NC0065358_Compliance Evaluation Inspection_20190212

4. A'
NORTH CAROLINA
ROY COOPER Environmental Quality
Governor
MICHAEL S. REGAN ` •
Secretary
LINDA CULPEPPER
Director
February 12, 2019
Mr. Sean Dyer
SIP Hidden Forest LLC
665 Hancock Street, Suite 3
Quincy, MA 02170
SUBJECT: Compliance Evaluation Inspection and Notice of Deficiency
NOD Tracking Number: NOD-2019-PC-0042
Hidden Forest Mobile Home Park WWTP
NPDES Permit No. NC0065358
Randolph County
Dear Mr. Dyer:
On February 6, 2019, Jenny Graznak, of this office, met with Paul Smith, operator in responsible
charge (ORC),to perform a Compliance Evaluation Inspection at the Hidden Forest Mobile Home
Park wastewater treatment plant(VWVfP). This type of inspection consists of two basic parts: an
in-office file review and an on-site inspection of the treatment facility.The attached EPA inspection
form details the areas that were evaluated for this inspection. Deficiencies and major areas of
concern observed from the inspection are described below.
1. The effluent composite sampler is currently set up to collect constant time/constant volume
samples instead of flow proportional samples as the permit requires. Use of the constant
time/constant volume method requires prior approval by the Division Director, which has not
been granted to this facility, according to our files. In addition, at the time of the inspection,
the refrigeration unit for the sampler was frozen, and the thermometer read less than zero
degrees Celsius. The entire composite sampler needs to be replaced, and immediate action
should be taken to start collection of flow proportional samples.
l
2. The generator on site was not functional during the inspection. Part II Section C.7 of the permit
states that "the Permittee is responsible for maintaining adequate safeguards to prevent the
discharge of untreated or inadequately treated wastes during electrical power failures either
by means of alternate power sources, standby generators or retention of inadequately treated
effluent." Please service the generator as soon as possible and be prepared to show
verification of the service visit.
3. Sludge hauling records were not available for review during the inspection. The Permit states
that records of sludge disposal activities shall be retained for a period of at least five years.
The Permit also requires that inspectors shall have access to any records that are kept under
the conditions of the permit. All documents must be available during the next inspection.
Q,
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 W Hanes Mill Road,Suite 300 I Winston-Salem,North Carolina 27105
336-776-9800

4. The aeration basin is currently operated by only one blower that runs continuously. The
second blower needs a new motor and should be serviced immediately to allow for proper
operation and maintenance of the facility.
These issues represent deficiencies of the facility's NPDES permit. Thus, this letter is being sent
to you as a Notice of Deficiency. Please reply in writing to this letter within 10 calendar days of
receiving it. Your 'written reply should address each of the noted deficiencies and provide a
corrective action plan along with an implementation/completion schedule to remediate them. A
review of your response will be considered along with any additional information provided.
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. Therefore,
your immediate attention is greatly appreciated. If you have any questions regarding the
inspection or this report, please contact Jenny Graznak or me at [phone] or by email at
lennv.graznak[c�ncdenr.00v.
Sincerely,
,.. r
Sherri V. Knight, P.E.
Regional Supervisor
Water Quality Regional Operations
Division of Water Resources
Enclosure: EPA Water Compliance Inspection Report
cc: Central Files
WSRO
NPDES Unit
•
Page 2 of 2

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 I 2 I5 I 3 I NC0065358 111 12 I 19/02/06 117 18 i i 19 I c I 201
1[—2I I I I ll I I I I I I I I l I l I I I I I I I. I I I I I I I I I I I I I I I I l l r6
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA Reserved
67I I 70 I I 71 I I 72 LJI N I 731 l 174
751 I I I l l l 180
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 permit Number) 11 OOAM 19/02/06 16/10/01
Hidden Forest Estates WWTP •
Exit Time/Date Permit Expiration Date
6602 Holder Inman Rd Ext
12 30PM 19/02/06 21/08/31
Randleman NC 27317 _
Name(s)of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data
///
Paul Matthew Smith/ORC/336-932-9347/
Name,Address of Responsible Official/Title/Phone and Fax Number
1
Contacted
Paul Matthew Smith,235 Richardson Rd Reidsville NC 27320//336-932-9347/
No
Section C Areas Evaluated During Inspection(Check only those areas evaluated)
Permit II Flow Measurement III Operations&Maintenance II Records/Reports
II Self-Monitoring Program 111 Sludge Handling Disposal Facility Site Review Effluent/Receiving Waters
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
Jennifer F Graznak WSRO WQ//336-771-5000/ 2-/t2/2019
9""bf'
Signature of M agemen' Q + eviewer Agency/Office/Phone and Fax Numbers
Date
\
()/(
EPA Form 3560-3(Rev 9-94)Previous editions are obsolete
Page# 1

