WQCSD0723_NOV-2020-PC-0471 Response_20201125

CHG MHP Roxboro, LLC
November 25, 2020
RE: Notice of Violation Tracking Number: NOV-2020-PC-0471
Scott Vinson
Regional Supervisor
Water Quality Regional Operations Section
3800 Barrett Drive
Raleigh, NC 27609
Dear Mr. Vinson,
1229 38tb Ave. N
PMB #300
Myrtle Beach, SC 29577
NC Kept of Environmental Quality
DEC - 4 2020
Raleigh Regional Office
I would like to address the violation letter we received on November 25t", for our Pineview
Mobile Home Park. We understand and agree this was a serious issue. The system has been
repaired and is fully operational.
In response to questions listed 1-5 on the violation letter:
As soon as a leak occurs, we immediately call the plumbing company.
This is our only park with a private sewer system. Consequently, we were unaware that your
office must be informed of these emergencies. Our entire staff has now been briefed on
proper reporting procedures. Your office will be promptly informed should this happen again.
In previous years, we had engaged Soloman Septic Tank Services Company to maintain the
lines and inspect the system. We now realize that for whatever reason, Solomon did not make
us aware of repairs that were necessary to the system. We no longer use their services.
In June 2020, we contracted Bobby Davis Jr Septic Tank Services (Morrisville) to inspect the
system and replace any areas they felt needed attention. Their initial inspection resulted in
$15,000 worth of repair work.
The issue in question happened in October. A small area of sewer line not previously repaired
by Bobby Davis Jr Septic Tank Services collapsed. This resulted in an additional $5,600 repair.
Bobby Davis Jr Septic Tank Services took away dirt from the affected area, sanitized, laid
down lime and replaced it with clean fill dirt.

Since March 2017 when our company acquired this park, much time and money has been
spent on improving the living conditions for all residents. I assure you, we are doing our best
to make this park a clean, safe environment for residents and the town.
Enclosed are all of the invoices we've spent with Bobby Davis Jr. Septic Tank Services.
The tenants have been given proper notice about grease in their drains. The notice is
attached. It's also given at lease signing.
Lastly, we are awaiting a proposal from Bobby Davis Jr. Septic Tank Services on a maintenance
contract to get our system inspected quarterly.
Sincerely,
�b�e,t� n1a�P
Donelle Nail
coo
CHG-MHP Roxboro, LLC
843-712-1480

Bobby Davis Jr. Septic Tank Service
5835 Family Farm Road
Morrisville, NC 27560
[phone]
[phone] Fax
Bill To
Pine View Mobile Home Park
711 Leasburg Rd.
Roxboro, NC
Invoice
Date
Invoice #
T282020
6856
Dept of Environn►ental Qaaltic\
NC
DEC
ItaleighRegionati Office
P.O. No.
Terms
Project
Due on receipt
Item
Description
Est Amt
Prior Amt
Prior %
aty
Rate
Curr %
Total %
Amount
repair
Repair Sewer Line breaks
I5,200.00
1
15,200.00
100.006o
100.00%
15.200.00
located between Lots 7 and 8,
Lots 56 and 57, Lots 65 and 66,
Lots 16 and 17, Lots 84 and 85
per walk through with Mark and
Allen. Also, cut asphalt and
replace entire sewer line from
Lot 61 across street to Lot 83.
This price does not include
replacing the asphalt after the
new line has been replaced
across the street
Contract
NOTE: We will not responsible
0.00
0.00
0.00
for relocating any utility lines
(ex. Power, Water. Gas, etc.) if
needed.
If additional electrical wiring is
required, a certified electrician
will have to be hired by the
property owner at their expense
to complete the work. We are
not responsible for any
additional costs incurred to
supply the needed power to
operate the system.
Customer is responsible for any
landscaping (seeding, strawing
Total
Payments/Credits
Balance Due
Page 1

Bobby Davis Jr. Septic Tank Service
5835 Family Farrn Road
Morrisville, NC 27560
(919)48 l -6929
[phone] Fax
Bill To
Pine View Mobile Home Park
711 Leasburg Rd.
Roxboro, NC
Invoice
Date
Invoice #
7 28 2020
6856
P.O. No.
Terms
Project
Due on receipt
Item
Description
Est Amt
Prior Amt
Prior %
city
Rate
Curr %
Total %
Amount
etc.) of disturbed areas upon
completion of system repair or
new installation. We are not
responsible for any shrubs,
landscaping, patios, sidewalks,
etc. that are in the area of repair.
The homeowner will be
responsible for removing and
replacing such items.
This price is provided that we
do not hit rock or any other
unsuitable material. Should this
happen, we will charge by the
hour to remove and dispose of
material properly.
`*We will not be responsible
for any utilities that are not
located by No -Cuts such as
private waterlines, propane
lines, etc. This includes
sprinkler systems and yard
lighting."
Due to the rapid increase of fuel
and materials, this price can
only be guaranteed for 7 days.
This estimate must be signed
Total
Payments/Credits
Balance Due
Page 2

