WQCSD0229_Compliance Evaluation Inspection_20190814

ROY COOPER o
Governor
MICHAEL S.REGAN ` ,s
Secretary " ^
LINDA CULPEPPER NORTH CARouNA
Director Environmental Quality
CERTIFIED MAIL 7011 1570 0001 8546 4273
RETURN RECEIPT REQUESTED
August 14, 2019
Apex Bank
Attn: Matthew Daniels, Owner
430 Montbrook Lane
Knoxville,TN 37919
SUBJECT: NOTICE OF VIOLATION WITH INTENT TO ASSESS CIVIL PENALTY
Tracking#: NOV-2019-PC-0579
Compliance Evaluation Inspection
Hidden Lakes Village Mobile Home Park Wastewater Collection System
Collection System Permit: WQCSD0229
Stokes County
Dear Mr. Daniels:
Ron Boone, of the NC Division of Water Resources (DWR), Winston-Salem Regional Office,
conducted a compliance evaluation inspection of the Hidden Lakes Village mobile home park
wastewater collection system,which is deemed permitted under NC administrative code 15A NCAC
02T .0400, on August 8, 2019. The assistance and cooperation of Jon Southern, who currently
operates the park's wastewater treatment plant,during the inspection,was greatly appreciated.
The inspection resulted in numerous violations of NC administrative code 15A NCAC 02T.
0403, a copy of which is attached for your convenience, as detailed on the attached EPA Water
Compliance Inspection Report. Please be aware that pursuant to NC General Statute (NCGS) 143-
215.6A, Enforcement Procedures; Civil Penalties, failure to comply with the 02T regulations,
mentioned above, which implement NCGS 143-215.1, Control of Sources of Water Pollution;
Permits Required,subjects Apex Bank to civil penalties(fines)of up to$25,000 per day,per violation.
Please reply to this violation notice in writing within 15 business days of receiving it.Your
written reply should address,in detail,each individual violation described in the attached compliance
inspection report and list all corrective actions Apex Bank has taken,or plans to take,to mitigate each
violation and return to full compliance with the 02T regulations.
Please be very detailed in your reply as it will be considered in our decision-making process
of whether to assess civil penalties against Apex Bank for these violations. Failure to submit a
satisfactory written reply within the required time frame, may result in the establishment of a civil
penalty case against Apex Bank for these violations.
D E Q�p North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1 450 Hanes Mill Road,Suite 300 1 Winston-Salem,North Carolina 27105
NORTH C. 0LINA
o•o•°^•mme""°""•"viu"•i� /� 336.776.9800

Thank you for your cooperation in this matter. If you have any questions, please contact Mr.
Boone by phone at 336-776-9690, or by email at ron.boonePncdenr.gov. You may also contact me
by phone at 336-776-9700, or by email at lon.sniderOncdenr.gov.
Sincerely,
DocuSiT <gnedby:
�w. l c. ,ider
145B49E225C94EA...
Lon T. Snider,Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources,NCDEQ
Attachments:
1. EPA Water Compliance Inspection Report
2. Copy of 15A NCAC 02T. 0403, Permitting by Regulation
cc: NCDWR WSRO File

Compliance Inspection Report
Permit: WQCSD0229 Effective: 03/01/00 Expiration: Owner: John Henry Oakley
SOC: Effective: Expiration: Facility: Hidden Lakes MHP Collection System
County: Stokes
Region: Winston-Salem
Contact Person: Matthew Daniels Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 08/08/2019 Entry Time: 04:OOPM Exit Time: 05:OOPM
Primary Inspector: Ron Boone Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Collection System Inspect Non Sampling
Permit Inspection Type: Deemed permitted collection system management and operation
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Miscellaneous Questions General Grease Control
Spills/Response Plan Inspections Lines
Manholes Pump Stations
(See attachment summary)
Page 1 of 6

Permit: WQCSD0229 Owner-Facility:John Henry Oakley
Inspection Date: 08/08/2019 Inspection Type:Collection System Inspect Non Sampling Reason for Visit: Routine
Inspection Summary:
Met with Jon Southern,who currently operates the wastewater treatment plant for the owner. Jon had no documentation for
the collection system and none of the required operation and maintenance items have been accomplished since at least the
last inspection in 2016.
Page 2 of 6

