct each of the listed violations. If you anticipate corrective actions
taking longer than 10 days, you must provide an estimated completion date for each corrective action
that takes longer than 10 days to complete. Failure to reply in writing, as directed, or to satisfactorily
correct the listed violations, may result in a recommendation by this office to proceed with the above -
mentioned enforcement procedures.
North Carolina Department of Environmental Quality I Division of Water Resources
RE;
QWinston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Winston-Salem, North Carolina 27105
NORTH CAHOJNA 336.776.9800

If you have any questions or concerns, please contact Mr. Boone by phone at 336.776.9690 or by email at
[e-mail]. Thank you for your time and immediate attention to these issues.
Sincerely,
DocuSiTgned by:
%A. l . 5,,. Gr
145B49E225C94EA...
Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
Attachments:
1. Compliance Inspection Report
North Carolina Department of Environmental Quality I Division of Water Resources
RE;
QWinston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Winston-Salem, North Carolina 27105
NORTH CAROLINA 336.776.9800
nepe .mo F.o. a wquay

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 111 121 23/05/22 I17 18 LC] I 19 I s I 201
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 ni 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)
11:00AM 23/05/22
22/10/01
Hidden Lakes Village Mobile Home Park WWTP
1020 Twin Lakes Dr
Exit Time/Date
Permit Expiration Date
King NC 27021
12:OOPM 23/05/22
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 DWR/WSRO WQ/336-776-9690/
cuSigned by:
naecl 6/29/2023
L;�-R
FeeeS
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
DocuSigned by:
6/29/2023
ti T.
F
145B49E225C94EA...
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

NPDES yr/mo/day Inspection Type
NCO057720 I11 12I 23/05/22 117 18 ici cJ
(Cont.)
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
On January 19, 2023, Division of Water Resources/Winston-Salem Regional Office (NCDWR/WSRO)
staff inspected the Hidden Lakes Village Mobile Home Park Wastewater Treatment Plant. This
inspection resulted in several violations as detailed in the table below:
PERMIT VIOLATIONS:
1. There is currently no bar screen installed or operational in the treatment system. Multiple system
components (including diffusers, blowers, chlorinator, and dechlorinator) 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, Paragraph 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, Paragraph 7.
3. Data records prior to July 2022 were not available at the time of inspection. This is in violation of
Part II, Section D, Paragraph 6.
4. 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 conditions Part II, Section D, Paragraphs 3 and 6.
On May 22, 2023, NCDWR/WSRO staff conducted a follow-up inspection. This inspection reflected
continuing non-compliance, in addition to new violations, as detailed in the table below:
PERMIT VIOLATIONS:
1. The bar screen, chlorinator, and dechlorinator are all still missing from the plant. Removal of
these processes, without adequate equivalent replacements, capable of providing comparable
treatment, was not authorized by the NCDWR as required by Part II, Section E, Paragraph 2, of the
permit, as well as NC General Statute (NCGS) 143-215.1(a)(3). Furthermore, as noted in the January
2023 inspection, it is also a violation of Part II, Section C, Paragraph 2, of the permit. The operator
uses a single tube each for chlorination and dechlorination that is only leaning against the wall of the
component it has been placed in.
2. There are still no adequate safeguards (including standby power) to prevent the discharge of
untreated or inadequately treated wastes during electrical power failures for the facility, in violation of
Part II, Section C, Paragraph 7.
3. Data records prior to July 2022 were still not available at the time of inspection, in violation of Part
II, Section D, Paragraph 6.
4. The flow meter was installed in early 2022. The meter has been installed longer than a year and
still has not been calibrated. The operator stated that they cannot find someone to calibrate it. This
violates Part II, Section D. Paragraph 3.
5. Corrosion and disrepair of treatment units is a violation of Part II, Section C, Paragraph 2, of the
permit, as detailed below:
a. The aeration basin has severe corrosion.
b. The air header and laterals are in very poor condition and were observed to provide insufficient
air diffusion throughout the tank.
c. The clarifiers have severe corrosion. The inlet/scum box on the southern clarifier is so overgrown
with weeds that have taken root in the scum layer that you cannot see the box. The northern
clarifier's inlet/scum box is visible but only about 50 percent of the original structure remains due to
corrosion, allowing the scum to flow right back into the clarifier.
d. The sludge holding tank has two large open holes in it just above the level of the current inlet
pipe. Sludge could flow out onto the ground, and possibly to the stream, if it reaches the level of
these holes.
Page#

Permit: NCO057720 Owner -Facility: Hidden Lakes Village Mobile Home Park)
Inspection Date: 05/22/2023 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: Bar screen, chlorinator, and dechlorinator units are all missing. No screening is being
done and chlorination and dechlorination are only occurring using single tablet tubes
placed in flow channels that facilitate only minimal contact with the wastewater, bringing
into question the effectiveness of the chlorination and dechlorination processes in
current use.
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: Lab records and DMRs were NOT reviewed during this inspection.
Page# 3

Permit: NCO057720 Owner -Facility: Hidden Lakes Village Mobile Home Park)
Inspection Date: 05/22/2023 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: None
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: Samples are taken at effluent weir.
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: None
Bar Screens
Type of bar screen
Yes No NA NE
a.Manual
❑
b.Mechanical
❑
Are the bars adequately screening debris?
❑
0
❑
❑
Is the screen free of excessive debris?
❑
■
❑
❑
Is disposal of screening in compliance?
❑
0
❑
❑
Is the unit in good condition?
❑
■
❑
❑
Comment: The bar screen has been removed from the
process without authorization to do so
from the Division.
Page# 4

