NC0022462_NOV2017PC0136_20170317

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Water -Resources
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Certified Magill # 7014 21120 0000 80571 90715
Return Receipt Reguested
March 07, 2017
Teresa I Schenk
Sherwood Mobile Home Park Association
Care of DRS Realty Company
8255 Cascade Ave Suite 120
Commerce Township, MI 48382-2217
ROY COOPER
Cowyna
MICHAEL S. xEGAN
sccrrtor;•
S. )AY ZIMiViERMAN
olrraor
SUBJECT: NOTICE OF VIOLATION ON & INTENT TO ASSESS CIIVE L PENALTY
Tracking Number: NOV-2017-PC-0136
Permit No. NCO022462
Sherwood Mobile Home Park WWTP
Onslow County
Dear Ms. Schenk:
RECEIVEDIMCDEUDWR
MAR 13 2017
water Quality
'Perfnitting saotion
The North Carolina Division of Water Resources conducted an inspection of the Sherwood Mobile Home Park
WWTP on February 20, 2017. This inspection was conducted to verify that the facility is operating in compliance
with the conditions and limitations specified in NPDES WW Permit No. NC0022462. 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 Wilmington
Regional Office. The following violation(s) were noted during the inspection:
0 Inspection Area Description of Violation
Flow Measurement - Effluent
Facility does not have a chart recorder. The Regional Office allowed this for the short term,
as far back as 2010, because the Permittee had plans to connect to ONWASA and take facility
off line. No schedule has been received by the Regional Office for this connection.
Record Keeping
Maintenance and day-to-day operation of the plant is not recorded, with the exception of the
ORC's time on site, collection of samples and field lab analyses. According to the permit, all
maintenance and operation records shall be maintained for a period of at least 3 years.
Sand Filters (Low rate)
Ponding was observed on the sand filter in operation, which has been an issue noted in past
inspections. There were no operation or maintenance records available.
Secondary Clarifier
The scum removal units in the clarifiers were not operational which has been observed and
noted on past inspections.
State of North Carolina I Environmental Quality I Water Resources
127 Cardinal Drive Extension, Wilmington, North Carolina 28405
910-796-7215

Hnspaeccition Area, Desccriptoon of Viloia,ftion
Effluent Pipe White solids, from the breakdown of the de -chlorination tablets were observed at the outfall
and along the channel leading to the creek. This issue has been observed and noted in past
inspections. Three of the four tubes were full of tablets.
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 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.
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 Discharge
Monitoring Report(s). You will then be notified of any civil penalties that may be assessed regarding the
violations. Hf no response [is recccelivedi lin thiis ®fflccce witlhiln the 20 -day period, al cciidAll pefuaptty
assessment may he 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.
l;Sceu iindlcer: 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 should have any questions, please do not hesitate to contact Helen Perez with the Water Quality
Regional Operations Section in the Wilmington Regional Office at 910-796-7215.
Sincerely,
f
Jas H. Gregson, Regional Supervisor
Water Quality Regional Operations Section
Wilmington Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS
Cc: WQS Wilmington Regional Office - Enforcement File
NPDES Compliance/Enforcement Unit - Enforcement File
State of North Carolina I Environmental Quality I Water Resources
127 Cardinal Drive Extension, Wilmington, North Carolina 28405
910-796-7215

United States Environmental Protection Agency
Form Approved.
EPA Washington, D C 20460
OMB No. 2040-0057
Water Compliance Inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 IN 1 2 15 I 3 I NCoo22462 111 12 17/02/20 17 18 I C J 19 LG] S 201 I
21111111 1111111111111111111111111 11111111111 i66
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ----------------Reserved------------
67 70 71 I I 72 I NJ 73 I I 174 751 111 1 1 1 180
L—I L_J I I I 1
Section B: FacilityData
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date '
Permit Effective Date
POTW name and NPDES permit Number)
10:OOAM 17/02/20
12/11/01
Sherwood Mobile Home Park WWTP
753 Tallman Cir
Exit Time/Date
Permit Expiration Date
Midway Park NC 28544
11:OOAM 17/02/20
17/06/30
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Mikel Howard Seely/ORC/910-330-9653/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Teresa I Schenk,Care Of Drs Realty Company Commerce Township MI
Yes
483822217/Managing Partner/248-363-6111/2483604073
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
® Permit ® Flow Measurement ® Operations & Maintenance Records/Reports
® Self -Monitoring Program ® Sludge Handling Disposal ® Facility Site Review ® Compliance Schedules
Effluent/Receiving Waters ® Laboratory
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Dean Hunkele \\ `Q� WIRO WQ//910-796-7215/ �•—�� ��
Helen I Perez n WIRO WQ//910-796-7387/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
James Gregson4, MRO WQ/// '
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