Permit: WQCSD0229 Owner-Facility:John Henry Oakley
Inspection Date: 08/08/2019 Inspection Type:Collection System Inspect Non Sampling Reason for Visit: Routine
General Yes No NA NE
#Is this system a satellite system? ❑ 0 ❑ ❑
#If Yes,what is system name or permit number?
Is there a overall sewer system map? ❑ ❑ ❑
Does the map include:
Pipe sizes ❑ ❑ ❑
Pipe materials(PVC, DIP,etc) ❑ ❑ ❑
Pipe location ❑ ❑ ❑
# Flow direction ❑ ❑ ❑
# Approximate pipe age ❑ ❑ ❑
# Pump station ID,location and capacity ❑ ❑ ❑
# Force main air release valve location&type ❑ ❑ ❑
# Location of satellite connections ❑ ❑ ❑
Are system maintenance records maintained? ❑ ❑ 0 ❑
Comment: None
Grease Control Yes No NA NE
Is grease/sewer education program documented with req'd customer distribution? ❑ ❑ ❑
#Are other types of education tools used like websites, booths,special meetings,etc? ❑ ❑ ❑
If Yes,what are they?(This can reduce mailing to annual.)
For public systems,is there a Grease Control Program via an ordinance/agreement? ❑ ❑ ❑
If Yes,does it require grease control devices at applicable locations? ❑ ❑ ❑
Is the Grease Control Program enforced via periodic inspections/records review? ❑ ❑ ❑
Is action taken against violators? ❑ ❑ 0 ❑
Comment: None
Spills and Response Action Plan Yes No NA NE
#Is system free of known points of bypass? ❑ ❑ ❑
#Have there been any sewer spills in the past 3 years? ❑ ❑ ❑
If Yes,were they reported to the Division if meeting the reportable criteria? ❑ ❑ ❑
If applicable, is there documentation of press releases and public notices issued? ❑ ❑ ❑
Are all spills or sewer related issues/complaints documented? ❑ ❑ ❑
#Are there repeated overflows/problems(2 or more in 12 months)at same location? ❑ ❑ ❑
#If Yes,is there a corrective action plan? ❑ ❑ ❑
Is a Spill Response Action Plan available? ❑ ❑ ❑
Is a Spill Response Action Plan available for all personnel? ❑ 0 ❑ ❑
Page 3 of 6

Permit: WQCSD0229 Owner-Facility:John Henry Oakley
Inspection Date: 08/08/2019 Inspection Type:Collection System Inspect Non Sampling Reason for Visit: Routine
Does the plan include:
# 24-hour contact numbers ❑ ❑ ❑
# Response time ❑ ❑ ❑
# Equipment list and spare parts inventory ❑ ❑ ❑
# Access to cleaning equipment ❑ ❑ ❑
# Access to construction crews,contractors,and/or engineers ❑ ❑ ❑
# Source of emergency funds ❑ ❑ ❑
# Site sanitation and cleanup materials ❑ ❑ ❑
# Post-overflow/spill assessment ❑ 0 ❑ ❑
Comment: No spills have been reported. There is no spill plan.
Inspections
Yes No NA NE
Are adequate maintenance records maintained? ❑ ❑ ❑
Are pump stations being inspected at the required frequency? ❑ ❑ ❑
Is at least one complete functionality test conducted weekly per pump station? ❑ ❑ ❑
Is there a system or plan in place to observe the entire system annually? ❑ ❑ ❑
Is the annual inspection documented? ❑ ❑ ❑
#Does the system have any high-priority lines/locations? ❑ ❑ ❑
Are inspections of HPL documented at least every 6 months? ❑ ❑ ❑
Are new lines being added to the HPL list when found or created? ❑ ❑ ❑
Comment: None
Lines/Right-of-Ways/Aerial Lines Yes No NA NE
Please list the Lines/Right of Ways/Aerial Lines Inspected:
Are right-of-ways and easements maintained for the full width for access? ❑ ❑ ❑
If No,give details on temporary access:
Is maintenance documented? ❑ ❑ ❑
Were all areas/lines inspected free of issues? ❑ 0 ❑ ❑
Comment: ROWS not currently under maintenance plan.
Manholes Yes No NA NE
Please list the Manholes Inspected:
None
Are manholes accessible? ❑ ❑ ❑
#Are manhole covers/vents above grade? ❑ ❑ ❑
Are manholes free of visible signs of overflow? ❑ ❑ ❑
Are manholes free of sinkholes and depressions? ❑ ❑ ❑
Are manhole covers present? ❑ ❑ ❑
#Are manholes properly seated? ❑ ❑ ❑
Page 4 of 6

