NC0089052_Inadequate Wastewater 2011_20110629

DIEHL & PHILLIPS, P.A.
CONSULTING ENGINEERS
219 East Chatham Street
Cary, North Carolina 27511
Telephone [phone] — Fax [phone]
March 4, 2011
WILLIAM C. DIEHL, P.E.
JOHN F. PHILLIPS, P.E.
COPY OF LETTER SENT CERTIFIED MAIL TO MS. RICE
ALAN R. KEITH, P.E.
Emma P. Williams Heirs, and Others
C/o Ms. Leta W. Rice
MAR 3 0 2011
6101 Zoo Parkway �
Asheboro, NC 27205
Re: 58.61 Acre Parcel located on Pisgah Covered Bridge Road
Parcel Identification Number 7647635561
Dear Ms. Rice:
Diehl & Phillips, P.A. is a civil engineering firm that is working for the Owner of Zooland
Campground (formerly known as Banjo Creek Campground), located at 3671 Pisgah
Covered Bridge Road. The Campground has an out of date and inadequate wastewater
treatment system, and we have been hired to help determine the best solution to their
wastewater problems. We have asked the NC Division of Water Quality for permission
to install a new wastewater treatment system on the Campground property, and to
discharge the treated water into the Little River. The Division of Water Quality will issue
permits to discharge treated wastewater into streams and rivers, but only if all the
other possible options are examined and determined to be impractical or too expensive.
One of the alternatives that we are required to examine is to have a treatment system
that would first treat the wastewater, and then dispose of the treated wastewater
through underground pipes. This is the same type of system as a residential septic
system, except that the wastewater would be more thoroughly treated before it was
discharged below ground.
There is not enough usable land on the Campground property to install a septic system.
In this case, the Division of Water Quality has asked that we contact the adjacent
property owners to determine if there is sufficient land available to construct a septic
system.
I am contacting you in this matter because the Randolph County property records list
you as the representative of the Owners of Parcel Number 7647635561, which is
immediately south of the land owned by Zooland Campground. We are required to
determine if you would be willing to sell a portion of your property for use as the septic
system for the Campground, if soil tests indicate your property would be suitable for
Page 1 of 3

wastewater disposal. We do not know at this time the exact amount of land that would
be required, as the area would depend upon the results of the soils testing that would
have to be performed. If the soils are similar to those on the Campground property, we
estimate the amount of land required would be between 19 and 20 acres.
At this point in time I am requesting you, or a person that can legally act for the owners
of this parcel, to provide responses to the attached three questions. We would like to
know if you have any interest in subdividing and selling a portion of your property for
use by the Campground and, if so, if you would you be willing to let others enter your
land for the purpose of evaluating whether or not the soils would be suitable for use as
septic disposal fields. Please understand that we are asking these questions to gather
information so that we may respond to the NC Division of Water Quality as to whether
it would be feasible to install a septic system on property adjacent to the Campground.
This letter is flptan offer to purchase land, but only an inquiry to determine if you have
any interest in selling some or all of the subject property. If you do have an interest in
considering the sale of some or all of your property, and if you are willing to allow
professionals to enter your property to test the soils, then Owner of the Campground
may elect to have this testing done.
Thank you for your help with this matter. Due to the time constraints of the wastewater
permitting process, I must ask that you complete one copy of the enclosed
questionnaire and return it in the envelope provided by Friday, March 25, 2011 (the
second copy of the questionnaire is for your records). If I have not received a response
by that date, I will assume you have no interest in the possible sale of some or all of
your property for use by the Campground as a septic disposal area.
If you have any questions in this matter, please contact me at 919 -467 -9972, extension
24. Thank you for your assistance in this matter.
Yours very truly,
Diehl & Phillips, P.A.
ORIGINAL SIGNED AND
MAILED 3/7/2011
John F. Phillips, P.E.
Page 2 of 3

Questionnaire for the Owners) of Randolph County Rropgrty
with PIN 7647635561
Printed name of person completing this questionnaire:
Signature of person completing this questionnaire:
Date:
1. Would you consider selling a portion of the 58.61 -acre parcel (Parcel
Identification Number 7647635561) for use as the septic disposal area
for Zooland Campground, located at 3671 Pisgah Covered Bridge Road?
At this time, the amount of land required is estimated to be
approximately 19.2 acres, as generally shown on the attached map.
(please put an X in the space in front of your response)
Yes, I would consider selling approximately 19.2 acres of the tract with
Parcel Identification Number 7647635561 for use as a septic system disposal area
for Zooland Campground.
No, I have no interest in selling approximately 19.2 acres of the tract with
Parcel Identification Number 7647635561 for use as a septic system disposal area
for Zooland Campground.
2. If you are not willing to consider subdividing and selling a portion of the
property, are you willing to sell the entire 58.61 acres?
Yes, I would consider selling all 58.61 acres of the tract with Parcel
Identification Number 7647635561 for use as a septic system disposal area for
Zooland Campground.
No, I have no interest in selling all 58.61 acres of the tract with Parcel
Identification Number 7647635561 for use as a septic system disposal area for
Zooland Campground.
3. Would you grant permission for Soil Scientists, Engineers, and Surveyors
to enter your property to evaluate the soils and to determine if your land
is suitable for a wastewater disposal area for the Campground? (All work
would be non - destructive — no trees would be cut down and no heavy
equipment would be brought onto the property).
Yes, I would grant permission.
No, I would not grant permission
Page 3of3

N/F
DIVERSIFIED LENDING
GROUP, INC. (ZOOLAND
CAMPGROUND) -
73.00 ACRES
DEAN Tom` "'T'T"'
509.92 ACRES
THE FARM AT LITTLE
RIVER, LLC
SR 1114 - PISGAH COVERED
BRIDGE ROAD -
60' PUBLIC R/ W
-- 96.31 ACRES
EMMA P. WILLIAMS HEIRS
FIGURE No. 4
ALTERNATIVE No. 4
CENTRAL TREATMENT SYSTEM
& SUBSURFACE DRIP IRRIGATION DISPOSAL

Zooland Family Campground EAA Review
Zooland Family Campground (formerly Banjo Creek RV Park) is a 32 acre RV campground with 195
camper spaces. It is in receivership due to nonpayment of loans. There is an unpermitted septic system
on the site, details are unknown. On September 13, 2010, the Winston -Salem Regional office discovered
black septic water flowing in a ditch to the Little River. A NOV was issued and the campground ceased
operation.
The receiver plans to obtain an NPDES permit for a wastewater treatment system, then hopes to sell the
facility to a buyer who would build and operate a WWTP and the campground facility. Towards this
goal, they have hired a consultant who developed a design for wastewater treatment and an
Engineering Alternatives Analysis. The receiver has submitted an application for an NPDES discharge
permit and the EAA.
The proposed WWTP (17,000 GPD) is a biological WWTP manufactured by Aquapoint. It consists of:
• Primary Settling Tank (17,000 gallon septic tank)
• 6,000 gallon Flow Equalization Tank with duplex pumps and aerator
• Aerated Moving Bed Biofilm Reactor with two blowers
Two parallel Bioclere fixed film systems with clarifiers, recirculation pumps and sludge return
pump
• 2,000 gallon filter feed tank
• Two tertiary pressure filters
• Alkalinity feed system
• Tablet chlorinator with 600 gallon contact tank
• (They will also need dechlorination)
• Prefab building for blowers, filters and the chemical feed system
Alternatives Evaluated:
1. Connection to a POTW
• Two pump stations due to high head requirements
22,400 feet of forcemain
• Standby power for each pump station
• Liquid chemical feed system for odor control
Net Present Value: $2,018,976
2. Connection to a Privately Owned Treatment Plant
Not evaluated, as there are no privately owned treatment plants in the area with the required capacity.

