NC0051713_Compliance Evaluation Inspection_20180705

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ROY COOPER
Governor
MICHAEL S.REGAN
Secretary
LINDA CULPEPPER
Water Resources
Interim Director
Environmental Quality
July 5, 2018
Lakeview Mobile Home Park, LLC
Attn: Walter B. Craven, Jr., Owner
420 Marion Drive, Unit 31
Wilmington, NC 28412
SUBJECT: Compliance Evaluation Inspection &Notice of Violation RECEIVED/DENR/DWR
NOV Tracking#: NOV-2018-PC-0207
Lakeview Mobile Home Park Wastewater Treatment Plant JUL 10 2018
NPDES Permit#: NC0051713 Water Resources
Forsyth County Permitting Section
Dear Mr. Craven:
Ron Boone, of the Winston-Salem Regional Office of the NC Division of Water Resources (DWR or the
Division), conducted a compliance evaluation inspection (CEI) of the Lakeview Mobile Home Park Wastewater
Treatment Plant(WWTP) on June 5, 2018. The assistance and cooperation of 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 April 30, 2019. The permit states that there is
a bar screen at the plant, but there isn't one.This must be corrected at the next permit renewal.
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 40 violations during that time frame, all of which have already been
addressed via separate correspondence.The plant also had one solids violation and two Ammonia violations
in May 2018,which haven't been addressed yet. This is a high number of violations.
III. Flow Measurement
Mr. Bell stated that he uses the effluent weir and a staff gauge to measure instantaneous flow. However,
when Mr. Boone asked Mr. Bell what size the weir is, he stated that"he assumed"the weir was 90-degrees
and was reading the corresponding rate from the flow chart. Mr. Boone reports that he believes the weir is
only 22.5-degrees. This must be corrected as soon as possible. Using flow chart readings for a 90-degree
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weir, when the weir is only 22.5-degrees, will result in highly inaccurate flow readings and may result in
violation notices for exceeding the flow limit.
For your information, prior to Mr. Bell taking over plant operations from R&A Labs in August 2017, the
operators used the park's potable water meter reading to estimate the WWTP's daily flow reading. This is
still an acceptable method of measuring flow.
IV. Operations and Maintenance
Mr. Boone reports that the WWTP is in fair condition. There is some corrosion and dilapidation, and some
components are constructed rather haphazardly, such as the chlorination and dechlorination. Plant condition
is a direct reflection of the operation and maintenance it has received through the years. Additionally, the
high number of violations, mentioned in paragraph II above, is indicative of operational difficulties. At this
time, the plant appears to be sufficiently operated and maintained to meet permit limits some of the time.
V. Facility Site Review
All components of this 0.015 million-gallon-per-day (MGD) facility appeared to be functioning properly. The
aeration basin had a dark brown color with very little foam.There were no foul odors but the plant also lacked
the earthy odor of a healthy extended aeration activated sludge plant and the dissolved oxygen concentration
was about 1.1 milligrams per liter. The effluent from the treatment plant was clear with no foam, surface
solids, or scum noted.
VI. Records/Reports
According to existing records, all required effluent monitoring has been performed in accordance with the
parameters and frequencies specified in the NPDES permit. Chains of custody, operations and maintenance
logs, operator's visitation logs, etc.,were all readily available for inspection.
However, Mr. Bell did not know the location of records produced prior to him taking over operation in August
2017. He had no sludge removal records or septic tank pumping records on site during the inspection. Solids
management is critical to the successful operation of the plant. These records must be maintained on site at
all times to show proper solids management. This is a violation of Part II, Section D, Paragraph 6, of the
permit, which covers records retention requirements.
Furthermore, Mr. Bell is unsure of how many septic tanks exist in the park.The permit states that every home
has a septic tank but due to the lack of tank pumping records and an accurate park map that shows the
location of all septic tanks, the homes that are connected to each tank, and the sewer lines that convey tank
effluent to the treatment plant, the number of tanks and their current solids levels is unverified.
This lack of information must also be clarified as soon as possible.As the septic tanks are part of the overall
treatment process, failure to manage them properly is failure to properly operate and maintain the WWTP,
which is covered in Part II, Section C, Paragraph 2, of the permit.

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VII. Effluent/Receivinq Waters
The effluent from the facility was clear on the day of the inspection but only a slight trickle was present. The
plant discharges to an unnamed tributary of Cuddybum Branch, which is currently classified as a class WS-
III (water supply) waters, and is located in the Yadkin Pee-Dee river basin. Please note that the permit
mistakenly calls it Cuddybum Creek. This should also be corrected at the next permit renewal.
