NC0061204_Compliance Evaluation Inspection_20180705

rC
ROY COOPER
�; Governor
MICHAEL S.REGAN
Secretary
Water Resources - LINDA CULPEPPER
Environmental Quality Interim Director
July 5, 2018
Mr. Thomas M. Alphin, Jr.
P.O. Box 5
Walkertown, NC 227051-0005
SUBJECT: Compliance Evaluation Inspection &Notice of Violation
NOV Tracking#: NOV-2018-PC-0218 RECEIVED/DENR/DWR
Scarlett Acres Mobile Home Park Wastewater Treatment Plant JUL 0201
NPDES Permit#: NC0061204
Forsyth County Water Resources
Permitting Section
Dear Mr.Alphin:
Ron Boone, of the Winston-Salem Regional Office (WSRO) of the NC Division of Water Resources (DWR or the
Division),conducted a compliance evaluation inspection(CEI)of the Scarlett Acres Mobile Home Park Wastewater
Treatment Plant(WWTP)on June 5,2018.Your assistance and cooperation,as well as that of Mr.Randy Bell,Operator
in Responsible Charge (ORC), was greatly appreciated. An inspection checklist is attached for your records and
inspection findings are summarized below.
I. Permit
The NPDES permit became effective July 1, 2014 and expires June 30, 2019. A copy of the permit was
available on site during the inspection.
II. Self-Monitoring Program
A review of the monthly discharge monitoring reports (DMR) for the period June 2013 through June 2018
showed that the facility experienced 80 violations during that time frame, all of which have already been
addressed via separate correspondence. Please note this is a relatively high number of violations.
III. Flow Measurement
Flow.is measured using an ISCO 4230 bubbler flow meter that was last calibrated May 31st, 2017, so, it is
again due for calibration.
IV. Operations and Maintenance
Mr. Boone reports that the WWTP is in fair condition, but the influent pump station is in poor condition and is
a severe safety hazard for operations staff. You should consider upgrading this pump station, or at a
' ',"Nothing Compares .—.
State of North Carolina I Environmental Quality
450 W.Hanes Mill Road,Suite 300,Winston-Salem,North Carolina 27105
Phone.[phone] FAX:[phone]

minimum, taking steps to reduce the hazards. Plant condition is a direct reflection of the operations and
maintenance it has received over the years and the condition of this plant brings into question whether the
plant can treat the wastewater to within permit requirements, despite the fact that a portion of the effluent
data indicates it can.
V. Facility Site Review
Most components of this 0.02 million-gallon-per-day (MGD) facility appeared to be functional during the
inspection, but Mr. Boone observed the following problems:
• The influent pump station's (IPS) high-level float and/or alarm was inoperable during the inspection.
Operators expressed that they thought an operational high-level float/alarm on the IPS is of low
importance and stated that the flow would simply backup the sewer line in the event of a pump failure.
Although true,raw wastewater would overflow the IPS once the level in the pipe reached the overflow
elevation of the IPS. This would then result in a bypass of the entire treatment works.
• The discharge piping on the IPS's pumps is currently constructed of some type of black, plastic,
corrugated, non-hard-wall material that apparently collapses under the vacuum created when the
pumps shut off and the pipe contents drain back down into the station. This piping needs to be
replaced with an appropriate hard-walled material.
• The plant has no bar screen and operators stated that it was removed a couple of years ago. The
2015 inspection report stated that the bar screen had been removed due to it being in extremely poor
condition and no longer reliable. However, the permit's plant description lists a bar screen, so,
obviously, the plant was designed to have one. Without it, these solids simply enter the aeration
basin and then go on to disturb the rest of the treatment process. The bar screen must be replaced
or you must formally ask permission from the Division to continue without it using the correct protocol
and documentation. It was also noted in the 2015 inspection that the Division was never notified of
removal of the bar screen, as is required.You should not undertake any future changes to the plant
without first notifying and garnering approval of the changes from the Division. These requirements
are fully explained in the permit. Please read the permit to ensure you're fully aware of all
requirements.
• The dissolved oxygen content of the aeration basin was only 0.36 milligrams per liter(mg/I). A light
brown foam covered the majority of the aeration basin surfaces, but appeared heavier in the northern
basin; the one with fixed media. The suspended solids concentration in the southern aeration basin
was only about 200 mg/I.
• There is some corrosion and dilapidation throughout the plant, particularly severe at the influent
pump station, as previously mentioned. Some components, such as the pump line from the pump
station to the splitter box, are constructed rather haphazardly, or of inappropriate materials, as also
mentioned earlier. These pipes should be replaced with appropriate materials.