3. Individual Sub - Surface Treatment Systems
Not evaluated because of soil conditions, and the close proximity of campsites together.
4. Wastewater Treatment System, with effluent disposal through a subsurface drip irrigation system
• Purchase additional land (7.3 acres)
• Install WWTP
• Install 126, 866 linear feet of drip tubing
Net Present Value: $1,643,506
5. Wastewater Treatment System with effluent disposal through a spray irrigation system
• Purchase additional land (26.2 acres)
• Construct 2.3 MG storage lagoon
• Install WWTP
• Construct spray system
Net Present Value: $1,737,780
6. Wastewater Treatment System with effluent disposal through a surface discharge to the Little river
• No additional land required
• Install WWTP
• Install gravity discharge line to the Little river
Net Present Value: $1,423,096
7. Wastewater Treatment to reuse standards with effluent disposal through spray irrigation system
• Purchase additional land (13.94 acres)
• Install WWTP
• 1 lined lagoon (130 days storage)
• 1 lined lagoon (5 days storage)
• Install spray field
Net Present Value: $2,142,395

7 151%
Problem
Our 02H rules (T15A: 02H.0105(c)(7) requires: "a statement to demonstrate financial qualification and
substantial previous compliance with federal and state laws, regulations, and rules for the protection of
the environment as required by G.S. 143- 215.1(b)(4)(b)." The facility is in receivership under federal
court supervision. The receiver has no intention of building a wastewater treatment facility, but is
interested in selling the campground to a buyer who would build and operate it. Would a Special
Condition requiring the buyer to provide documentation to comply with this requirement be
appropriate?
SUMMARY:
Alternative
% of Alternative's PW to Alternative No. 6
1
142%
2
N/A
3
N/A
4
115%
5
122%
6
100%
7 151%
Problem
Our 02H rules (T15A: 02H.0105(c)(7) requires: "a statement to demonstrate financial qualification and
substantial previous compliance with federal and state laws, regulations, and rules for the protection of
the environment as required by G.S. 143- 215.1(b)(4)(b)." The facility is in receivership under federal
court supervision. The receiver has no intention of building a wastewater treatment facility, but is
interested in selling the campground to a buyer who would build and operate it. Would a Special
Condition requiring the buyer to provide documentation to comply with this requirement be
appropriate?

Assessment Unit Number
Description
Classification 8 -Digit HUC
Name
Miles/Acres
Overall
Category
Use
Support
Category
Use
Support Reason for
Rating Rating
Parameter of
Interest
DWQ Subbasin 03 -07 -15
Collection Listing IR
Year Year Category
13- 25-(1) Little River
From source to Suggs Creek
C 03040104
23.9 FW Miles
2
Aquatic Life Supporting No Criteria Exceeded
Ecological/biologicalIntegrity 2006
FishCom
1
13- 25411.5) Little River
From Suggs Creek to Densons Creek
C;HQW 03040104
12.9 FW Miles
2
Aquatic Life Supporting No Criteria Exceeded
Water Quality Standards
Aquatic Life
2006
1
Aquatic Life Supporting No Criteria Exceeded
Ecological/biological Integrity 2006
Benthos
1
Recreation Supporting No Criteria Exceeded
Fecal Colifonn (recreation) 2006
1
13- 25 -(19) Little River
From Densons Creek to Hammer Creek
C 03040104 18.5 FW Miles
2
Aquatic Life Supporting No Criteria Exceeded
Ecological/biological Integrity 2006
Benthos
1
13 -25- (37.5) Little River
From Hamer Creek to Pee Dee River
WS -IV 03040104
3.7 FW Miles
2
Aquatic Life Supporting No Criteria Exceeded
Water Quality Standards 2006
Aquatic Life
1
Recreation Supporting No Criteria Exceeded
Fecal Coliform (recreation) 2006 1
13 -25 -15 West Fork Little River
From source to Little River
C 03040104
23.7 FW Miles
2
Aquatic Life Supporting No Criteria Exceeded
Ecological/biologicalIritegrity 2006
FishCom
1
Aquatic Life Supporting No Criteria Exceeded
Ecological/biological Integrity 2006
Benthos
1
13 -25- 20-(9) Densons Creek
From dam at Troy Reservoir to Little River
C 03040104
2.8 FW Miles
2
Aquatic Life Supporting No Criteria Exceeded
Ecological/biological Integrity 2004
FishCom
1
13- 25 -20 -8 Dumas Creek
From source to Densons Creek
C;HQW
13 -25-24
03040104
9.4 FW Miles
2
Aquatic Life Supporting No Criteria Exceeded
Ecological/biological Integrity 2001
FishCom
1
Bridgers Creek
From source to Little River
C;HQW 03040104
9.2 FW Miles
2
Aquatic Lift Supporting No Criteria Exceeded
Ecological/biological Integrity 2006
FishCom
1
"Draft 2008 Integrated Report All Assessed Waters Yadkin River Basin"
Page 42 of 46

IWC Calculations
Facility: Zooland Family Campground WWTP
NCO089052
Prepared By: Jim McKay
Enter Design Flow (MGD): 0.017
Enter s7Q10 (cfs): 0.03
Enter w7Q10 (cfs): 0.03
Total Residual Chlorine (TRC)
Daily Maximum Limit (ug /1)
Ammonia (Summer)
Monthly Average Limit (mg NH3 -N /1)
s7Q10 (CFS)
0.03
s7Q10 (CFS)
0.03
DESIGN FLOW (MGD)
0.017
DESIGN FLOW (MGD)
0.017
DESIGN FLOW (CFS)
0.02635
DESIGN FLOW (CFS)
0.02635
STREAM STD (UG /L)
17.0
STREAM STD (MG /L)
1.0
Upstream Bkgd (ug /1)
0
Upstream Bkgd (mg /1)
0.22
IWC ( %)
46.76
IWC ( %)
46.76
Allowable Conc. (ug /1)
36
Allowable Conc. (mg /1)
1.9
Ammonia (Winter)
Monthly Average Limit (mg NH3 -N /1)
Fecal Coliform
w7Q10 (CFS)
0.03
Monthly Average Limit:
200 /100m1 DESIGN FLOW (MGD)
0.017
(If DF >331; Monitor)
DESIGN FLOW (CFS)
0.02635
(If DF <331; Limit)
STREAM STD (MG /L)
1.8
Dilution Factor (DF)
2.14 Upstream Bkgd (mg /1)
0.22
IWC ( %)
46.76
Allowable Conc. (mg /1)
3.6
Total Residual Chlorine
1. Cap Daily Max limit at 28 ug /l to protect for acute toxicity
Ammonia (as NH3 -N)
1. If Allowable Conc > 35 mg /I, Monitor Only
2. Monthly Avg limit x 3 = Weekly Avg limit (Municipals); capped at 35 mg /I
3. Monthly Avg limit x 5 = Daily Max limit (Non- Munis); capped at 35 mg /I
4. BAT for Minor Domestics: 2 mg /I (summer) and 4 mg /I (winter)
5. BAT for Major Municipals: 1 mg /I (year- round)
Fecal Coliform
1. Monthly Avg limit x 2 = 400/100 ml = Weekly Avg limit (Municipals) = Daily Max limit (Non -Muni)
NPDES Server /Current Versions/WLA; TB 1/16/2009

