NC0043257_Compliance Evaluation Inspection_20221101

DocuSign Envelope ID: 943EC068-268B-418F-BB6F-962C10606A67
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director Environmental Quality
Matthew E. Raynor
Nature Trails Associates
Nature Trails MHC WWTP
524 Meadow Ave Loop
Banner Elk, NC 28604
Dear Mr. Raynor:
NORTH CAROLINA
November 1, 2022
Subject: Compliance Evaluation Inspection
Nature Trails Mobile Home Park WWTP
NPDES Permit No. NC0043257
Chatham County
On July 18, 2022, Colleen Cohn of the Raleigh Regional Office (RRO) conducted an inspection at the
subject facility. The cooperation of Peter Salisbury, Operator in Responsible Charge (ORC) of the
facility, was greatly appreciated. Findings during the inspection were as follows:
1. The current NPDES permit was issued effective on November 1, 2021 and will expire on April
30, 2026.
2. The 0.04 MGD treatment plant consists of an influent pump station, equalization basin, flow
splitter box, aeration basins, dual clarifiers, aerobic sludge digesters, effluent chlorination,
dechlorination, and flow monitoring.
3. The plant discharges to Cub Creek [16-41-2-10-(0.5)] which is classified as WS-IV;NSW waters
in the Cape Fear River Basin.
4. The field parameters performed by the operator are pH and Dissolved Oxygen. Enco Laboratories
performs analysis for all other permitted parameters.
5. A cursory review of laboratory data and discharge monitoring report (DMR) data for July 2021
and January 2022 showed one typo for the weekly composite TSS value for July 15, 2021. Please
revise the eDMR values for TSS for the week of July 15, 2021.
6. A cursory review of DMR data for July 2021 and January 2022 showed a monthly average for
Ammonia (NH3) as N in January 2022. The monthly average was 7.825 mg/L which exceeds the
permit limit of 5.2 mg/L for the period of November 1 - March 31. A cursory review of data from
July 2018 to July 2022 showed that the facility has had ten (10) Monthly Average Exceedances
for Nitrogen, Ammonia. Within 30-days receipt of this letter, please provide a written
response to this office outlining the Nature Trails Association CLP's efforts to analyze
and/or investigate the cause for Nitrogen, Ammonia exceedances.
NORTH CAROLINA
Department M Environmental Quality
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office I 3800 Barrett Drive I Raleigh, North Carolina 27609
919.791.4200

DocuSign Envelope ID: 943EC068-268B-418F-BB6F-962C10606A67
7. The facility has two equalization basins. The housing for both equalization basins appeared to be
heavily corroded. The air pipe to one of the basins was rusted through and inoperable. Within 30-
days receipt of this letter, please provide a written response to this office outlining the
schedule you will take or have taken to repair the equalization basins and aeration system.
8. The dual clarifiers appeared to be operating satisfactorily. Effluent from the clarifier in Plant 1
was clear with minimal algae, and effluent from the clarifier in Plant 2 was slightly cloudy with
some algae.
9. The aerobic sludge digesters appeared to be operating satisfactorily. Mr. Salisbury stated that the
digesters hold approximately 12,000 gallons total and that 10,000 gallons of sludge are hauled by
Granville Farms approximately every 1.5 months.
10. The liquid disinfection and tablet dechlorination systems appeared to be operating satisfactorily.
11. The digital flow meter and chart recorder were not working during the inspection. Mr. Salisbury
stated that they stopped working over the weekend and a maintenance request had been
submitted. Within 30-days receipt of this letter, please provide a written response to this
office outlining the schedule you will take or have taken to repair the digital flow meter and
chart recorder.
12. The effluent flow meter was calibrated on August 24, 2021.
13. Mr. Salisbury stated he did not believe the onsite diesel generator is working. Within 30-days
receipt of this letter, please provide a written response to this office outlining the schedule
you will take or have taken to repair the onsite diesel generator. Please also include
information regarding the onsite diesel generator's maintenance and testing schedule.
14. The effluent discharge was clear and free of excess solids and foam at the time of the inspection.
No detrimental impacts to Cub Creek were observed.
15. A daily operator logbook was readily available for review.
Please respond in writing to items 5, 6, 7, 11, and 13 within 30 days of receipt of this letter
describing how these items have been resolved.
If you have questions concerning this report, please contact Colleen Cohn at 919-791-4258 or
[e-mail].
LICb{f V IA,SDIA,
BCDA9D825D4A46D...
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Sincerely,
DocuSigned by:
Attachment 1: EPA Compliance Inspection Report
cc: Laserfiche
£ D_E
NORTHCAROLINA
Department of Environmental Deep
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office I 3800 Barrett Drive I Raleigh, North Carolina 27609
919.791.4200

