NC0051713_CEI_ NOV-2021-PC-0346_20210719

DocuSign Envelope ID: E7C0C368-00BD-4136-99B6-EE15C407B479
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
July 19, 2021
CERTIFIED MAIL 7018 1130 0000 1612 5419
RETURN RECEIPT REQUESTED
Mr. Walter B. Craven, Jr.
Lakeview MHP LLC
420 Marion Dr. #31
Wilmington, NC 28412
SUBJECT: Notice of Violation (NOV-2021-PC-0346)
Lakeview MHP WWTP
Permit No. NC0051713
Forsyth County
Dear Mr. Craven:
On July 9, 2021, staff of the North Carolina Division of Water Resources Winston-Salem Regional
Office (Division) performed an announced routine compliance inspection of the subject Wastewater
Treatment Plant (WWTP). The inspection was conducted by Division staff members Patrick
Mitchell and Jordan Burbage from the Winston-Salem Regional Office. A separate in -office file
review of the self -monitoring reports was also conducted for the reporting period of January 2019
through April 2021. The inspection found the subject facility to be noncompliant with NPDES
Permit No. NC0051713. Therefore, this inspection report is being sent as a Notice of Violation.
The violations listed below require your attention and action.
1. At the time of the inspection there were no records for solids removal from the system (i.e.,
no septic tank cleanouts and no WWTP sludge cleanouts). Permit Part II.C.6. requires that
solids, sludge, etc. shall be removed and disposed of in accordance with NCGS 143-215.1.
Permit Part II.D.6. requires that records of sewage sludge shall be retained for a period of at
least five years. Failure to remove solids from the system and maintain records of
removal is a violation of Permit No. NC0051713. This is a repeat item that was also included
in a Notice of Violation issued in July 2018 following the most recent onsite compliance
inspection.
Please forward copies of all solids removal records for the period of January 2019
through present to this office to my attention. To avoid future non-compliance, please
maintain records of solids removal events (e.g. hauling records, removal logs, etc.) onsite
and have them available for review during future compliance inspections as required.
2. At the time of the inspection, four of the five diffusers serving the system's aeration basin
were found to not be operating properly. Permit Part II.C.2. requires that the system shall be
properly operated and maintained at all times. Failure to properly operate and maintain
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 3001 Winston-Salem, North Carolina 27105
336.776.9800

DocuSign Envelope ID: E7C0C368-00BD-4136-99B6-EE15C407B479
the diffusers on the aeration basin is a violation of Permit No. NC0051713. It should be
noted that onsite representatives indicated diffusers are most likely clogged. Solids and trash
were observed to be present in the aeration basin. Failure to adequately remove solids from
the septic tanks serving the system is likely contributing to this violation.
Please take necessary actions for cleaning, repairing, or replacing diffusers as soon as
possible. Adequate removal of solids and trash from the system may help ensure proper
operation of diffusers and prevent future malfunctioning.
3. At the time of the inspection the skimmer serving the clarifier was not functional. Again,
Permit Part II.C.2. requires that the system shall be properly operated and maintained at all
times. Failure to properly maintain the skimmer serving the clarifier is a violation of
Permit No. NC0051713. It should be noted that solids were observed bulking in the clarifier
at the time of inspection. Also, solids and trash were observed in the skimmer trough. Trash
should primarily be removed during primary treatment within the septic tanks serving the
system. If solids removal is adequate from septic tanks, minimal trash should be present in
the clarifier.
Please repair the clarifier skimmer as soon as possible. Again, adequate removal of solids
and trash from the system may help ensure proper operation and prevent future
malfunctioning.
4. The discharge monitoring reports (DMR) for the subject review period reported multiple
effluent limit exceedance violations for Ammonia, Fecal Coliform, TSS, and BOD. These
violations resulted in a total of five Notices of Violations, two Notice of Deficiencies and one
Enforcement issued during the review period. It should be noted that the April 2021 DMR
also reported effluent limit violations for Ammonia and Fecal Coliform, which has not been
addressed by this office yet. These exceedances are chronic repeat violations of Permit
No. NC0051713, Part I.A.1. These effluent limit exceedance violations could be a result of
the operations and maintenance violations listed above.
Please take actions necessary to allow proper operation, maintenance and repair of the
subject system to help ensure effluent limits are met in the future.