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality Dee Freeman
Beverly Eaves Perdue Coleen H. Sullins Secretary
Governor Director
January 25, 2011
Mr. David A. Gill
Receiver
2029 Century Park East, Third Floor
Los Angeles, CA 90067
Subject: Zooland Family Campground
Engineering Alternatives Analysis
Randolph County
Dear Mr. Gill: permit
You recently submitted an Engineering Alternatives Analysis in the EAA Gu�danc DDocument the goal of the
r
Zooland Family Campground in Randolph County, NC. As stated
NPDES permitting program is to eliminate all point source discharges all actical alternates ase water. to di n support of this goal, we
require all new or expanding facilities to thoroughly evaluate P
submitted for Zooland Family Campground, two alternatives were close in cost. We request
When we reviewe
d the EAA
that you further evaluate alternate 4 (Wastewater Treatment System, h Effluent Disposal through a Discharge to the Little
Y
Irrigation Lines) and alternate 6 (Wastewater Treatment System,
River.) Alternate 6, discharge to surface waters, would require treatment oo light. strin disinfection t levels with / L BnOeDis used,
Ri )
mg/ L ammonia nitrogen, with disinfection with either chlorine h g
hen the treated effluent must also be dechlorinated prior to discharnot rAlternate uire disinfection/ dechlorinat on prior to
then
not require such extensive wastewater treatment, and would q
disposal.
If alternate 4 is found to be feasible, and sufficient land nearby ifurthe aexaminat on of alternate 4 shows that t
Water Quality would prefer this route over a direct discharge alternate. if
is not feasible, then report back to me and a permit will be developed.
Please contact me if there are any questions or comments. I can be reached at (919) 807 -6404.
Sincerely,
Jim McKay
Complex NPDES Permitting
CC: Diehl & Phillips, P.A./ 219 E. Chatham St. /Cary, NC 27511/ Attn: Mr. John F. Phillips, P.E.
Mike Mickey, WSRO - via email
Central Files
1617 Mail Service Center, Raleigh, North Carolina 276991617 One
North
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 Carolina
Phone: [phone] \ FAX: 919 - 807 -6495 \ Customer Service: 1. 877 -623 -6748
Internet: www.rimaterquality.org K "
An Equal Opportunity \ Affirmative Action Employer

cc: Central Files
WSRO
NPDES STAFF REPORT AND RECOMMENDATION
To: Attention: Jim McKay
Point Source Branch - SWP
Application No. NCO089052
Date: January 5, 2011
County: Randolph
PART I - GENERAL INFORMATION
1. Permittee: Diversified Lending Group, Inc., A Corporation in Receivership
c/o Mr. David A. Gill, Receiver
2029 Century Park East, Third Floor
Los Angeles, CA 90067 -2904
Facili : Zooland Family Campground
3671 Pisgah Covered Bridge Road
Asheboro, NC 27205
2. Report Prepared by: Mike Mickey, Environmental Specialist/WSRO
3. Contact Person: John Phillips, PE, Diehl & Phillips, P.A., (919) 467 -9972
4. Directions to Site: Take Hwy 220 South out of Asheboro. Exit at Hwy 134 and take
Dawson Miller Road to the right. Proceed to Pisgah Covered Bridge Road and turn left.
Zooland Campground is on the left after crossing the bridge over the Little River.
5. Discharge Point: Latitude: 350 36' 05" Longitude: 790 50' 58"
U.S.G.S. Quad Name: Seagrove, NC
6. Site size and expansion area consistent with application? The Zooland Family Campground
property consists of 32.21 acres (Parcel ID # 7647751280).
7. Topog_raphy: The campground property has relatively flat topography. The site is bordered
by Pisgah Covered Bridge Road and the Little River.
8. Location of nearest dwelling: The closest dwelling not located on the Zooland site just is
across Pisgah Covered Bridge Road at the SW corner of the property.
�'
D
NPDES Permit Staff Report
LK JAN 12 2011
Version 10/92
Page 1 NT SO;:;-%;E 2RANJC14

9. Receiving stream or affected surface waters: The existing unpermitted discharge currently
goes into an unnamed tributary of the Little River. The proposed new system would
discharge directly into the Little River. The proposed discharge point would have a drainage
area of 14.74 square miles. The USGS low -flow estimate for the proposed outfall location
was as follows: 7Q10 = 0.03 cfs; 30Q2 = 1.0 cfs.
a. Classification: C
b. River Basin and Subbasin No.: 03 -07 -15
C. Describe receiving stream features and pertinent downstream uses: The Little River
flows through rural Randolph County and a portion of the Uwharrie National Forest
before reaching the Montgomery County line.
Part II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
a. Volume of Wastewater to be permitted: The wastewater flow calculation for the
existing Zooland Family Campground is computed as follows:
92 full service spaces (w /water and sewer hookups) @ 100 gpd/space = 9,200 gpd
103 camp spaces (without water and sewer hookup) @ 75 gpd /space = 7,725 gpd
3 employees at 25 gpd/employee = 75 gpd
Total projected wastewater flow = 17,000 gpd
Note: All of the full service spaces along with two dump stations and the
laundry/bathhouse are connected to the illegally discharging system. Additionally,
there are two subsurface ground absorption systems on site permitted through the
Randolph County Health Department that are believed to serve the store, arcade and
another bathhouse.
b. What is the permitted capacity of the existing system? The capacity of the illegally
installed system is unknown.
C. Actual treatment capacity of the current facility? Unknown.
d. Date(s) of AtC's issued in the previous twos. NA.
Description of existing unpermitted WWTP: The only known unit of the
unpermitted system is a septic tank. What is located in between the septic tank and
the black septic wastewater observed in a ditch leading to the Little River on 9/8/10 is
unknown. Back on 12/14/73 this facility was issued a permit for a package treatment
type system which was never installed. The 1973 permit was never renewed.
Evidently, the previous owner installed some type of system without the knowledge
of the county or the state.
NPDES Permit Staff Report
Version 10/92
Page 2

f. Please provide a description of proposed wastewater treatment facilities: The
proposed 0.017 MGD treatment system would consist of the following:
• 17,000 gallon septic tank for primary settling
• 6,000 gallon flow equalization tank
• 5,000 gallon Moving Bed Biofilm Reactor (MBBR) tank with duplex blowers
• flow divider box
• two Model 30/32 Bioclere fixed film systems in parallel with integral 2,300
gallon clarifiers, recirculation pumps and sludge return pumps
• 2,000 gallon tertiary filter feed tank
• two 30" diameter tertiary pressure filters
• alkalinity feed system
• Tablet chlorinator with 600 gallon contact tank (no dechor unit was specified)
g. Possible toxic impacts to surface waters: None known.
2. Residuals handling and utilization/disposal scheme: The schematic diagram in Figure No. 2
of Alternative No. 6 in the EAA indicates that solids from the two Bio -Clere units (clarifiers)
and the two pressure filter units will be returned to the 17,000 gallon septic tank for annual
removal by a licensed pumper.
PART III - OTHER PERTINENT INFORMATION
1. Is this facility being constructed with Construction Grant Funds (municipals only)? NA.
2. Special monitoring or limitations (including toxicity) requests: NA.
3. Important SOC, JOC or Compliance Schedule dates: NA.
4. Alternative Analysis Evaluation: The Engineering Alternatives Analysis prepared by Diehl
& Phillips concluded that a NPDES discharging system is the most environmentally sound
alternative as selected from the reasonably cost effective options.
PART IV - EVALUATION AND RECOMMENDATIONS
The Zooland Family Campground was sent a Notice of Violation by DWQ on 9/13/10 for an
unpermitted discharge into an unnamed tributary of the Little River. The site inspection found black
septic wastewater in the tributary downslope from a system that receives waste from 92 full service
RV spaces, two dump stations and a bathhouse /laundry. The only known treatment component is a
septic tank believed to be installed around 1974. The exact location of the discharge pipe could not
be found.
Whether the subsurface treatment unit is a sandfilter or a ground absorption system modified
NPDES Permit Staff Report
Version 10/92
Page 3