NPDES yr/mo/day Inspection Type (Cont) 1
31 NC0065358 I11 121 19/02/06 117 18 Li
Section D Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
MAJOR ISSUES:
1.The effluent composite sampler is currently set up to collect constant time/constant volume samples
instead of flow proportional samples as the permit requires Use of the constant time/constant volume
method requires prior approval by the Division Director,which has not been granted to this facility,
according to our files. In addition, at the time of the inspection, the refrigeration unit for the sampler was
frozen, and the thermometer read less than zero degrees Celsius. The entire composite sampler
needs to be replaced, and immediate action should be taken to start collection of flow proportional
samples.
2.The generator on site was not functional during the inspection. Part II Section C.7 of the permit
states that"the Permittee is responsible for maintaining adequate safeguards to prevent the discharge
of untreated or inadequately treated wastes during electrical power failures either by means of alternate
power sources, standby generators or retention of inadequately treated effluent." Please service the
generator as soon as possible and be prepared to show verification of the service visit
3. Sludge hauling records were not available for review during the inspection.The Permit states that
records of sludge disposal activities shall be retained for a period of at least five years.The Permit also ,
requires that inspectors shall have access to any records that are kept under the conditions of the
permit.All documents must be available during the next inspection.
4.The aeration basin is currently operated by only one blower that runs continuously The second
blower needs a new motor and should be serviced immediately to allow for proper operation and
maintenance of the facility.
- Page# 2

1-
" Permit: NC0065358 Owner-Facility: Hidden Forest Estates WWTP
Inspection Date: 02/06/2019 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'? III 0 ❑ ❑
#Are there any special conditions for the permit'? ❑ II 0 ❑
Is access to the plant site restricted to the general public'? • ❑ ❑ ❑
Is the inspector granted access to all areas for inspection'? • ❑ ❑ 0
Comment.
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping'? • ElEl ❑
Does the facility analyze process control parameters, for ex MLSS, MCRT, Settleable • ❑ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable'?
Comment The plant shows signs of age and disrepair as a result of time However, in general,the
plant and surrounding area was clean.
Record Keeping Yes No NA NE
Are records kept and maintained as required by the permit'? ❑ IN ❑ ❑
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? IN 0 ❑ ❑
Is the chain-of-custody complete'? • ❑ ❑ ❑
Dates,times and location of sampling •
Name of individual performing the sampling U
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? ❑ ❑ III ❑
(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? II ❑ ❑ ❑
Is the ORC certified at grade equal to or higher than the facility classification'? M ❑ ❑ ❑
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'? • ❑ ❑ ❑
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Permit: NC0065358 Owner-Facility: Hidden Forest Estates WWTP
Inspection Date: 02/06/2019 Inspection Type. Compliance Evaluation
Record Keeping Yes No NA NE
Facility has copy of previous year's Annual Report on file for review'? ❑ 0 U ❑
Comment. Sludge hauling records were not available for review dunnq the inspection.The inspector
checked the October 2018 DMR alongside the analytical results for the same month, and all
data was consistent.The Back Up ORC is Gary Moore, Grade IV.
Bar Screens Yes No NA NE
Type of bar screen
a.Manual •
b.Mechanical ❑
Are the bars adequately screening debris'? • 0 ❑ 0
Is the screen free of excessive debris'? • ❑ ❑ ❑
Is disposal of screening in compliance? U ❑ ❑ ❑
Is the unit in good condition? • ❑ ❑ ❑
Comment Bar screenings are placed either in the digester or the dumpster The digester is emptied
every 2-3 months by Carolina Septic. The inspector noted that the influent was clear water
Grease Removal Yes No NA NE
#Is automatic grease removal present'? ❑ • 0 ❑
Is grease removal'operating properly'? ❑ ❑ • ❑
Comment There was some evidence of grease build up in the aeration and clarifier, but not a
significant amount.
Aeration Basins Yes No NA NE
Mode of operation Ext Air
Type of aeration system Diffused
Is the basin free of dead spots'? • ❑ ❑ ❑
Are surface aerators and mixers operational'? ❑ ❑ II ❑
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) • ❑ ❑ ❑
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Permit: NC0065356 Owner-Facility: Hidden Forest Estates WINTP
Inspection Date: 02/06/2019 Inspection Type: Compliance Evaluation
Aeration Basins Yes No NA NE
Comment The aeration basin appeared to be healthy, according to amount of foam and color.The
operator stated that he keeps the dissolved oxygen at 3 mg/I in the aeration.There is only
one functional blower working at the moment, and it runs continuously The second blower
needs a new motor.
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? ❑ El • El
Are weirs level? • ❑ ❑ 0
Is the site free of weir blockage'? II 0 ❑ ❑
Is the site free of evidence of short-circuiting'? • ❑ El El
Is scum removal adequate'? • 0 0 ❑
Is the site free of excessive floating sludge'? IN 0 El ❑
Is the drive unit operational'? - • El El ❑
Is the return rate acceptable(low turbulence)? II ❑ 0 El
Is the overflow clear of excessive solids/pin floc'? • El 0 ❑
Is the sludge blanket level acceptable'? (Approximately%4 of the sidewall depth) ❑ ❑ El
II
Comment- The clarifier looked decent. However,there was some floating trash and a small amount of
floating sludge.
Disinfection -UV Yes No NA NE
Are extra UV bulbs available on site'? • El ❑ El
Are UV bulbs clean'? • ❑ ❑ El
Is UV intensity adequate'? • ❑ ❑ ❑
Is transmittance at or above designed level'? • ❑ ❑ El
Is there a backup system on site'? • ❑ ❑ ❑
Is effluent clear and free of solids'? • ❑ 0 ❑
Comment: There are two units,with 6 bulbs in each unit Back up bulbs were available
Effluent Sampling Yes No NA NE
Is composite sampling flow proportional'? El MI El El
Is sample collected below all treatment units'? • ❑ El El
Is proper volume collected? • El El El
Is the tubing clean'? El • El ❑
Page# 5