In addition, the following item of concern also warrants your attention and action:
At the time of inspection, a water hose that was connected to a potable water faucet was found
to continuously be leaking potable water into the chlorine contact chamber just prior to the
effluent sampling location. Permit Part II.A. and Part II.D.1. both require that the effluent
samples collected, and the measurements taken shall be representative. Sampling effluent that
is diluted with potable water prior to a sampling point is not representative of effluent
produced from the WWTP.
Please remove the water hose that is discharging potable water when cleaning operations
are not being conducted.
A Notice of Violation is being issued for the above listed violations of NPDES Permit No.
NC0051713. Pursuant to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand
dollars ($25,000.00) as well as criminal penalties may be assessed against any person who violates
or fails to act in accordance with the terms, conditions, or requirements of any permit issued
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DocuSign Envelope ID: E7C0C368-00BD-4136-99B6-EE15C407B479
pursuant to G.S. 143-215.1.
Please provide a written response to this office within thirty (30) days of receipt of this Notice
regarding your plans or measures to be taken to address these violations. Please include any
information requested above with your response. Remedial actions should have already been taken
to correct these problems and prevent future occurrences. The Division appreciates your immediate
attention and action. Please be aware that failure to properly address the items listed above may
result in further enforcement actions.
Please refer to the enclosed compliance inspection report form for additional observations and
comments. If you believe 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.
As a reminder, Permit Part II.E.6., requires that the Permittee or Permittee's representative shall
verbally notify the Regional Office as soon as possible, not to exceed 24 hours, from first
knowledge of any non-compliance at the facility including limit violations, bypasses of, or failure
of a treatment unit. A written report may be required within 5 days if directed by Division staff. In
addition, Regional Office notification shall be given for anticipated noncompliance or potential
problems due to planned maintenance activities, repairs, taking units off-line, etc.
If you have any questions regarding this Notice, please contact Patrick Mitchell or me at the
letterhead address or phone number, or by email at [e-mail].
Sincerely,
DocuSigned by:
OD2 CE 1B7 6...
Jenm er . raznak, Assistant Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
enc: Compliance Inspection Report
cc: Mr. Randy Bell, ORC (Electronic Copy)
Forsyth County Environmental Health (Electronic Copy)
Laserfiche File NC0051713
WSRO Electronic Files
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DocuSign Envelope ID: E7C0C368-00BD-4136-99B6-EE15C407B479
United States Environmental Protection Agency
EPA Washington, D.C. 20460
Water Compliance Inspection Report
Form Approved.
OMB No. 2040-0057
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction
1 IN I
21IIIIII
Code NPDES yr/mo/day Inspection
2 IL I 3 I NC0051713 111 121 21/07/09 117
Type
1810I
IIIIIIIIIII
Inspector Fac Type
19I S I 2011
IIIIIIIIIII IIIIIII I IIIIII
P6
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA
671 I 7° I I 711 172 I N I 73I
Reserved
1 74 71
I I
I I I I I I 180
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES Dermit Number)
Lakeview Mobile Home Park WWTP
5186 High Point Rd
High Point NC 27265
Entry Time/Date
09:OOAM 21/07/09
Permit Effective Date
19/05/01
Exit Time/Date
10:45AM 21/07/09
Permit Expiration Date
24/04/30
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Randall Keith Bell/ORC/336-373-7514/
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Walter B Craven,420 Marion Dr #31 Wilmington NC 28412//910-777-1998/9103958265
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenar Records/Reports
Self -Monitoring Progran Sludge Handling DispoFacility Site Review Effluent/Receiving Wate
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
Patrick Mitchell DWR/Division of Water Quality/336-776-9698/
Jordan Burbage DWR/WSRO WQ/336-776-9697/
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by: Date
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Signature of
Management Q A Reviewer Agency/Office/Phone and Fax Numbers
DocuSigned by:
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EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
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DocuSign Envelope ID: E7C0C368-00BD-4136-99B6-EE15C407B479
31
NPDES yr/mo/day
NC0051713 111 121 21/07/09
I17
Inspection Type
18LI
(Cont.)
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
On July 9, 2021, WSRO staff conducted an inspection of the subject facility. Mr. Randy Bell (ORC)
accompanied staff on the inspection. An in -office review of self -monitoring reporting data (DMRs) for
the period of January 2019 through April 2021 was also conducted as part of this inspection. The
inspection found the subject facility to be noncompliant with the permit. Below is a summary of
observations & violations noted during this inspection. Follow up inspection is needed to ensure
corrective actions are taken in a timely manner.