to discharge is unknown. It is known that no permit has been issued by DWQ or the Randolph
County Health Department for this waste disposal method.
It should be noted that the Zooland Family Campground property is subject to the jurisdiction
of the federal court and is currently held by a Receiver due to foreclosure on a promissory note. The
Receiver hopes to obtain the NPDES permit and then sell the property to a purchaser who would
construct the W WTP.
The applicant has proposed installing a 0.017 MGD AquaPoint Aerated Moving Bed Biofilm
Reactor (MBBR) type unit. This office is unfamiliar with the MBBR treatment system as none exist
in our region.
WSRO recommends processing of this application per current Division policy for existing
unpermitted dischargers.
Report Preparer & Date
SWP Region Supervis &Date
The following documents are attached to this staff report:
1) USGS topo map indicating proposed discharge location.
2) Map of the campground obtained from http: / /www.zoolandfc.com/
3) Notice of Violation letter issued 9/13/10.
4) Response letter dated 9/23/10 from David A. Gill, Receiver.
5) Permit issued 12/14/73 by the NC Office of Water and Air Resources (system never installed).
6) AquaPoint brochure explaining the Moving Bed Biological Reactor (MBBR) process.
NPDES Permit Staff Report
Version 10/92
Page 4

DAVID A. GILL
A PROFESSIONAL CORPORATION
PARTNER
E -MAIL ADDRESS:
[e-mail]
LAW OFFICES
DANNING, GILL, DIAMOND & KOLLfTZ, LLP
A LIMITED LIABILITY PARTNERSHIP COMPOSED OF PROFESSIONAL CORPORATIONS REFER TO:
2029 CENTURY PARK EAST, THIRD FLOOR 25175
LOS ANGELES, CALIFORNIA 90067 -2904
TELEPHONE: (31 O) 277 -0077
FACSIMILE: (310) 277 -5735
September 23, 2010
VIA FACSIMILE (336- 771 -4630) & U.S. MAIL
Mr. Steve W. Tedder
Water Quality Regional Supervisor
North Carolina Department of Environment and Natural Resources
Winston -Salem Regional Office
585 Waughtown Street
Winston - Salem, North Carolina 27107
Re: Securities and Exchange Commission v. Diversified Lending Group, Inc.,
Applied Equities, Inc., and Bruce Friedman, et al.
U.S.D.C. Case No.: 2:09 -CV- 01533 -R -SS
Zooland Family Campground, Randolph County
Notice of Violation & Recommendation for Enforcement
Dear Mr. Tedder:
RECEIVED
N.C. Deot. of ENR
SEP 2 7 2010
V�insicraar.
Re�lonal G ...
This confirms the receipt of your Notice of Violation dated September 13, 2010. While I did respond
to Mike Mickey by e -mail, I feel I should probably send you something of a more formal nature.
I am the Receiver in the above - referenced matter, pending in the United States District Court for the
Central District of California, Western Division (Los Angeles). I have recorded proof of my authority
in Randolph County in March of 2009. Further information about the receivership can be found at my
website, www.diversifiedreceivership.com or I will be happy to provide documentation reasonably
requested.
The Receivership acquired the subject property through foreclosing on a promissory note which was
an asset of the Receivership, and has operated the property in that capacity through Mr. Larry Perry.
Mr. Charles Salas has also assisted me as has the listing broker, Mr. Clark Simpson of CBRE. My
local counsel is Peter Carlino, Esq., of MacNeill & Carlino, PLLC, in Charlotte.
Although the property is subject to the jurisdiction of the federal court, you will have my full
cooperation, to the extent that it is within my capabilities as Receiver. The estate is not in good shape
financially, but I can afford to and am in the process of retaining Diehl & Phillips, P.A., as my
consultant in this matter. They will be in touch with you as soon as possible.
359492.01 [XP] 25176

DANNING, GILL, DIAMOND & KOLLfrz, LLP
Mr. Steve W. Tedder
September 23, 2010
Page 2
For the record, I do wish to make clear, although I am sure that you understand, that I do not operate in
my personal capacity, but in my official capacity as receiver, and any liability which might exist,
would be a claim against the receivership estate and not me personally.
Hopefully, matters will not come to this point, and we will be able to do that necessary to resolve the
problem and to facilitate my marketing of this property to a responsible operator, as is my duty
pursuant to the court's directions.
Please do not hesitate to call me and be assured of my desire to resolve this issue promptly.
Respectfully,
David A. Gill
Receiver
DAG:pwm
cc: John F. Phillips, PE.
Mr. Charles Salas
Mr. Larry Perry
Mr. Clark J. Simpson
Peter N. Carlino, Esq.
359492.01 [XP] 25176

kPIA
NCDENR
North Carolina Department of Environment and
Division of Water Quality
Beverly Eaves Perdue
Governor
Coleen H. Sullins
Director
September 13, 2010
CERTIFIED MAIL # 7008 0150 0002 7876 8447
RETURN RECEIPT REQUESTED
Mr. David A. Gill, Receiver
Diversified Lending Group, Inc.
4711 Viewridge Avenue, Suite 270
San Diego, CA 92123
Natural Resources
SUBJECT: Notice of Violation & Recommendation for Enforcement
Unpermitted Wastewater Discharge
Zooland Family Campground
Randolph County
Dear Mr. Gill:
Dee Freeman
Secretary
The Division of Water Quality recently discovered that the Zooland Family Campground is
operating a wastewater disposal system without a valid permit. Specifically, an unpermitted system is
receiving wastewater from approximately 88 RV spaces, a dump station and bath house /laundry facility.
The system then discharges into an unnamed tributary to the Little River, Class "C" waters in the Yadkin -
Pee Dee River Basin. Observations of the tributary on September 8, 2010 revealed pools of black water
and a strong septic odor.
Please be advised that operating a disposal system without a valid permit is a violation of North
Carolina General Statute 143 - 215.1.(2). The illegal discharge must be ceased immediately. This situation
requires that you obtain the services of a consultant to assist you with evaluating the possible permitting
options. An option would be to apply to this Division for a NPDES permit for the existing discharge.
This would require the submittal of the following: a NPDES permit application (NC Form D), an
Engineering Alternatives Analysis, a Local Government Concurrence form, along with a $860 non-
refundable processing fee. These forms can be obtained at the following link:
http://I)ortal.ncdenr.org/web/wq/swp/-os/npdes/apl)fonns
Submittal of the above application package does not guarantee that you will be granted a permit.
Review of a NPDES application typically takes from six to eighteen months. If a permit is issued, the
existing system must be upgraded, a certified wastewater operator must be retained, and monthly
monitoring reports would have to be submitted to the state containing sample results from a certified
laboratory for compliance determination.
North Carolina Division of Water Quality, Winston -Salem Regional Office
Location: 585 Waughtown St. Winston - Salem, North Carolina 27107
Phone: [phone] FAX: 336 - 77146301 Customer Service: 1-877-623-6748
Internet: www.ncwaterquality.org
An Equal Opportunity 1 Affirmative Action Employer
NorthCarolina
Natmallry