NPDES yr/mo/day Inspection Type (Cont.) 1
31 N00022462 111 121 17/02/20 117 18
Section D: Summary of Finding/Comments (Attach additionalsheetsof narrative and checklists as necessary)
A compliance inspection of the Sherwood MHP WWTP was conducted on February 20, 2017. The
facility was found to be noncompliant with the NPDES permit NC0022462.
The facility was in need of maintenance, some of which has been noted in past inspections. Ponding
was observed on the left sand filter and some weeds and algae on the right filter which was not in use.
There was no maintenance or operation documentation found in regards to the sand filters. The scum
removal units in the clarifiers were not operational and there is no record of how long they have been
inoperable and what maintenance has been done to try to correct the problem. White solids from the
breakdown of the de -chlorination tablets were observed at the outfall and along the channel leading to
the creek. Three of four tubes were loaded with tablets, but this does not appear to help with the
ongoing problem. The roof and entrance to the lab building is in need of repair. This building houses
important and expensive equipment needed for the compliance of the facility.
Please note that according to the permit's Standard Conditions, the Permittee shall at all times properly
operate and maintain all facilities and systems of treatment and control (and related appurtenances)
which are installed or used by the Permittee to achieve compliance with the conditions of this permit.
Proper operation and maintenance documentation is required and should be maintained for a period of
at least 3 years.
A flow chart recorder has not been installed. The Regional Office allowed this for the short-term as far
back as 2010 because the Permittee had plans to connect to the Onslow Water and Sewer Authority
system and shut down the plant. It appears that there are no plans in place for this connection;
therefore, a chart recorded needs to be installed to meet the requirements of the permit.
The Permittee has applied for permit renewal. The Regional Office will be recommending to the
Central Office Permitting Section that a schedule be required to address the above issues for the new
permit.
Page#

Permit: NCO022462 Owner -Facility: Sherwood Mobile Home Park VWVTP
Inspection Date: 02/20/2017 Inspection Type: Compliance Evaluation
Permit
Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new
®
❑
❑
❑
application?
9
❑
❑
❑
Is the facility as described in the permit?
10
❑
❑
❑
# Are there any special conditions for the permit?
❑
❑
®
❑
Is access to the plant site restricted to the general public?
❑
of
❑
❑
Is the inspector granted access to all areas for inspection?
lip
❑
❑
❑
Comment: Area at the back of facilitv where the sand filters, liquid chlorine storage and lab buildina are
located is not secure. ORC indicated there has been evidence of trespassing in this area.
Lab building is locked when not in use.
Compliance Schedules Yes No NA NE
Is there a compliance schedule for this facility? ❑ ❑ ® ❑
Is the facility compliant with the permit and conditions for the review period? ❑ ® ❑ ❑
Comment: Violations occurred over the past three years: 2014- BOD for JuIV and August, Flow for JuIV.
2015- BOD for June, Fecal for June and July.
2016- BOD for June and October, DO for July.
Record) Keeping
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 CDCs
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?
Yes No NA NE
❑
P1
❑
❑
❑
V
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❑
9
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❑
❑
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❑
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IN
❑
❑
❑
IN
of
it
Is
a
®
❑
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❑
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®
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❑
in
❑
M ❑ ❑ ❑
® ❑ ❑ ❑
Page# . 3

Permit: NCO022462 Owner -Facility: Sherwood Mobile Home Park VVWTP
Yes No NA NE
Are field parameters performed by certified personnel or laboratory?
Inspection Date: 02/20/2017 Inspection Type: Compliance Evaluation
❑
❑
❑
Are all other parameters(excluding field parameters) performed by a certified lab?
Record Keeping
Yes No NA NE
Is the backup operator certified at one grade less or greater than the facility classification?
FW1
❑
❑
❑
Is a copy of the current NPDES permit available on site?
W
❑
❑
❑
Facility has copy of previous year's Annual Report on file for review?
❑
E]'IN
FA
❑
Comment: Maintenance and day-to-day operation of the plant is not recorded, with the exception of the
ORC's time on site, collection of samples and field lab analyses. According to the permit, all
maintenance and operation records shall be maintained for a period of at least 3 years.
Laboratory
Yes No NA NE
Are field parameters performed by certified personnel or laboratory?
PQ
❑
❑
❑
Are all other parameters(excluding field parameters) performed by a certified lab?
0
❑
❑
❑
# Is the facility using a contract lab?
N
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
N
❑
❑
❑
Celsius)?
FA
❑
❑
❑
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
❑
❑
N
❑
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
❑
❑
NN
❑
Comment: Sherwood MHP is field certified, certification number 5490. Envirochem is the contract lab.
Bar Screens
Yes No NA NE
Type of bar screen
51
❑
❑
❑
a.Manual
0
❑
❑
❑
b.Mechanical
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❑
❑
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Are the bars adequately screening debris?
N
❑
❑
❑
Is the screen free of excessive debris?
FA
❑
❑
❑
Is disposal of screening in compliance?
❑
❑
❑
Is the unit in good condition?
RN
❑
❑
❑
Comment: No comment.
Equalization Basins
Yes No NA NE
Is the basin aerated?
51
❑
❑
❑
Is the basin free of bypass lines or structures to the natural environment?
0
❑
❑
❑
Is the basin free of excessive grease?
❑
❑
❑
Are all pumps present?
IN
❑
❑
❑
Are all pumps operable?
❑
❑
❑
W
Are float controls operable?
❑
❑
❑
Page# 4