1. During the subject review period for self -monitoring reporting data there have been five NOVs
issued, two NODs issued, one Enforcement and there are violations reported in the April 2021 DMR
that need to be addressed. Ammonia, TSS, BOD, and Fecal Coliform exceedances have occurred
during this period.
2. There were no records available at the time of the inspection for solids removal from the system
(none for the septic tanks or WWTP sludge). Onsite representatives indicated the septic tank
pumping service provider is being switched in an effort to obtain solids removal records. Reportedly
Transou's Septic Tank Service will begin routinely pumping out the septic tanks serving this system
along with any sludge accumulated in the WWTP, and providing records to the ORC. The previous
septic tank pumping service was reportedly pumping out tanks once every six months. If this is the
case, it appears to be grossly inadequate to prevent solids and trash from entering the WWTP (see
items below). There is no bar screen present on the WWTP due to the septic tanks being present for
solids and trash removal.
3. There are reportedly five septic tanks serving this system which provide primary treatment for the
system (solids removal). However, there is no records of any solids being removed from the system
(septic tanks or WWTP). It should be noted that this violation was included in an NOV issued in July
2018. Requested solids removal records be obtained and made available for future inspections.
4. The septic tanks serving this system reportedly do not have effluent filters present and it is
unknown if they have sanitary T's present in the tanks either. The exact locations of the septic tanks
are unknown. Division staff was able to locate four concrete risers located inside the MHP that may
be the location of four of the five septic tanks. Request that the Permittee provide a site map showing
the locations of the five septic tanks.
5. The aeration basin serving the system was found to be in need of repair at the time of the
inspection. Only one of the five diffusers was operating properly at the time. Diffusers #1 appeared to
not be working at all. Diffusers #2, #4 and #5 were very weak. Diffuser #3 was doing most of the work
at the time of inspection.
There was a lot of solids including trash present in the WWTP at the time of inspection. Onsite
representatives indicated that the diffusers are clogged. Diffusers that were either not working or
barely working need to be cleaned, repaired, or replaced as soon as possible. Reportedly DO was
running —2.8 mg/L and settleability —360 mL (jar method) at the time of inspection. Note: these
measurements were not conducted during the inspection.
6. The skimmer serving the clarifier was not working at the time of the inspection. Needs to be
repaired or replaced as soon as possible.
7. The clarifier appeared to have a lot of solids present with some sludge bulking to the top of the
clarifier. A sludge judge was not available for sludge depth measurement at time of the inspection.
Request that a sludge judge be present for measurement during the follow up inspection. Trash was
also found to be present in the clarifier. Algal growth was present on weirs and a minor amount of
solids and what might be fungal growth was observed to be in the trough. Weirs need to be cleaned
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DocuSign Envelope ID: E7C0C368-00BD-4136-99B6-EE15C407B479
Permit: NC0051713
Inspection Date: 07/09/2021
Owner - Facility: Lakeview Mobile Home Park WWTP
Inspection Type: Compliance Evaluation
soon.
8. It appears that mismanagement/insufficient removal of solids is contributing to the issues noted at
the WWTP. The issues noted during the inspection are contributing to the chronic effluent limit
exceedances that are reported.
9. At the time of the inspection a garden hose connected to the potable water faucet was found to be
leaking a continuous stream of potable water into the chlorine contact chamber, just prior to the
effluent sampling point. Effluent was found to be clear and odorless with no foam or solids present.
Potable water should be turned off and not left running into the effluent. Sampling effluent that has
been diluted with potable water is not representative of effluent produced from the subject system.
Request water hose not be left running into the chlorination chamber.
OTHER NOTES:
• Water use meter is now being used to calculate average daily flows with weekly meter readings.
Daily flows using water use data is averaging around 1,000 GPD.
• Checked lab reports for April 2021 DMR. Lab report supports DMR data and chain of custodies
present.
• Upstream and downstream sample stations were reviewed. Upstream location had very little flow.
Downstream sample is being collected from Cuddybum Branch just below confluence with the UT that
receives effluent discharge. Stream appears to be healthy with no algal growth, no fungal growth, fish
present, no odors or foam observed.
