NC0060283_Response to multiple NOVs_20231101

a PROPERTIES I americA home'
VIA OVERNIGHT DELIVERY
October 25, 2023
Mr. Danial Boss, Assistaint Regional Surevisor
Water Quality Regional Op[erations Section
Division of Water Resources
North Carolina Department of Environmental Quality
1621 Mail Service Center
Raleigh, North Carolina 27699
Re: Notice of Violation
NPDES Permit No. NCO060283
Ridgeview NC MHC, LLC
Dear Mr. Boss:
NOV 0 12023 J
Water Quality Regional Operations
Asheville Regional Office
This letter is in response to your letters dated April 27, 2023, May 1, 2023, and June 23, 2023,
regarding the notice of violation for toxicity exceedance during February and March 2023.
Copies of these letters have been included for your convenience.
We are conducting a detailed mapping of the sanitary discharge system to avoid exceedance in
the future. It is our belief that the exceedances are caused during high flow events (Non rain) at
the discharge point. Mapping of the system will help identify the cause to allow for corrections.
We have been informed that there are no known plans for this system on file with your agency.
As you are aware, during your onsite visit in early 2023 with a state engineer and Mark Jones,
Jones Environmental. The only above ground component of this plant is the chlorine contact
chamber with the balance of the plant located underground. The location of the underground
plant is not known currently. We are hoping the mapping will allow us to locate and excavate
the sand beds to determine their efficiency.
Currently the effluent is in compliance with our NPDES permit as required. Please see the
attached Effluent Toxicity Report Form for your reference.
We consider this item to be addressed.
31200 Northwestern Hwy., Farmington Hills, MI 48334 1 Main [phone] 1 Fax [phone] rhp-properdes.com

If you have any questions, please do not hesitate to call me at [phone].
Sincerely yours,
Richard D. Marengere
Utilities Infrastructure Manager
Enclosures:

DocuSign Envelope ID: BD493727-5FEC-4FB2-A39C-72517107E7Do
d STATL,
ROY COOPER
Governor pq,
ELIZABETH S. BISER
�•�'
Secretary -"
RICHARD E. ROGERS, JR, NORTH CAROLINA
Director Environmental Quality
Certified Mail # 7022 0410 0002 1249 8514
Return Receipt Requested
April 27, 2023
Joel K Brown
Ridgeview NC MHC LLC
31200 Northwestern Hwy
Farmington Hills, MI 48334
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" ater Quality Regional Operations
Asheville Regional Office
SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY
Tracking Number: NOV-2023-LV-0285
Permit No. NCO060283
Ridgeview Acres Mobile Home Park
Buncombe County
Dear Permittee:
A review of the February 2023 Discharge Monitoring Report (DMR) for the subject facility revealed the
violation(s) indicated below:
Limit Exceedance Violation(s):
Sample Limit Reported
Location Parameter Date Value Value Type of Violation
001 Effluent Flow, in conduit or thru 2/28/2023 0.0078 0.0113 Monthly Average Exceeded
treatment plant (50050)
A Notice of Violation/Intent to Issue Civil Penalty is being issued for the noted violation of North Carolina General
Statute (G.S.) 143-215.1 and the facility's NPDES WW Permit. Pursuant to G.S. 143-215.6A, a civil penalty of
not more than twenty-five thousand dollars ($25,000.00) may be assessed against any person who violates or
fails to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S.
143-215.1.
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DocuSign Envelope iD: BD493727-5FEC-4FB2-A39C-72517107E7D0
If you wish to provide additional information regarding the noted violation, request technical assistance, or
discuss overall compliance please respond in writing within ten (10) business days after receipt of this Notice. A
review of your response will be considered along with any information provided on the submitted Monitoring
Report(s). You will then be notified of any civil penalties that may be assessed regarding the violations. If no
response is received in this Office within the 10-day period, a civil penalty assessment may be
prepared.
Remedial actions should have already been taken to correct this problem and prevent further occurrences in the
future. The Division of Water Resources may pursue enforcement action for this and any additional violations of
State law. If the violations are of a continuing nature, not related to operation and/or maintenance problems,
and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by
Consent.
Reminder: Pursuant to Permit Condition 6 in Section E, the Permittee is required to verbally notify the Regional
Office as soon as possible, not to exceed 24 hours, from first knowledge of any non-compliance at
the facility including limit violations, bypasses of, or failure of a treatment unit. A written report may
be required within 5 days if directed by Division staff. Prior notice should be given for anticipated or
potential problems due to planned maintenance activities, taking units off-line, etc.
