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Home My WebLink AboutWQCSD0217_NOD2022PC0048_20220411ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director Countryside LLC Attn: Robert Kane 1150 Hungry Neck Blvd, Ste 359 Mt Pleasant, SC 29464 NORTH CAROLINA Environmental Quality April 11, 2022 SUBJECT: Notice of Deficiency & Compliance Evaluation Inspection Tracking #: NOD-2022-PC-0048 Countryside MHP Collection System Deemed Permitted Collection System Tracking #: WQCSD0217 NPDES Permit Number NC0022098 Randolph County Dear Mr. Kane: Mr. Ron Boone, of the NC Division of Water Resources (NCDWR), Winston-Salem Regional Office (WSRO), conducted a compliance evaluation inspection of the Countryside MHP Collection System, on March 16, 2022. Mr. Boone met with Paul Smith, Operator in Responsible Charge of the wastewater treatment system, along with Kevin Davidson, with Agri -Waste Technologies, Inc., and Steve Barry, with AQWA, Inc. Their assistance and cooperation were greatly appreciated. Inspection findings are detailed in the attached Compliance Inspection Report and summarized below. Deemed permitted wastewater collection systems in North Carolina must be operated and maintained in accordance with NC regulation 15A NCAC 02T .0400, a copy of which is attached to this letter. Mr. Smith stated that he is not under contract to operate and maintain the wastewater collection system and did not know of anyone who is. No operation and maintenance records or documentation of any type was presented for evaluation during the inspection, and it appears that none of the required operation and maintenance has been done. Countryside is therefore considered non -compliant with many of the ten conditions listed under 15A NCAC 02T .0403, as reflected in the attached Compliance Inspection Report. Please be aware that the Division may take enforcement action against any permittee who fails to comply with any requirement of their permit. Pursuant to NC General Statute (NCGS) 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. GDE NORTH C OLI JA ' omm mr� ep..of o�.i North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105 336.776.9800 If you have any questions or concerns, please do not hesitate to contact Mr. Boone by phone at 336-776-9690, or by email at ron.boone@ncdenr.gov. Thank you in advance for your time and attention to this matter. Sincerely, DocuSigned by: (JeA‘@, 4. ,.,,,etu►t. 0D2D3CE3F 167456 Jennifer F. Graznak, Assistant Regional Supervisor Water Quality Regional Operations Section Winston-Salem Regional Office Division of Water Resources, NCDEQ Attachments: 1. Water Compliance Inspection Report 2. Copy of 15A NCAC .0400 Regulations cc: 1. Laserfiche 2. Rich CoAngelo, Owner, via email rich@trubild.com D_E NORTH CARCLINA gaparMeM of Environment,/quay North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1450 W. Hanes Mill Rd, Suite 300 I Raleigh, North Carolina 27105 336.776.9800 Compliance Inspection Report Permit: WQCSD0217 Effective: 03/01/00 Expiration: SOC: Effective: Expiration: County: Randolph Region: Winston-Salem Contact Person: Robert Kane Directions to Facility: Owner : Countryside LLC Facility: Countryside MHP Collection System Title: Phone: 508-320-7053 System Classifications: Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): Related Permits: Inspection Date: 03/16/2022 Primary Inspector: Ron Boone Secondary Inspector(s): Entry Time 12:OOPM DocuSigned by: oruch 13oon.e B20F8DD5F2A3460... Exit Time: 01:OOPM 4/11/2022 Phone: 336-776-9690 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 II Spills/Response Plan ▪ Manholes (See attachment summary) ▪ General ▪ Inspections ▪ Pump Stations ▪ Grease Control ▪ Lines Page 1 of 7 Permit: WQCSD0217 Owner - Facility: Countryside LLC Inspection Date: 03/16/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Inspection Summary: Ron Boone, of the NC Division of Water Resources (DWR), Winston-Salem Regional Office, met with Paul Smith, Operator in Responsible Charge of the wastewater treatment system, on 3/16/2022, to perform a compliance evaluation inspection of the Countryside Mobile Home Park wastewater collection system. Below is a summary of the inspection findings. According to Mr. Smith, he is not operator for the collection system and no operator has been assigned to his knowledge. As such, none the requirements for the proper operation and maintenance of the wastewater collection system are currently being met. There are ten primary requirements, which are detailed below: In accordance with 15A NCAC 02T .0403 PERMITTING BY REGULATION (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 water standards. Although no wastewater spills have been recorded or reported at Countryside Mobile Home Park, there was no documentation available during the inspection to show compliance with this condition or the other nine conditions listed below. You are therefore considered noncompliant with this condition. (2) A map of the collection system shall have been developed and shall be maintained. A map of the collection system was not available during the inspection and Mr. Smith was not aware