WQCSD0523_NOI NOV-2020-PC-0423_20200922

DocuSign Envelope ID: 0EF5C1132-BD32-4621-85213-81DB131318115B
ROY COOPER
covernor
MICHAEL S. REGAN
secretary
S. DANIEL SMITH
Director
Certified Mail # 7018 0680 00019160 6164
Return Receipt Requested
Michael Ayala
Collins Estate Jacksonville NC LLC
950 Idaho St
Elko, NV 89801
NORTH CAROLINA
Environmental Quality
September 21, 2020
SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY
Tracking Number: NOV-2020-PC-0423
Deemed Permit Number WQCSD0523
Collins Estates MHP Deemed Collection System
Onslow County
Dear Permittee:
The North Carolina Division of Water Resources conducted an inspection of the Collins Estates MHP Deemed
Collection System on September 2, 2020. This inspection was conducted to verify that the facility is
operating in compliance with the conditions and limitations specified in North Carolina Administrative Code
Subchapter 2T Section .0403. A summary of the findings and comments noted during the inspection are
provided in the enclosed copy of the inspection report.
The compliance inspection was conducted by Division of Water Resources staff from the Wilmington Regional
Office. The following violation(s) were noted during the inspection:
Inspection Area Description of Violation
Map System does not currently have a map of the collection system.
Sewer and FOG Ordinances System does not have a written oil and grease control program.
North Caro tnaDepart rnentofEnvironmeatadQuality I DiuisionofWater Rescurces
'��Q�WdtningtanRegonaIOffice 1127 CarMusiDiive Extension I Wilra ngton, North Caroina2S405
RT 910-786-721.5

DocuSign Envelope ID: 0EF5C1132-BD32-4621-85213-81D13131318115B
Inspection Area Description of Violation
Inspections The system does not have a written operation and maintenance plan.
A Notice of Violation/Intent to Issue Civil Penalty is being issued for the noted violation of North Carolina General
Statute (G.S.) 143-215.1 and the facility's Collection System Permit. Pursuant to G.S. 143-215.6A, a civil penalty
of not more than twenty-five thousand dollars ($25,000.00) may be assessed against any person who violates
or fails to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S.
143-215.1.
If you wish to provide additional information regarding the noted violation, request technical assistance, or discuss
overall compliance please respond in writing within fifteen (15) business days after receipt of this Notice. A review
of your response will be considered along with any additional information provided. You will then be notified of
any civil penalties that may be assessed regarding the violations. If no response is received in this Office
within the 15-day period, a civil penalty assessment may be prepared.
Remedial actions should have already been taken to correct this problem and prevent further occurrences in the
future. The Division of Water Resources may pursue enforcement action for this and any additional violations of
State law. If the violations are of a continuing nature, not related to operation and/or maintenance problems, and
you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by
Consent.
If you should have any questions, please do not hesitate to contact Bryan Lievre with the Water Quality
Regional Operations Section in the Wilmington Regional Office at 910-796-7215.
Sincerely,
EW
DocuSigned by:
mUa, Sad GIA�Al"
EMBAMA=C434...
Morelia Sanchez -King, Regional Supervisor
Water Quality Regional Operations Section
Wilmington Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS
Cc: WQS Wilmington Regional Office - Enforcement File
Laserfiche
Aimee Lentz (via email)
Patrick Mullally (via email)
North Caro:•naDepsrtmePtofEnvircmrneatalQusiity I DiuisionofWater Resources
W11m;ngton Feg•3rLa-Off' w 1 127 CaAinaiDrive Extenson I Wiawrtgtoa, North Caro ,ms234D5
a10-7 M-7215

Permit: WQCSD0523
SOC:
County: Onslow
Region: Wilmington
Compliance Inspection Report
Effective: 03/01/00 Expiration: Owner : Collins Estate Jacksonville NC LLC
Effective: Expiration: Facility: Collins Estates MHP Deemed Collection Syster
Contact Person: Alisa Chawki
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Title: VP
Certification:
Phone: [phone] Ext.703
Phone:
Related Permits:
NC0036676 Collins Estate Jacksonville NC LLC - Collins Estates Mobile Home Park
WWTP
Inspection Date: 09/02/2020 Entry Time 02:30PM Exit Time: 03:15PM
Primary Inspector: Bryan Lievre 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 Sewer & FOG Ordinances
Map Reporting Requirements Inspections
Spills Lines Manholes
Pump Stations
(See attachment summary)
Page 1 of 8