Permit: NC0065358 Owner-Facility: Hidden Forest Estates WWTP
Inspection Date: 02/06/2019 Inspection Type: Compliance Evaluation
Effluent Sampling Yes No NA NE
#Is proper temperature set for sample storage(kept at less than or equal to 6.0 degrees 01100
Celsius)?
Is the facility sampling performed as required by the permit(frequency,sampling type • ❑ ❑ 0
representative)?
Comment The effluent composite sampler is currently set up to collect constant time/constant volume
samples instead of flow proportional samples as the permit requires.At the time of the
inspection, the refrigeration unit was frozen, and the thermometer read less than 0 degrees
Celsius.The tubing was also discolored and should be changed.
Effluent Pipe Yes No NA NE
Is right of way to the outfall properly maintained'? ❑ ❑ ❑ •
Are the receiving water free of foam other than trace amounts and other debris'? 0 ❑ ❑ •
If effluent (diffuser pipes are required) are they operating properly'? 0 ❑ IN ❑ •
Comment The facility discharges to the other side of Highway 220 under Randleman Lake and is
obviously inaccesible.
Flow Measurement-Effluent Yes No NA NE
#Is flow meter used for reporting'? • ❑ ❑ ❑
Is flow meter calibrated annually'? M ❑ ❑ ❑
Is the flow meter operational'? III ❑ ❑ ❑
(If units are separated) Does the chart recorder match the flow meter'? ❑ ❑ • ❑
Comment The facility does have a new flow meter: an Endress Hauser Prosonic that was calibrated by
Delta Systems in March 2018 Documentation of the calibration event was available during
the inspection.
Standby Power Yes No NA NE
Is automatically activated standby power available'? - ❑ MI 0 ❑
Is the generator tested by interrupting primary power source'? ❑ U ❑ ❑
Is the generator tested under load? 011101=1
Was generator tested&operational during the inspection? ❑ • ❑ ❑
Do the generator(s)have adequate capacity to operate the entire wastewater site'? Ill' ❑ ❑ ❑
Is there an emergency agreement with a fuel vendor for extended run on back-up power'? 0 II ❑ ❑
Is the generator fuel level monitored'? • ODE
Comment The generator on site was not functional during the inspection. Please service the generator
as soon as possible and be prepared to show verification of the service visit.
Page# 6