'Zooland Family Campground.
Page #2
September 13, 2010
The Division of Water Quality requests that you respond in writing to this office within twenty
(20) days of receipt of this Notice. The response should outline your proposed plans to obtain a permit
for the wastewater treatment system serving the Zooland Family Campground.
Please be advised that this violation, and any future violations, could subject Zooland to a civil
penalty assessment of up to $25,000 per day, per each violation. Our Office is considering a
recommendation for enforcement action to the Director of the Division of Water Quality regarding this
issue. Your response to this correspondence, along with completion corrective actions, will be considered
in this process.
Your cooperation in this matter would be appreciated. Should you have questions, please contact
Mike Mickey or me at (336) 771 -5000.
Sincr ly,
Steve W. Tedder
Water Quality Regional Supervisor
cc: Wayne Jones (Environmental Health Sup., Randolph Co. Health Dept., 2222 -B South Fayetteville St., Asheboro, NC 27205)
Charles Sales (Underwriter's Funding Group, LLC, 4711 Viewridge Avenue, Suite 270. San Diego, CA 92123)
Larry Perry (Zooland Family Campground, 3671 Pisgah Covered Bridge Road, Asheboro, NC 27205)
Alec Chaplin (Chaplin Company, LLC, P.O.Box 12187, Columbia, SC 29211)
WSRO

JUL- 12-2007 09:31A FR(71: PRRTT 910 592 f202
1
I
M;!. Herbert Marton
Rcute 1, Boa: 416
f:aheboxo, Nextn Carolina �i v
:kiax %!r. 1iartgn1
I U: 123JUJbULIJC7
7
U nc-= ci' -vATER &ID felt. had.S c�J 2P'*
L)ecember 1.4, 1973 " --
SutUECT. permit No. W65
zooland Cnrperound
Randolph County
In accordance wit43 your application received aepii 111 1973, v:
ere forwarc3:ng hvsewith Fanuit No. 3065, dated Decemaer 14, 1973, to
ooland Cac�F r surd, :candoITh County, for tt�o con: Erection an r
d opeation
of apprcxiruitely LOGO Iineal font of 6 and 8 -inch col 'Lotion sewer$, 3
12,401) t?D cixtended eeration troatment facility consisting of t3'ree (3)"
aeration chi bra, clarifiier$ 2crat ©d sludge ;holding tank, chlolLle
contact chassbor and & 0.017 acre fine solids settling basin, and approxi-
mately 0 1),ne:al foot of G- incur outfall sewer to serve Looland Cacri-uround,
and -the discharge of the treated effluent into Uttlo Ridoj.
This uarclit shall ba effective frtm th© date of its iscuarica uAti>.
July 1, 11"7`II , arni shy?1 a subjec± to the rorldytf :?s 2nd Unzitations as
zpecifiad therein.
:1so, enclosed is a co-,-.y of 1�9FG s o r "Cost or ':rite a *her ireainenE.
kixks.n M.s corm is to be completed and returned to this office tyithin
thirty t33) days after the ;;raiect is coMr-lsted.
We ().) set of appraved -,,Ions and s;;ecifications is being forM---cied
to you.
rnclosuro s
cc$ i-iUgh Ctrood Hssociato:;, iFIC. ,
Randolph County wealth department'.",
Mr. L. I. e'-nt r_, Jr.
tor. T. F. i .xnastrong
;�. M. R. Peeler
Technical -�erviCOs
MP/mcb
Sinceroly 7 yours,
L• 'r• i1LiCt✓ci.Td '
Assistant Director

7ik..,- 12-2007 09:31A F'R31: Pt RIT 9J O 692 jamj? TD- 18525600529
f
ORTH CAROLINA
DEPARTMENT OF NATURAL AND ECONOMIC RESOURCES
i
P, 4,,5
(".0r.A0 :.,F 2i
OFFICE OI WATER AND AIR RESOURCES
Ratetgh , North Carolina
i
PERMIT
Far the Discharge of Sewage, Industrial Wastes, or tither Wasieo
In accordance with the provisions Qf Article 21 of Chapter 143, General Statutes of North Carolina
as amended, and other applicable L.1ws, Rules and Regulations
PERT ISSTON IS IiERni BY GRAxTRD TO
2ool.,and Campground
Randolph County
FOR THE
constsvotion fixed operi ti,on of approximately I pOW lined `reel-
of 6 airl 8 -inch collection servers, a 1.2,000 GPD Vxteisded aeration
treat ey# facility coOsisting of three (3) aeration chambers,
clarif':ier, aerated sludge holding talk, chlorine contact chamber
end a 0.017 zero fine' solids s6ttling basin, and approximately
50 lira--al feet of 6 -inch outfall suer to serve Zooland Caopground,
and the discharge of the treated effluent into Little River,
in accordance with the application received - _- - -''°� ��`` _�'._ . -, 13 , and in ewfernuty with
the plans, specifications, and other supporting Bata, all of which are filers with the Office of
Water and Air Resources And are considered a part of this Permit.
This Permit shall be effective from the date of its issuance until . -__ 4uiy It 977______, and
shall he subject to the following specified conditions and limitation:
1. Thus permit shall become void unless the fUilitigfj are c+ trucxed %
accol-dame, frith the approved plans, specifloaticns and Other suPportiing data
and are c oa pleted and placed in operation on or before PgR2pLbqr _31 97�,
or as tills date may be a4ended*
2. This perciit is effective mly vAth sespoct to i e nature and volMe Of
waatet describad in the rapplication and other stgporting data.
3. The wastewater treatment facili.tle5, including chl0ii.nati6h faellit.ev,
theii be properly operated in such a manner as to effect overall reductions
in polixalon substantially in seeping with those indicated in the application
and othexwdse to pZOduc9 an effluent of such quality as to protect the
receiving stream.
4. ! ds i?P.I'mit it, not z.msleTiiUe9
5. The p,- -posed facilities 4iall be a6equatoly pr faded against, flooding.

i
J Iu -12 -2007 D9:3'_A FR,J :PRATT 910 692 b-02 T0:165856005zy P: S
(Page z of 2)
Zooland empgx•aund
Randolph Cixunty
i
U, upvn the Avaitai>(lity'of public oewerage facilities to the campground,
Oil r+astcullter will be di6charged to the public system and the treatment
facilities abandangd - v41U4n six (6) months of the data Such facilities ere
Fd a.do available.
iervlt�: on the operat }ores of the facilitieo shall be eutmitted to the
staff of tho North Carolina affics of stater and lair Rewurcee at regular
intervals e.ttd in such folm and detail as may be required by the Board ox
its adninit;txative staff.1
e .oy%ond Campground, at least six (6) mont46 prior to the expiration
Of this Permit, shall recvhst its extension. tkma receipt of the request,
the Board 14111 review the ''adequacy of the facilit'Ies described t<esreirts
and if indicated, will extend the pex�njit for such poriod of ticae ,,in
such conditions and limitations as deemed proper.
°• This ii; a Gass 1 aStOw0ter Treatment Plant itlich requirez that the
operator in responsible charge hold a valid Grade i Cex'tifjcate.
14TH DECENi3 ZR N4
Permit issued finis Mile _.___ -_ -- oay as -- --------------- ��__ f
3465 �: t;. i :u'ihazd� !A tnss:s�nt Directur
Permit :10. -- _- - -- - -- Office of Water and Air Resoutces