*FOLLOW-UP INSPECTION NEEDED
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DocuSign Envelope ID: E7C0C368-00BD-4136-99B6-EE15C407B479
Permit: NC0051713
Inspection Date: 07/09/2021
Owner - Facility: Lakeview Mobile Home Park WWTP
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 MODE
application?
Is the facility as described in the permit? • ❑ ❑ ❑
# Are there any special conditions for the permit? ❑ El • El
Is access to the plant site restricted to the general public? • ❑ ❑ ❑
Is the inspector granted access to all areas for inspection? • ❑ ❑ ❑
Comment:
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? • ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable MEI ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: Settleable Solids & DO
Septic Tank Yes No NA NE
(If pumps are used) Is an audible and visual alarm operational? ❑ ❑ • ❑
Is septic tank pumped on a schedule? ❑ • ❑ ❑
Are pumps or syphons operating properly? ❑ El • El
Are high and low water alarms operating properly? El El • El
Comment: See summary - Issues with solids removal and inadequate pumping of 5 septic tanks
serving the system.
Aeration Basins Yes No NA NE
Mode of operation Ext. Air
Type of aeration system Diffused
Is the basin free of dead spots? ❑ • ❑ El
Are surface aerators and mixers operational? El • El El
Are the diffusers operational? El • El El
Is the foam the proper color for the treatment process? El • El El
Does the foam cover less than 25% of the basin's surface? El El • El
Is the DO level acceptable? El El El •
Is the DO level acceptable?(1.0 to 3.0 mg/I) El El El •
Comment: See Summary - Issues with aeration basin & diffusers.
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DocuSign Envelope ID: E7C0C368-00BD-4136-99B6-EE15C407B479
Permit: NC0051713
Inspection Date: 07/09/2021
Owner - Facility: Lakeview Mobile Home Park WWTP
Inspection Type: Compliance Evaluation
Pumps-RAS-WAS
Are pumps in place?
Are pumps operational?
Are there adequate spare parts and supplies on site?
Comment:
Secondary Clarifier
Is the clarifier free of black and odorous wastewater?
Is the site free of excessive buildup of solids in center well of circular clarifier?
Are weirs level?
Is the site free of weir blockage?
Is the site free of evidence of short-circuiting?
Is scum removal adequate?
Is the site free of excessive floating sludge?
Is the drive unit operational?
Is the return rate acceptable (low turbulence)?
Is the overflow clear of excessive solids/pin floc?
Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth)
Comment: See Summary.
Yes No NA NE
• ❑ ❑ ❑
Yes No NA NE
• ❑ ❑ ❑
❑ • ❑ ❑
❑ • ❑ ❑
❑ • ❑ ❑
Disinfection -Tablet Yes No NA NE
Are tablet chlorinators operational? • ❑ ❑ ❑
Are the tablets the proper size and type? • ❑ ❑ ❑
Number of tubes in use? 1
Is the level of chlorine residual acceptable? • ❑ El ❑
Is the contact chamber free of growth, or sludge buildup? • El El El
Is there chlorine residual prior to de -chlorination? • El ❑ ❑
Comment:
De -chlorination Yes No NA NE
Type of system ? Tablet
Is the feed ratio proportional to chlorine amount (1 to 1)? El El El •
Is storage appropriate for cylinders? • El El El
# Is de -chlorination substance stored away from chlorine containers? • El El El
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DocuSign Envelope ID: E7C0C368-00BD-4136-99B6-EE15C407B479
Permit: NC0051713
Inspection Date: 07/09/2021
Owner - Facility: Lakeview Mobile Home Park WWTP
Inspection Type: Compliance Evaluation
De -chlorination Yes No NA NE
Comment:
Are the tablets the proper size and type? • ❑ ❑ ❑
Are tablet de -chlorinators operational? • ❑ ❑ ❑
Number of tubes in use? 1
Comment:
Effluent Sampling Yes No NA NE
Is composite sampling flow proportional? ❑ ❑ • ❑
Is sample collected below all treatment units? • ❑ ❑ ❑
Is proper volume collected? ■ ❑ ❑ ❑
Is the tubing clean? El ❑ • ❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 El El • El
degrees Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type • ❑ ❑ ❑
representative)?
Comment:
Effluent Pipe
Is right of way to the outfall properly maintained?
Are the receiving water free of foam other than trace amounts and other debris?
If effluent (diffuser pipes are required) are they operating properly?
Comment:
Yes No NA NE
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