Please work with Mr. Bell to correct the deficiencies noted above in paragraphs 1, 3, and 6. Please reply in
writing to this letter with 30 business days of receiving it. Your written reply should address each of the
deficiencies noted above and propose corrective action plans and time frames by which each deficiency
should be corrected. If you have any questions at all regarding these requirements, please do not hesitate to
contact us.
Due to the plant's current condition and its violation history, it is highly recommended that you begin now to
consider future options to repair/replace this system.A catastrophic failure of some kind in imminent in plants
where inadequate funding is provided for proper operation and maintenance.
Please be aware that violations of your NPDES permit, or the NC statutes and regulations by 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,
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 Unif l
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7- 7._ - • -

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 I,,,j 2 3 NC0051713 111 12 I 18/06/05 117 , 18 I,I 19 1 s I 201 1
211111111111111111111111111111111 11111111111 p6
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA -Reserved —
671 I 70 LI 711 72 I N I 731 1 1' 75] 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) 09 00AM 18/06/05 14/07/01
Lakeview Mobile Home Park
Exit Time/Date
Permit Expiration Date
5186 High Point Rd
10 OOAM 18/06/05 19/04/30
High Point NC 27265
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
Walter B Craven,420 Marion Dr#31 Wilmington NC 2841211910-777-1998/9103958265
No
Section C Areas Evaluated During Inspection(Check only those areas evaluated)
Permit • Flow Measurement • Operations&Maintenance • Records/Reports
Self-Monitoring Program IN Sludge Handling Disposal • Facility Site Review • Effluent/Receiving Waters
El 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 I, ' WSRO WQ//336-776-9690/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers ,' Date
EPA Form 3560-3(Rev 9-94)Previous editions are obsolete
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NPDES yr/mo/day Inspection Type 1
31 NC0051713 111 121 18/06/05 1 17 18 li
ls
Section D Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
Please refer to the attached inspection summary letter.
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Permit: NC0051713 Owner-Facility- Lakeview Mobile Home Park
Inspection Date: 06/05/2018 Inspection Type: Compliance Evaluation ,
PermitYes No NA NE
(If the present permit expires in 6 months or less) Has the permittee submitted a new 01:1M1=1
application?
Is the facility as described in the permit? 0 • 00
#Are there any special conditions for the permit? , 1=1 • 1=11=1
Is access to the plant site restricted to the general public? El DOD
Is the inspector granted access to all areas for inspection? • 1=1 ,00
Comment: No bar screen. Number of septic tanks not specified
Record Keeping Yes No NA NE
Are records kept and maintained as required by the permit? 011100
Is all required information readily available, complete and current? D • 1=10
Are all records maintained for 3 years(lab reg required 5 years)? DEDD
Are analytical results consistent with data reported on DMRs? • 0120
Is the chain-of-custody complete? I ❑ ❑ ❑
Dates,times and location of sampling
Name of individual performing the sampling U
Results of analysis and calibration
Dates of analysis II
Name of person performing analyses El
Transported COCs / MI
Are DMRs complete do they include all permit parameters? MOOD
Has the facility submitted its annual compliance report to users and D_WQ? DURO
(If the facility is=or>5 MGD permitted flow) Do they operate 24/7 with a certified operator 0 • 00
on each shift?
Is the ORC visitation log available and current? U ❑ ❑ ❑
Is the ORC certified at grade equal to or higher than the facility classification? U ❑ ❑ ❑
Is the backup operator certified at one grade less or greater than the facility classification? MOOD
Is a copy of the current NPDES permit available on site? MOOD
Facility has copy of previous year's Annual Report on file for review? 00 • 0
Comment- Sludge and septic tank pumping records, as well as all records prior to arrival of current
ORC in August 2017, appear to be missing.
Laboratory Yes No NA NE
Are field parameters performed by certified personnel or laboratory? MOOD
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Permit: NC0051713 Owner-Facility' Lakeview Mobile Home Park
Inspection Date: 06/05/2018 Inspection Type:'Compliance Evaluation
Laboratory Yes No NA NE
Are all other parameters(excluding field parameters)performed by a certified lab? 11000
#Is the facility using a contract lab? • 000
#Is proper temperature set for sample storage(kept at less than or equal to 6.0 degrees ❑ ❑ ❑ M
Celsius)?
Incubator(Fecal Coliform)set to 44 5 degrees Celsius+/-02 degrees'? 000I
Incubator(BOD)set to 20 0 degrees Celsius+1-1 0 degrees'? 00011
Comment. None
Effluent Sampling Yes No NA NE
Is composite sampling flow proportional'? 00 • 0
Is sample collected below all treatment units'? • 000
Is proper volume collected'? • ❑ ❑ ❑
Is the tubing clean'? 00 • 0
#Is proper temperature set for sample storage(kept at less than or equal to 6 0 degrees ❑, ❑ ❑ U
Celsius)?