c /,�, � 5 ` /I 41-.0 �I IWC Calculations
Facility: Zooland Family Campground WWTP
NC0089052
Prepared By: Jim McKay
Enter Design Flow (MGD): 0.017
Enter s7Q10 (cfs): 0.03
Enter w7Q10 (cfs): 0.5
ig5 r4tre
Total Residual Chlorine (TRC)
Ammonia (Summer)
Daily Maximum Limit (ug /1)
Monthly Average Limit (mg NH3 -N /1)
s7010 (CFS)
0.03
s7Q10 (CFS)
0.03
DESIGN FLOW (MGD)
0.017
DESIGN FLOW (MGD)
0.017
DESIGN FLOW (CFS)
0.02635
DESIGN FLOW (CFS)
0.02635
STREAM STD (UG /L)
17.0
STREAM STD (MG /L)
1.0
Upstream Bkgd (ug /1)
0
Upstream Bkgd (mg /1)
0.22
IWC ( %)
46.76
IWC ( %)
46.76
Allowable Conc. (ug /1)
36
Allowable Conc. (mg/1)
1.9
Ammonia (Winter)
Monthly Average Limit (mg NH3 -N /1)
Fecal Coliform
w7Q10 (CFS)
0.5
Monthly Average Limit:
2001100ml
DESIGN FLOW (MGD)
0.017
(If DF >331; Monitor)
DESIGN FLOW (CFS)
0.02635
(If DF <331; Limit)
STREAM STD (MG /L)
1.8
Dilution Factor (DF)
2.14
Upstream Bkgd (mg /1)
0.22
IWC ( %)
5.01
Allowable Conc. (mg /l)
31.8
Total Residual Chlorine
1. Cap Daily Max limit at 28 ug /l to protect for acute toxicity
Ammonia (as NH3 -N)
1. If Allowable Conc > 35 mg /l, Monitor Only
2. Monthly Avg limit x 3 = Weekly Avg limit (Municipals); capped at 35 mg /I
3. Monthly Avg limit x 5 = Daily Max limit (Non - Munis); capped at 35 mg /l
4. BAT for Minor Domestics: 2 mg /I (summer) and 4 mg /I (winter)
5. BAT for Major Municipals: 1 mg /l (year- round)
Fecal Coliform
1. Monthly Avg limit x 2 = 400/100 ml = Weekly Avg limit (Municipals) = Daily Max limit (Non -Muni)
NPDES Server /Current Versions/WLA; TB 1/16/2009

LEVEL B MODEL INFORMATION
Facility Information Flow Information
Facility Name
Zooland Family
Topo Quad/ State Grid
Seagrove NC E19SE
NPDES No.
NCO089052
USGS sta. #
Type of wastewater
100% Domestic
Date of flow estimate
1211012010
Facility status
New
Drainage Area (mi)
14.74 sq. mi.
Receiving stream
Little River
Summer7Q10 (cfs)
0.03
Stream class
C
Winter7Q10 (cfs)
0.5
Subbasin
03 -07 -15
Average flow (cfs)
County
Randolph
30Q2 (cfs)
1
Regional Office
MRO
IWC at discharge ( %)
46.76% (Summer) 5.01% (Winter)
Summer
Segment/Reach
1
2
3
4
5
Length of reach (mi)
2.062
1.52
1.53
0.6
0.8
Incremental length
0.2
0.15
0.15
0.06
0.08
Waste characteristics
WWTP name
Zooland Family
Campground
Flow (MGD)
0.017
BOD
5
BOD Multiplier
1.5
CBOD
7.5
NH3N
2
NH3N multiplier
4.5
NBOD
9
DO (mg /1)
6
Background DO (mg/1-1
(Auto)
(Auto)
(Auto)
(Auto)
Runoff charactericstics
7Q10 (cfs /mi)
QA (cfs /mi)
CBOD (mg /1)
2
2
2
2
NBOD (mg /1)
1
1
1
1
DO (mg /1)
(Auto)
(Auto)
(Auto)
(Auto)
Tributary characteristics
Tributary name
s7Q10 (cfs /mi)
QA (cfs /mi)
CBOD (mg /1)
2
2
2
2
2
NBOD (mg /1)
1
1
1
1
1
DO (mg /1)
Slope
5.33
3.29
20.26
22.8
6.25
Minimum DO/ Loc Mi
File name: zoos

LEVEL B MODEL INFORMATION
Facility Information
Facility Name
Zooland Family
NPDES No.
NC0089052
Type of wastewater
100% Domestic
Facility status
New
Receiving stream
Little River
Stream class
C
Subbasin
03 -07 -15
County
Randolph
Regional Office
MRO
Winter
Segment/Reach
1
Length of reach (mi)
2.062
Incremental length
0.2
Waste characteristics
WWTP name
Zooland Family
Campground
Flow (MGD)
0.017
BOD
10
BOD Multiplier
1.5
CBOD
15
NH3N
4
NH3N multiplier
4.5
NBOD
18
DO (mg /1)
6
Background DO (mg/1-1
(Auto)
Runoff charactericstics
7Q10 (cfs /mi)
QA (cfs /mi)
CBOD (mg /1)
2
NBOD (mg /1)
1
DO (mg /1)
(Auto)
Tributary characteristics
Tributary name
s7Q10 (cfs /mi)
QA (cfs /mi)
CBOD (mg /1)
2
NBOD (mg /1)
1
DO (mg /1)
Slope
5.33
Minimum DO/ Loc Mi
File name: zoow
Flow Information
Topo Quad/ State Grid
USGS sta. #
Date of flow estimate
Drainage Area (mi )
Summer7Q10 (cfs)
Winter7Q10 (cfs)
Average flow (cfs)
30Q2 (cfs)
IWC at discharge ( %)
2 3
1.52 1.53
0.15 0.15
r
2
1
2 2
1 1
3.29 1 20.26
Seagrove NC E19SE
12/10/2010
14.74 sq. mi.
0.03
0.5
1
46.76% (Summer) 5.01% (Win
4 5
0.6 0.8
0.06 0.08
uto
2 2
1 1
2 2
1 1
22.8 1 6.25

SUMMER
ZOOLAND 5 2 SUMMER
Seg #
Reach #
Seg Mi I
D.O. I
CBOD I
NBOD
Flow
1
1
0.00
6.69
8.31
4.74
0.06
1
1
0.20
6.27
7.94
4.47
0.06
1
1
0.40
5.94
7.59
4.22
0.06
1
1
0.60
5.67
7.26
3.98
0.06
1
1
0.80
5.47
6.94
3.76
0.06
1
1
1.00
5.31
6.63
3.54
0.06
1
1
1.20
5.20
6.34
3.34
0.06
1
1
1.40
5.12
6.06
3.15
0.06
1
1
1.60
5.08
5.79
2.98
0.06
1
1
1.80
5.06
5.53
2.81
0.06
1
1
2.00
5.07
5.29
2.65
0.06
Seg #
Reach #
Seg Mi
D.O. I
CBOD I
NBOD I
Flow

•
MODEL RESULTS
SUMMER
ZOOLAND 5 2 SUMMER
Discharger
:
ZOOLAND FAMILY CAMPGROUND
Receiving Stream :
LITTLE RIVER
----------------------------------------------------------------------
The End D.O.
is 5.07
mg /1.
The End CBOD
is 5.29
mg /l.
The End NBOD
----------------------------------------------------------------------
is 2.65
mg /1.
WLA
WLA
WLA
DO Min
CBOD
NBOD
DO Waste Flow
(mg /1)
- - - - --
Milepoint Reach #
--- - - - - -- - - - - - --
(mg /1)
- - --
(mg /1)
- - --
(mg /1) (mgd)
-- ---- - - - - --
Segment 1
5.06
1.80 1
Reach 1
15.50
9.00
6.00 0.01700