If you have any questions concerning this matter or to apply for an SOC, please contact Lauren Armeni of the
Asheville Regional Office at 828-296-4667.
Sincerely,
HDocuftL,
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7192DABF84FF...
Daniel Boss, Assistant Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ
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Daniel ]ones (]ones Environmental, ORC)
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DocuSign Envelope ID: 7B59795F-F296-4FA9-93CB-4A162A007A01
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Joel K Brown
Ridgeview N C M H C LLC
31200 Northwestern Hwy
Farmington Hls, MI 48334
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NORTH CAROLINA
Environmental Quality
SUBJECT: NOTICE OF VIOLATION
Tracking Number: NOV-2023-PC-0176
Permit No. NCO060283
Ridgeview Acres Mobile Home Park
Buncombe County
Dear Permittee:
May 01, 2023 1 NOV 0 12023
Water Quality Regional Operations
Asheville Regional Office
The North Carolina Division of Water Resources conducted an inspection of the Ridgeview Acres Mobile Home
Park on February 16, 2023. This inspection was conducted to verify that the facility is operating in compliance
with the conditions and limitations specified in NPDES WW Permit No. NC0060283. A summary of the findings
and comments noted during the inspection are provided in the enclosed copy of the inspection report.
The Compliance Evaluation inspection was conducted by Division of Water Resources staff from the Asheville
Regional Office. The following violation(s) were noted during the inspection:
Inspection Area Description of Violation
Operations & Maintenance The location and number of the sand filters and septic tanks is unknown,
In addition, the issues below must also be addressed:
Compliance Issue(s): This facility has been routinely failing whole effluent toxicity testing. The
cause of these failures needs to be discovered and abated.
Remedial actions should have already been taken to correct this problem and prevent further occurrences in the
future. The Division of Water Resources may pursue enforcement action for this and any additional violations of
State law.
North Carolhta Depanmeru of Enrvoronmtal quality ! Di M.s of Water Resources
�--D_E Q Mhevllle Regional Office l 2090 U S. KQh— 70 5---a. North Carol.na 28778

DocuSign Envelope ID: 7B59795F-F296-4FA9-93CB-4A162A007A01
To prevent further action, please respond in writing to this office within 30 days upon your receipt of this Notice
of Violation regarding your plans or measures to be taken to address the indicated violations and other identified
issues, if applicable.
If you should have any questions, please do not hesitate to contact me with the Water Quality
Regional Operations Section in the Asheville Regional Office at 828-296-4500.
ATTACHMENTS
Ec: Laserfiche
Sincerely,
COocuftned by: A.
E397182DABFB4FF...
Daniel Boss, Assistant Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ
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DocuSign Envelope ID: 4D479B28-019E-4356-8B59-COC3D9C7E551
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ROY COOPER'.
EUZABETH S. BISER
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....
RICHARD E. ROGERS.A
NORTH CAROLINA
Dt-1w
E.W—M—W Quality
Certified Mail # 7022 2410 0003 1436 8948
Return Receipt Requested
June 23, 2023
Joel K Brown
Ridgeview N C M H C LLC
31200 Northwestern Hwy
Farmington Hills, MI 48334
NOV 0 12023
`',-!'er Quality Regional Operations
Asheville Regional Office
SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY
Tracking Number: NOV-2023-LV-0366
Permit No. NCO060283
Ridgeview Acres Mobile Home Park
Buncombe County
Dear Permittee:
A review of the March 2023 Discharge Monitoring Report (DMR) for the subject facility revealed the violation(s)
indicated below:
Limit Exceedance Violation(sl:
Sample Limit Reported
Location Parameter Date Value Value Type of Violation
001 Effluent Flow, in conduit or thru 3/31/2023 0.0078 0.0125 Monthly Average Exceeded
treatment plant (50050)
A Notice of Violation/Intent to Issue Civil Penalty is being issued for the noted violation of North Carolina General
Statute (G.S.) 143-215.1 and the facility's NPDES WW Permit. Pursuant to G.S. 143-215.6A, a civil penalty of
not more than twenty-five thousand dollars ($25,000.00) may be assessed against any person who violates or
fails to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S.
143-215.1.
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DocuSign Envelope ID: 4D479B28-019E-4356-8859-COC3D9C7E551
If you wish to provide additional information regarding the noted violation, request technical assistance, or
discuss overall compliance please respond in writing within ten (10) business days after receipt of this Notice. A
review of your response will be considered along with any information provided on the submitted Monitoring
Report(s). You will then be notified of any civil penalties that may be assessed regarding the violations. If no
response is received in this Office within the 10-day period, a civil penalty assessment may be
prepared.
