WQCSD0203_NOV2018PC0036_20180218

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
Water Resources LINDA CULPEPPER
Environmental Quality Interim Director
Certified Mail # 70131710 00021865 7133
Return Receipt Requested
February 9, 2018
Mr. Walter B. Craven RECEIVED/DENR/DWR
Lakeview MHP LLC
420 Marion Drive #31 FEB 208
Wilmington, NC 28412 Water Resources
Permitting Section
Subject: Compliance Evaluation Inspection Report and Notice of Violation
Deemed Permitted Wastewater Collection System # WQCSD0203
NOV Tracking # NOV-2018-PC-0036
Lakeview MHP Collection System, Forsyth County
Dear Mr. Craven:
On February 2, 2018, Paul DiMatteo of the Division of Water Resources (Division), Winston-Salem Regional
Office met with Mr. Matt Moger, park manager, to conduct a Compliance Evaluation Inspection of the above referenced
Wastewater Collection System.
This inspection consists of (1) a review of the permit and accompanying documentation to determine
compliance with permit conditions, and (2) an on-site inspection of several collection system components. Observations
and conclusions for each condition evaluated are stated in the following report, and a summary is attached for your
records.
Requirements — As Specified by 15A NCAC 02T.0403
1. a 1 : Requires the sewer system to 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.
Summary: No overflows or bypasses have been reported to date and Mr. Moger said that he wasn't aware of
any spills having occurred in recent years.
Compliance Status: Compliant
2. a 2 : Requires a map of the sewer system to be developed and actively maintained.
Summary: A map was submitted to this office in 2012; however, Mr. Moger said that he did not have a copy of
the map available. Mr. Moger said that he would try to obtain a copy, and took pictures of the map in our files.
Please ensure that a map is developed and properly maintained.
Compliance Status: Not compliant
3. LaJJ3L Requires an operation and maintenance plan including pump station inspection frequency, preventative
maintenance schedule, spare parts inventory and overflow response to be developed and implemented.
-`"7`No'thing Compares' -7-4.,
State of North Carolma'I Environmental Quality
450 W Hanes Mill Road, Suite 300, Winston-Salem, North Carolina 27105
Phone- 336-776-98001 FAX [phone]

Summary: An O&M plan was not available during the inspection. The purpose and importance of such a plan
was discussed with Mr. Moger. A plan should be developed that includes the following:
Operation, maintenance and inspection schedules for lines, manholes, cleanouts, rights-of-way, pump
stations, septic tanks, etc.
Spare parts inventory for any parts maintained on site. If no spare parts are maintained, a source of
spare parts should be identified and specified within the plan.
Overflow response plan that identifies contact information for responsible parties, spill teams,
contractors and reporting agencies; spill thresholds; and response, containment, cleanup and reporting
procedures.
Compliance Status: Not compliant
4. a 4 : Requires pump stations that are not connected to a telemetry system to be inspected everyday (i.e. 365
days per year), and pump stations that are connected to telemetry to be inspected once per week.
Summary: There are no pump stations in the collection system.
Compnance Status: Not applicable
5. JgM Requires high-priority sewers to be inspected at least once every six months and inspections to be
documented.
Summary: Mr. Moger said that there are no high priority lines in the system.
Compliance Status: Not applicable
6. Lal U6. Requires a general observation of the entire sewer system to be conducted at least once per year.
Summary: No documentation showed that the annual observation had been conducted.
Compliance Status: Not compliant
7. LaU7 : Requires overflows and bypasses to be reported to the Division regional office in accordance with 15A
NCAC 02B .0506(a), and public notice to be issued in accordance with G.S. 143-215.1C.
Summary: Mr. Moger said that there were no recent overflows or bypasses at this collection system. You may
wish to review the requirements in 15A NCAC 02B .0506(a) and G.S. 143-215.1C to ensure you are fully familiar
with all requirements.
When reporting SSOs to DWR, you must call the Winston-Salem Regional Office at 336-776-9800 during normal
business hours. If outside normal business hours, you must report the spill to the NC Division of Emergency
Management at 1-800-858-0368. Please note that all reportable SSOs must be reported within 24 hours of the
occurrence, or first knowledge, of the SSO. Please also note that voice mail or faxed messages are not
considered as the initial verbal report. You must talk to and report the spill to a live person.
Compliance Status: Compliant
8. Igagh Requires a Grease Control Program to be in place as follows:
For publicly owned collection systems, the Grease Control Program shall include at least bi-annual
distribution of educational materials for both commercial and residential users and the legal means to
require grease interceptors for new construction and retrofit, if necessary, of grease interceptors at
existing establishments. The plan shall also include legal means for inspections of the grease
interceptors, enforcement for violators and the legal means to control grease entering the system from
other public and private satellite sewer systems. (Note — not applicable to this permitl