Bobby Davis Jr. Septic Tank Service
5835 Family Farm Road
Morrisville, NC 27560
[phone]
[phone] Fax
Bill To
Pine View Mobile Home Part:
711 Leasburg Rd
Roxboro. NC
Invoice
Date
Invoice #
W2812020
6856
P.O. No.
Terms
Project
Due on receipt
Item
Description
Est Amt
Prior Amt
Prior %
Oty
Rate
Curr %
Total %
Amount
and returned within 7 days for
this price to hold. No work will
begin until this estimate is
signed and returned.
Payment is Due at the time of
our part orthe job being
complete. We expect to be paid
as soon as we are finished on
thejob.
A 34u Service Charge will be
added to any credit card
transactions over $1000.00.
Customer Signature
Date
Total $15,200.00
Payments/Credits $0.00
FBalance Due 515,200.00
Page 3

24 Hour Service
SEPTIC TANK SERVICEV
5835 Family Farm Road
_ Mordsv€lle, NC 27560
[phone]
CUsTOMER' ORDER Np PNQNE
0A7E
NAkIE
ADDRESS c
SOLD BY CASH
C.O.D. i CHARGE ON ACCT. MQSE. REr0. PAID OUT
OTY. DESCRIPTION
PRICE AMOUNT
Not responsi or drivewa or landscaping.
TAX
RECER+EO BY r
C PR0M1C %r0 I CW s returned goods must be accompanied by this pill.
118 0u'cw

24 Hour Service
OZA _SEPTIC TANK SERRIC
5835 Family Farm Road _
Morrisville, NC 27560
[phone]
CUSTOMER'S ORDER NO 1*-QNE
. Ga-/
HAME l` O LsIzaZU
appRess C/
L 16-e-'J
e-
SOLD BY CASH CAD,CHARGE ON ACCT. MOSS. RETp PAFO OUT
QTY. DESCRIPTION PRICE AMOUNT
Nfi 2s .� I-Ra
6r�1
447--�
F
� t
ti Z'7 J
J
Not rest ' driveways or landscaping. TAX
REC[7VEp
TOTAL f70 "
C PKKK=610 aims and MIUMed geods must be a=Mpanled by IN% hilt.
1 � 5 9 6 �a.',�

NOTICE TO ALL RESIDENTS:
Over the last several months we have had increased problems
with our septic system and had to make many costly repairs. To
avoid these costly repairs from happening the following issuses
need to be addressed:
Do not put these items down a drain
(including toilets, sinks, tubs and showers)
since they can trigger a septic -system failure:
. Baby wipes and diapers
. Large amounts of food waste
Any kind of cirease.When needed,
use alternative cleaning solutions that
are septic -safe (like vinegar).
Tenants should also avoid very long showers,
use the washing machine no more than once
a day, and refrain from excessive use of
garbage disposals.
Thank you,
PINEVIEW MANAGEMENT

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
November 12, 2020
CERTIFIED MAIL 7017 0190 0000 9569 8756
RETURNED RECEIPT REQUESTED
Gary Wadsten, Managing Member
CHG-MHP Roxboro, LLC
4605C Oleander Drive, Suite 301
Myrtle Beach, SC 29577
CERTIFIED MAIL 7017 0190 0000 9569 8763
RETURNED RECEIPT REQUESTED
Aland Dunn, Property Manager
Lehigh Mobile City / Pine View MHP
711 Leasburg Rd
Roxboro, NC 27573
Subject: Notice of Violation — Notice of Intent to Enforce (NOV-NOI)
Tracking Number: NOV-2020-PC-0471
Sanitary Sewer Overflow (SSO) — October 2020
Lehigh Mobile City/ Pine View Mobile Home Park
711 Leasburg Rd, Roxboro, NC 27573
Deemed Collection System Permit No. WQCSD0723
Person County
Dear Mr. Wadsten & Mr. Dunn:
This office was informed by Person County Health Department of sewage surfacing at the subject location
on October 09, 2020. lane Bernard with the Division of Water Resources visited the site on October 20,
2020 and confirmed that a large quantity of raw sewage was discharging from a broken sewer line onto
the ground (see picture in Attachment A).
Since the sewer line is privately owned, it is the owner's responsibility to operate and maintain this system
Because the system has a daily flow below 200,000 gallons per day, the system is considered permitted
by regulation (deemed permitted) (Permit # WQCSD0723) and must meet the requirements of Rule 15A
NCAC 02T.0403 (Attachment C).
The sewer overflow that occurred constitutes a violation of NCGS 143-215.1 (a) (1) and 15A NCAC
02T.0403 (a) (1). In addition, a file review failed to reveal the receipt of a 24 notification or a 5-day written
report detailing the sewer spill as required by 15A NCAC 02T.0403 (7). These Statutes and North Carolina
Administrative Code violations states the following:
15A NCAC 02T.0403 (a) (1) "The sewer system is effectively maintained and operated at all times
to prevent discharges to land or surface waters, and to prevent any contravention of groundwater
standards or surface water standards." (see Attachment C for this and other requirements)
� 4 North Carolina Department of Environmental Quality i Division of Water Resources
` Raleigh Regional office 13800 Barrett Drive ? Rakigh. North Carolina 27609
9197914200