* ** MODEL SUMMARY DATA * **
Discharger ZOOLAND FAMILY CAMPGROUND Subbasin 030715
Receiving Stream LITTLE RIVER Stream Class: C
Summer 7Q10 0.03 Winter 7Q10 : 0.5
Design Temperature: 26.0
Reach 1
t
LENGTHI
SLOPE
VELOCITY
DEPTH
Kd
Kd
Ka
Ka
KN
mile
--------------------------------------------------------------------------------
ft /mi
fps
ft
design
@20°
design
@20°
design
Segment 1
2.06
5.33
0.100
0.19 1
0.37 1
0.28
1 1.09
0.96
0.48
Reach 1
t
* Runoff flow is in cfs /mile
Flow
CBOD
NBOD
D.O.
cfs
mg /l
mg /l
mg /l
Segment 1
Reach 1
Waste
0.026
15.500
9.000
6.000
Headwaters
0.030
2.000
1.000
7.300
Tributary
0.000
2.000
1.000
7.300
* Runoff
0.000
2.000
1.000
7.300
* Runoff flow is in cfs /mile

Zooland Family Campground EAA Review
Zooland Family Campground (formerly Banjo Creek RV Park) is a 32 acre RV campground with 195
camper spaces. It is in receivership due to nonpayment of loans. There is an unpermitted septic system
on the site, details are unknown. On September 13, 2010, the Winston -Salem Regional office discovered
black septic water flowing in a ditch to the Little River. A NOV was issued and the campground ceased
operation.
The receiver plans to obtain an NPDES permit for a wastewater treatment system, then hopes to sell the
facility to a buyer who would build and operate a WWTP and the campground facility. Towards this
goal, they have hired a consultant who developed a design for wastewater treatment and an
Engineering Alternatives Analysis. The receiver has submitted an application for an NPDES discharge
permit and the EAA.
The proposed WWTP (17,000 GPD) is a biological WWTP manufactured by Aquapoint. It consists of:
• Primary Settling Tank (17,000 gallon septic tank)
• 6,000 gallon Flow Equalization Tank with duplex pumps and aerator
• Aerated Moving Bed Biofilm Reactor with two blowers
• Two parallel Bioclere fixed film systems with clarifiers, recirculation pumps and sludge return
pump
• 2,000 gallon filter feed tank
• Two tertiary pressure filters
• Alkalinity feed system
0 Tablet chlorinator with 600 gallon contact tank
• (They will also need dechlorination)
• Prefab building for blowers, filters and the chemical feed system
Alternatives Evaluated:
1. Connection to a POTW
• Two pump stations due to high head requirements
• 22,400 feet of forcemain
• Standby power for each pump station
• Liquid chemical feed system for odor control
Net Present Value: $2,018,976
2. Connection to a Privately Owned Treatment Plant
Not evaluated, as there are no privately owned treatment plants in the area with the required capacity.

3. Individual Sub - Surface Treatment Systems
Not evaluated because of soil conditions, and the close proximity of campsites together.
4. Wastewater Treatment System, with effluent disposal through a subsurface drip irrigation system
• Purchase additional land (7.3 acres)
• Install WWTP
• Install 126, 866 linear feet of drip tubing
Net Present Value: $1,643,506
5. Wastewater Treatment System with effluent disposal through a spray irrigation system
• Purchase additional land (26.2 acres)
• Construct 2.3 MG storage lagoon
• Install WWTP
• Construct spray system
Net Present Value: $1,737,780
6. Wastewater Treatment System with effluent disposal through a surface discharge to the Little river
• No additional land required
• Install WWTP
• Install gravity discharge line to the Little river
Net Present Value: $1,423,096
7. Wastewater Treatment to reuse standards with effluent disposal through spray irrigation system
• Purchase additional land (13.94 acres)
• Install WWTP
• 1 lined lagoon (130 days storage)
• 1 lined lagoon (5 days storage)
• Install spray field
Net Present Value: $2,142,395

Problem
Our 02H rules (T15A: 02H.0105(c)(7) requires: "a statement to demonstrate financial qualification and
substantial previous compliance with federal and state laws, regulations, and rules for the protection of
the environment as required by G.S. 143- 215.1(b)(4)(b)." The facility is in receivership under federal
court supervision. The receiver has no intention of building a wastewater treatment facility, but is
interested in selling the campground to a buyer who would build and operate it. Would a Special
Condition requiring the buyer to provide documentation to comply with this requirement be
appropriate?
SUMMARY:
Alternative
% of Alternative's PW to Alternative No. 6
1
142%
2
N/A
3
N/A
4
115%
5
122%
6
100%
7
151%
Problem
Our 02H rules (T15A: 02H.0105(c)(7) requires: "a statement to demonstrate financial qualification and
substantial previous compliance with federal and state laws, regulations, and rules for the protection of
the environment as required by G.S. 143- 215.1(b)(4)(b)." The facility is in receivership under federal
court supervision. The receiver has no intention of building a wastewater treatment facility, but is
interested in selling the campground to a buyer who would build and operate it. Would a Special
Condition requiring the buyer to provide documentation to comply with this requirement be
appropriate?

NPDES APPLICATION - FORM D
For privately owned treatment systems treating 100% domestic wastewaters X1.0 MGD
Mail the complete application to:
N. C. DENR / Division of Water Quality / NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699 -1617
NPDES Permit C00 TV0 j ,2
If you are completing this form in computer use the TAB key or the up - down arrows to moue from one
field to the next. To check the boxes, click your mouse on top of the box. Otherwise, please print or type.
1. Contact Information:
Owner Name
Diversified Lending Group, Inc., a corporation in Receivership'
Facility Name
Zooland Family Campground
Mailing Address
c/o Mr. David A. Gill, 2029 Century Park East, Third Floor
City
Los Angeles
State / Zip Code
CA 90067 -2904
Telephone Number
(310) 277 -0077
Fax Number
(310) 277 -5735
e -mail Address
DAGQDGDK.com
2. Location of facility producing discharge:
Check here if same address as above ❑
Street Address or State Road 3671 Pisgah Covered Bridge Road
City
State / Zip Code
County
Asheboro
NC 27205
Randolph
3. Operator Information:
Name of the firm, public organization or other entity that operates the facility. (Note that this is not
referring to the Operator in Responsible Charge or ORC)
Name Receivership of Diversified Lending Group, Inc., David A. Gill
as Receiver
Mailing Address c/o Mr. David A. Gill, 2029 Century Park East, Third Floor
City Los Angeles
State / Zip Code CA 90067 -2904
Telephone Number (310) 277 -0077
Fax Number (310) 277 -5735
' In re SEC vs. Diversified Lending Group, Inc., et. al, U.S. District Court, Central District of California,
Western Division, case number CV 09- 01533 -R (SSx). The Receiver acts only in his official capacity
and not in his personal capacity).X
P
1 of 3 4j Form•D 05/08
O`f ``F . I Y
P01_NT S0I;Y:1_:_L: �� ;H

