NC0057720_Remission (Request)_20231218

RECEIVED
JUSTIFICATION FOR REMISSION REQUEST
DWR Case Number: PC-2023-0034
Assessed Entity:
Permit No.:
Jones Estate Hidden Lakes, LLC
NCO057720
County:
Stokes
WR/NPDES
Amount Assessed: $6,941.84
Please use this form when requesting remission of this civil penalty. You must also complete the
"Request For Remission, Waiver of Right to an Administrative Hearing, and Stipulation of Facts"
form to request remission of this civil penalty. You should attach any documents that you believe
support your request and are necessary for the Director to consider in evaluating your request
for remission. Please be aware that a request for remission is limited to consideration of the five
factors listed below as they may relate to the reasonableness of the amount of the civil penalty
assessed. Requesting remission is not the proper procedure for contesting whether the
violation(s) occurred or the accuracy of any of the factual statements contained in the civil
penalty assessment document. Pursuant to N.C.G.S. § 143B-282.1(c), remission of a civil penalty
may be granted only when one or more of the following five factors apply. Please check each
factor that you believe applies to your case and provide a detailed explanation, including copies
of supporting documents, as to why the factor applies (attach additional pages as needed).
❑ (a) one or more of "the civil penalty assessment factors in N.C.G.S. 143B-282.1(b) were
wrongfully applied to the detriment of the petitioner (the assessment factors are listed in the civil
penalty assessment document);
(b) the violator promptly abated continuing environmental damage resulting from the
violation (i.e., explain the steps that you took to correct the violation and prevent future
occurrences);
❑ (c) the violation was inadvertent or a result of an accident (Le., explain why the violation
was unavoidable or something you could not prevent or prepare for);
❑ (d) the violator had not been assessed civil penalties for any previous violations;
❑ (e) payment of the civil penalty will prevent payment for the remaining necessary remedial
actions (i.e., explain how payment of the civil penalty will prevent you from performing the
activities necessary to achieve compliance).
EXPLANATION:
n
North Carolina Departtnett ofEuviroom aW Quality 1 Division of Water Resources
Winston-Salem Regional Office 1450 W. Hams 164M Rd, Suite 3001 Winston-Salem. North Carolina 27105
336.776.9800

Stackhouse Management LLC
PO Box 14466
R Durham, NC 27709
ECEI
V
DEC] 5 1", ,
G?/D WF?/N PO ,
v. November 25, 2023
Jennifer F. Graznak
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
450 West Hanes Mill Road, Ste 300
Winston-Salem, NC 27105
RE: Notice of Violation & Intent to Assess Civil Penalty
NPDES Permit No: NCO057720
Hidden Lakes Village Mobile Home Park WWTP
Case Number: PC-2023-0034
Notice: NOV-2023-PC-0069
Dear Jennifer,
This letter responds to the Violation and Intent to Assess Civil Penalty dated November 1, 2023, issued to
Jones Estates Hidden Lakes LLC. The NOV states that the DEQ staff detected the following issues:
• 1 of 1 Violation(s) of NPDES Permit No. NC0057720, Part II. Section C. Paragraph 2. By failing
to properly operate and maintain at all times all facilities and systems of treatment and control
(and related appurtenances) which are installed or used by the Permittee to achieve compliance
with the conditions of this permit.
• 1 of 1 Violation(s) of NPDES Permit No. NC0057720, Part II. Section C. Paragraph 7. By failing
to maintain adequate safeguards (as required by 15A NCAC 02H .0124) to prevent the discharge
of untreated or inadequately wastes during electrical power failures either by means of alternate
power sources, standby generators, or retention of inadequately treated effluent.
• 1 of 1 Violation(s) of NPDES Permit No. NC0057720, Part 1I. Section D. Paragraph 3. By failing
to install appropriate, Director -approved flow measurement devices which can be accurately
calibrated at a minimum of once per year and maintained to ensure that the accuracy of the
measurements is consistent with the accepted capability of that type of device.
• 1 of 1 Violation(s) of NPDES Permit No. NC0057720, Part Il. Section D. Paragraph 6 and NC
Administrative Code 15A NCAC 02B .0506(axDxi) by failing to maintain required records for a
period of at least 3 years from the date of the sample, measurement, report, or application; and
Part III. Section A. Paragraph a & NC General Statute 143-215.1 (ax3) by failing to obtain
proper authorization to construct permits form the division prior to changing the treatment plant's
process.

