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U.S. ENVIRONMENTAL PROTECTION AGENCY REGION III CLEAN WATER ACT COMPLIANCE INSPECTION REPORT for Name of Facility: Hill Mobile Home Park Sewage Treatment Plant Facility Address: Intersection of Lakewood Road and A.P. Hill Boulevard, Bowling Green, VA 22427 Mailing Address: 5805 Staples Mill Road, Richmond,VA23228 Report Prepared on: 12/22/2020 Date Report Final as of: 12/23/20 Date By: Signature STACIE PRATT By: Signature Digitally signed by STACIE PRATT Date: 2020.12.23 07:57:02 -05'00' , PG , EPA General Information Type of Inspection: Owner: Operator: Permittee: NPDES Permit No: NPDES Permit Effective Date: NPDES Permit Expiration Date: Receiving Water and/or MS4: Latitude and Longitude: Wastewater Treatment Plant CEI Six-O-Five Mobile Home Group, LLC Raynor Environmental Enterprises (REE) Six-O-Five Mobile Home Group, LLC VA0090689 July 1, 2016 June 30, 2021 Unnamed tributary to Maracossic Creek, to York River 38 03' 51" N, 77 19' 52" W On-Facility Inspection Overview On October 29, 2020, U.S. Environmental Protection Agency (EPA) Region III's contract inspector from PG Environmental, (hereinafter referred to as Inspector) inspected the Hill Mobile Home Park Sewage Treatment Plant (hereinafter, STP or Plant) in Bowling Green, Virginia. Six-O-Five Mobile Home Group, LLC owns the STP and collection system and is the permit holder. REE has been hired to contract operate the Plant. The Inspector was joined by members from EPA, the Virginia Department of Environmental Quality (VDEQ), and Discharger representatives (as listed in the Introduction section of the report). Approximate Entry Time: 10:00 AM (EDT) Approximate Exit Time: 11:20 AM (EDT) U.S. Environmental Protection Agency, Region III 1650 Arch Street Philadelphia, PA 19103 WASTEWATER TREATMENT FACILITY COMPLIANCE EVALUATION INSPECTION Hill Mobile Home Park Sewage Treatment Plant VPDES Permit No. VA0090689 INSPECTION REPORT Inspection Date: October 29, 2020 Report Date: December 22, 2020 Hill Mobile Home Park STP (VA0090689) Compliance Evaluation Inspection Report EXECUTIVE SUMMARY Hill Mobile Home Park Sewage Treatment Plant (VPDES Permit No. VA0090689) On October 29, 2020, U.S. Environmental Protection Agency (EPA) Region III's contract inspector from PG Environmental, (hereinafter referred to as Inspector) inspected the Hill Mobile Home Park Sewage Treatment Plant (hereinafter, STP or Plant) in Bowling Green, Virginia. Six-O-Five Mobile Home Group, LLC (hereinafter, Discharger) owns the STP and collection system and is the permit holder. REE has been hired to contract operate the Plant. The Inspector was joined by members from EPA, the Virginia Department of Environmental Quality (VDEQ), and Discharger representatives (as listed in the Introduction section of the report). The Plant is a sequence batch reactor (SBR) style package treatment plant designed to provide secondary level treatment of domestic wastewater for a local mobile home park. There are about 15 units at the mobile home park and a population of between 45 to 60 residents. The Plant has a design capacity of 5,000 gallons per day. Flow from the mobile home park is conveyed via gravity to an old septic tank that has been converted into a collection tank for wastewater, prior to it being pumped to the SBR for treatment. Some minimal settling may occur in the collection tank. The SBR process consists of the following phases: fill, interact/react, settle, and decant. Following the decant cycle, flow is sent to a chlorination chamber, holding tank, aeration chamber, and then dechlorinated at Outfall 001 to the unnamed tributary to Maracossic Creek. The Plant typically discharges approximately ten (10) 381-gallon batches per day. Solids from the SBR process are collected in a waste tank at the east end of SBR unit. Wastes solids are pumped out and hauled off by contractor as needed. REE took over operations at the Plant in June 2020. At that time, the Discharger had already been issued several Warning Letters and Notices of Violation (NOVs) for effluent limit violations occurring over the preceding year. The Discharger's activities are regulated under Virginia Pollutant Discharge Elimination System (VPDES) Permit No. VA0090689 (hereinafter, Permit), which became effective on July 1, 2016 and is set to expire on June 30, 2021. The primary purpose of the inspection was to review the accuracy and reliability of the Discharger's selfmonitoring and reporting program and to obtain information that will assist EPA in assessing the Discharger's compliance with the requirements of the Permit. The Inspector held discussions with Discharger representatives, conducted a detailed site inspection, and reviewed pertinent documentation regarding the Discharger's compliance with the Permit. Based on the information obtained and reviewed, the Inspector made several observations related to the specific Permit requirements evaluated. These observations are summarized in Table E1. Inspection Date: October 29, 2020 1 Hill Mobile Home Park STP (VA0090689) Compliance Evaluation Inspection Report Table E1. Summary of Permit Requirements and Inspection Observations Permit Reference Observations Permit Status and Effluent Exceedances Permit Part I.A.2 1. The Plant experienced 83 effluent limit exceedances from Outfall 001 between July 1, 2016 and September 30, 2020. 2. VDEQ issued numerous warning letters and notices of violation (NOVs) to the Discharger between September 2019 and September 2020, primarily related to effluent limit exceedances. These correspondences, including any Discharger responses and proposed corrective actions, are described in Observation 2. Permit Part I.A.1 3. The Inspector observed light brown solids directly under Outfall 001 and downstream in the receiving water. Proper Operation and Maintenance Permit Part II.Q 4. The Inspector observed turbidity and cloudiness in the effluent holding tank and post-aeration chamber. 5. Discharger representatives stated that there is no backup or auxiliary power source for the Plant. Permit Part I.C.3 6. The Plant's operations and maintenance (O&M) manual shows influent coming into the SBR in the anaerobic chamber at the east end of the system; however, the Inspector observed influent being pumped directly into the SAM tank from the wastewater collection tank. 7. The Inspector observed that effluent flow was being estimated by the operator by totaling the number of batches discharged from the SBR; this process is not described in the Plant's O&M manual. Collection System Discharger representatives stated that since they had only been onsite operating for about five months prior to the inspection, and most of that time had involved troubleshooting significant problems with the SBR, they had not yet had a chance to evaluate the collection system. Inspection Date: October 29, 2020 2 Hill Mobile Home Park STP (VA0090689) Compliance Evaluation Inspection Report TABLE OF CONTENTS Page EXECUTIVE SUMMARY........................................................................................................................... 1 I. INTRODUCTION ........................................................................................................................... 4 II. INSPECTION PROCESS ............................................................................................................... 5 Facility Site Walk ............................................................................................................................ 5 III. SUMMARY OF OBSERVATIONS................................................................................................ 6 A. Permit Status and Effluent Exceedances.............................................................................6 B. Proper Operation and Maintenance .................................................................................. 12 C. Collection System ............................................................................................................. 