DocuSign Envelope ID: 943EC068-268B-418F-BB6F-962C10606A67
United States Environmental Protection Agency
EPA Washington, D.C. 20460
Water Compliance Inspection Report
Form Approved.
OMB No. 2040-0057
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code
1 IN I 2 L
21IIIIII
NPDES yr/mo/day Inspection
3 I NC0043257 111 121 22/07/18 117
Type
1810I
IIIIIIIIIII
Inspector Fac Type
191S I 2011
IIIIIIIIIII IIIIIII I IIIIII
P6
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA Reserved
671 I 70I I 711 172 I N I 731 1 74 71
I I
I I I I I I 180
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES oermit Number)
Nature Trails Mobile Home Park WWTP
101 Nature Trl
Chapel Hill NC 27514
Entry Time/Date
10:OOAM 22/07/18
Permit Effective Date
21/11/01
Exit Time/Date
11:OOAM 22/07/18
Permit Expiration Date
26/04/30
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Matthew E. Raynor,524 Meadow Ave Loop Banner Elk NC 286047402/Environmental
Director/828-733-5028/9198691572 No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenar Records/Reports
Facility Site Review Effluent/Receiving Wate
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s)
Colleen Cohn
of Inspector(s) Agency/Office/Phone and Fax Numbers Date
-DocuSignedby: DWR/RRO WQ/919-791-4258/
f //lam 11/1/2022
'-F13CB8277092044D...
Signature of
Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
DocuSigned by:
1 \fAit UutAhla, 11/1/2022
EPA Form 3-60 q290 4$41Previous editions are obsolete.
Page# 1

DocuSign Envelope ID: 943EC068-268B-418F-BB6F-962C10606A67
31
NPDES yr/mo/day
N C 0043257 I11 121 22/0 7/ 18
17
Inspection Type
18LI
(Cont.)
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
On July 18, 2022, Colleen Cohn of the Raleigh Regional Office (RRO) conducted an inspection at the
subject facility. The cooperation of Peter Salisbury, Operator in Responsible Charge (ORC) of the
facility, was greatly appreciated. Findings during the inspection were as follows:
1. The current NPDES permit was issued effective on November 1, 2021 and will expire on April 30,
2026.
2. The 0.04 MGD treatment plant consists of an influent pump station, equalization basin, flow
splitter box, aeration basins, dual clarifiers, aerobic sludge digesters, effluent chlorination,
dechlorination, and flow monitoring.
3. The plant discharges to Cub Creek [16-41-2-10-(0.5)] which is classified as WS-IV;NSW waters in
the Cape Fear River Basin.
4. The field parameters performed by the operator are pH and Dissolved Oxygen. Enco
Laboratories performs analysis for all other permitted parameters.
5. A cursory review of laboratory data and discharge monitoring report (DMR) data for July 2021
and January 2022 showed one typo for the weekly composite TSS value for July 15, 2021. Please
revise the eDMR values for TSS for the week of July 15, 2021.
6. A cursory review of DMR data for July 2021 and January 2022 showed a monthly average for
Ammonia (NH3) as N in January 2022. The monthly average was 7.825 mg/L which exceeds the
permit limit of 5.2 mg/L for the period of November 1 - March 31. A cursory review of data from July
2018 to July 2022 showed that the facility has had ten (10) Monthly Average Exceedances for
Nitrogen, Ammonia. Within 30-days receipt of this letter, please provide a written response to this
office outlining the Nature Trails Association CLP's efforts to analyze and/or investigate the cause for
Nitrogen, Ammonia exceedances.
7. The facility has two equalization basins. The housing for both equalization basins appeared to be
heavily corroded. The air pipe to one of the basins was rusted through and inoperable. Within
30-days receipt of this letter, please provide a written response to this office outlining the schedule
you will take or have taken to repair the equalization basins and aeration system.
8. The dual clarifiers appeared to be operating satisfactorily. Effluent from the clarifier in Plant 1 was
clear with minimal algae, and effluent from the clarifier in Plant 2 was slightly cloudy with some algae.
9. The aerobic sludge digesters appeared to be operating satisfactorily. Mr. Salisbury stated that
the digesters hold approximately 12,000 gallons total and that 10,000 gallons of sludge are hauled
by Granville Farms approximately every 1.5 months.
10. The liquid disinfection and tablet dechlorination systems appeared to be operating satisfactorily.
11. The digital flow meter and chart recorder were not working during the inspection. Mr. Salisbury
stated that they stopped working over the weekend and a maintenance request had been submitted.
Within 30-days receipt of this letter, please provide a written response to this office outlining the
schedule you will take or have taken to repair the digital flow meter and chart recorder.
12. The effluent flow meter was calibrated on August 24, 2021.
13. Mr. Salisbury stated he did not believe the onsite diesel generator is working. Within 30-days
receipt of this letter, please provide a written response to this office outlining the schedule you will
take or have taken to repair the onsite diesel generator. Please also include information regarding
Page# 2