Stackhouse Management LLC
PO Box 14466
Durham, NC 27709
To address Violation
Violation (1) ofNPDES Permit No. NC0057720 Part II Section C. Paragraph 2•
�P
Violation (1) ofNPDES Permit No. NC0057720 Part II Section C. Paragraph 7•
AND
AND Violation (1) of NPDES Permit No. NC0057720 Part II Section Q. Para age nh 3_
Violation (1) of NPDES Permit No. NC0057720 Part II Section Q. Paragraph 6
PERMIT VIOLATION DETAIL:
a. No Bar Screen Installed or Operational in the Treatment System. Multiple system components are either
not present or insufficient. There is an uncontained leak in the pipe going from the post -chlorination tank to
the metered well.
b. There are no adequate safeguards to prevent discharge or inadequately treat waste during power failures.
c. Records of the flow meter were not available on -site during inspection.
d. Data records prior to July 2022 were not available during time of inspection.
Jones Estates Hidden Lakes LLC has taken the following action to rectify the abovementioned violations:
Airlines Installation: Jul 2023
o Airline on the claarifer return. This has been installed to improve the efficiency and
functionality of the system. This ensures proper operation and compliance with the
permitted requirements. Returns are clear on clarifier.
Bar Screen Repair: Fall 2023
o The bar screen repair has since been and is expected to maintain the function of
proper flow and filtration for the wastewater system.
Skimmer Line: July 2023
Timer For Blower: Timer issue has been addressed with the operator and will be ordered and
installed.
Flow Meter: September 2023
Flow Meter: October 2023
o Jones Estates Hidden Lakes LLC contracted the engineering firm Horizon
Engineering & Consulting, Inc. to install and calibrate meter (SN: 204J00826) on
9/11/2023.
The Flow meter was calibrated on 10/30/2023 by Horizon Engineering & Consulting.
It has been confirmed to be in working order programmed, calibrated, and level of
flow conversion for primary device to be correct. Records to support the installation
Records: Correcte July -Current 2023
o To rectify this issue, Jones Estates Hidden Lakes LLC has implemented measures to
ensure that all relevant records are retained on -site moving forward. We have
reviewed our record -keeping procedures and have put in place a system to track and
maintain these records in a readily accessible manner.

Stackhouse Management LLC
PO Box 14466
Durham, NC 27709
We have reviewed the violations carefully and have taken the complete and necessary steps to rectify the
situation promptly. Our team worked diligently to ensure that all reppaair�rss were completed in accordance
with the regulations set forth by the North Carolina Department of Env ronmental Quality. We are
confident that the repairs made to the system will satisfy the violations and bring us back into compliance.
We have implemented measures to prevent similar issues from occurring in the future, including regular
maintenance, and monitoring protocols.
Jones Estates Hidden Lakes LLC is aware of the seventy of the violations addressed and takes all
reasonable steps to correct these issues. We appreciate the concern and attention drawn to these matters
as it ensures our compliance and safety for our system.
If there are additional steps or documentation required to demonstrate our compliance, please let us know,
and we will promptly provide the necessary information. Thank you for your understanding and
cooperation in this matter. We value our relationship with the North Carolina Department of
Environmental Quality and are committed to maintaining a high standard of environmental stewardship.
Thank you,
Kellen P. Buss
Director of Site
Infrastructure 2310 S.
Miami Blvd.
Durham, NC 27703
419-357-9091
[e-mail]

_ 4!�
Horizon Engineering & Consulting. Inc.
Walker oa
Mt. Pleasant, N C. 28124
704-7W7730
Flow Meter Calibration Data Sheet
Facility Name: Hidden Lakes Estates MHP City: King State: N C.
Utility Name: NA Primary Device (weir): 22.5 dam_
Flow Meter Manf.: Teledyne ISCO Model: 4210 Serial No. 210J01029
Type- Bubbler: _L,,-' Ultrasonic: Other:
I- Primary Device:
A.
B.
C
D.
E.
F
II. Meter:
A.
B.
Level
_�/ yes
no
Free Flow
✓ yes
no
Turbulence
yes
no
Blockage
yes
no
Surface
Buildup
yes
no
Comments
Property
Mounted dyes no
Tlrs ivy /Av e-g/L"r-a-110-1 o-r4
Programmed correct Zyes no
Calibration:
1. Calibrated with flow cut off yes _L'-' no
If yes. Level Before
Level After
Resume flow, compare measured level to meter reading.
Verify that readings agree yes no
2. If no. Flow Level Before /, 0 9
Flow Level After /, S5 S
C. Check if level to flow conversion for primary device is correct: ✓ yes _ no
D. Check O sq-.avtii3lotalized correctly yes no
Calibrated by;.-'( / -
11
P.E.
Date: lo 131
Time: - a AM

A --,.Horizon Engineering & Consulting. Inc.
Walker IM
Mt.. Pleasant N.C. 28124
704-79&7730
Flow Meter Calibration Data Sheet
Facility Name: Hidden Lakes Estates MHP City: King State: N.C.
Utility Name: NA Primary Device (weir): 22.5 deg.
Flow Meter Manf.: Teledyne ISCO Model. 4210 Serial No. 204J00826
Type: Bubbler: Ultrasonic: Other:
1. Primary Device:
A. Level
B. Free Flow
C. Turbulence
D. Blockage
E. Surface
Buildup
F. Properly
yes no
yes no
yes _L.,-- no
yesy no
yes t.✓ no
Comments:
Mounted ✓yes no
11. Meter: IY& f e v 2-s c��'1• � i'a fez �`hs �•��
file- oy e w om. ele,,t.,
A. Programmed correct ✓yes no
B- Calibration, %
1 Calibrated with flow cut off yes ✓ no
If yes. Level Before
Level After
Resume flow, compare measured level to meter reading.
Verify that readings agree yes no
2. If no, Flow Level Before
r�
Flow Level After 2, ©OD
C. Check if level to flow conversion for primary device is correct: dyes no
D. Chlft^o flow i t lized correctly: ✓yes no
Calibrated by: Date: 9
J n e, P.E. Time: S AM o