13 Attachment A: Photograph Log Attachment B: Exhibit Log Inspection Date: October 29, 2020 3 Hill Mobile Home Park STP (VA0090689) Compliance Evaluation Inspection Report I. INTRODUCTION On October 29, 2020, U.S. Environmental Protection Agency (EPA) Region III's contract inspector from PG Environmental, (hereinafter referred to as Inspector) inspected the Hill Mobile Home Park Sewage Treatment Plant (hereinafter, STP or Plant) in Bowling Green, Virginia. Six-O-Five Mobile Home Group, LLC owns the STP and collection system and is the permit holder. REE has been hired to contract operate the Plant. The Inspector was accompanied by a representative from EPA Region III as well as a representative from the Virginia Department of Environmental Quality (VDEQ). The primary purpose of the inspection was to review the accuracy and reliability of the Discharger's self-monitoring and reporting program as well as the operation and maintenance of the STP. The weather at the time of the inspection was cool, with periods of heavy precipitation. The Plant is a sequence batch reactor (SBR) style package treatment plant designed to provide secondary level treatment of domestic wastewater for a local mobile home park. There are about 15 homes and between 45 to 60 residents at the mobile home park. The Plant has a design capacity of 5,000 gallons per day. Flow from the mobile home park is conveyed via gravity to an old septic tank that has been converted into a centralized collection tank for wastewater, prior to it being pumped to the SBR for treatment. Some minimal settling may occur in the collection tank. The SBR process consists of the following phases: Fill: Influent fills into an anoxic tank at the head of the SBR unit (referred to as the SAM tank). The fill cycle is flow dependent. The SBR will continue to fill and mix until the system is full. This could take anywhere from 1 to 4 hours depending on time of day and flow conditions. Interact: Wastewater flows into the aeration chamber where air is cycled on and off to promote denitrification. The SBR will continue to react until the system has enough wastewater for a batch (381 gallons). This could take anywhere from 1 to 4 hours depending on time of day and flow conditions. Settle: Air delivery is stopped, and solids settle out of the effluent for 40 minutes. Decant: At the end of the 40-minute decant cycle, and automated solenoid valve is opened at the west side of the SBR unit, and effluent is decanted from the top of the tank for 10 to 11 minutes. Following the decant cycle, flow is sent to a chlorination chamber, holding tank, aeration chamber, and then dechlorinated at Outfall 001 to the unnamed tributary to Maracossic Creek. The Plant typically discharges approximately ten (10) 381-gallon batches per day. Solids from the SBR process are collected in a waste tank at the east end of SBR unit. Waste solids are pumped out and hauled off by contractor as needed. The Plant is covered under Virginia Pollutant Discharge Elimination System (VPDES) Permit No. VA0090689, which became effective on July 1, 2016 and is set to expire on June 30, 2021 (refer to Attachment B, Exhibit 1). Refer to Attachment B, Exhibit 2 for the Plant operation and maintenance (O&M) manual, which includes diagrams of the facility. Inspection Date: October 29, 2020 4 Hill Mobile Home Park STP (VA0090689) Compliance Evaluation Inspection Report The following personnel were involved in the inspection: Hiway Mobile Home Community, LLC Representatives: Matthew Raynor, Owner Representative, Director, Raynor Environmental Enterprises (REE) John Shook, Operator, REE EPA Inspectors: Jake Albright, PG Environmental (contractor) Shane McAleer, EPA Region III VDEQ Representative: Rebecca Johnson, Senior Water Compliance Inspector II. INSPECTION PROCESS The Inspector held discussions with Discharger representatives, conducted a detailed site inspection, and conducted a records review of pertinent documentation regarding the Discharger's compliance with the Permit. This report documents the Inspector's observations. Facility Site Walk As part of the process, the Inspector visually observed the treatment train and site conditions in the presence of EPA, VDEQ, and Discharger representatives. The treatment train consists of: A wastewater collection tank; A three chambered (including waste solids chamber), 5,000-gallon capacity SBR system Chlorination chamber; Effluent holding tank; Post-aeration chamber; and Dechlorination. The Inspector also viewed Outfall 001 and the receiving water. Records Review The Inspector conducted a records review to evaluate the Discharger's compliance with the Permit. Most of the records and reports required by the Permit were available for review onsite. The Plants O&M manual and discharge monitoring reports were provided electronically and reviewed offsite after the onsite inspection. The following were reviewed: Plant O&M manual (addendum date July 28, 2020); Electronic Discharge Monitoring Report (eDMR) data during the period from July 2016 through September 2020; pH meter, colorimeter, and dissolved oxygen (DO) meter calibration records (June 1, 2020 to date of inspection) and equipment manuals; Operations log (June 1, 2020 to date of inspection); Field data collection sheets (Compliance and Process Control; June 1, 2020 to date of inspection); Spot check of 2020 contract laboratory chain-of-custodies. Inspection Date: October 29, 2020 5 Hill Mobile Home Park STP (VA0090689) Compliance Evaluation Inspection Report III. SUMMARY OF OBSERVATIONS The following section summarizes the Inspector's observations relative to the Discharger's Permit requirements, including the status of certain treatment units, operation and maintenance practices, and the Discharger's monitoring and reporting. A. Permit Status and Effluent Exceedances Part I.A.2 of the Permit defines effluent limitations and monitoring requirements for Outfall 001 discharges. According to EPA's Integrated Compliance Information System (ICIS) database, the Plant experienced 83 effluent limit exceedances from Outfall 001 between July 1, 2016 and September 30, 2020 (i.e., since the Permit took effect, refer to Attachment B, Exhibit 3). VDEQ issued a series of Warning Letters and Notices of Violation (NOVs) to the Discharger during that time period for effluent exceedances (refer to Attachment B, Exhibits 4 and 5, respectively). EPA's Enforcement and Compliance History Online (ECHO) Database indicates the Plant was in a state of significant noncompliance (SNC) continuously between July 1, 2019 and June 30, 2020. ECHO indicated that violations had been identified during the quarter encompassing the date of the inspection but did not indicate SNC. Table 1. Outfall 001 Final Effluent Exceedances (July 1, 2016 through September 30, 2020) Permit # Monitoring Period End Date Parameter Name DMR Value Permit Limit Units Limit Type VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 6/30/2019 7/31/2019 7/31/2019 8/31/2019 8/31/2019 8/31/2019 9/30/2019 10/31/2019 10/31/2019 10/31/2019 10/31/2019 10/31/2019 10/31/2019 10/31/2019 10/31/2019 BOD, carbonaceous [5 day, 20 C] Solids, total suspended Phosphorus, total [as P] Solids, total suspended Solids, total suspended Solids, total suspended Phosphorus, total [as P] Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Nitrogen, Kjeldahl, total [as N] Nitrogen, Kjeldahl, total [as N] Nitrogen, Kjeldahl, total [as N] Nitrogen, Kjeldahl, total [as N] 18 14 3.91 0.26 17.3 17.3 4.48 0.386 0.386 51 51 0.1 0.1 14.16 14.16 15 mg/L Monthly Average 10 mg/L Weekly Average 2.0 mg/L Monthly Average 0.19 kg/d Monthly Average 10 mg/L Monthly Average 15 mg/L Weekly Average 2.0 mg/L Monthly Average 0.19 kg/d Monthly Average 0.28 kg/d Weekly Average 10 mg/L Monthly Average 15 mg/L Weekly Average 0.09 kg/d Weekly Average 0.06 kg/d Monthly Average 3.0 mg/L Monthly Average 4.5 mg/L Weekly Average Inspection Date: October 29, 2020 6 Hill Mobile Home Park STP (VA0090689) Compliance Evaluation Inspection Report Permit # Monitoring Period End Date Parameter Name VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 11/30/2019 11/30/2019 11/30/2019 12/31/2019 12/31/2019 12/31/2019 12/31/2019 12/31/2019 12/31/2019 1/31/2020 