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VI. Records/Reports
According to existing records, all required effluent monitoring has been performed in accordance with the
parameters and frequencies required by the NPDES permit. Chains of custody,operations and maintenance
logs, operator's visitation logs, etc., were all available for inspection.
Sludge records need to be improved and should always be on site and available during all inspections.
Please provide sludge removal records for the past two years along with your reply to this letter.
VII. Effluent/Receiving Waters
Pin floc was flowing over the clarifier weir troughs at the time of the inspection but the effluent pipe was
completely obscured by vegetation and the effluent flow could not be assessed. It was agreed during the
inspection that the outfall would be cleared and then Mr. Boone would return for a reinspection.
The plant discharges to an unnamed tributary of Mill Creek, which is currently classified as Class C waters,
and is located in the Yadkin Pee-Dee river basin.
Please work with Mr. Bell to correct the deficiencies noted above in paragraphs 4 through 7. Overall, the
plant must be better maintained and more should be invested in the plant's proper upkeep.
00
Please reply in writing to this letter within 30 business days of receiving it. We trust, by then, the high-level
float/alarm and the right-of-way to the outfall should be fixed.Additionally,you should be able to immediately
provide the sludge pumping/hauling records. If not, your written reply should address each of these
deficiencies, as well as the bar screen, the discharge piping on the IPS's pumps, and the overall poor
condition of the plant and whether there are any plans to invest more to improve the plant's overall condition.
A poorly maintained facility will likely eventually experience a catastrophic failure which will require major
investment to fix. It's best to avert such circumstances.
If you have any questions at all regarding these requirements, please do not hesitate to contact us. Please
be aware that violations of your NPDES permit, or the NC statutes and regulations under which it is
promulgated, are subject to fines of up to$25,000 per day, per violation, as set forth in NC General Statute
(NCGS) 143-215.6A, Enforcement Procedures, Civil Penalties.

If you have any questions regarding the inspection or this report, please contact Ron Boone or me at (336)
776-9800.
Sincerely,
i'd—gui-v:\( . ,,,,,,,ti-
Sherri V. Knight, P.E.
Regional Supervisor
Water Quality Regional Operations
Division of Water Resources
Attachments:
• 1. BIMS Inspection Report
cc: Central Files
WSRO
NPDES Unit

4
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 !ILI 2 LI I 3 1 NC0061204 111 12 I 18/06/05• 117 18I 11 19 I S I 20 I I
211I1III IIIII11IIII III1III I III_ III IIIIIII11II 166
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA — '-Reserved —
671 1 701,LJ I 711 I 72 1 i I 731 I 174 751 1 1 1 1 1 1 180
Section B Facility Data LJ
Name and Location of Facility Inspected(For Industrial Users discharging to POTW,also include Entry Time/Date Permit Effective Date
POTW name and NPDES permit Number) 10 05AM 18/06/05 14/07/01
Scarlett Acres MHP WWTP
5528 Sherene Ln Exit Time/Date Permit Expiration Date
Walkertown NC 27051 11 05AM 18/06/05 19/06/30
Name(s)of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data
///
Randall Keith Bell/ORC/336-373-7514/
Name,Address of Responsible Official/Title/Phone and Fax Number
Contacted
Thomas M Alphin,PO Box 5 Walkertown NC 270510005//336-655-8287/
No
Section C Areas Evaluated During Inspection(Check only those areas evaluated)
• Permit • Flow Measurement • Operations&Maintenance El Records/Reports
▪ Self-Monitoring Program • Sludge Handling Disposal IN Facility Site Review • Effluent/Receiving Waters
▪ 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 WSRO WQ//336-776-9690/
')/s7/.e
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
A-e/te,t,,t,
EPA Form 3560-3(Rev 9-94)Previous editions are obsolete
Page# 1

NPDES yr/mo/day Inspection Type 1
31 NC0061204 I11 ' 121 18/06/05 117 18 ls
i i
Section D Summary of Finding/Comments(Attach additional fsheets of narrative and checklists as necessary)
Please refer to the attached inspection summary letter.
•
•
Page# 2

