WQCSD0215_CEI_Letter_NOD2022PC0071_20220509

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Sunrise & Sons, LLC
Attn: Stephen R. Davis, Owner
P.O. Box 2153
Asheboro, NC 27204-2153
NORTH CAROLINA
Environmental Quality
May 9, 2022
SUBJECT: Compliance Evaluation Inspection & Notice of Deficiency
Case #: NOD-2022-PC-0071
Sunrise Park Mobile Home Park Collection System
Deemed Permitted Collection System Tracking Number WQCSD0215
Guilford County
Dear Mr. Davis:
Mr. Ron Boone, of the NC Division of Water Resources (DWR), Winston-Salem Regional Office
(WSRO) performed a scheduled inspection of the above mentioned deemed permitted wastewater
collection system (WWCS) on March 24, 2022. Your assistance and cooperation during the inspection
was greatly appreciated. The findings of the inspection are listed in the table below and detailed in
the attached compliance inspection report.
Requirement
Findings
1.
Operation &
No spills have been reported, however, several items were not
Maintenance 0&M
documented as required by regulation, as detailed below.
2.
WWCS Map
None available during the inspection.
3.
0&M and Spill Plan
There is no written 0&M ors ill plan.
4.
Pump Station (PS)
Not applicable, there are no PSs in the WWCS. This should be
Inspection Frequency
specified in the 0&M plan.
S.
High Priority Sewers
There is no documentation of HPSs or their inspections. Whether
(HPS)
HPSs exist in the system should be specified in the 0&M plan. If HPSs
do exist, then they should be inspected and the inspections
documented as required by the regulation.
6.
Annual General
There is no documentation of the AGOs being done.
Observation AGO
7.
Sanitary Sewer
No SSOs have been reported or recorded.
Overflow (SSO)
Reporting
8.
Grease Control
You stated your property management company distributes grease
Program
control material to park residents quarterly and provided a copy of
material distributed in 4/22. However, no copies of materials
distributed previous to that were provided. According to regulations,
you must maintain all required materials on file for three years.
Because you did not provide copies of previous materials, it was not
demonstrated that materials are distributed at least semi-annually,
as required by regulation.
DffNorth Carolina Department of Environmental Quality I Division of Water Resources
oan caaouNn
Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105
M336.776.9800
oep.m.m or em�nmen� Qualm,

Requirement
Findings
9. Right -of -Ways (ROW)
There is no documentation of ROWs or their inspections. Whether
ROWS exist in the system should be specified in the 0&M plan. If
ROWS do exist, then they should be inspected and maintained, and
all activities documented, as required by the regulation.
10. Documentation
Documentation is insufficient and does NOT comply with regulatory
requirements.
These non-compliance issues have resulted in this Notice of Deficiency, which Sunrise and Sons
should respond to and follow up on promptly in order to properly and timely address all identified
violations and avoid any further action.
Sunrise and Sons must remedy each identified violation fully and properly within 60 days of
receiving this correspondence. Failure to do so may result in this office proceeding with further
actions. You are reminded that, in accordance with NC General Statute 143-215.6A., Enforcement
Procedures: Civil Penalties, a civil penalty of not more than twenty-five thousand dollars ($25,000)
per violation, per day, may be assessed for such violations.
Thank you for your prompt attention to this matter. If you have any questions or require assistance,
please do not hesitate to contact Mr. Boone, or me, by phone at 336.776.9690, or 336.776.9700,
respectively. You may also contact us by email at [e-mail] or lon.sniderOncdenr.gov,
respectively.
Sincerely,
EDocuSigned by:
�-T.sMat-
-"49E225C94EA...
Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
Attachments:
1. Water Compliance Report
2. 15A NCAC 02T .0400 Deemed Permitted Collection System Rules
cc: 1. Laserfiche
REQ� North Carolina Department ofEnvironmental Quality I Division ofWater Resources
Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Raleigh, North Carolina 27105
NORTH CAROLINA 336.776.9800
onparhnem of EmironmanW 9uallly