1/31/2020 1/31/2020 1/31/2020 1/31/2020 1/31/2020 1/31/2020 1/31/2020 1/31/2020 1/31/2020 1/31/2020 2/29/2020 2/29/2020 3/31/2020 3/31/2020 3/31/2020 3/31/2020 3/31/2020 Solids, total suspended Solids, total suspended Solids, total suspended Nitrogen, Kjeldahl, total [as N] Nitrogen, Kjeldahl, total [as N] Nitrogen, Kjeldahl, total [as N] Nitrogen, Kjeldahl, total [as N] Solids, total suspended Solids, total suspended Phosphorus, total [as P] Solids, total suspended Solids, total suspended Solids, total suspended Nitrogen, Kjeldahl, total [as N] Nitrogen, Kjeldahl, total [as N] Nitrogen, Kjeldahl, total [as N] Nitrogen, Kjeldahl, total [as N] BOD, carbonaceous [5 day, 20 C] BOD, carbonaceous [5 day, 20 C] BOD, carbonaceous [5 day, 20 C] Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Nitrogen, Kjeldahl, total [as N] DMR Value 0.23 21 21 0.31 0.31 21.42 21.42 24 24 3.95 0.24 20.8 20.8 0.18 0.18 16.58 16.58 0.22 20 20 0.21 14 0.43 0.43 29 29 0.15 7 Permit Limit 0.19 10 15 0.09 0.06 3.0 4.5 10 15 2.0 0.19 10 15 0.09 0.06 3.0 4.5 0.19 15 10 0.19 10 0.19 0.28 10 15 0.09 Units Limit Type kg/d mg/L mg/L kg/d kg/d mg/L mg/L mg/L mg/L mg/L kg/d mg/L Monthly Average Monthly Average Weekly Average Weekly Average Monthly Average Monthly Average Weekly Average Monthly Average Weekly Average Monthly Average Monthly Average Monthly Average mg/L Weekly Average kg/d Weekly Average kg/d Monthly Average mg/L Monthly Average mg/L Weekly Average kg/d Monthly Average mg/L Weekly Average mg/L Monthly Average kg/d Monthly Average mg/L Monthly Average kg/d Monthly Average kg/d Weekly Average mg/L Monthly Average mg/L Weekly Average kg/d Weekly Average Inspection Date: October 29, 2020 Hill Mobile Home Park STP (VA0090689) Compliance Evaluation Inspection Report Permit # Monitoring Period End Date Parameter Name VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 3/31/2020 3/31/2020 3/31/2020 4/30/2020 6/30/2020 6/30/2020 6/30/2020 6/30/2020 6/30/2020 6/30/2020 6/30/2020 6/30/2020 6/30/2020 6/30/2020 6/30/2020 7/31/2020 7/31/2020 7/31/2020 7/31/2020 7/31/2020 7/31/2020 7/31/2020 7/31/2020 8/31/2020 8/31/2020 8/31/2020 Nitrogen, Kjeldahl, total [as N] Nitrogen, Kjeldahl, total [as N] Nitrogen, Kjeldahl, total [as N] Nitrogen, Kjeldahl, total [as N] Nitrogen, Kjeldahl, total [as N] Nitrogen, Kjeldahl, total [as N] Nitrogen, Kjeldahl, total [as N] Nitrogen, Kjeldahl, total [as N] Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended BOD, carbonaceous [5 day, 20 C] BOD, carbonaceous [5 day, 20 C] BOD, carbonaceous [5 day, 20 C] Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Nitrogen, Kjeldahl, total [as N] Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] BOD, carbonaceous [5 day, 20 C] Nitrogen, Kjeldahl, total [as N] Nitrogen, Kjeldahl, total [as N] Nitrogen, Kjeldahl, total [as N] DMR Value 0.15 10.06 10.06 4.23 0.13 0.13 7.79 7.79 0.84 0.84 72 72 0.26 22 22 0.72 0.9 54 68 5.93 3.98 3.92 11 0.16 0.1 21.95 8 Permit Limit Units Limit Type 0.06 kg/d Monthly Average 3.0 mg/L Monthly Average 4.5 mg/L Weekly Average 3.0 mg/L Monthly Average 0.09 kg/d Weekly Average 0.06 kg/d Monthly Average 4.5 mg/L Weekly Average 3.0 mg/L Monthly Average 0.19 kg/d Monthly Average 0.28 kg/d Weekly Average 10 mg/L Monthly Average 15 mg/L Weekly Average 0.19 kg/d Monthly Average 15 mg/L Weekly Average 10 mg/L Monthly Average 0.19 kg/d Monthly Average 0.28 kg/d Weekly Average 10 mg/L Monthly Average 15 mg/L Weekly Average 4.5 mg/L Weekly Average 3.0 mg/L Monthly Average 2.0 mg/L Monthly Average 10 mg/L Monthly Average 0.09 kg/d Weekly Average 0.06 kg/d Monthly Average 4.5 mg/L Weekly Average Inspection Date: October 29, 2020 Hill Mobile Home Park STP (VA0090689) Compliance Evaluation Inspection Report Permit # Monitoring Period End Date Parameter Name VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 8/31/2020 8/31/2020 8/31/2020 8/31/2020 8/31/2020 9/30/2020 9/30/2020 9/30/2020 9/30/2020 9/30/2020 9/30/2020 9/30/2020 9/30/2020 9/30/2020 9/30/2020 Nitrogen, Kjeldahl, total [as N] Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Nitrogen, Kjeldahl, total [as N] Nitrogen, Kjeldahl, total [as N] Nitrogen, Kjeldahl, total [as N] Nitrogen, Kjeldahl, total [as N] Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended BOD, carbonaceous [5 day, 20 C] BOD, carbonaceous [5 day, 20 C] DMR Value 14.18 0.5 0.52 78.5 85 0.19 0.11 101.4 73 0.11 0.19 14.69 26 25 15 Permit Limit Units Limit Type 3.0 mg/L Monthly Average 0.19 kg/d Monthly Average 0.28 kg/d Weekly Average 10 mg/L Monthly Average 15 mg/L Weekly Average 0.09 kg/d Weekly Average 0.06 kg/d Monthly Average 4.5 mg/L Weekly Average 3.0 mg/L Monthly Average 0.19 kg/d Monthly Average 0.28 kg/d Weekly Average 10 mg/L Monthly Average 15 mg/L Weekly Average 15 mg/L Weekly Average 10 mg/L Monthly Average In addition to the exceedances listed above, the ICIS data also indicates the Discharger failed to report total nitrogen monitoring for December 2019. October 2020 eDMR data and monitoring results were not available at the time of the inspection. As stated in Observation 1, VDEQ issued Warning Letters and NOVs in response to the Discharger's noncompliance. See Table 2 for a summary of this correspondence. Operator responses are included in Attachment B, Exhibit 6, where applicable. Responses from both the former Plant operator and the current operator (REE) indicate that continuous adjustments had to be made at the STP, including modifying SBR cycle times and trying to optimize the Plant's biomass; however, exceedances continued to occur. Correspondence Type Warning Letter Table 2. Summary Date September 30, 2019 of VDEQ/Discharger Compliance Correspondence Description Operator Response Correspondence cites various June 2019 and July 2019 effluent exceedances for TSS, total phosphorus, and CBOD5. Not provided Inspection Date: October 29, 2020 9 Hill Mobile Home Park STP (VA0090689) Compliance Evaluation Inspection Report Correspondence Type Date Description Warning Letter October 24, 2019 Correspondence cites various August 2019 effluent exceedances for TSS. Warning Letter November 22, 2019 Correspondence cites a September 2019 exceedance for total phosphorus. NOV NOV January 3, 2019 Correspondence cites various October 2019 effluent exceedances for TSS and TKN, as well as observations from an October compliance inspection by VDEQ. Observations included solids in the receiving water, overgrown grass inside the treatment facility fence, inadequate aeration in the SBR treatment unit, and the biomass in the SBR was gray and had a raw influent aroma. January 26, 2020 Correspondence cites various November 2019 effluent exceedances for TSS. Operator Response The former Plant operator stated TSS exceedances were believed to be due to a power failure preventing the SBR system from resetting, creating a temporary loss of treatment and disrupting the biomass. The email states the operator reset the system and began adding supplemental bacteria and extending the reaction time/aeration and mixing to aid in recovery. The previous Plant operator stated they pumped out the anoxic tank and going forward would increase alum dosage and extend the settling cycle time in the SBR. The previous Plant operator responded that they inspected the receiving stream and could not verify any solids loss of the magnitude displayed in described in the report. The operator acknowledged there were some treatment concerns at the time that had were in the process of being addressed, including adding supplemental bacteria to accelerate recovery of the biomass, which the operator believed may have created a toxic shock to the system. He further states that the PLC was checked and they began adding soda ash for pH adjustments as well as supplementing the food source with moderate amounts of sugar to aid in the biomass recovery. Not provided Inspection Date: October 29, 2020 10 Hill Mobile Home Park STP (VA0090689) Compliance Evaluation Inspection Report Correspondence Type NOV NOV NOV NOV NOV Date March 3, 2020 May 19, 2020 June 15, 2020 August 25, 2020 September 22, 2020 Description Correspondence cites various December 2019 effluent exceedances for