DocuSign Envelope ID: 943EC068-268B-418F-BB6F-962C10606A67
Permit: NC0043257
Inspection Date: 07/18/2022
Owner - Facility: Nature Trails Mobile Home Park WWTP
Inspection Type: Compliance Evaluation
the onsite diesel generator's maintenance and testing schedule.
14. The effluent discharge was clear and free of excess solids and foam at the time of the inspection.
No detrimental impacts to Cub Creek were observed.
15. A daily operator logbook was readily available for review.
Please respond in writing to items 5, 6, 7, 11, and 13 within 30 days of receipt of this letter describing
how these items have been resolved.
Page# 3

DocuSign Envelope ID: 943EC068-268B-418F-BB6F-962C10606A67
Permit: NC0043257
Inspection Date: 07/18/2022
Owner - Facility: Nature Trails Mobile Home Park WWTP
Inspection Type: Compliance Evaluation
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? • ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑ � ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: Clean, but lots of rust and corrosion noted
Permit Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new ❑ ❑ � ❑
application?
Is the facility as described in the permit? • ❑ ❑ ❑
# Are there any special conditions for the permit? ❑ • ❑ ❑
Is access to the plant site restricted to the general public? • ❑ ❑ ❑
Is the inspector granted access to all areas for inspection? • ❑ ❑ ❑
Comment:
Record Keeping Yes No NA NE
Are records kept and maintained as required by the permit? • ❑ ❑ ❑
Is all required information readily available, complete and current? • ❑ ❑ ❑
Are all records maintained for 3 years (lab. reg. required 5 years)? • ❑ ❑ ❑
Are analytical results consistent with data reported on DMRs? • ❑ ❑ ❑
Is the chain -of -custody complete? • ❑ ❑ ❑
Dates, times and location of sampling •
Name of individual performing the sampling •
Results of analysis and calibration •
Dates of analysis •
Name of person performing analyses •
Transported COCs ■
Are DMRs complete: do they include all permit parameters? • ❑ ❑ ❑
Has the facility submitted its annual compliance report to users and DWQ? ❑ ❑ ❑ •
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified ❑ ❑ • ❑
operator on each shift?
Is the ORC visitation log available and current? • ❑ ❑ ❑
Is the ORC certified at grade equal to or higher than the facility classification? • ❑ ❑ ❑
Is the backup operator certified at one grade less or greater than the facility ❑ ❑ ❑ •
classification?
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DocuSign Envelope ID: 943EC068-268B-418F-BB6F-962C10606A67
Permit: NC0043257
Inspection Date: 07/18/2022
Owner - Facility: Nature Trails Mobile Home Park WWTP
Inspection Type: Compliance Evaluation
Record Keeping
Is a copy of the current NPDES permit available on site?
Facility has copy of previous year's Annual Report on file for review?
Comment:
Pump Station - Influent
Is the pump wet well free of bypass lines or structures?
Is the wet well free of excessive grease?
Are all pumps present?
Are all pumps operable?
Are float controls operable?
Is SCADA telemetry available and operational?
Is audible and visual alarm available and operational?
Comment:
Equalization Basins
Is the basin aerated?
Is the basin free of bypass lines or structures to the natural environment?
Is the basin free of excessive grease?
Are all pumps present?
Are all pumps operable?
Are float controls operable?
Are audible and visual alarms operable?
# Is basin size/volume adequate?
Yes No NA NE
• ❑ ❑ ❑
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Yes No NA NE
❑ • ❑ ❑
• ❑ ❑ ❑
❑ • ❑ ❑
❑ ❑ ❑ •
Comment: Two EQ basins. Both show heavy corrosion. Air supply to one not functional at all, and
the other was somewhat operational. Difficult to evaluate.
Secondary Clarifier
Is the clarifier free of black and odorous wastewater?
Is the site free of excessive buildup of solids in center well of circular clarifier?
Are weirs level?
Is the site free of weir blockage?
Is the site free of evidence of short-circuiting?
Is scum removal adequate?
Is the site free of excessive floating sludge?
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
❑ ❑ ❑ •
• ❑ ❑ ❑
▪ ❑ ❑ ❑
Page# 5