b. For privately owned collection systems, the Grease Control Program shall include at least bi-annual
distribution of grease education materials to users of the collection system by the permittee or its
representative.
c. Grease education materials shall be distributed more often than required in Parts (A) and (B) of this
Subparagraph if necessary to prevent grease -related sanitary sewer overflows.
Summary: There was no documentation that demonstrated that educational fats, oils and grease (FOG)
materials were distributed to users, and Mr. Moger said that he was not aware of this requirement.
Compliance Status: Not compliant
9. Statement: Requires that rights-of-way and easements are maintained in the full easement width for personnel
and equipment accessibility.
Summary: Rights-of-way appeared well maintained during the inspection.
Compliance Status: Compliant
10. (a)(10): Requires documentation to be kept for subparagraphs (a)(1) through (a)(9) of this Rule for a minimum of
three years with exception of the map, which is required to be maintained for the life of the system.
Summary: As discussed above, documentation was not available for the collection system map, operation and
maintenance plan, annual observation or educational FOG program.
Compliance Status: Not compliant
Site Inspections
1. Several septic tanks were inspected and appeared to be in acceptable condition with no signs of recent
overflows.
Required Response
Please respond to this notice within 30 calendar days of receipt. Your response should be sent to this office at
the letterhead address and should include timelines for developing programs to comply with the items noted as not
compliant above. Please be advised that, in accordance with G.S. 143-215.6A, these violations are subject to civil
penalty assessments not to exceed $25,000.00 per day,, per violation. Your written response and the actions you take
to address these violations listed herein will be considered in deciding whether or not such penalties are necessary to
compel compliance.
If you should have any questions, please do not hesitate to contact Paul DiMatteo at [phone] or our
office at [phone].
Sincerely,
Att—Ar , 1 4-P
Sherri V. Knight, P.E., Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
Enclosures – Inspection Report, 15A NCAC 02T.0403
CC: Matt Moger, 5186 High Point Road #7, High Point, NC 27265
WQS Winston-Salem Regional Office - Enforcement File
PERCS Unit
Central Files

Appendix A —15A NCAC 02T.0403
15A NCAC 02T.0403 PERMITTING BY REGULATION
(a) Collection systems having an actual, permitted or Division approved average daily flow less than 200,000 gallons per day are
deemed permitted pursuant to Rule .0113 of this Subchapter provided the system meets the criteria in Rule .0113 of this Subchapter and
all specific criteria required in this Rule:
(1) The sewer system is 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.
(2) A map of the sewer system has been developed and is actively maintained.
(3) An operation and maintenance plan including pump station inspection frequency, preventative maintenance schedule,
spare parts inventory and overflow response has been developed and implemented.
(4) Pump stations that are not connected to a telemetry system (i.e., remote alarm system) are inspected by the permittee
or its representative every day (i.e., 365 days per year). Pump stations that are connected to a telemetry system are
inspected at least once per week.
(5) High-priority sewers are inspected by the permittee or its representative at least once every six -months and inspections
are documented.
(6) A general observation by the permittee or its representative of the entire sewer system is conducted at least once per
year.
(7) Overflows and bypasses are reported to the appropriate Division regional office in accordance with 15A NCAC 02B
.0506(a), and public notice is provided as required by G.S. 143-215.1C.
(8) A Grease Control Program is in place as follows:
(A) For publicly owned collection systems, the Grease Control Program shall include at least bi-annual
distribution of educational materials for both commercial and residential users and the legal means to require
grease interceptors for new construction and retrofit, if necessary, of grease interceptors at existing
establishments. The plan shall also include legal means for inspections of the grease interceptors,
enforcement for violators and the legal means to control grease entering the system from other public and
private satellite sewer systems.
(B) For privately owned collection systems, the Grease Control Program shall include at least bi-annual
distribution of grease education materials to users of the collection system by the permittee or its
representative.
(C) Grease education materials shall be distributed more often than required in Parts (A) and (B) of this
Subparagraph if necessary to prevent grease -related sanitary sewer overflows.
(9) Right-of-ways and easements are maintained in the full easement width for personnel and equipment accessibility.
(10) Documentation shall be kept for Subparagraphs (a)(1) through (a)(9) of this Rule for a minimum of three years with
exception of the map, which shall be maintained for the life of the system.
(b) Private collection systems on a single property serving an industrial facility where the domestic wastewater contribution is less than
200,000 gallons per day shall be deemed permitted.
(c) The Director may determine that a collection system should not be deemed to be permitted in accordance with this Rule and Rule
.0113 of this Subchapter. This determination shall be made in accordance with Rule .0113(e) of this Subchapter.
History Note Authority G.S 143-215 ](a), 143-215 3(a), 143-215 9B;
Eff September 1, 2006