TSS and TKN, as well as a missed sample for total nitrogen. Correspondence cites various March 2020 effluent exceedances for TSS and TKN. Correspondence cites an April 2020 exceedance for TKN. Correspondence cites various June 2020 effluent exceedances for TSS, TKN, and CBOD5. Correspondence cites various July 2020 effluent exceedances for TSS, total phosphorus, TKN, and CBOD5. Operator Response Not provided Not provided Not provided REE responded that they had made changes to correct operating issues with the programmable logic controller (PLC) that controls the SBR. REE responded stating that July 2020 was full of problems with PLC adjustments, which disrupted the SBR biomass and required reseeding and trying to constantly restart the plant. The email also states the Plant had issues in August due to problems with the influent line, pumps and tanks. Part I.A.1 of the Permit states, "There shall be no discharge of floating solids or visible foam in other than trace amount." The Inspector observed light-colored brown solids in the unnamed tributary to Maracossic Creek, immediately under Outfall 001 and at least 40 to 50 feet downstream (refer to Attachment A, Photographs 12 through 16). The solids appeared different than the natural material in the creek bed. There was no observable odor at the time of the inspection. The Inspector also observed turbidity in the post-aeration chamber and effluent holding tank (refer to Attachment A, Photographs 9 through 11), which are both located upstream of Outfall 001 and downstream of where effluent is decanted from the SBR system. Solids in the treatment train are further discussed in Observation 4. A VDEQ inspector made a similar observation during an October 2019 compliance inspection; the operator was not present at the time of the VDEQ inspection. The inspector also noted a "raw influent aroma" was present (refer to Attachment B, Exhibit 7 for a copy of the inspection report). At that time, REE was not operating the plant. The previous operator responded to the VDEQ inspector's observation via email, stating that the receiving stream was re-inspected and the operator could not Inspection Date: October 29, 2020 11 Hill Mobile Home Park STP (VA0090689) Compliance Evaluation Inspection Report verify any solids loss at the magnitude shown in the report. It does not appear any photographs were provided to support this. The email does acknowledge other potential issues going on at the Plant at the time the email was written (November 15, 2019; refer to Attachment B, Exhibit 6). As shown in Observation 1, the Plant had TSS exceedances during 12 of the 15 months between July 2019 and September 2020, including in October 2019. B. Proper Operation and Maintenance Permit Part II.Q requires the permittee to, "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 terms of and conditions of this permit. Proper operation and maintenance also includes effective plant performance, adequate funding, adequate licensed operator staffing, and adequate laboratory and process controls, including appropriate quality assurance procedures. This provision requires the operation of back-up or auxiliary facilities or similar systems which are installed by the permittee only when the operation is necessary to achieve compliance with the conditions of this permit." Calibration records, daily log sheets, the Plant operator logbook, and laboratory chain of custodies were reviewed onsite. Examples of documentation are provided in (Attachment B, Exhibit 8). As stated in Observation 3, turbidity and cloudiness were observed in the effluent holding tank and post-aeration chamber (refer to Attachment A, Photographs 9 through 11), and light-colored solids were observed downstream of Outfall 001 (refer to Attachment A, Photographs 12 through 16). The Discharger representatives stated that they were unsure of exactly what was causing the turbidity downstream of the decant location but guessed that it may be related to the chlorine tablets not dissolving fully. As shown in Observation 1, the Plant had TSS exceedances during 12 of the 15 months between July 2019 and September 2020. Discharger representatives stated that there is no backup or auxiliary power source for the Plant. They explained that in the event of a prolonged power outage, wastewater would be held in the wastewater collection tank and collection system and would overflow once capacity is exceeded. As shown in Observation 2, the previous Plant operator attributed August 2019 TSS exceedances to a power failure event that prevented the SBR from resetting, comprising treatment effectiveness. Permit Part I.C.3 states, "The permittee shall maintain a current Operations and Maintenance (O&M) Manual for the treatment works that is in accordance with Virginia Pollutant Discharge Elimination System Regulations, 9VAC25-31 and (for sewage treatment plants) Sewage Collection and Treatment Regulations, 9VAC25-790... The O&M manual shall detail the practices and procedures which will be followed to ensure compliance with the requirements of this permit. This manual shall include, but not necessarily be limited to, the following items, as appropriate: a. Permitted outfall locations and techniques to be employed in the collection, preservation, and analysis of effluent, storm water and sludge samples; Inspection Date: October 29, 2020 12 Hill Mobile Home Park STP (VA0090689) Compliance Evaluation Inspection Report b. Procedures for measuring and recording the duration and volume of treated wastewater discharged; c. Discussion of Best Management Practices, if applicable; d. Procedures for handling, storing, and disposing of all wastes, fluids, and pollutants characterized in Part I B 8 that will prevent these materials from reaching state waters. List type and quantity of wastes, fluids, and pollutants (e.g. chemicals) stored at this facility; e. Discussion of treatment works design, treatment works operation, routine preventative maintenance of units within the treatment works, critical spare parts inventory, and record keeping; f. Plan for the management and/or disposal of waste solids and residues; g. Hours of operation and staffing requirements for the plant to ensure effective operation of the treatment works and maintain permit compliance; h. List of facility, local and state emergency contacts; and i. Procedures for reporting and responding to any spills/overflows/ treatment works upsets." The O&M manual shows influent coming into the SBR in the anaerobic chamber at the east end of the system (refer to Attachment B, Exhibit 2; page 12). The O&M manual also describes the anaerobic chamber as a location where solids can settle during the SBR process. However, at the time of the inspection, influent was being pumped from the wastewater collection tank over the anaerobic chamber, directly into the SAM tank (refer to Attachment A, Photographs 2 and 3). The O&M manual was reviewed after the inspection, and this finding was not explicitly discussed with the Discharger representatives. While onsite they stated that modifications had been made to the SBR in an effort to achieve better biomass conditions and nitrogen removal, particularly for TKN. As noted previously, the anaerobic chamber was being used to store wasted solids at the time of the inspection. The "Sampling, Lab Procedures & Reporting" section of the manual states, "For the facility, flow is reported based on daily readings of the water supply flow meters and reporting the quantity of water used during the intervening period." While onsite, the Discharger representatives stated that flow was actually calculated by totaling the number of 381-gallon batches discharged from the SBR. For example, four batches would equal a calculated flow of 1,524 gallons/day. C. Collection System The collection system was not a focus of the inspection. The Discharger representatives stated that since they had only been onsite operating for about five months prior to the inspection, and most of that time had involved troubleshooting significant problems with the SBR, they had not yet had a chance to evaluate the collection system. Inspection