Is the facility sampling performed as required by the permit(frequency, sampling type 11000
representative)?
Comment None
Upstream/ Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit(frequency,sampling type,and U ❑ ❑ ❑
sampling location)?
Comment None
Aeration Basins • Yes No NA NE
Mode of operation Ext.Air
Type of aeration system Diffused
Is the basin free of dead spots'? • 000
Are surface aerators and mixers operational'? 00110
Are the diffusers operational'? • 000
Is the foam the proper color for the treatment process'? 0 • 00
Does the foam cover less than 25%of the basin's surface'? • ❑ ❑ ❑
Is the DO level acceptable'? M ❑ ❑ ❑
Is the DO level acceptable?(1 0 to 3 0 mg/I) • 000
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Permit: NC0051713 Owner-Facility: Lakeview Mobile Home Park
Inspection Date: 06/05/2018 Inspection Type: Compliance Evaluation
Aeration Basins Yes No NA NE
Comment Dark activated sludge with very little foam, if any, and DO on the low side.
Secondary Clarifier Yes No NA NE
Is the clarifier free of black and odorous wastewater'? • ❑ ❑ ❑
Is the site free of excessive buildup of solids in center well of circular clarifier'? ❑ ❑ U ❑
Are weirs level'? M ❑ ❑ ❑
Is the site free of weir blockage'? • ❑ ❑ ❑
Is the site free of evidence of short-circuiting? • 000
Is scum removal adequate'? U ❑ ❑ ❑
Is the site free of excessive floating sludge'? • ❑ ❑ ❑
Is the drive unit operational? ❑ ❑ E ❑
Is the return rate acceptable(low turbulence)' U ❑ ❑ ❑
Is the overflow clear of excessive solids/pin floc? • 000
Is the sludge blanket level acceptable'?(Approximately IA of the sidewall depth) 00011
Comment: None
Disinfection-Tablet Yes No NA NE
Are tablet chlorinators operational'? 111000
Are the tablets the proper size and type? • 01=10
Number of tubes in use'? 1
Is the level of chlorine residual acceptable'? ❑ ❑ ❑ •
Is the contact chamber free of growth, or sludge buildup'? • 000
Is there chlorine residual prior to de-chlorination' ❑ ❑ ❑ M
Comment. None
De-chlorination Yes No NA NE
Type of system'? Tablet
Is the feed ratio proportional to chlorine amount(1 to 1)7 ❑ ❑ ❑ M
Is storage appropriate for cylinders'? ❑ ❑ E ❑
#Is de-chlorination substance stored away from chlorine containers' - • 000
Are the tablets the proper size and type'? • 000 ,
•
Comment None
Are tablet de-chlorinators operational'? • 000
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Permit: NC0051713 Owner-Facility: Lakeview Mobile Home Park
Inspection Date 06/05/2018 Inspection Type: Compliance Evaluation
De-chlorination Yes No NA NE
Number of tubes in use'? 1
Comment: None
Pumps-RAS-WAS Yes No NA NE
Are pumps in place'? • ❑ 0 ❑
Are pumps operational'? • 0 0 ❑
Are there adequate spare parts and supplies on sire? • ❑ ❑ ❑
Comment: None
Flow Measurement-Effluent Yes No NA NE
#Is flow meter used for reporting'? • ❑ ❑ ❑
Is flow meter calibrated annually'? 0 ❑ IN ❑
Is the flow meter operational'? 0 I ❑ ❑
(If units are separated) Does the chart recorder match the flow meter'? 0 0 I ❑
Comment. None
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 0 I ❑
Comment: None
Aerobic Digester Yes No NA NE
Is the capacity adequate'? • 0 0 ❑
Is the mixing adequate'? • ❑ El ❑
Is the site free of excessive foaming in the tank'? • 0 ❑ El
#Is the odor acceptable'? • 0 ❑ ❑
#Is tankage available for properly waste sludge'? • ❑ ❑ ❑
Comment None
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, NMCRT, Settleable • ❑ ❑ El
Solids, pH, DO, Sludge Judge, and other that are applicable'?
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Permit: NC0051713 Owner-Facility: Lakeview Mobile Home Park
Inspection Date• 06/05/2018 Inspection Type: Compliance Evaluation
Operations & Maintenance Yes No NA NE
Comment: Did not see records of process control analyses.
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