WQCSD0671_NOV2018DV0120_20180118

Water Resources
ENVIRONMENTAL QUAL11"Y'
January 31, 2018
CERTIFIED MAIL 7014 1200 8628 5060
RETURNED RECEIPT REQUESTED
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
interim
Director
RECEIVED/DENR/DWR
FEB 0 5 2018
James R. Edwards Water Resources
1808 Pinecrest Street Permitting Section
Burlington, NC 27215
Subject: Notice of Violation
NOV-2018-DV-0120
SS Mobile Home Park Wastewater Collection System
Permit Number WQCSD0671
Chatham County
Dear Mr. Edwards:
On January 19, 2018, Division of Water Resources Raleigh Regional Office (RRO) was informed
of a sanitary sewer overflow (SSO) in the SS Mobile Home Park in Siler City. Ray Milosh of RRO
arrived on site at 4 PM on January 21, 2018. He observed evidence that a significant quantity of
wastewater had flowed from a broken cleanout behind 51 JR Edwards Lane. There was evidence
that the conveyance system had been dug up and that blockage had been removed. It was also
evident that wastewater had flowed out of the next upgradient cleanout which was open with no
cap at the time of the inspection. There was no evidence that efforts had been made to clean up
the solids in the wastewater or to lime the area. At least two cleanouts downgradient were found
to have no caps.
The collection system (permit number WQCSD0671) is deemed permitted and must comply with
the criteria in 15A NCAC 02T.0403 which are included in Attachment A. Reporting requirements
for sanitary sewer overflows (SSO's) are included in Attachment B.
The sewer overflow constitutes a violation of 15A NCAC 02T .0403 (a) (1) which states the
following:
15A NCAC 02T.0403 (a) (1)
"The sewer system is effectively maintained and operated at all times to prevent discharges to land
or surface waters, and to prevent any contravention of groundwater standards or surface water
standards."
These -violations -and any future violations are subject to civil penalty assessment of up to $25,000
per day per violation. Please see attached copy of the rules regarding waste NOT discharged to
waters and spill reporting requirements. Please respond to this letter in writing within 30 days of
receipt. Your response should minimally address the following items:
State of North Carolina I Environmental Quality I Water Resources I Raleigh Regional Office
1628 Mail Service Center I Raleigh, North Carolina 27699-1628
9197914200

Mr. James Edwards
NOV-2018-DV-0026
Page 2
January 31, 2018
1) Clearly detail the cause(s) of the overflow and explain how you repaired/corrected the
problem. Please explain when the Overflow was first observed and what actions had been
taken.
2) Please explain what changes you aie planning to implement to ensure spill reporting
requirements (bgp://portal.ncdenr.grrg/web/wq/swp/ps/cs/ssoreport) are followed, clean-
up efforts are timely, and waste collection systems are properly maintained.
The Raleigh Regional Office is consideri g assessing a Civil Penalty Assessment regarding this
matter. Your response to this letter will considered as a part of this process. If you have any
questions about this letter, please contact a at 919.791.4200.
Sincerely, �_...
Dann
Smith.,
Wate Quality Regional Supervisor
Ralei h Regional Office
Cc: RRO —File Copy
DWR — PERCS — Deborah Gore
Central Files

Mr. James Edwards
NOV-2018-DV-0026
Page 3
January 31, 2018
Photo to left shows broken cleanout and freshly
dug soil where repair was made.
Photo below shows evidence of overland flow of
wastewater toward 51 JR Edwards Lane.
Photo below and left shows upgradient cleanout
with evidence of overflow and no cap.