Permit: WQCSD0523 Owner - Facility: Collins Estate Jacksonville NC LLC
Inspection Date: 09/02/2020 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Inspection Summary:
A routine compliance inspection of the Collins Estates Mobile Home Park (MHP) Deemed Collection System was conducted
on September 2, 2020. The purpose of the inspection was to verify that the facility is operating in compliance with the
conditions and limitations specified within Permit WQCSD0523. Present during the inspection were Patrick Mullally,
operator for the system, and myself (Bryan Lievre) with DWR.
The facility has a physical address of 1138 Rocky Run Road, Midway Park, Onslow County, NC 28544. The collection
system is a gravity system which is equipped with only one pump station which is located on the south side of the second
most northern road, close to the midpoint of the road. The collection system discharges into a 25,000 gallons per day (gpd)
treatment system located near the southeast corner of the property. The treatment facility operates under Permit Number
NCO036676 and discharges into an unnamed tributary of Rocky Run in the White Oak River Basin.
The pump station was inspected during the recent visit. The station is a duplex station with a new controls system,
equipped with visual and audio alarms as well as a telemetry system. During the visit, the operator lifted the high water float
which activated the alarms and sent a notification to his cell phone. The system has a portable generator to power the
pump station, however additional wiring would be required to easily connect the generator and prevent having to "hard wire"
the unit to the control panel.
The pump station was constructed with a 5 to 6 feet diameter steel tank was is mostly submerged within a concrete block
and wood frame building. The visible portion of the steel tank was observed to be in poor condition and had a large corrosior
hole from the top of the tank to a depth of about 1.5 feet and approximately four feet long. The concrete block walls extend
at least two to three feet below grade and extend approximately three feet above grade. A wooden structure with walls and
roof was constructed on top of the concrete block walls. A large crack was observed in the concrete block wall and large
holes were present within the wooden part of the building. Concerns were expressed to the operator regarding the safe
operation of the pump station given the dilapidated condition of the structure. The operator stated that management had
provided approval for repairs to the tank and reconstruction of the surrounding structure.
Prior to performing the inspection, the operator was provided with a copy of the rules regarding deemed collection systems
(i.e. 15A NCAC 2T .0403) as well as copies of generic DEQ prepared forms to document the proper operation and
maintenance of the system.
During the inspection, the operator was not able to provide a map of the system, an operation and maintenance plan nor a
Grease Control Program. The operator also mentioned that he intends to prepare these items and has obtained approval
from management to do so.
Violations noted during the recent inspection include:
1. Failure to provide a map of the collection system, as required within 15A NCAC 2T .0403(2);
2. Failure to provide an Operation and Maintenance Plan, as required within 15A NCAC 2T .0403(3); and,
3. Failure to provide a Grease Control Program, as required within 15A NCAC 2T .0403(8).
Please review the comment sections of the inspection report for more details.
Page 2 of 8

Permit: WQCSD0523 Owner - Facility: Collins Estate Jacksonville NC LLC
Inspection Date: 09/02/2020 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
General Yes No NA NE
Is there a properly designated primary ORC and at least one back-up of proper grade? ❑ ❑ 0 ❑
Are logs being reviewed by the system management or owner on a regular basis? ❑ ❑ ❑
# What is that frequency?
# Are there any issues being addressed currently or any in the planning stages? ❑ ❑ ❑
Is there a specific pump failure plan available for all pump stations? ❑ ❑ ❑
Does plan indicate if pump parts/new pumps are in spare parts/equipment inventory? ❑ ❑ ❑
Are new/significantly upgraded pump stations equipped with anti -corrosion materials? ❑ ❑ ❑
Does the permittee have a copy of their permit? ❑ ❑ ❑
# Is permit expiring within the next 6 months? ❑ ❑ ❑
If Yes, has the Permittee applied for renewal? ❑ ❑ ❑
Comment: Since the last insDection a missina DumD has been reDlaced and a new control Danel with
alarms and telemetry has been installed. The operator indicated that he has approval from
management to make repairs to the pump station tank and surrounding building as well as
prepare a map, maintain O&M logs and prepare an oil & Grease Control Program.
Sewer and FOG Ordinances Yes No NA NE
Is Sewer Use Ordinance (SUO) or other Legal Authority available? ❑ ❑ ❑
Does it appear that the Sewer Use Ordinance is enforced? ❑ ❑ ❑
Is there a Grease Control Program that legally requires grease control devices? ❑ ❑ ❑
What is the standard grease trap cleaning requirement in the FOG ordinance?
Is Grease Control Program enforced via periodic inspections/records review?
Is action taken against violators?
# Have satellite systems adopted an equivalent or more stringent ordinance?
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.)
Comment: System does not have a written oil and grease control program.
Map
Is there a overall sewer system map?
Does the map include:
Pipe Type (GS/FM)
Pipe sizes
Pipe materials (PVC, DIP, etc)
Pipe location
Flow direction
Yes No NA NE
❑■❑❑
Page 3 of 8