whether one exists. You are therefore considered noncompliant with this condition. (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. No O&M plan was available during the inspection and Mr. Smith was not aware whether one exists. You are therefore considered noncompliant with this condition. (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 permittee 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. There are no pump stations in the collection system. Therefore this condition does not apply. (5) High -priority sewers shall be inspected by the permittee or its representative once every six months, and inspections shall be documented. It is unknown whether any HPSs, as defined in 15A NCAC 02T .0402 DEFINITIONS, exist within the collection system. There were no records of inspections and maintenance of HPSs (6) A general observation by the permittee or its representative of the entire collection system shall be conducted once per year. There were no records of general observations being conducted as required above. You are therefore considered noncompliant with this condition. (7) Overflows and bypasses shall be reported to the appropriate Division regional office in accordance with 15A NCAC 02B.0506(a), and public notice shall be provided as required by G.S. 143215.1C. Page 2 of 7 Permit: WQCSD0217 Owner - Facility: Countryside LLC Inspection Date: 03/16/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine As mentioned above, no wastewater spills have been recorded or reported at Cranbrook. (8) A Grease Control Program shall be in place as follows: (B) For privately owned collection systems, which Countryside Mobile Home Park, is, the Grease Control Program shall include biannual 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 Part (B) of this Subparagraph if necessary to prevent grease -related sanitary sewer overflows. No grease education documentation was availabe during the inspection. It appears this requirement is NOT being accomplished. You are therefore considered noncompliant with this condition. (9) Right-of-ways and easements shall be maintained in the full easement width for personnel and equipment accessibility. There is no record of whether any such right-of-ways exist in the system and there are no records of the required maintenance. You are therefore considered noncompliant with this condition. (10) Documentation of compliance with Subparagraphs (a)(1) through (a)(9) of this Rule shall be maintained by the collection system owner for three years with the exception of the map, which shall be maintained for the life of the system. No such documentation was presented during the inspection and Mr. Smith was unsure whether any such documentation exists. You are therefore considered noncompliant with this condition. Page 3 of 7 Permit: WQCSD0217 Owner - Facility: Countryside LLC Inspection Date: 03/16/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine General # Is this system a satellite system? # 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? Comment: None Grease Control 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? Comment: None Spills and Response Action Plan # Is system free of known points of bypass? If No, describe type of bypass and location # 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? Yes No NA NE ▪ • ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ Yes No NA NE ❑ ❑ • ❑ Yes No NA NE • ❑ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ Page4of7 Permit: WQCSD0217 Owner - Facility: Countryside LLC Inspection Date: 03/16/2022 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 Comment: None Inspections 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 Please list the Lines/Right of Ways/Aerial Lines Inspected: None 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? Comment: It is unknown if any high priority lines or right-of-ways exist in the system. Manholes 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? ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ Yes No NA NE ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • Yes No NA NE ❑ ❑ ❑ • ❑ ❑ ❑ • Yes No NA NE ❑ ❑ ❑ • Page5of7 Permit: WQCSD0217 Owner - Facility: Countryside LLC Inspection Date: 03/16/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine # 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? Comment: None Pump Stations Please list the Pump Stations Inspected: There are no pump stations in the collection system. All pump stations are a part of the treatment plant. # 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 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? ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • Yes No NA NE 0 0 0 0 0 0 ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ Page6of7 Permit: WQCSD0217 Owner - Facility: Countryside LLC Inspection Date: 03/16/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine # 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? Inspecting and lubricating pumps and other equipment? Inspecting alarms, telemetry and auxiliary equipment? Comment: None ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ Page 7 of 7