Permit: WQCSD0215
SOC:
County: Guilford
Region: Winston-Salem
Compliance Inspection Report
Effective: 03/01/00 Expiration: Owner: Sunrise & Sons, LLC
Effective: Expiration: Facility: Sunrise Park MHP Collection System
Contact Person: Stephen R Davis Title:
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 03/24/2022 Entry Time 10:30AM
Primary Inspector: Ron Boone
Secondary Inspector(s):
Certification:
Phone: [phone]
Phone:
Exit Time: 11:30AM
Phone: [phone]
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: WQCSD0215 Owner -Facility: Sunrise & Sons, LLC
Inspection Date: 03/24/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Inspection Summary:
Mr. Ron Boone, of the NC Division of Water Resources (DWR), Winston-Salem Regional Office (WSRO) performed a
scheduled inspection of the above mentioned deemed permitted wastewater collection system (WWCS) on March 24, 2022.
Your assistance and cooperation during the inspection was greatly appreciated. The findings of the inspection are listed
below:
1. Operation & Maintenance (O&M): No spills have been reported, however, several items were not documented as required
by regulation, as detailed below.
2. WWCS Map: None available during the inspection.
3. O&M and Spill Plan: There is no written O&M or spill plan.
4. Pump Station (PS) Inspection Frequency: Not applicable, there are no PSs in the WWCS. This should be specified in the
O&M plan.
5. High Priority Sewers (HPS): There is no documentation of HPSs or their inspections. Whether HPSs exist in the system
should be specified in the O&M plan. If HPSs do exist, then they should be inspected and the inspections documented as
required by the regulation.
6. Annual General Observation (AGO): There is no documentation of the AGOs being done.
7. Sanitary Sewer Overflow (SSO) Reporting: No SSOs have been reported or recorded.
8. Grease Control Program: You stated your property management company distributes grease control material to park
residents quarterly and provided a copy of material distributed in 4/22. However, no copies of materials distributed previous
to that were provided. According to regulations, you must maintain all required materials on file for three years. Because you
did not provide copies of previous materials, it was not demonstrated that materials are distributed at least semi-annually, as
required by regulation.
9. Right -of -Ways (ROW): There is no documentation of ROWs or their inspections. Whether ROWs exist in the system
should be specified in the O&M plan. If ROWs do exist, then they should be inspected and the inspections documented as
required by the regulation.
10. Documentation: Documentation is insufficient and does NOT comply with regulatory requirements.
These non-compliance issues have resulted in this Notice of Deficiency, which Sunrise and Sons should respond to and
follow up on promptly in order to properly and timely address all identified violations and avoid any further action.
Sunrise and Sons must remedy each identified violation fully and properly within 60 days of receiving this correspondence.
Failure to do so may result in this office proceeding with further actions. You are reminded that, in accordance with NC
General Statute 143-215.6A., Enforcement Procedures: Civil Penalties, a civil penalty of not more than twenty-five thousand
dollars ($25,000) per violation, per day, may be assessed for such violations.
Thank you for your prompt attention to this matter. If you have any questions or require assistance, please do not hesitate to
contact Mr. Boone, or me, by phone at 336.776.9690, or 336.776.9700, respectively. You may also contact us by email at
[e-mail] or [e-mail], respectively.
Page 2 of 6

Permit: WQCSD0215 Owner -Facility: Sunrise & Sons, LLC
Inspection Date: 03/24/2022 Inspection Type : Collection System Inspect Non Sampling
Reason for Visit: Routine
General
Yes No NA NE
# 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: No map available
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? ❑ ❑ ❑ ❑
Comment: Owner provided one copy of material distributed in April, 2022, only. No previous materials
were Drovided so it is unknown if it's been done at least bi-annually in the Dast.
Spills and Response Action Plan
Yes No NA NE
# Is system free of known points of bypass?
0
❑ ❑ ❑
If No, describe type of bypass and location
# Have there been any sewer spills in the past 3 years?
❑
0 ❑ ❑
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?
❑
❑ ❑
Page 3 of 6

Permit: WQCSD0215 Owner -Facility: Sunrise & Sons, LLC
Inspection Date: 03/24/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Is a Spill Response Action Plan available for all personnel?
❑
0 ❑ ❑
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: There is no written O&M or spill plan. No spills
have been reported. No spills or sewer issues
have been recorded.
Inspections Yes No NA NE
Are adequate maintenance records maintained? ❑ 0 ❑ ❑
Are pump stations being inspected at the required frequency? ❑ ❑ 0 ❑
Is at least one complete functionality test conducted weekly per pump station? ❑ ❑ 0 ❑
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: There are no records of maintenance/ inspection requirements. If no HPLs exist in the system,
then the only other requirement is the annual general observation (AGO). There were no
records of the AGO. There are no pump stations in the system.
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? ❑ ❑ 0 ❑
If No, give details on temporary access:
Is maintenance documented? ❑ ❑ ❑
Were all areas/lines inspected free of issues? ❑ ❑ 0 ❑
Comment: None
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? ❑ ❑ ❑
Page 4 of 6

Permit: WQCSD0215 Owner -Facility: Sunrise & Sons, LLC
Inspection Date: 03/24/2022 Inspection Type : Collection System Inspect Non Sampling
Reason for Visit: Routine
Are manholes free of sinkholes and depressions?
❑
❑ 0 ❑
Are manhole covers present?
❑
❑ 0 ❑
# Are manholes properly seated?
❑
❑ 0 ❑
# Are manholes in good condition?
❑
❑ 0 ❑
# Are inverts in good condition?
❑
❑ 0 ❑
Is flow unrestricted in manholes?
❑
❑ 0 ❑
Are manholes free of excessive amounts of grease?
❑
❑ 0 ❑
Are manholes free of excessive roots?
❑
❑ 0 ❑
Are manholes free of excessive sand?
❑
❑ 0 ❑
Are manhole vents screened?
❑
❑ 0 ❑
Are vents free of submergence?
❑
❑ 0 ❑
Are manholes free of bypass structures or pipes?
❑
❑ 0 ❑
Comment: There are no manholes in the system
Pump Stations
Yes No NA NE
Please list the Pump Stations Inspected:
# 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?
❑
❑ 0 ❑
Pump station identifier?
❑
❑ ❑
# Address?
❑
❑ ❑
Instructions for notification?
❑
❑ ❑
24-hour emergency contact numbers?
❑
❑ ❑
Are audio and visual alarms present?
❑
❑ ❑
Page 5 of 6

Permit: WQCSD0215 Owner -Facility: Sunrise & Sons, LLC
Inspection Date: 03/24/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
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?
Inspecting and lubricating pumps and other equipment?
Inspecting alarms, telemetry and auxiliary equipment?
Comment: There are no pump stations in the system.
❑❑■❑
❑❑■❑
Page 6 of 6