Permit: NC0061204 , Owner-Facility: Scarlett Acres MHP VVWTP
Inspection Date: 06/05/2018 Inspection Type: Compliance Evaluation
Record Keeping Yes No NA NE
Are records kept and maintained as required by the permit'? ❑ • El El
Is all required information readily available, complete and current'? ❑ • ❑ ❑
Are all records maintained for 3 years(lab. reg. required 5 years)? ❑ • ❑ 0
Are analytical results consistent with data reported on DMRs? • 0 0 0
Is the chain-of-custody complete'? • 0 0 0
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'? U 0 El El
Has the facility submitted its annual compliance report to users and DWQ? El ❑ U ❑
(If the facility is=or>5 MGD permitted flow) Do they operate 24/7 with a certified operator El IN El El
on each shift'?
Is the ORC visitation log available and current? • ❑ El El
Is the ORC certified at grade equal to or higher than the facility classification'? • ❑ El El
Is the backup operator certified at one grade less or greater than the facility classification'? • El El 0
Is a copy of the current NPDES permit available on site'? • ❑ El El
Facility has copy of previous year's Annual Report on file for review'? ❑ El • El
Comment- Sludge records are incomplete or unavailable.
Permit Yes No NA NE
(If the present permit expires in 6 months or less) Has the permittee submitted a new El ❑ U ❑
application'?
Is the facility as described in the permit? El III 0 ❑
#Are there any special conditions for the permit'? El U ❑ El
Is access to the plant site restricted to the general public? • ❑ El El
Is the inspector granted access to all areas for inspection'? ❑ ❑ ❑ El
Comment Bar screen missing
Laboratory Yes No NA NE
Are field parameters performed by certified personnel or laboratory'? • ❑ ❑ El
Are all other parameters(excluding field parameters)performed by a certified lab?. • ❑ El ❑
Page# 3

Permit: NC0061204 • Owner-Facility: Scarlett Acres MI-IP WWTP
Inspection Date: 06/05/2018 Inspection Type• Compliance Evaluation
Laboratory Yes No NA NE
#Is the facility using a contract lab'? • El ❑ El
#Is proper temperature set for sample storage(kept at less than or equal to 6 0 degrees El 0 0 •
Celsius)?
Incubator(Fecal Coliform)set to 44 5 degrees Celsius+/-0.2 degrees? 0 El El
III
Incubator(BOD)set to 20 0 degrees Celsius+/-1 0 degrees? 0 ❑ El •
Comment- None
Effluent Sampling Yes No NA NE
Is composite sampling flow proportional'? El ❑ • 0
Is sample collected below all treatment units'? • El 0 El
Is proper volume collected'? • El 0 El
Is the tubing clean'? El ❑ • ❑
#Is proper temperature set for sample storage(kept at less than or equal to 6 0 degrees El 0 ❑ •
Celsius)?
Is the facility sampling performed as required by the permit(frequency,sampling type • El El El
representative)'
Comment- None
Upstream/ Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit(frequency,sampling type, and • El 0 El
sampling location)'
Comment: None
Pump Station -Influent Yes No NA NE
Is the pump wet well free of bypass lines or structures? • ❑ El 0
Is the wet well free of excessive grease'? El III ❑ ❑
Are all pumps present'? • 0 ❑ El
Are all pumps operable'? • ❑ El El
Are float controls operable'? ❑ U ❑ El
Is SCADA telemetry available and operational'? ❑ IN El ❑
Is audible and visual alarm available and operational' El III El El
Comment: Station is in very poor condition. High-level float/alarm are inoperable, as they have been in
several past inspections.Also, the discharge piping from the station's pumps to the splitter
box is inappropriate must be replaced with hardwall piping
Page# 4