Date: October 29, 2020 13 Hill Mobile Home Park STP (VA0090689) Compliance Evaluation Photograph Log Attachment A Photograph Log Hill Mobile Home Park STP (VA0090689) Compliance Evaluation Photograph Log Photograph 1. View of the wastewater collection tank. Anaerobic solids chamber Influent line Influent/SAM tank Aeration chamber Photograph 2. Overview of the SBR unit. Note that the influent line comes over the solids chamber and discharges directly into the SAM tank. Inspection Date: October 29, 2020 2 Hill Mobile Home Park STP (VA0090689) Compliance Evaluation Photograph Log Influent Anaerobic solids chamber SAM tank Photograph 3. View of the influent chamber, referred to as the SAM tank. Note the location of the solids chamber. Overflow weir back to SAM tank Solenoid valve chamber Photograph 4. View of the aeration chamber. Inspection Date: October 29, 2020 3 Hill Mobile Home Park STP (VA0090689) Compliance Evaluation Photograph Log Photograph 5. View of the SBR control panel. Solenoid valve Photograph 6. View inside the solenoid valve chamber. Inspection Date: October 29, 2020 4 Hill Mobile Home Park STP (VA0090689) Compliance Evaluation Photograph Log Photograph 7. Closeup view of the solenoid valve. Note that it was red, indicating it was closed at the time of the inspection. Chlorine tablet feed Photograph 8. View inside the chlorination chamber where sodium hypochlorite tablets are fed to the effluent. Inspection Date: October 29, 2020 5 Hill Mobile Home Park STP (VA0090689) Compliance Evaluation Photograph Log Photograph 9. View of the effluent holding tank. Note the effluent in the chamber was turbid. Overflow to postaeration Photograph 10. Additional view the effluent in the holding tank. Note the turbidity. Inspection Date: October 29, 2020 6 Hill Mobile Home Park STP (VA0090689) Compliance Evaluation Photograph Log Photograph 11. View inside the post aeration chamber. Note that the effluent appeared cloudy. Outfall 001 Lightcolored solids Photograph 12. View of dechlorination tablet feed at Outfall 001. Note the presence of lightcolored brown solids just under the outfall. Inspection Date: October 29, 2020 7 Hill Mobile Home Park STP (VA0090689) Compliance Evaluation Photograph Log Lightcolored solids Photograph 13. View downstream of Outfall 001. Note the light-colored solids in the unnamed tributary. Lightcolored solids Photograph 14. Additional view downstream of Outfall 001. Note the light-colored solids in the unnamed tributary. Inspection Date: October 29, 2020 8 Hill Mobile Home Park STP (VA0090689) Compliance Evaluation Photograph Log Lightcolored solids Photograph 15. Additional view downstream of Outfall 001. Note the light-colored solids in the unnamed tributary. Photograph 16. Close up view of the light-colored solids shown in Photograph 15. Inspection Date: October 29, 2020 9 Hill Mobile Home Park STP (VA0090689) Compliance Evaluation Inspection Exhibit Log Attachment B Exhibit Log Hill Mobile Home Park STP (VA0090689) Compliance Evaluation Inspection Exhibit Log Exhibit 1 VPDES Permit No. VA0090689 Molly Joseph Ward Secretary of Natural Resources COMMONWEALTH of VIRGINIA DEPARTMENT OF ENVIRONMENTAL QUALITY NORTHERN REGIONAL OFFICE 13901 Crown Court, Woodbridge, Virginia 22193 (703) 583-3800 www.deq.virginia.gov David K. Paylor Director Thomas A. Faha Regional Director 24 June 2016 Via email: JimmvBens0nJr@2mail.com CERTIFY RECEIPT REQUESTED Jimmy Benson Manager Member Six-O-Five Mobile Home Group, LLC 5805 Staples Mill Road Richmond, VA 23228 Re: Reissuance of VPDES Permit No. VA0090689 Hill Mobile Home Park Sewage Treatment Plant #2 Caroline County Dear Mr. Benson: The Department of Environmental Quality (DEQ) has approved the enclosed effluent limitations and monitoring requirements for the aforementioned permit. Copies of your permit and fact sheet are enclosed. A Discharge Monitoring Report (DMR) form is no longer included in the reissuance package since you are enrolled in DEQ's electronic DMR (eDMR) program. Thefirstelectronic DMR submittal for the month of July 2016 is due by 10 August 2016. Please reference the effluent limits in your permit and report monitoring results in eDMR to the same number of significant digits as are included in the permit limits for the parameter. The regional contact for eDMR is Rebecca Vice; she can be reached at 703-583-3922 or via email at Rebecca.Vicefgldeq.Virginia.gov. Please note that compliance with the permit's requirements for use and disposal of sewage sludge does not relieve you of your responsibility to comply with federal requirements set forth in 40 CFR Part 503. Until DEQ seeks and is granted authority to administer the Part 503 regulations by EPA, treatment works treating domestic sewage should continue to work directly with EPA to comply with them. For more information, you may call the EPA Region III office in Philadelphia at 215-814-5735. As provided by Rule 2A:2 of the Supreme Court of Virginia, you have thirty daysfromthe date of service (the date you actually received this decision or the date it was mailed to you, whichever occurred first) within which to appeal this decision by filing a notice of appeal in accordance with the Rules ofthe Supreme Court of Virginia with the Director, Department of Environmental Quality. In the event that this decision is served on you by mail, three days are added to that period. Alternately, any owner under 62.1-44.16, 62.1-44.17, and 62.1-44.19 of the State Water Control Law aggrieved by any action of the State Water Control Board taken without a formal hearing, or by inaction of the Board, may demand in writing a formal hearing of such owner's grievance, provided a petition requesting such hearing is filed with the Board. Said petition must meet the requirements set forth in 1.23(b) ofthe Board's Procedural Rule No. 1. In cases involving actions of the Board, such petition must befiledwithin thirty days after notice of such action is mailed to such owner by certified mail. VA0090689 Final Permit to Facility 24 June 2016 Page 2 of2 A Reliability Class II is assigned to this facility and this facility has Class III licensed operator requirements. Please contact Douglas Frasier at 703-583-3873 or via email at Douglas.Frasier@deq.virginia.gov should you have any questions concerning the permit. Respectfully, Bryant Thomas Regional Water Permits & Planning Manager Enc.: Permit for VA0090689 Fact Sheet for VA0090689 cc: DEQ-Water, OWPP EPA-Region HI, 3WP12 Department of Health, Culpeper Water Compliance, NRO William Stanley, Operator via wps2@outlook.com COMMONWEALTH of VIRGINIA DEPARTMENT OF ENVIRONMENTAL QUALITY Permit No. VA0090689 Effective Date: July 1,2016 Expiration Date: June 30,2021 AUTHORIZATION TO DISCHARGE UNDER THE VIRGINIA POLLUTANT DISCHARGE ELIMINATION SYSTEM AND THE VIRGINIA STATE WATER CONTROL LAW In compliance with the provisions of the Clean Water Act as amended and pursuant to the State Water Control Law and regulations adopted pursuant thereto, the following owner is authorized to discharge in accordance with the information submitted with the permit application, and with this permit cover page, Part I - Effluent Limitations and Monitoring Requirements, and Part II - Conditions Applicable To All VPDES Permits, as set forth herein. Owner Name: Facility Name: County: Facility Location: Six-O-Five Mobile Home Group, LLC Hill Mobile Home Park STP #2 Caroline Intersection of Lakewood Road and A.P. Hill Boulevard, Bowling Green, VA The owner is authorized to discharge to the following receiving stream: Stream Name: Maracossic Creek, UT River Basin: York River River Subbasin: None Section: 3 Class: I I I Special Standards: None Thomas A. Faha Director, Northern Regional Office Department of Environmental Quality , LKC\ <L_ c 2 < ^ C ^ O ( U Date VA0090689 Part I Page 1 of 5 A. Effluent Limitations and Monitoring Requirements Outfall 001 -0.005 MGD Facility 1 There shall be no discharge of floating solids or visible foam in other than trace amounts 2 During the period beginning with the permit's effective date and lasting until the expiration, the permittee is authorized to discharge from