DocuSign Envelope ID: 943EC068-268B-418F-BB6F-962C10606A67
Permit: NC0043257
Inspection Date: 07/18/2022
Owner - Facility: Nature Trails Mobile Home Park WWTP
Inspection Type: Compliance Evaluation
Secondary Clarifier Yes No NA NE
Is the drive unit operational?
Is the return rate acceptable (low turbulence)?
Is the overflow clear of excessive solids/pin floc?
Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth)
Comment:
• ❑ ❑ ❑
Aeration Basins Yes No NA NE
Mode of operation Ext. Air
Type of aeration system Diffused
Is the basin free of dead spots? ■ ❑ ❑ ❑
Are surface aerators and mixers operational? El El • ❑
Are the diffusers operational? El El El •
Is the foam the proper color for the treatment process? • El ❑ ❑
Does the foam cover less than 25% of the basin's surface? • El El El
Is the DO level acceptable? El El ❑ •
Is the DO level acceptable?(1.0 to 3.0 mg/I) El El El •
Comment: Audible air leak evident
Disinfection -Liquid
Is there adequate reserve supply of disinfectant?
(Sodium Hypochlorite) Is pump feed system operational?
Is bulk storage tank containment area adequate? (free of leaks/open drains)
Is the level of chlorine residual acceptable?
Is the contact chamber free of growth, or sludge buildup?
Is there chlorine residual prior to de -chlorination?
Comment:
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
❑ ❑ ❑ •
De -chlorination Yes No NA NE
Type of system ? Tablet
Is the feed ratio proportional to chlorine amount (1 to 1)? El El El •
Is storage appropriate for cylinders? El ❑ • ❑
# Is de -chlorination substance stored away from chlorine containers? El El ❑ ❑
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DocuSign Envelope ID: 943EC068-268B-418F-BB6F-962C10606A67
Permit: NC0043257
Inspection Date: 07/18/2022
Owner - Facility: Nature Trails Mobile Home Park WWTP
Inspection Type: Compliance Evaluation
De -chlorination Yes No NA NE
Comment:
Are the tablets the proper size and type? ❑ ❑ ❑ •
Are tablet de -chlorinators operational? • ❑ ❑ ❑
Number of tubes in use? 2
Comment:
Standby Power Yes No NA NE
Is automatically activated standby power available? • ❑ ❑ ❑
Is the generator tested by interrupting primary power source? ❑ ❑ ❑ •
Is the generator tested under load? ❑ ❑ ❑ ■
Was generator tested & operational during the inspection? ❑ • ❑ ❑
Do the generator(s) have adequate capacity to operate the entire wastewater site? ❑ ❑ ❑ •
Is there an emergency agreement with a fuel vendor for extended run on back-up ❑ ❑ ❑ ■
power?
Is the generator fuel level monitored? ❑ ❑ ❑ ■
Comment: Another party responsible for testing generator. Mr. Salisbury does not believe it
works.
Effluent Pipe
Is right of way to the outfall properly maintained?
Are the receiving water free of foam other than trace amounts and other debris?
If effluent (diffuser pipes are required) are they operating properly?
Comment:
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
❑ ❑ • ❑
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