Permit: NCO022462 Owner -Facility: Sherwood Mobile Home Park WWTP
Inspection Date: 02/20/2017 Inspection Type: Compliance Evaluation
Egualizafion Basins Yes No RIA NE
Are audible and visual alarms operable? 14, ❑ ❑ ❑
# Is basin size/volume adequate? ❑ ❑ ❑ IN
Comment: The audible and visual alarms are not monitored by an autodialer that alerts ORC or MHP
managers of a high water level or power loss.
Nutrient Removal
# Is total nitrogen removal required?
# Is total phosphorous removal required?
Type
# Is chemical feed required to sustain process?
Is nutrient removal process operating properly?
Comment: Ferric sulfate is dosed at the splitter box.
Aeration Basins
Mode of operation
Type of aeration system
Is the basin free of dead spots?
Are surface aerators and mixers operational?
Are the diffusers operational?
Is the foam the proper color for the treatment process?
Does the foam cover less than 25% of the basin's surface?
Is the DO level acceptable?
Is the DO level acceptable?(1.0 to 3.0 mg/1)
Yes No RIA NE
❑ ❑ ® ❑
31 ❑ ❑ ❑
Chemical
In ❑ ❑ ❑
® ❑ ❑ ❑
Yes No NA NE
Ext. Air
Diffused
FO ❑ ❑ ❑
❑ ❑ ® ❑
® ❑ ❑ ❑
* ❑ ❑ ❑
* ❑ ❑ ❑
❑ ❑ ❑
❑ ❑ ❑
Comment: ORC does not conduct any process contol tests to measure the MLSS in aeration basins.
Secondary Clarifier
Yes No NA NE
Is the clarifier free of black and odorous wastewater?
❑
❑
❑
Is the site free of excessive buildup of solids in center well of circular clarifier?
❑
❑
9
❑
Are weirs level?
®
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❑
❑
Is the site free of weir blockage?
®
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❑
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Is the site free of evidence of short-circuiting?
®
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❑
Is scum removal adequate?
❑
It
❑
❑
Is the site free of excessive floating sludge?
a
❑
❑
❑
Is the drive unit operational?
❑
❑
0
❑
Page# 5

Permit: NC0022462 Owner -Facility: Sherwood Mobile Home Park WWrP
Inspection Date: 02/20/2017 Inspection Type: Compliance Evaluation
Secondary Clarifier Yes No NA NE
Is the return rate acceptable (low turbulence)?
PA
❑
❑
❑
Is the overflow clear of excessive solids/pin floc?
9
❑
❑
❑
Is the sludge blanket level acceptable? (Approximately % of the sidewall depth)
❑
❑
❑
ON
Comment: The scum removal units in the clarifiers were not operational which
has been an issue
# Is the odor acceptable?
Q
❑
observed and noted on past inspections. A small amount of floating
solids was observed.
# Is tankage available for properly waste sludge?
4
Aerobic Digester
Yes No NA NE
Is the capacity adequate?
❑
❑
❑
M
Is the mixing adequate?
❑
❑
❑
❑
Is the site free of excessive foaming in the tank?
❑
❑
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# Is the odor acceptable?
Q
❑
❑
❑
# Is tankage available for properly waste sludge?
4
❑
❑
❑
Comment: Lewis Farms removes the residuals approximately
every 6 months. Solids removal records
❑
0
were sent via email by ORC.
Sand Filters (Loud rate)
Yes No NA NE
(If pumps are used) Is an audible and visible alarm Present and operational?
®
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❑
❑
Is the distribution box level and watertight?
❑
❑
❑
R
Is sand filter free of ponding?
❑
IR
❑
❑
Is the sand filter effluent re -circulated at a valid ratio?
❑
❑
H
❑
# Is the sand filter surface free of algae or excessive vegetation?
❑
❑
❑
# Is the sand filter effluent re -circulated at a valid ratio? (Approximately 3 to 1)
❑
❑
0
❑
Comment: Pondinq was observed on the left sand filter, which has been an issue noted in past
inspections. The right sand filter had some weeds and algae on surface and ORC indicated
that maintenace was scheduled once the sand is dried. He indicated that he alternates
between the two filters so maintenance can be performed, but there are no records kept to
show this activity. The dosing tank pump audible and visible alarms were operational.
Disinfection -Liquid
Yes No NA NE
Is there adequate reserve supply of disinfectant?
®
❑
❑
❑
(Sodium Hypochlorite) Is pump feed system operational?
re
❑
❑
❑
Is bulk storage tank containment area adequate? (free of leaks/open drains)
Fd
❑
❑
❑
Is the level of chlorine residual acceptable?
❑
❑
❑
IX
Is the contact chamber free of growth, or sludge buildup?
❑
❑
❑
Is there chlorine residual prior to de -chlorination?
❑
❑
❑
N
Page# 6