Outfall Number 001 Such discharges shall be limited and monitored by the permittee as specified below Parameter Discharge Limitations Monitoring Requirements Monthly Average(1) Weekly Average( l ) Minimum Maximum ( 1 ) Frequency Sample Type Flow| 2 ) (MGD) NL NA NA pH NA NA 6.0 S U. cBOD5(3) 10 mg/L 0.19 kg/day 15 mg/L 0 28 kg/day NA Total Suspended Solids (TSS)13114) 10 mg/L 0 19 kg/day 15 mg/L 0 28 kg/day NA Dissolved Oxygen NA NA 5 0 mg/L Total Kjeldahl Nitrogen (TKN) 3 0 mg/L 0.06 kg/day 4 5 mg/L 0 09 kg/day NA E. coli (Geometric Mean)(5><6) 126n/100 mL NA NA Total Residual Chlorine (after contact tank) NA NA 1 Omg/L Total Residual Chlorine (after dechlorination) 0.008 mg/L 0 010 mg/L NA N 0 2 + NO, as Nitrogen NL mg/L NA NA Total Nitrogen <7) NL mg/L NA NA Total Phosphorus 2.0 mg/L NA NA ( l ) See Part I B MGD = Million gallons per day m The design flow is 0 005 MGD NA = Not applicable | 3 > At least 85% removal for cBOD5and TSS shall be attained NL = No limit, monitor and report <4) TSS shall be expressed as two significant figures S U = Standard units (5) Between 10 AM and 4 PM. (6) The permittee shall sample and submit E. coh results at the frequency of once every week for three (3) months NL 9.0 S.U. NA NA NA NA NA NA NA NA NA NA 1/D Estimate 1/D Grab 1/M Grab 1/M Grab 1/D Grab 1/M Grab l/W Grab 1/D Grab 1/D Grab 1/YR Grab 1/YR Calculated _1/M_ Grab 1 /D = Once every day 1AV = Once every week 1/M = Once every month 1/YR = Once every calendar year If all reported results for E. coh do not exceed 126 n/lOOmL, reported as the geometric mean, the permittee may submit a written request to DEQ-NRO for a reduction in the sampling frequency to once per quarter Upon approval, the permittee shall collect four (4) samples during one month within each quarterly monitoring period as defined below The results shall be reported as the geometric mean The quarterly monitoring periods shall be January through March, April through June, July through September and October through December. The DMR shall be submitted no later than the 1 Oth day of the month following the monitoring period Should any of the quarterly monitoring results for E coh exceed 126 n/IOOmL, reported as the geometric mean, the monitoring frequency shall revert to once per week for the remainder of the permit term Total Nitrogen = Sum of TKN plus Nitrate+Nitnte Nitrate+Nitnte and TKN samples shall be taken concurrently during the same month Estimate : Reported flow is to be based on the technical evaluation ofthe sources contributing to the discharge Grab : An individual sample collected over a period of time not to exceed 15-minutes (Remainder of page intentionally left blank) VA0090689 Fartl Fage^of^ B. Additional Monitoring Requirements, Quantification Levels and Compliance Reporting 1. AdditionalTotal Residual Chlorine ^TRC^ Limitations and Monitoring Requirements a. The permittee shall monitor theTRC at the outlet ofthe chlorine contact tank once per day by grab sample. b. No more than three (3)ofthe total number of monthly samples taken at the outlet ofthe chlorine contact tank shall be less than l.Omg^L for any one calendar month. c. NoTRC sample collected at the outlet ofthe chlorine contact tank shall be less than 0.6 mg^L. d. Ifdechlorination facilities exist the samples above shall be collected prior to dechlorination. e. If dismtection is byamethod other than chlorination, ^ . ^ ^ s h a l l be limited and monitored by the permittee as specified below and this requirement, if applicable, shall substitute fortheTRC and ^ . ^ ^ requirements delineated elsewhere in Fartlof this permit. Discharge Limitations Monthly Average 126n^l00mL Geometric Mean Monitoring Frequency Requirements Cnceperweek(l^) SampleType Crab Between 1 0 A M ^ 4 R M 2. Quantification Levels a. The quantification levels (QL) shall be less than or equal to the following concentrations: Characteristic Total Suspended Solids (TSS) carbonaceous- Biochemical Oxygen Demand-5 day (cBOD5) Total Residual Chlorine (TRC) Total Kjeldahl Nitrogen (TKN) Quantification Level 1.0 mg/L 2 mg/L 0.10 mg/L 0.50 mg/L b. The QL is defined as the lowest concentration used to calibrate a measurement system in accordance with the procedures published for the method. It is the responsibility of the permittee to ensure that proper quality assurance/quality control (QA/QC) protocols are followed during the sampling and analytical procedures. QA/QC information shall be documented to confirm that appropriate analytical procedures have been used and the required QLs have been attained. The permittee shall use any method in accordance with Part II.A of this permit. 3. Compliance Reporting for Parameters in Part LA. a. Monthly Average - Compliance with the monthly average limitations and/or reporting requirements for the parameters listed in Part I.B.2.a. of this permit condition shall be determined as follows: All concentration data below the QL used for the analysis (QL must be less than or equal to the QL listed in Part I.B.2.a. above) shall be treated as zero. All concentration data equal to or above the QL used for the analysis shall be treated as it is reported. An arithmetic average shall be calculated using all reported data for the month, including the defined zeros. This arithmetic average shall be reported on the Discharge Monitoring Report (DMR) as calculated. If all data are below the QL used for the analysis, then the average shall be reported as "< QL". If reporting for quantity is required on the DMR and the reported monthly average concentration is < QL, then report "< QL" for the quantity. Otherwise, use the reported concentration data (including the defined zeros) and flow data for each sample day to determine the daily quantity and report the monthly average of the calculated daily quantities. b. Weekly Average - Compliance with the weekly average limitations and/or reporting requirements for the parameters listed in Part I.B.2.a. of this permit condition shall be determined as follows: All concentration data below the QL used for the analysis (QL must be less than or equal to the QL listed in Part I.B.2.a. above) shall be treated as zero. All concentration data equal to or above the QL used for the analysis shall be treated as reported. An arithmetic average shall be calculated using all reported data, including the defined zeros, collected within each complete calendar week and entirely contained within the reporting month. VA0090689 Parti The maximum value ofthe weekly averages thus determined shall be reported on the DMR. Ifall data are below the QL used for the analysis, then the weekly average shall be reported as"^QL". Ifreporting for quantity is required on the DMR and the reported weekly average concentration is^QL, then report"^QL"for the quantity. Otherwise use the reported concentration data (including the defined zeros)and flow data for each sample day to determine the daily quantity and report the maximum weekly average ofthe calculated daily quantities. Single Datum^Any single damm required shall be reported as"^QL"ifit is less than the QL used in the analysis (QL must be less than or equal to the QL listed in Part l.f3.2.a. above). Otherwise the numerical value shall he reported. Significant Digits-The permittee shall report at least the same number of significant digits as the permit limit fbra given parameter. Regardless of the rounding convention used by the permittee (i.e.