Permit: WQCSD0203
SOC:
County: Forsyth
Region: Winston-Salem
Compliance Inspection Report
Effective: 03/01/00 Expiration: Owner: Lakeview MHP LLC
Effective: Expiration: Facility: Lakeview MHP Collection System
Contact Person: Walter B Craven Title:
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 02/02/2018 Entry Time: 09.00AM
Primary Inspector: Paul DiMatteo
Secondary Inspector(s):
Certification:
Phone: [phone]
Phone:
Exit Time: 10 OOAM
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Collection System Inspect Non Sampling
Permit Inspection Type: Deemed permitted collection system management and operation
Facility Status: ❑ Compliant E Not Compliant
Question Areas:
Miscellaneous Questions Performance Standards Operation & Maint Reqmts
Records inspections
(See attachment summary)
Page 1

Permit WQCSD0203 Owner - Facility: Lakeview MHP LLC
Inspection Date. 02/02/2018 Inspection Type - Collection System Inspect Non Sampling Reason for Visit: Routine
Inspection Summary -
We lifted the lids of 3 septic tanks in the park. No issues were noted at any of the tanks and none of them appeared to have
evidence of overflow.
Page 2

Permit: WQCSD0203 Owner - Facility Lakeview MHP LLC
Inspection Date: 02/02/2018 Inspection Type • Collection System Inspect Non,Sampling Reason for Visit: Routine
Performance Standards Yes No NA NE
Is Public Education Program for grease established and documented? ❑ 0 1:11:1
What educational tools are used?
No records of FOG material being distributed, and Mr Moger said he wasn't aware that it was done.
Is Sewer Use Ordinance/Legal Authority available? ❑ ❑ 0 ❑
Does it appear that the Sewer Use Ordinance is enforced? ❑ ❑ M ❑
Is Grease Trap Ordinance available? ❑ ❑ 0 ❑
Is Septic Tank Ordinance available (as applicable, i.e annexation) ❑ 1:10 ❑
List enforcement actions by permittee, if any, in the last 12 months
Has an acceptable Capital Improvement Plan (CIP) been implemented?
❑ 1:10 ❑
Does CIP address short term needs and long term \"master planT concepts?
❑ ❑ 0 ❑
Does CIP cover three to five year period?
❑ ❑ 0 ❑
Does CIP include Goal Statement?
❑ ❑ M ❑
Does CIP include description of project area?
❑ ❑ M ❑
Does CIP include description of existing facilities?
❑ ❑ 0 ❑
Does CIP include known deficiencies?
❑ ❑ M ❑
Does CIP include forecasted future needs?
❑ ❑ M ❑
Is CIP designated only for wastewater collection and treatment?
❑ ❑ M ❑
Approximate capital improvement budget for collection system?
Total annual revenue for wastewater collection and treatment?
CIP Comments
Is system free of known points of bypass?
0 ❑ ❑ ❑
If no, describe type of bypass and location
Is a 24-hour notification sign posted at ALL pump stations?
❑ ❑ 0 ❑
# Does the sign include.
Instructions for notification?
❑ ❑ 0 ❑
Pump station identifier?
❑ 1:10 ❑
24-hour contact numbers
❑ ❑ M ❑
If no, list deficient pump stations
No pump stations in the collection system There is one in the wastewater plant
# Do ALL pump stations have an "auto polling" feature/SCADA?
❑ ❑ 0 ❑
Number of pump stations
Number of pump stations that have SCADA
Number of pump stations that have simple telemetry
Number of pump stations that have only audible and visual alarms
Number of pump stations that do not meet permit requirements
Page 3

