WQCSD0273_NOV2022PC0642_20221012

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Fred D. Curl
707 N. English St
Greensboro, NC 27405
NORTH CAROLINA
Environmental Quality
October 121h, 2022
Subject: Compliance Evaluation Inspection & Notice of Violation
NOV Tracking #: NOV-2022-PC-0642
Cedar Park Mobile Home Park Wastewater Collection System
Deemed Permitted Wastewater Collection System Tracking #: WQCSD0273
Guilford County
Dear Mr. Curl:
Ron Boone of the North Carolina Division of Water Resources (NCDWR) Winston-Salem Regional
Office (WSRO) conducted a compliance evaluation inspection of the Cedar Park Mobile Home
Park Wastewater Collection System on September 8th, 2022. You were present for the inspection.
The inspection findings and violations are listed below and detailed in the attached Compliance
Inspection Report.
REGULATION CITATION
VIOLATION DESCRIPTION
15A NCAC 02T .0403(a)(2)
No collection system map available during the
inspection.
15A NCAC 02T .0403(a)(3)
No written operation & maintenance plan or
spill plan.
15A NCAC 02T .0403(a)(4)
Pump station inspections not performed as
required.
15A NCAC 02T .0403(a)(5)
High priority lines not inspected as required.
15A NCAC 02T .0403(a)(6)
Annual general observation not being
conducted as required.
15A NCAC 02T .0403(a)(9)
Right-of-ways not properly identified or
maintained as required.
15A NCAC 02T .0403(a)(10)
Not all of the required documentation has
been generated or maintained as required.
Please be aware that the Division may take enforcement action against any individual who fails
to comply with the requirements of all applicable permits, regulations, and/or statutes. Pursuant
D North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105
Moan caaouNn 336.776.9800
oep.m.m or em�nmen� ouaim,

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, or applicable regulations, issued
pursuant to G.S. 143-215.1.
Please reply, in writing, to this notice of violation, with 10 days of receiving it. Your written
response must address each violation listed in the compliance inspection report and provide your
intended remedial actions, with estimated completion dates, for each violation. You will then be
expected to make all the necessary corrective actions to achieve full compliance within 90 days
of receiving the notice. Failure to do so will result in further enforcement actions.
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 [e-mail]. Thank you in advance for your time and
attention to this matter.
Sincerely,
DocuSiTgned by:
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Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
Attachments:
1. Compliance Inspection Report, WQCSD0273
NORTH CAROLINAD E Q
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North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Raleigh, North Carolina 27105
336.776.9800

Permit: WQCSD0273
SOC:
County: Guilford
Region: Winston-Salem
Contact Person: Fred Curl
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Compliance Inspection Report
Effective: 03/01/00 Expiration: Owner: Curl Fred D
Effective: Expiration: Facility: Cedar Park MHP Collection System
Inspection Date: 09/08/2022
Primary Inspector: Ron Boone
Secondary Inspector(s):
Title:
Entry Time 03:OOPM
DocuSigsene��d by:
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Certification:
Phone: [phone]
Phone:
Exit Time: 04:OOPM
Phone: [phone]
10/11/2022
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
(See attachment summary)
Page 1 of 4

Permit: WQCSD0273 Owner - Facility: Curl Fred D
Inspection Date: 09/08/2022 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, conducted a compliance
evaluation inspection of the Cedar Park Mobile Home Park wastewater collection system on September 8th, 2022. Fred
Curl, park owner, was present for the inspection.
The Cedar Park collection system is deemed permitted. Deemed permitted collection systems in NC are regulated under
NC regulations 15A NCAC 02T .0400 - 0405. The primary requirements of these regulations are enumerated below along witl
Cedar Park's compliance status for each:
(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.
The Cedar Park mobile home park has one pump station. The station's audible and visual alarms were operational during the
inspection. The pump station and the rest of the collection system appeared to be in overall good condition. No deficiencies
were noted. No overflows from the collection system have been reported to date. These are all indicators the collection
system is effectively maintained and operated.
(2) A map of the collection system shall have been developed and shall be maintained.
No map of the collection system was provided during the inspection.
(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 written plan that meets the above requirements was provided during the inspection.
(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.
The pump station has both audible and visual alarms, but no telemetry or SCADA systems. It therefore must be inspected
365 days per year. No records of the inspections of the pump station and collection system were provided during the
inspection. It is unknown at what frequency the station and system are normally checked. No O&M or spill plan was
provided during the inspection.
(5) High -priority sewers shall be inspected by the permittee or its representative once every six -months, and inspections
shall be documented.
As stated above, no O&M or spill plan was provided during the inspection, so it is not documented whether any high priority
sewers (HPS) are present in the system. HPSs need to be identified and properly inspected, and the inspections
documented, as set out above.
(6) A general observation by the permittee or its representative of the entire collection system shall be conducted once per
year.
No such records of such observations were provided during the inspection.
(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. 143-215.1C.
Page 2 of 4

Permit: WQCSD0273 Owner - Facility: Curl Fred D
Inspection Date: 09/08/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
According to Division records, no overflows have been reported from this collection system to date. As stated above, no spill
plan was provided during the inspection.
(8) A Grease Control Program shall be in place as follows: For privately owned collection systems, the Grease Control
Program shall include bi-annual distribution of grease education materials to users of the collection system by the permittee
or its representative.
Samples of grease educational materials and a log which included the dates of distribution along with the distribution
method, was presented during the inspection. The permittee appears to be compliant with this requirement.
(9) Right-of-ways and easements shall be maintained in the full easement width for personnel and equipment accessibility.
As stated above, no O&M or spill plan was provided during the inspection, so it is not documented whether any such
right-of-ways (ROW) are present in the system. ROWs need to be identified and properly inspected, and the inspections
documented, as set out above.
(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.
Not all required documenatation, as specified above, was presented during the inspection.
Page 3 of 4

Permit: WQCSD0273 Owner - Facility: Curl Fred D
Inspection Date: 09/08/2022 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine
Page 4 of 4