^always rounding up or to the nearest even numbers the permittee shall use the convention consistently and shall ensure that consulting laboratories employed hy the permittee use the same convention. For total phosphorus, all daily concentration data below the quantification level(QL)for the analytical method used should he treated as half the QL. All daily concentration data equal to or above the QL for the analytical method used shall he treated as it is reported. For total nitrogen (TN), if none of the daily concentration data for me respective species (i.e.T^ are equal to or above the QL for the respective analytical methods used,the dailyTN concentration value reported shall equal one halfofthe largest QL used for the respective species. Ifone ofthe data is equal to or ahove the QL, the dailyTN concentration value shall be treated as that data point is reported. Ifmore than one ofthe data is above the QL, the dailyTN concentration value shall equal the sum ofthe data points as reported. C. Other Requirements and Special Conditions 1. Capacity Reopener Awritten notice andaplan of action for ensuring continued compliance with the terms ofthis permit shall be submitted to the DFQ-Northem Regional Office (DFQ-NRO)when the monthly average fiowinfiuent to the sewage treatment plant reaches 95^ ofthe design capacity authorized in this permit for each month ofany three consecutive month period. The written notice shall be submitted within 30 days and the plan ofaction shall be received at the DLQ-NRO no later than 90 days from the third consecutive month for which the fiow reached 95^ ofthe design capacity. The plan shall include the necessary steps andaprompt schedule ofimplementation for controlling any current or reasonably anticipated problem resulting from high influent flows. Failure to submit an adequate plan inatimely manner shall be deemedaviolation of this permit. 2. Indirect Discharges The permittee shall provide adequate notice to the Department ofthe following: a. Any new introduction ofpollutants into the treatment works from an indirect discharger which would be subject to Section 301 or 306 of CleanWater Act and the State Water Control Law i f i t were directly discharging those pollutants; and b. Any substantial change in the volume or character of pollutants being introduced into the treatment works hya source introducing pollutants into the treatment works at the time ofissuance ofthis permit. Adequate notice shall include mfbrmation on (i) the quality and quantity of effiuent introduced mto the treatm and (ii) any anticipated impact ofthe change on the quantity or quality ofeffiuent to be discharged from the treats works. (Remainder of page intentionally left blank) VA0090689 Parti Page^of^ 3. Operations and Maintenance Manual Requirement The permittee shall maintainacurrent Operations and Maintenance(O^M) Manual for the treatment works that is accordance with Virginia Pollutant Discharge Elimination System Regulations, 9VAC25-31and Sewage Collection and Treatment Regulations, 9VAC25-790. The O^M Manual and subsequent revisions shall include the manual effective date and meet Part and Part 11.K.4 Signatory Requirements ofthe permit. Any changes in the practices and procedures followed hy the permittee shall he documented in the O ^ M Manual within 90 days ofthe effective date ofthe changes. The permittee shall operate the treatment works in accordance with the O ^ M Manual and shall make the O ^ M manual available to Department personnel for review during facility inspections. Within 30 days ofarequest by DEQ, the current O^M Manual shall be submitted to the DEQ-NRO for review and approval. The O ^ M Manual shall detail the practices and procedures which will be followed to ensure compliance with the requirements ofthis permit. This manual shall include, but not necessarily be limited to, the following items, as appropriate: a. Permitted outfall locations and techniques to be employed in the collection, preservation and an storm water and sludge samples; b. Procedures for measuring and recording the duration and volume oftreated wastewater discharged; c. Discussion ofEest Management Practices, if applicable; d. Procedures for handling, storing and disposing ofall wastes, fluids and pollutants that will prevent these materials from reaching state waters. List type and quantity of wastes, fluids and pollutants(e.g.chemicals)stored at this facility; e. Discussion oftreatment works design, treatment works operation, routme preventative maintenance of units within the treatment works, critical spare parts inventory and record keeping; f. Plan for the management and/or disposal ofwaste solids and residues; g. Hours ofoperation and staffmg requirements f^r me plant to ensure effective operation of maintain permit compliance; h. List offacility,local and state emergency contacts; and i. Procedures for reporting and responding to any spills/overflows/treatment works upsets. 4. Certificate to Construct/Certificate to Operate Requirements In accordance with ^ ^ ^ C ^ ^ ^ ^ ^ ^ ^ ^ r e g u l a t i ^ to Construct(CTC)andaCertificate to Operate(CTO)from the Department ofEnvironmental Quality p r ^ constructmg wastewater treatment works and operating the treatment works, respectively. Non-compliance with the CTC or CTO shall be deemedaviolation ofthe permit. 5. Pinancial Assurance The permittee shall provide continuous coverage to implement the approved closure plan until released fr^ assurance requirements by the State Water Control Eoard. Ifatransfer of ownership or operational control ofthis facility occurs, the permittee shall comply with the requirementsof9VAC25-650 until the new owner or o ^ demonstrated compliance with the requirements of9VAC25-650. Pailure to maintain adequate financial assurance in accordance with 9VAC25-650 shall beabasis for termination of this VPDES permit. During the term ofthis VPDES permit, the permittee shall revise the closure plan implementation cost estimate concurrently with any revisi^^ the closure plan which increases the closure plan cost. Ataminimum,the permittee shall annually adjust the closure plan implementation cost estimate in accordance with 9VAC25-650 within 60 days prior to the anniversary date ofthe establishment ofthe approved financial assurance mechanism. VA0090689 Parti Page5of5 The permittee shall disclose the provisions ofthis permit to all purchasers ofproperty served by this permitted facility accordance with Section55-519ofthe Code ofVirginia. 6. Licensed Operator Requirement The permittee shall employ or contract at least one Class 111 licensed wastewater works operator for this facility. The license shall be issued in accordance withTitle 54.1 of the Code ofVirginia and Board for Waterworks and Wastewater Works Operators and Onsite Sewage System Professionals Regulations. The permittee shall notify the Department in writing whenever he is not complying, or has grounds for anticipating he will not comply with this requirement. The notification shall includeastatement of reasons andaprompt schedule for achieving compliance. 7. Reliability Class The permitted treatment works shall meet Reliability Class 11. 8. Water Quality Criteria Reopener Should effluent monitoring indicate the need for any water quality-based limitations, this permit may be modified or alternatively revoked and reissued to incorporate appropriate limitations. 9. Sludge Reopener The Board may promptly modify or revoke and reissue this permit ifany applicable standard for sewage sludge use or disposal promulgated under Section 405(d) ofthe Clean Water Act is more stringent than any requirements for sludge use or disposal in this permit, or controlsapollutant or practice not limited in this permit. 10. Sludge Use and Disposal The permittee shall conduct all sewage sludge use or disposal activities in accordance with the Sludge Management Plan (SMP) approved with the issuance ofthis permit. Any proposed changes in the sewage sludge use or disposal practices or procedures followed by the permittee shall be documented and submitted for DEQ-NRO approval 90 days prior to the effective date ofthe changes. Upon approval, the revised SMP becomes an enforceable part ofthe permit. The permit may be modified or alternatively revoked and reissued to incorporate limitations or conditions necessitated by substantive changes in sewage sludge use or disposal practices. 