• 15A NCAC 02T .0403 (a) (7) "Overflows and bypasses are reported to the appropriate Division
regional office in accordance with 15A NCAC 02B .0506 (a), and public notice is provided as
required by G.S. 143-215.1 C (also see Attachment B for Reporting Requirements)
• 15A NCAC .028 .0506 (a) (2) "Every person subject to this Section shall report by telephone to
either the central office or appropriate regional office of the Division as soon as possible but no
later than 24 hours after occurrence or the next working day (however, if the occurrence is one
which may endanger the public health , or fish or wildlife, and contact with the central office or
the appropriate regional office cannot be made, such persons shall report as soon as possible to
the State Highway Patrol Warning point in State 1-800-622 7956 or out of state [phone])
following the occurrence of or first knowledge of the occurrence of any of the following:
(A) Any failure of a collection system, pumping station or treatment facility resulting in a by-
pass without treatment of all or any portion of the wastewater.
• 15A NCAC 02B .0506 (a) (3) "Persons reporting such occurrences by telephone shall also provide
a written report to the Division in letter from setting out the information required in
Subparagraph (a) (4) of this rule and pertinent information pertaining to the occurrence. This
report must be received by the Division within five days following first knowledge of the
occurrence."
These violations and any future violations are subject to civil penalty assessment of up to $25,000 per
day per violation.
Please see attached copy of the rules regarding wastewater collection systems that are "Permitted by
Regulation" (deemed) and spill reporting requirements (15A NCAC 02T .0403). Please respond to this
letter in writing with 10 days of receipt. Your response should minimally address the following items:
1) Immediately take actions to stop the flow of wastewater from the broken/clogged sewerline
and stop waste from being conveyed to the surface.
2) Clearly detail and explain the cause of the overflow, the failures of the pipes, how the issue was
resolved, and how the area was cleaned.
3) Explain why there was no notification within 24-hours of occurrence or a written report provided
to this office within 5 days following first knowledge of the wastewater overflow as required by
15A NCAC 028.0506 (3) (See Attachment B).
4) Please explain what changes you are planning to prevent future spills, to ensure spill reporting
requirements are followed, clean-up efforts are timely, and waste collection systems are
properly maintained.
5) Make plans to start keeping records of how the requirements of 15A NCAC 02T .0403
(Attachment C) are being met, including at least biannual distribution of grease educational
materials to residents. You will be contacted in the future to check on what is being done to
meet State Regulations.
Please understand, periodic or routine occurrences of untreated waste (sewer) overflows from this
collection system must be eliminated. This cannot continue to occur.
Thank you for your attention to this matter. This office requires that the violations, as detailed above,
be abated immediately and properly resolved. Environmental damage and/or failures to properly

maintain and operate collection system infrastructure and report spills have been documented for the
subject site as stated above. Your efforts to undertake activities to bring the subject site back into
compliance is not an admission, rather it is an action that must be taken in order to begin to resolve
ongoing environmental issues. Please understand, periodic or routine occurrences of untreated waste
(sewer) overflows from this collection system must be eliminated. This cannot continue to occur. These
violations and any future violations are subject to a civil penalty assessment of up to a maximum of
$25,000.00 per day for each violation. Your above -mentioned response to this correspondence will be
considered in any civil penalty assessment process that may occur. Should you have any questions
regarding these matters, please contact Mitch Mayes at 919.791.4200.
Sincerely,
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Attachments:
A- Picture
B- Reporting Requirements
C- Collection System requirements for "Permitted by Regulation" (deemed) systems