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Permit: NC0061204 Owner-Facility: Scarlett Acres MHP WWTP
Inspection Date: 06/05/2018 Inspection Type: Compliance Evaluation
Bar Screens Yes No NA NE
Type of bar screen
a Manual ❑
b Mechanical ❑
Are the bars adequately screening debris'? ❑ • ❑ ❑
Is the screen free of excessive debris'? ❑ . ❑ ❑
Is disposal of screening in compliance'? ❑ MI El ❑
Is the unit in good condition'? El • 0 0
Comment There is currently no bar screen installed since approximately the end of 2015. It still hasn't
been replaced yet.
Aeration Basins Yes No NA NE
Mode of operation Ext Air
Type of aeration system Diffused
Is the basin free of dead spots'? • 0 0 ❑
Are surface aerators and mixers operational'? ❑ 0 U ❑
Are the diffusers operational'? • ❑ 0 El
Is the foam the proper color for the treatment process'? • ❑ El ❑
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/I) 0 • 0 0
Comment. Low dissolved oxygen and suspended solids. Foam covers a majority of both basins, but
more in the northern basin.
Secondary Clarifier Yes No NA NE
Is the clarifier free of black and odorous wastewater'? • 0 0 0
-
Is the site free of excessive buildup of solids in center well of circular clarifier? 0 0 • El
Are weirs level'? • 0 0 El
Is the site free of weir blockage'? • 0 0 ❑
Is the site free of evidence of short-circuiting'? • El 0 ❑
Is scum removal adequate'? • El El ❑
Is the site free of excessive floating sludge'? • 0 0 ❑
Is the drive unit operational'? 0 0 • El
Is the return rate acceptable(low turbulence)' II ❑ ❑ El
Is the overflow clear of excessive solids/pin floc'? ❑ I 0 ❑
Page# 5

Permit: NC0061204 Owner-Facility: Scarlett Acres MHP wVVrP
Inspection Date: 06/05/2018 Inspection Type: Compliance Evaluation
Secondary Clarifier Yes No NA NE
Is the sludge blanket level acceptable'?(Approximately Y.of the sidewall depth) 01:1011
Comment. Pin floc overflowing the weirs.
Pumps-RAS-WAS Yes No NA NE
Are pumps in place'? I ❑ LI ❑
Are pumps operational'? 111:100
Are there adequate spare parts and supplies on site'? U ❑ ❑ 0
Comment. None
Flow Measurement- Effluent Yes No NA NE
#Is flow meter used for reporting'? • ❑ ❑ ❑
Is flow meter calibrated annually? U ❑ ❑ ❑
Is the flow meter operational'? U 0 0 ❑
(If units are separated) Does the chart recorder match the flow meter? U ❑ 0 ❑
Comment None
Disinfection-Tablet Yes No NA NE
Are tablet chlorinators operational'? ■ ❑ ❑ ❑
Are the tablets the proper size and type? • 0 ❑ ❑
Number of tubes in use'? 4
Is the level of chlorine residual acceptable'? ODOM
Is the contact chamber free of growth, or sludge buildup? • ❑ ❑ ❑
Is there chlorine residual prior to de-chlorination'? ❑ ❑ ❑ •
Comment: None
De-chlorination Yes No NA NE
Type of system? Tablet
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'? 111:100
Are the tablets the proper size and type'? • ❑ ❑ ❑
Comment: None
Are tablet de-chlorinators operational'? U ❑ 0 ❑
• Page# 6

Permit: NC0061204 Owner-Facility: Scarlett Acres MHP WWTP
Inspection Date: 06/05/2018 Inspection Type: Compliance Evaluation
De-chlorination Yes No NA NE
Number of tubes in use? 4
Comment- None
Pump Station -Effluent Yes No NA NE
Is the pump wet well free of bypass lines or structures'? • ❑ 0 ❑
Are all pumps present? I 0 0 ❑
Are all pumps operable'? • 0 ❑ ❑
Are float controls operable'? • 0 ❑ 0
Is SCADA telemetry available and operational'? 0 • 0 ❑
Is audible and visual alarm available and operational'? • ❑ ❑ ❑
Comment: None
Effluent Pipe Yes No NA NE
Is right of way to the outfall properly maintained? ❑ II ❑ ❑
Are the receiving water free of foam other than trace amounts and other debris'? 0 0 0
If effluent (diffuser pipes are required) are they operating properly'? 0 ❑ • ❑
Comment. Outfall not accessible due to the overgrowth.
Aerobic Digester Yes No NA NE
Is the capacity adequate'? I ❑ 0 ❑
Is the mixing adequate'? • 0 0 ❑
Is the site free of excessive foaming in the tank'? II 0 ❑ ❑
#Is the odor acceptable'? • ❑ ❑ ❑
#Is tankage available for properly waste sludge'? • 0 ❑ ❑
Comment. None
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping'? ❑ • ❑ ❑
Does the facility analyze process control parameters,for ex MLSS, MCRT, Settleable I ❑ ❑ El
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment. None
Page# 7