Mr. James Edwards
NOV-2018-DV-0026
Page 4
January 31, 2018
Attachment A
15A NCAC 02T.0403 PERMITTING BY REGULATION
(a) Collection systems having an actual, permitted or Division approved average daily flow less than 200,000
gallons per day are deemed permitted pursuant to Rule .0113 of this Subchapter provided the system meets the
criteria in Rule .0113 of this Subchapter and all specific criteria required in this Rule:
(1) The sewer system is 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.
(2) A map of the sewer system has been developed and is actively maintained.
(3) An operation and maintenance plan including pump station inspection frequency, preventative maintenance
schedule, spare parts inventory and overflow response has been developed and implemented.
(4) Pump stations that are not connected to a telemetry system (i.e., remote alarm system) are inspected by the
permittee or its representative every day (i.e., 365 days per year). Pump stations that are connected to a telemetry
system are inspected at least once per week.
(5) High-priority sewers are inspected by the permittee or its representative at least once every six -months and
inspections are documented.
(6) A general observation by the permittee or its representative of the entire sewer system is conducted at least once
per year.
(7) Overflows and bypasses are reported to the appropriate Division regional office in accordance with 15A NCAC
02B .0506(a), and public notice is provided as required by G.S. 143-215.1C.
(8) A Grease Control Program is in place as follows:
(A) For publicly owned collection systems, the Grease Control Program shall include at least bi-annual distribution
of educational materials for both commercial and residential users and the legal means to require grease interceptors
for new construction and retrofit, if necessary, of grease interceptors at existing establishments. The plan shall also
include legal means for inspections of the grease interceptors, enforcement for violators and the legal means to
control grease entering the system from other public and private satellite sewer systems.
(B) For privately owned collection systems, the Grease Control Program shall include at least bi-annual distribution
of grease education materials to users of the collection system by the permittee or its representative.
(C) Grease education materials shall be distributed more often than required in Parts (A) and (B) of this
Subparagraph if necessary to prevent grease -related sanitary sewer overflows.
(9) Right-of-ways and easements are maintained in the full easement width for personnel and equipment
accessibility.
(10) Documentation shall be kept for Subparagraphs (a)(1) through (a)(9) of this Rule for a minimum of three years
with exception of the map, which shall be maintained for the life of the system.
(b) Private collection systems on a single property serving an industrial facility where the domestic wastewater
contribution is less than 200,000 gallons per day shall be deemed permitted.
(c) The Director may determine that a collection system should not be deemed to be permitted in accordance with
this Rule and Rule .0113 of this Subchapter. This determination shall be made in accordance with Rule .0113(e) of
this Subchapter.
History Note: Authority G. S. 143-215.1(a); 143-215.3(a); 143-215.9B;
Eff. September 1, 2006.

Mr. James Edwards
NOV-2018-DV-0026
Page 5
January 31, 2018
Attachment B: Reporting Requirements: Sewer Overflows (SSO)
Division of Water Resources reporting requirements for Sanitary Sewer Overflows (spills)
1. Did the sewer spill reach surface waters?
You must report any amount that reaches surface waters. You must provide a verbal report within 24 hours
to the Raleigh Regional Office at [phone].
Telephone Regional Office within 24 hours of `first knowledge'. (If after hours, Emergency
Management) (800)-858-0368)
You must follow up with a 5 day written repot to the Raleigh Regional Office:
Division of Water Resources
Water Quality - Regional Operations Section
3800 Barrett Drive
Raleigh NC 27609
�I
The report must address the following information: Location, quantity, water body affected (name of
stream), date and time of occurrence, duration, weather Conditions, spill clean-up and infrastructure repair
information.
2. Is the spill 1000 gallons or more?
Wastewater spills that are 1,000 gallons or greater, whether reaching a stream or surface waters or contained
on dry land must be reported. You must provide a verbal report within 24 hours to the Raleigh Regional
Office at [phone].
Telephone Regional Office within 24 hours of `first knowledge'. (If after hours, Emergency
Management) (800)-858-0368)
You must follow up with a 5 day written report to the Raleigh Regional Office:
Division of Water Resources
Water Quality - Regional Operations Section
3800 Barrett Drive
Raleigh NC 27609
3. Do you need issue a Press Release? Do you need to issue a Public Notice?
NCGS 143-215.1C.(b) (1) and (2)
Press Release = if 1,000 gallons or more of untreated waste are discharged to the surface waters of the
State, the responsible party must provide a news release to all print and electronic news media that
provide general coverage in the county — within 48 hours.
Publish a "Notice of Discharge'— 15,000 galloi
State must be noticed in the news paper having
occurred and affected - within 10 days of DEN
newspaper must be submitted to the Raleigh Re,
If you have questions please do not hesitate to
791-4200. Note: failure to properly report w
of up to $25,000.00 per day.
or more of untreated waste to the surface waters of the
general circulation in the county in which the discharge
's approval. A copy of the notice that was placed in the
ional Office within 30 days.
ontact the Raleigh Regional Office for assistance (919)
stewater spills may result in a civil penalty assessment