Permit: WQCSD0229 Owner-Facility:John Henry Oakley
Inspection Date: 08/08/2019 Inspection Type:Collection System Inspect Non Sampling Reason for Visit: Routine
#Are manholes in good condition? ❑ ❑ ❑
#Are inverts in good condition? ❑ ❑ ❑
Is flow unrestricted in manholes? ❑ ❑ ❑
Are manholes free of excessive amounts of grease? ❑ ❑ ❑
Are manholes free of excessive roots? ❑ ❑ ❑
Are manholes free of excessive sand? ❑ ❑ ❑
Are manhole vents screened? ❑ ❑ ❑
Are vents free of submergence? ❑ ❑ ❑
Are manholes free of bypass structures or pipes? ❑ ❑ ❑
Comment: None
Pump Stations
Yes No NA NE
Please list the Pump Stations Inspected:
There are no PSs in this system.
#Number of duplex or larger pump stations in system 0
#Number of vacuum stations in system 0
#Number of simplex pump stations in system 0
#Number of simplex pump stations in system serving more than one building 0
How many pump/vacuum stations have:
# A two-way"auto polling"communication system(SCADA)installed? 0
# A simple one-way telemetry/communication system(auto-dialer)installed? 0
For pump stations inspected:
Are they secure with restricted access? ❑ ❑ ❑
Were they free of by-pass structures/pipes? ❑ ❑ ❑
Were wet wells free of excessive grease/debris? ❑ ❑ ❑
# Do they all have telemetry installed? ❑ ❑ ❑
Is the telemetry system functional? ❑ ❑ ❑
Is a 24-hour notification sign posted? ❑ ❑ ❑
Does the sign include:
Owner Name? ❑ ❑ ❑
Pump station identifier? ❑ ❑ ❑
# Address? ❑ ❑ ❑
Instructions for notification? ❑ ❑ ❑
24-hour emergency contact numbers? ❑ ❑ ❑
Are audio and visual alarms present? ❑ ❑ ❑
Are audio and visual alarms operable? ❑ ❑ ❑
#Is there a backup generator or bypass pump connected? ❑ ❑ 0 ❑
Page 5 of 6

Permit: WQCSD0229 Owner-Facility:John Henry Oakley
Inspection Date: 08/08/2019 Inspection Type:Collection System Inspect Non Sampling Reason for Visit: Routine
If tested during inspection,did it function properly? ❑ ❑ 0 ❑
Is the back-up system tested at least bi-annually under normal operating conditions? ❑ ❑ ❑
#Does it have a dedicated connection for a portable generator? ❑ ❑ ❑
#Is the owner relying on portable units in the event of a power outage? ❑ ❑ ❑
#If Yes,is there a distribution plan? ❑ ❑ ❑
If Yes,what resources(Units/Staff/Vehicles/etc)are included in Plan?
#Does Permittee have the approved percentage of replacement simplex pumps? ❑ ❑ ❑
Is recordkeeping of pump station inspection and maintenance program adequate? ❑ ❑ ❑
Do pump station logs include at a minimum:
Inside and outside cleaning and debris removal? ❑ ❑ 0 ❑
Inspecting and exercising all valves? ❑ ❑ 0 ❑
Inspecting and lubricating pumps and other equipment? ❑ ❑ 0 ❑
Inspecting alarms,telemetry and auxiliary equipment? ❑ ❑ 0 ❑
Comment: None
Page 6 of 6