Permit: WQCSD0523 Owner - Facility: Collins Estate Jacksonville NC LLC
Inspection Date: 09/02/2020 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Approximate pipe age ❑ 0 ❑ ❑
Pump station ID, location and capacity ❑ 0 ❑ ❑
# Force main air release valve location & type ❑ 0 ❑ ❑
# Location of satellite connections ❑ 0 ❑ ❑
Is the map being updated for changes/additions within 1 year of activation? 0 ❑ ❑ ❑
Comment: System does not currently have a map of the collection system. Operator indicated that he has
obtained mamagement approval to prepare a map. The operator was provided with information
that is reauired to be Dresent within the maD. such as information noted above.
Reporting Requirements Yes No NA NE
# 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? ❑ ❑ ❑
Is an Annual Wastewater Performance Report being filed with the Division, if required? ❑ ❑ ❑
Is the report being made available to all its sewer customers? ❑ ❑ ❑
# How is it being made available?
Comment:
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? ❑ ❑ 0 ❑
Comment: The operator reportedly visits the system on a daily basis. Records were not available to
document any activities performed. Copies of generic forms, prepared by DEQ were provided
and reviewed while on -site.
Spllls Yes No NA NE
Is system free of known points of bypass? ❑ ❑ ❑
If No, describe type of bypass and location
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? ❑ ❑ ❑
Comment: System staff could not produce copies of any issues, complaints, overflows or other problems
reported during the inspection.
Lines/Right-of-Ways/Aerial Lines Yes No NA NE
Page 4 of 8

Permit: WQCSD0523 Owner - Facility: Collins Estate Jacksonville NC LLC
Inspection Date: 09/02/2020 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Please list the Lines/Right of Ways/Aerial Lines Inspected:
Are right-of-ways/easements maintained for full width for access by staff/equipment? ❑ ❑ 0 ❑
If No, give details on temporary access:
Is maintenance documented?
Are gravity sewer cleaning records available?
Has at least 10% of lines older than 5 yrs been cleaned annually?
Were all areas/lines inspected free of issues?
Comment: According to the operator, at least 10% of lines are cleaned annually; however, no records were
available to document these activities.
Manholes Yes No NA NE
Please list the Manholes Inspected:
Are manholes accessible?
❑
❑ 0 ❑
# 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?
❑
❑ ❑
# 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?
❑
❑ N ❑
Comment: Two manhole covers were observed during
the recent inspection. According to the operator, the
covers are placed over cleanout locations and do not cover manholes. Manhole covers were
observed on roads north and south of pump
station. Neither location was inspected.
Pump Stations Yes No NA NE
Please list the Pump Stations Inspected:
The one and only duplex station located on the south side of the second most northern road within the
subdivision.
# Number of duplex or larger pump stations in system 1
# 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
Page 5 of 8

Permit: WQCSD0523 Owner - Facility: Collins Estate Jacksonville NC LLC
Inspection Date: 09/02/2020 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
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?
For pump stations inspected:
Are they secure with restricted access?
❑
0 ❑ ❑
Were they free of by-pass structures/pipes?
0
❑ ❑ ❑
Were wet wells free of excessive grease/debris?
❑
0 ❑ ❑
# Do they all have telemetry installed?
0
❑ ❑ ❑
Is the communication system functional?
0
❑ ❑ ❑
Is a 24-hour notification sign posted ?
0
❑ ❑ ❑
Does the sign include:
Owner Name?
0
❑ ❑ ❑
Pump station identifier?
❑
0 ❑ ❑
# Address?
❑
0 ❑ ❑
Instructions for notification?
0
❑ ❑ ❑
24-hour emergency contact numbers?
❑
❑ ❑
Are audio and visual alarms present?
0
❑ ❑ ❑
Are audio and visual alarms operable?
0
❑ ❑ ❑
# Is there a backup generator or bypass pump connected?
❑
0 ❑ ❑
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?
0
❑ ❑ ❑
# Is the owner relying on portable units in the event of a power outage?
0
❑ ❑ ❑
# If Yes, is there a distribution plan?
❑
❑ 0 ❑
If Yes, what resources (Units/Staff/Vehicles/etc) are included in Plan?
# Does Permittee have the approved percentage of replacement simplex pumps?
❑
❑ 0 ❑
Is recordkeeping of pump station inspection and maintenance program adequate?
❑
0 ❑ ❑
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: Since the last inspection, the system now has 2 pumps and replaced the controls
system.
Existing control system has visual and audible alarms with telemetry system.
Due to the poor
condition of the structure, the pump station is not considered safe nor secure.
No logs were
available to document activities performed.
MAIN PUMP STATION -
Page 6 of 8

Permit: WQCSD0523 Owner - Facility: Collins Estate Jacksonville NC LLC
Inspection Date: 09/02/2020 Inspection Type : Collection System Inspect Non Sampling
Reason for Visit: Routine
Pump Stations
Yes No NA NE
Please list the Pump Stations Inspected:
# Number of duplex or larger pump stations in system
# Number of vacuum stations in system
# Number of simplex pump stations in system
# Number of simplex pump stations in system serving more than one building
How many pump/vacuum stations have:
# A two-way "auto polling" communication system (SCADA) installed?
# A simple one-way telemetry/communication system (auto -dialer) installed?
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 communication 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?
❑
❑ ❑ ❑
If tested during inspection, did it function properly?
❑
❑ ❑ ❑
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?
❑
❑ ❑ ❑
Inspecting and exercising all valves?
❑
❑ ❑ ❑
Page 7 of 8

Permit: WQCSD0523
Inspection Date: 09/02/2020
Owner - Facility: Collins Estate Jacksonville NC LLC
Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Inspecting and lubricating pumps and other equipment?
Inspecting alarms, telemetry and auxiliary equipment?
Comment:
Page 8 of 8