NPDES APPLICATION - FORM D
For privately owned treatment systems treating 100% domestic wastewaters <1.0 MGD
4. Description of wastewater:
Facility Generating Wastewater(check all that apply):
Industrial
❑
Number of Employees
Commercial
❑
Number of Employees
Residential
❑
Number of Homes
School
❑
Number of Students /Staff
Other
®
Explain: See below
Describe the source(s) of wastewater (example: subdivision, mobile home park, shopping centers,
restaurants, etc.):
Campground for recreational vehicles and campers. Property has spaces for 92 sites with water and
sewer connections (at 100 gpd /space), and spaces for 103 sites without water and sewer hookups, but
with access to a common comfort station /bathhouse (at 75 gpd /space). Total estimated flow is:
(92x100) +(103x75) = 16,925 gpd, plus allowance for 3 employees at office at 25 gpd /emp =
17,000 gallons per day estimated total flow
Population served: 393
5. Type of collection system
® Separate (sanitary sewer only) ❑ Combined (storm sewer and sanitary sewer)
6. Outfall Information:
Number of separate discharge points one
Outfall Identification number(s) 001
Is the outfall equipped with a diffuser? ❑ Yes ® No
7. Name of receiving stream(s) (Provide a map showing the exact location of each outfall):
Little River
8. Frequency of Discharge: ® Continuous ❑ Intermittent
If intermittent:
Days per week discharge occurs: Duration:
9. Describe the treatment system
List all installed components, including capacities, provide design removal for BOD, TSS, nitrogen and
phosphorus. If the space provided is not sufficient, attach the description of the treatment system in a
separate sheet of paper.
See attached description
2 of 3 Form -D 05/08

NPDES APPLICATION - FORM D
For privately owned treatment systems treating 100% domestic wastewaters <1.0 MGD
10. Flow Information:
Treatment Plant Design flow 0.017 MGD
Annual Average daily flow Not available MGD (for the previous 3 years)
Maximum daily flow Not available MGD (for the previous 3 years)
11. Is this facility located on Indian country?
❑ Yes ® No
12. Effluent Data
Provide data for the parameters listed. Fecal Coliform, Temperature and pH shall be grab samples, for all other
parameters 24 -hour composite sampling shall be used. If more than one analysis is reported, report daily maximrun
and monthly average. f only one analysis is reported, report as daily maximum.
Parameter
Daily
Maximum
Monthly
Average
Units of
Measurement
Biochemical Oxygen Demand (BOD5)
NA - Proposed
Discharge
NA - Proposed
Discharge
NA - Proposed
Discharge
Fecal Coliform
N/A Prop. Disch.
N/A Prop. Disch.
N/A Prop. Disch.
Total Suspended Solids
N/A Prop. Disch.
N/A Prop. Disch.
N/A Prop. Disch.
Temperature (Summer)
N/A Prop. Disch.
N/A Prop. Disch.
N/A Prop. Disch.
Temperature (Winter)
N/A Prop. Disch.
N/A Prop. Disch.
N/A Prop. Disch.
pH
N/A Prop. Disch.
N/A Prop. Disch.
N/A Prop. Disch.
13. List all permits, construction approvals and /or applications:
Type Permit Number Type
Hazardous Waste (RCRA) NESHAPS (CAA)
UIC (SDWA) Ocean Dumping (MPRSA)
NPDES X Dredge or fill (Section 404 or CWA)
PSD (CAA) Other
Non - attainment program (CAA)
14. APPLICANT CERTIFICATION
Permit Number
I certify that I am familiar with the information contained in the application and that to the
best of my knowledge and belief such information is true, complete, and accurate.
David A. Gill Receiver
Printed name of Person S(gning Title
Signature of Applicant
Date
North Carolina General Statute 143 -215.6 (b)(2) states: Any person who knowingly makes any false statement representation, or certification in any
application, record, report, plan, or other document files or required to be maintained under Article 21 or regulations of the Environmental Management
Commission implementing that Article, or who falsifies, tampers with, or knowingly renders inaccurate any recording or monitoring device or method
required to be operated or maintained under Article 21 or regulations of the Environmental Management Commission implementing that Article, shall be
guilty of a misdemeanor punishable by a fine not to exceed $25,000, or by imprisonment not to exceed six months, or by both. (18 U.S.C. Section 1001
provides a punishment by a fine of not more than S25,000 or imprisonment not more than 5 years, or both, for a similar offense.)
3 of 3 Form -D 05/08

NARRATIVE DESCRIPTION OF THE PROPOSED TREATMENT WORKS:
1. Design Flows: Proposed Plant: 0.017 MGD = 12 gallons per minute
(approximately)
Peaking Factor: 3.0
Peak Flow = 3.0 x 0.017 mgd = 0.051 mgd = 36 gpm
2. Pretreatment: Primary Settling (Septic Tank with minimum volume of
17,000 gallons)
3. Treatment Plant:
Volumes: Flow Equalization 6,000 gallons (35% of design flow)
MBBR Tank
Filter Feed Tank
Pumps: Flow Equalization
dose
Dosing Pumps
Bioclere
Recycle Pump
Filter Feed Pump
Filter Backwash
Pump
5,000 gallons
2,000 gallons
duplex submersible pumps with timed
duplex submersible pumps in each
simplex submersible pump in each
Bioclere
simplex end - suction pump for each filter
simplex end - suction pump for each filter
Aeration: The MBBR (Moving Bed Biofilm Reactor) will have a duplex
blower system. The estimated air requirements are 72 scfm
at 5.61 psi for each blower.
Bioclere: Two model 30/32, each with an integral 2,300 - gallon
clarifier.
4. Tertiary Filter: Two pressure filters, each with an effective filter surface
area of area 4.9 square feet, total filter area of 9.8
square feet
Filtration rate — 1.2 gpm /SF at ADF
Backwash return to the septic tank
Backwash rate— up to 20 gpm /SF
Media — spherical silica sand
5. Disinfection Unit: Tablet chlorination

6. Effluent Flow Measurement: Turbine water meter
7. Chemical Feed System: Alkalinity feed to supplement natural alkalinity as
required for complete nitrification
8. Sludge Storage: In 17,000 gallon septic tank

r
0
• a
. w
Iw
�cn
17,000 GAL. 6,000 GAL. �__�_ MBBR : Z
SEPTIC TANK PUMP TANK p� ($'x$'x10'D) #1 �.,
I
:H
1
ALKALINITY
FEED
25% SODIUM
HYDROXIDE
FLOW
SPLIITER
IN 4'0
MANHOLE
BIO -CLERE
BIO -CLERE
2,000 GAL.
SLOUGH &
FILTER FEED
TANK
PRESSURE
FILTER
— TABLET
CHLORINATOR
O evaw
PRESSURE
FILTER
TO
LITTLE
RIVER
600 GAL.
CHLORINE
CONTACT
FIGURE No. 2
ALTERNATIVE No. 6
PROPOSED WASTEWATER TREATMENT SYSTEM
EAA-6 NO SCALE

Labels
Name: Proposed Discharge Location Zooland Family Campground Little River, Class 'C' waters
Coordinates: 035° 36'04.80" N, 079° 50'56.68" W

I
ZOOLAND FAMILY CAMPGROUND
Legend
3671 Pisgah Covered Bridge Road • Asheboro, NC 27205
Randolph County • 336- 381 -3422 • Fax: 336 - 381 -3313 1-0
V4 a
F-130/50 Amp =4 J®
50 Amp
30 Amp
COBathhou,se
Store
Arcade
i
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©
Phone
Dump Station
Trail
Trash
4
C
�1Nlti
;,�..a • 4360 Peters Rd. • Ft. Lauderdale, FL 33317 - 0327690680