Permit- WQCSD0203 Owner - Facility: Lakeview MHP LLC
Inspection Date: 02/02/2018 Inspection Type. Collection System Inspect Non Sampling Reason for Visit: Routine
# Does the permittee have a root control program? 110 ❑ ❑
# If yes, date implemented?
Describe
Comment: No FOG materials are distributed.
Inspections
Are maintenance records for sewer lines available?
Are records available that document pump station inspections?
Are SCADA or telemetry equipped pump stations inspected at least once a week?
Are non-SCADA/telemetry equipped pump stations inspected every day?
Are records available that document citizen complaints?
# Do you have a system to conduct an annual observation of entire system?
# Has there been an observation of remote areas in the last year?
Are records available that document inspections of high-priority lines?
Has there been visual inspections of high-priority lines in last six months?
Comment- 1. No high Drioritv lines.
Yes No NA NE
001:113
❑❑■❑
❑ ❑ N ❑
❑ ❑ N ❑
2. Mr. Moger said that the septic tanks are on contract to be Dumped once/year, and last
pumped
in December. He did not have the records on hand. I recommended checking the tanks
periodically to assess whether additional pumping may be needed.
3. There was no documentation demonstrating compliance with the annual observation
requirement.
Operation & Maintenance Requirements
Yes No NA NE
Are all log books available?
❑ 0 ❑ ❑
Does superviscr review all log books on a regular basis?
❑ ❑ 0 ❑
Does the supervisor have plans to address documented short-term problem areas?
❑ ❑ 0 ❑
What is the schedule for reviewing inspection, maintenance, & operations logs and problem areas?
N/A
Are maintenance records for equipment available?
❑ ❑ M ❑
Is a schedule maintained for testing emergency/standby equipment?
❑ 1:10 ❑
What is the schedule for testing emergency/standby equipment?
Do pump station logs include
Inside and outside cleaning and debris removal?
❑ ❑ ❑
Inspecting and exercising all valves?
❑ ❑ N ❑
Inspecting and lubricating pumps and other equipment?
❑ ❑ M ❑
Inspecting alarms, telemetry and auxiliary equipment?
❑ ❑ N ❑
Is there at least one spare pump for each pump station w/o pump reliability?
❑ ❑ N ❑
Are maintenance records for right-of-ways available?
❑ M ❑ ❑
Are right-of-ways currently accessible in the event of an emergency?
N ❑ ❑ ❑
Are system cleaning records available?
❑ 0 ❑ ❑
Page 4

Permit: WQCSD0203 , Owner - Facility: Lakeview MHP LLC
Inspection Date. 02/02/2018 Inspection Type - Collection System Inspect Non Sampling Reason for Visit:
Routine
Has at least 10% of system been cleaned annually?
❑ 1:10 ❑
What areas are scheduled for cleaning in the next 12 months?
E ❑ ❑ ❑
Is a Spill Response Action Plan available?
❑ N ❑ ❑
Does the plan include -
❑ ❑ 0 ❑
24 -hour contact numbers
❑ 0 ❑ ❑
Response time
❑ 0 ❑ ❑
Equipment list and spare parts inventory
❑ N ❑ ❑
Access to cleaning equipment
❑ E ❑ ❑
Access to construction crews, contractors, and/or engineers
❑ E ❑ ❑
Source of emergency funds
❑ 0 ❑ ❑
Site sanitation and cleanup materials
❑ N ❑ ❑
Post-overflow/spill assessment
❑ N ❑ ❑
Is a Spill Response Action Plan available for all personnel?
❑ ❑ N ❑
Is the spare parts inventory adequate?
❑ ❑ 0 ❑
Comment: There was no spill action plan or any other log books I discussed the requirements with Mr
Moger. The only pump station is Inside the wastewater treatment plant.
Records Yes No NA NE
Are adequate records of all SSOs, spills and complaints available? ❑ ❑ N ❑
Are records of SSOs that are under the reportable threshold available? ❑ ❑ N ❑
Do spill records indicate repeated overflows (2 or more in 12 months) at same location? 1:11:1 N ❑
If yes, is there a corrective action plan? ❑ ❑ 0 ❑
Is a map of the system available? 0 ❑ 111:1
Does the map include.
Pipe sizes
❑ ❑ 0 ❑
Pipe materials
❑ ❑ 0 ❑
Pipe location
E ❑ ❑ ❑
Flow direction
N ❑ ❑ ❑
Approximate pipe age
❑ ❑ 0 ❑
Number of service taps
❑ ❑ ❑
Pump stations and capacity
❑ ❑ ❑
If no, what percent is complete?
List any modifications and extensions that need to be added to the map
A copy of an approximate map was submitted in January, 2012
# Does the permittee have a copy of their permit? ❑ ❑ ❑
Comment: Mr. Moger said he was not aware of any spills occurring outside the wastewater treatment plant
in recent years He also did not have a copy of the collection system map on-site. I suggested
contacting the company that drew the map in 2012 to try and obtain a copy. He also took
pictures of our Coln with his phone.
Page 5

Permit: WQCSD0203 Owner - Facility. Lakeview MHP LLC
Inspection Date 02/02/2018 Inspection Type • Collection System Inspect Non Sampling Reason for Visit- Routine
Page 6