Permit: NCO057720
Inspection Date: 05/22/2023
Bar Screens
Owner -Facility: Hidden Lakes Village Mobile Home Park)
Inspection Type: Compliance Evaluation
Aeration Basins
Mode of operation
Type of aeration system
Is the basin free of dead spots?
Are surface aerators and mixers operational?
Are the diffusers operational?
Is the foam the proper color for the treatment process?
Does the foam cover less than 25% of the basin's surface?
Is the DO level acceptable?
Is the DO level acceptable?(1.0 to 3.0 mg/I)
Yes No NA NE
Yes No NA NE
Ext. Air
Diffused
■
❑
❑
❑
❑
❑
■
❑
❑
■
❑
❑
•
❑
❑
❑
•
❑
❑
❑
❑
❑
❑
■
❑
❑
❑
■
Comment: The air header and laterals are in very poor condition and provide little air diffusion
throughout the tank. The basin itself is severely corroded.
Secondary Clarifier
Is the clarifier free of black and odorous wastewater?
Is the site free of excessive buildup of solids in center well of circular clarifier?
Are weirs level?
Is the site free of weir blockage?
Is the site free of evidence of short-circuiting?
Is scum removal adequate?
Is the site free of excessive floating sludge?
Is the drive unit operational?
Is the return rate acceptable (low turbulence)?
Is the overflow clear of excessive solids/pin floc?
Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth)
Comment: The clarifier has severe corrosion.
Pumps-RAS-WAS
Are pumps in place?
Are pumps operational?
Are there adequate spare parts and supplies on site?
Comment: None
Yes No NA NE
■ ❑ ❑ ❑
❑ ■ ❑ ❑
■ ❑ ❑ ❑
❑ ❑ ❑
Yes No NA NE
❑ ❑ ❑
❑ ❑ ❑
❑ ❑ ❑
Page# 5

Permit: NC0057720
Inspection Date: 05/22/2023
Flow Measurement - Effluent
# Is flow meter used for reporting?
Is flow meter calibrated annually?
Owner -Facility: Hidden Lakes Village Mobile Home Park)
Inspection Type: Compliance Evaluation
Is the flow meter operational?
(If units are separated) Does the chart recorder match the flow meter?
Comment: The flow meter still has not been calibrated. According to the
someone to calibrate it.
Disinfection -Tablet
Are tablet chlorinators operational?
Are the tablets the proper size and type?
Number of tubes in use?
Is the level of chlorine residual acceptable?
Is the contact chamber free of growth, or sludge buildup?
Is there chlorine residual prior to de -chlorination?
Yes
No
NA
NE
■
❑
❑
❑
❑
■
❑
❑
❑
❑
❑
■
❑
❑
■
❑
thev cannot find
Yes
No
NA
NE
❑
■
❑
❑
■
❑
❑
❑
1
❑ ❑ ❑ ■
❑ ■ ❑ ❑
❑ ❑ ❑ ■
Comment: The chlorinator has been completely removed from the plant without authorization from
the Division. The operator only uses a single chlorinator tablet tube that he fills with
tablets and places somewhere in the flow pattern after the clarifier's weir. The
thoroughness of contact with flow as well as contact time is highly questionable.
De -chlorination
Type of system ?
Is the feed ratio proportional to chlorine amount (1 to 1)?
Is storage appropriate for cylinders?
# Is de -chlorination substance stored away from chlorine containers?
Are the tablets the proper size and type?
Comment: None
Yes No NA NE
Tablet
❑ ❑ ❑ ■
❑ ❑ ■ ❑
❑ ❑ ❑ ■
■ ❑ ❑ ❑
Are tablet de -chlorinators operational? ❑ 0 ❑ ❑
Number of tubes in use? 1
Comment: The dechlorinator has been completely removed from the plant without authorization
from the Division. The operator only uses a single dechlorinator tablet tube that he fills
with tablets and places somewhere in the flow pattern after the clarifier's weir. The
thoroughness of contact with flow, and therefore the effectiveness of the
dechlorination, is highly questionable .
Effluent Pipe
Is right of way to the outfall properly maintained?
Yes No NA NE
■ ❑ ❑ ❑
Page# 6

Permit: NCO057720
Inspection Date: 05/22/2023
Owner -Facility: Hidden Lakes Village Mobile Home Park)
Inspection Type: Compliance Evaluation
Effluent Pipe
Are the receiving water free of foam other than trace amounts and other debris?
If effluent (diffuser pipes are required) are they operating properly?
Comment: Pipe is difficult to access. Samples are currently taken at the effluent weir.
Anaerobic Digester
Type of operation:
Is the capacity adequate?
# Is gas stored on site?
Is the digester(s) free of tilting covers?
Is the gas burner operational?
Is the digester heated?
Is the temperature maintained constantly?
Is tankage available for properly waste sludge?
Yes
No
NA
NE
■
❑
❑
❑
❑
❑
❑
Yes No NA NE
No cover
■ ❑ ❑ ❑
❑ ❑ ❑
❑ ❑ ❑
❑ ❑ ❑
❑ ❑ ❑
❑ ❑ ❑
❑ ❑ ❑
Comment: This is just a sludge holding tank. It is not aerated. There are two large open holes in
the tank that need to be permanently sealed. Otherwise, sludge will freely flow out of
the tank onto the ground if it reaches the level of these holes.
Operations & Maintenance
Is the plant generally clean with acceptable housekeeping?
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable
Solids, pH, DO, Sludge Judge, and other that are applicable?
Yes No NA NE
❑ ■ ❑ ❑
❑ ❑ ❑
Comment: The entire plant is severely corroded and in poor condition. Units that have broken in
the past have not been properly fixed or replaced, therefore bringing into question
whether sufficient treatment is taking place.
Page# 7