Attachment B
Reporting Re uirements: Sanita1y Sewer Overflows SSO
Division of Water Resources (DWR) reporting requirements for Sanitary Sewer Overflows
(spills)
I. Did any wastewater each surface waters?
You must report any amount that reaches surface waters. You must provide a verbal report within
24 hours to the Raleigh Regional Office at [phone]. Telephone the Regional Office within
24 hours of first knowledge. (If after hours, Emergency Management) (800)-858-0368)
You must follow up with a 5-day written report to the Raleigh Regional Office (please contact
Division for 5-day reporting form and email address)
Division of Water Quality
Surface Water Protection Section
3800 Barrett Drive
Raleigh NC 27609
The report must address the following information: Location, quantity, water body affected (name
of stream), date and time of occurrence, duration, weather Conditions, spill clean-up and
infrastructure repair information.
2. Is the gpill 1000 gallonsmore (reggrdless of whether it reached surface waters)?
Wastewater spills that are 1,000 gallons or greater, whether reaching a stream or surface waters or
contained on dry land must be reported. You must provide a verbal report within 24 hours to the
Raleigh Regional Office at [phone]. Telephone the Regional Office within 24 hours of first
knowledge'. (If after hours, Emergency Management) (800)-858-0368)
You must follow up with a 5-day written report to the Raleigh Regional Office (please contact
Division for 5-day reporting form and email address):
Division of Water Quality
Surface Water Protection Section
3800 Barrett Drive
Raleigh NC 27609
3. NCGS 14 -2 5. c (11 an 2 - Press Release and Public Notige
Press Release = if 1,000 gallons or more of untreated waste are discharged to the surface waters of
the State, the responsible party must provide a news release to all print and electronic news media
that provide general coverage in the county - within 48 hours.
Publish a "Notice Qf Discharge_'=15,000 gallons or more of untreated waste to the surface waters of
the State must be noticed in the newspaper having general circulation in the county in which the
discharge occurred and affected - within 10 days of DENR's approval. A copy of the notice that was
placed in the newspaper must be submitted to the Raleigh Regional Office within 30 days.
If you have questions, please do not hesitate to contact the Raleigh Regional Office for
assistance [phone]. Note: failure to properly report wastewater spills may
result in a civil penalty assessment of up to $25,000.00 per day.

Attachment C
1 * �i ti C AC 0? T .0403 P3 PURTM i G BY REGiZ ATIO?`
(a) Collection systems having an actual. permitted or Division -approved average daily flow less than 200.000
gallons per day shall be deemed permitted. pursuant to Rule .0113 of this Subchapter if the system meets the criteria
in Rule .0113 of tins Subchapter and all criteria required in this Rule'
(1) The collection system shall be effectively maintained and operated at all times to prevent
discharge to land or surface waters and to prevent any contravention of groundwater standards or
surface Rater standards.
(2) A map of the collection system shall have been developed and shall be maintained.
(3) An operation and maintenance plan, including pump station inspection frequency, preventative
maintenance schedule. spare parts inventory' and overflow response shall have been developed
and implemented
(4) Pump stations that are not connected to a telemetry system shall be inspected by the permittee or
its representative every day. 365 days per year. unless the permttee demonstrates that daily
inspections are not necessary because the pump station has sufficient storage capacity. above the
elevation at which the pump activates, to justify a longer inspection interval_ In no case shall the
inspection interval exceed seven days_ Pump stations that are connected to a telemetry system
shall be inspected once per week
(5) Mgh-priority sewers shall be inspected by the permittee or its representative once every six -
months, and inspections shall be documented
(6) A general observation by the permittee or its representative of the entire collection system shall be
conducted once per year.
(7) Overflows and bypasses shall be reported to the appropriate Division regional office in accordance
with 15A . CAC 02B .0506(a). and public notice shall be provided as required by G_S. 143-
215AC.
(8) A Grease Control Program shall be in place as folloRs:
(A) For publicly owned collection systems. the Grease Control Program shall include bi-
annual distribution of educational materials for both commercial and residential users and
the legal means to require grease interceptors for new construction and retrofit and if
necessary. of grease interceptors at existing establishments. The plan shall also include
legal means for inspections of the grease interceptors. enforcement for violators and the
legal means to control grease entering the system from other public and private satellite
collection systems.
(B) For privately owned collection systems_ the Grease Control Pro_efam shall include bi-
annual distribution of grease education materials to users of the collection system by the
permittee or its representative.
(C) Grease education materials shall be distributed more often than required in Parts (A) and
(B) of this Subparagraph if necessary to prevent grease -related sanitary sewer overflows.
(9) Right-of-ways and easements shall be maintained in the full easement width for personnel and
equipment accessibility.
(10) Documentation of compliance uith Subparagraphs (a)(1) through (a)(9) of this Rule shall be
maintained by the collection system owner for three yeas with the exception of the map, which
shall be maintained for the life of the system-
(b) Private collection systems on a single property serving an industrial facility from which the domestic wastewater
contribution is less than 200.000 gallons per day shall be deemed permitted.
(c) The Director may determine that a collection system shall not be deemed to be pernimed in accordace with this
Rule and Rule .0113 of this Subchapter. This determination shall be made in accordance uuith Rule .0113(e) of this
Subchapter.
Hisron Note: Atdhoni3 G.S. 143-215.1(nj; 143-215.3(a); 143-215.9B;
.Ff. September 1, 2006,
Readopted( Eff. Seprembor 1, 2018.