Remedial actions should have already been taken to correct this problem and prevent further occurrences in the
future. The Division of Water Resources may pursue enforcement action for this and any additional violations of
State law. If the violations are of a continuing nature, not related to operation and/or maintenance problems,
and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by
Consent.
Reminder: Pursuant to Permit Condition 6 in Section E, the Permittee is required to verbally notify the Regional
Office as soon as possible, not to exceed 24 hours, from first knowledge of any non-compliance at
the facility including limit violations, bypasses of, or failure of a treatment unit. A written report may
be required within 5 days if directed by Division staff. Prior notice should be given for anticipated or
potential problems due to planned maintenance activities, taking units off-line, etc.
If you have any questions concerning this matter or to apply for an SOC, please contact Lauren Armeni of the
Asheville Regional Office at 828-296-4667.
Ec: Laserfiche
Sincerely,
EvDoeuSigned by:
AIA. t t ;6ss
E397192DABF84FF...
Daniel Boss, Assistant Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ
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Asheville, NC 28902
Phone: [phone]
Fax. [phone]
Effluent Toxicity Report Form • Chronic Pass/Fall and Acute LCSO [date: August 16, 2023
Fatihlty: Jones Environmental NPDES # NC 0060283 Pipe #: 001 County: Buncombe
Ridgeview Acres MIHP
Laboratory Performing Test: Environmental Testing Solutions_InWCertificate # 037 Comments
Signature of Operator in Responsible Charge (ORC)
ORC Phone / E-mail L L7t7 Project N: 18 5
Signature of Laboratory Supervisor ,. � ..�..,�.,�. I .: Sample M: 230801.{19r 23p903.07
e-mail to: ATF.wms A n 4nr,Agrv_
Or MailOriginal to: North Carolina Division of Water ResourceS
Water Sciences Section / Aquatic Toxicology Branch
1621 Mail Service Center
Raleigh; NC 27699.1621
North Carolina Cerrot/clpfutfcr Chronic PasslFail Reproduction Toxicity Test
l ontml tlt ranism 1 2 3 4 5 6 7 S 9 10 11 12
Number of Youn Produced
28
30
28128
27
33
130129
32
29
29
27
Adult Survival': Live, (D)ead
I L
I L
L I
L
L
I L
I L
I L I L
L
I L
I L
Effluent Percentage 55 t
Treatmarst 2 [3ro_ranisms 1 2 3 4 S 6 7 8 9 10 11 12
Number of Young Produces!
37
35
34
34
33
34
36
32
35
34
33 32
Adult Survival: L)ive7 D eat!
L
L
L
L
L
L
L
L
L
L
L L
Chronic Test Results
t-Stat / Rank Sum -7.140
1-TaNad Critical 2.508
% Reduction: -16.9
Percent
Average
Morttrlity
Reproduction
Control
Control
0.0
29.2
Treatment 2
Treatment 2
0,0
34.1
Control Cv
6.3
PASS FAIL
Speawdwq�n4mr Oi5Miij'.
-
Im 1—d
X
100-0
PH (S.u.) 1st Sam le 2nd Sara l 2nd Sara le "rest Start Date: August 2, 2023
Control E7.20
7.92 7.97 8.00 7.82 7.86
Treatment 2 7.22 7.53 7.(j9 7.50 7.39 Collection Start) Date:
R t Sample 1 08-01-23 Sample 2 0"3-2323
L %- ix W w
D.O. (mg/L) 1st Samle 2nd Sml2nd Sam l
Control 7.6 7A 7.9 7.8 7.7 7.8
0 8.1 7.8 7 7.8Treatment 2 8.0
LC./Acute Toxicity Test
(Mortality expressed as combining replicates.)
Comoe"tratko M)
h.+lorts�liN (�l
LC50 Method of Determination
sample Type/Duration
Crab Wimp. duratfun
SarnpJe 1 X
Sample 2 X
Alkalinity (mg CaCOI&
hardness (mg CaCOI/L
Conductivity (µmhos/em',
Total Resiclual Chlorine f rng/t
trample Temta at Recerpt (°C
C r1 M
1E
61
as
3a7.301.3W
219
231
c 0:10
< O. u
2.9
1 1S
9S% Confidence Limits Trimmed Spearman Karber et t ti
to Probit
Lather' Control
High Conc.
Organism Tested. -- Duration: � pH (S.U.) DO (Mg/L)
DWR Report Form AT-1