Permit: NCO022462 Owner -Facility: Sherwood Mobile Home Park VWVTP
Inspection Date: 02/20/2017 Inspection Type: Compliance Evaluation
Disinfection-Licguid Yes No NA NE
Comment: Storaqe of the liquild chlorine is not secure and the roof protectina it from the weather is in
poor condition.
Yes No NA NE
Is composite sampling flow proportional?
10
❑
Flow Measurement - Effluent
Yes No NA NE
# Is flow meter used for reporting?
K
❑
❑
❑
Is flow meter calibrated annually?
14
❑
❑
❑
Is the flow meter operational?
RON
❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
❑
N
❑
❑
Comment: Facility does not have a chart recorder. The Regional Office allowed no chart recorder, as
far back as 2010, because the Permittee had plans to connect to ONWASA system and
take facility off line. No schedule has been received by the Regional Office for this
connection. Flow meter was calibrated by Delta Systems Environmental on 03-24-2016.
Effluent Sampling
Yes No NA NE
Is composite sampling flow proportional?
10
❑
❑
❑
Is sample collected below all treatment units?
NO
❑
❑
❑
Is proper volume collected?
❑
❑
❑
0
Is the tubing clean?
RON
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
[IN
❑
❑
❑
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type W ❑ ❑ ❑
representative)?
Comment: Temperature of sample storage was 3 degrees C. Last date of calibration of thermometer
was 08-30-2015. There was no documentation of calibration of sampler
volume to insure
that at least 100 ml are collected with each cycling of the sampler.
Effluent Pipe
Yes No NA NE
Is right of way to the outfall properly maintained?
A
❑
❑
❑
Are the receiving water free of foam other than trace amounts and other debris?
❑
N
❑
❑
If effluent (diffuser pipes are required) are they -operating properly?
❑
❑
FOR
❑
Comment: White solids, from the breakdown of the dechlorination tablets, were observed at the outfall
and alonq the channel leading to the creek. This issue has been observed and noted in past
inspections. Three of the four tubes were full of tablets.
®e -chlorination Yes No NA NE
Type of system ? Tablet
Is the feed ratio proportional to chlorine amount (1 to 1)? ❑ ❑ ❑ a
Page# 7

Permit: NCO022462 Owner -Facility: Sherwood Mobile Home Park WWTP
Inspection Date: 02/20/2017 Inspection Type: Compliance Evaluation
®e -chlorination Yes No NA NE
Is storage appropriate for cylinders? Q ❑ ❑ ❑
# Is de -chlorination substance stored away from chlorine containers? ❑ ❑ ❑
Comment:
Are the tablets the proper size and type? ❑ ❑ ❑
Are tablet de -chlorinators operational? ❑ ❑ ❑
Number of tubes in use? 3
Comment: No comment.
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, and ❑ ❑ ❑ ❑
sampling location)?
Comment: No comment.
®aerations & Maintenance Yes No YEA WE
Is the plant generally clean with acceptable housekeeping? ❑ IR ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ PA ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: Maintenance issues need to be addressed and documented. The roof and the entrance to
building that houses the lab, composite sampler and flow meter is in need of repair as well
as the pate that leads to this back area of the site. The roof that protects the liquid chlorine
storage from the weather is in need of repair.
Standby Power
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?
Yes No NA NE
❑ W ❑ ❑
❑ ❑ RA ❑
❑ ❑ 0 ❑
❑ ❑ RU ❑
❑ ❑ ® ❑
❑ ❑ ® ❑
❑ ❑ 9 ❑
Comment: There is no standby power available on site. The permittee is responsible for maintaining
adaquate safeguards to prevent the discharge of untreated wastes during eletrical power
failures either by means of alternate power sources or retention of inadequately treated
effluent.
Page# 8