11. Treatment Works Closure Plan or Closure Plan Ifme permittee plans an expansion or upgrade to replace the existing treatment works, or if facilities are permane^^ closed, the permittee shall submit to the DEQ-NROaclosure plan tor the existing treatment works. The plan shall address me following information asaminimum: Verification ofeliminationofsourcesand/or alternate treatment scheme; treatment, removal and final disposition ofresidual wastewater and solids; removal/demolition/disposal of structures, equipment, pipmg and appurtenances; site grading, and erosion and sediment control; restoration vegetation; access control; fill materials; and proposed land use (post-closure)of the site. The plan should contain proposed dates for beginning and completion ofthe work. The plan must be approved by the DEQ prior to implementation. Once approved, the plan shall become an enforceable part ofthis permit and closure shall be implemented in accordance with the approved plan. No later than 14calendar days following closure completion, the permittee shall submit to the DLQ-NRO written notification of the closure completion date andacertification of closure in accordance with the approved plan. 12. Total Maximum Daily Load ^TMDL^Reopener This permit shall be modified or alternatively revoked and reissued ifany approved wasteload allocation procedure, pursuant to Section 303(d) ofthe Clean Water Act, imposes wasteload allocations, limits or conditions on the facility that are not consistent with the permit requirements. VA0090689 Part 11 Pagelof^ CONDITIONS APPLICABLE TO ALL VPOES PERMITS A. Monitoring L Samples and measurements required by this permit shall be taken at the permit designated or approved location and be representative ofthe monitored activity. a. Monitoring shall be conducted according to procedures approved underTitle 40 Code ofPederal Regulations Part 136 or alternative methods approved by theU.S. Environmental Protection Agency,unless other procedures have heen specified in this permit. h. The permittee shall periodically calibrate and perform maintenance procedures on all monitoring and anal^^ instrumentation at intervals that will insure accuracy of measurements. c. Samples taken shall be analyzed in accordance with 1VAC30-45, Certification for Noncommercial Environmental Laboratories, or 1VAC30-46, Accreditation for Commercial Environmental Laboratories. 2. Any pollutant specifically addressed by this permit that is sampled or measured at the permit designated or approved location morefrequentlythan required by this permit shall meet the requirements inAlathroughcabove and the results ofthis monitoring shall be included in the calculations and reporting required by this permit. 3. Operational or process control samples or measurements shall not be taken at the designated permit sampling or measurement locations. Operational or process control samples or measurements do not need to follow procedures approved under Title 40 Code ofPederal Regulations Part 136 or be analyzed in accordance withlVAC30-45, Certification for Noncommercial Environmental Laboratories, or 1VAC30-46, Accreditation for Commercial Environmental Laboratories. B. Records L Records ofmonitoring information shaii include: a. The date, exact place, and time ofsampling or measurements; h. The individual(s)who performed the sampling or measurements; c. The date(s)andtime(s)analyses were performed; d. The individual(s)who performed the analyses; e. The analytical techniques or methods used; and f. The results of such analyses. 2. Except for records ofmonitoring information required by this permit related to the permittees and disposal activities, which shall be retamed foraperiod of at least five years, the permittee shall retain rec all monitoring mformation,mcludmg all calibration and maintenance records and all original strip chart recordm^ mr continuous monitormg instrumentation, copies ofall reports required by this permit, and records to complete the application for mis permit, foraperiod of at least3years from the date of the sample, measurements report or application. This period ofretention shall be extended automatically during the course of any unresolved litigation regarding the regulated activity or regardmg control standards applicable to the permittee,^ by the Board. C. Reporting Monitoring Results 1. The permittee shall submit the results ofthe monitormg required by mis permit not later than thel^ month after monitoring takes place, unless another reporting schedule is specified elsewhere in this permit. VA0090689 Partll Page2of8 Monitoring results shall be submitted to: Department ofEnvironmental Quality-Northern Regional Ctfice(DEO-NRC) 13901 Crown Court Woodbridge,VA22193 2. Monitoring results shall be reported onaDischarge Monitoring Report (DMR)or on forms provided, approved or specified by the Department. 3. Calculations for all limitations which require averaging ofmeasurements shall utilize an arithmetic mean unless otherwise specified in this permit. D. Duty to Provide Information The permittee shall furnish to the Department, withinareasonable time, any information which the Board may request to determine whether cause exists for modifying, revoking and reissuing, or terminating this permit or to determine compliance with this permit. The Board may requhe the permittee to furnish, upon request, such plans, specifications, and other pertment information as may be necessary to determine the effect ofthe wastes from this discharge on the quality ofstate waters, or such omermformation as may be necessary to accomplish the purposes ofthe State Water Control Law. The permittee shall also fnmish to me Department upon request, copies ofrecords required to be kept by this permit. E. Compliance Schedule Reports Reports ofcompliance or noncompliance with, or any progress reports on, mterim and final requirements contained in any compliance schedule ofthis permit shall be submitted no later than 14daysfbllowing each schedule date. P. Unauthorized Discharges Except in compliance with this permit, or anomer permit issued by the Board, it shall be unlawful for any person to: 1. Discharge into state waters sewage, industrial wastes, other wastes, or any noxious or deleterious substances; or 2. Otherwise alter the physical, chemical or biological properties of such state waters and make them detrimental to the public health, or to animal or aquatic life, or to the use ofsuch waters for domestic or industrial consumption, or for recreation, or for other uses. G. Reports ofUnauthorized Discharges Any permittee who discharges or causes or allowsadischarge o^sewage, industrial waste, other wastes or any noxious or deleterious substance into or upon state waters in violation ofPart 11.P.; or who discharges or causes or allowsa discharge that may reasonably be expected to enter state waters in violation ofPartll.P.,shall notify the Department of me discharge immediately upon discovery of the discharge, butmno case later than24hours after said discovery. A written report ofthe unauthorized discharge shall be submitted to me Department, within five days of discove discharge. The written report shall contain: 1. Adescription ofthe nature and location of the discharge; 2. The cause ofthe discharge; 3. The date on which the discharge occurred; 4. The length oftime that the discharge continued; 5. The volume ofthe discharge; 6. Ifthe discharge is continuing, how long it is expected to continue; 7. If the discharge is continuing,what the expected total volume of the discharge will be; and VA0090689 Fartll Fage3of8 8. Any steps planned or taken to reduce, eliminate and preventarecurrence of the present discharge or any fhture discharges not authorized by this permit. Discharges reportable to the Department under the immediate reporting requirements ofother regulations are exempted from this requirement. H. ReportsofUnusualor Extraordinary Discharges If any unusual or extraordinary discharge includingabypass or upset should occur fromatreatment works and the discharge enters or could be expected to enter state waters, the permittee shall promptly notify,in no case later than24 hours, the Department hy telephone after the discovery ofthe discharge. This notification shall provide all available details ofthe incident, including any adverse affects on aquatic life and the known number offish killed. The permittee shall reduce the report to writing and shall submit it to the Department within five days ofdiscovery ofthe discharge in accordance with Part 11.1.2. Unusual and extraordinary discharges include but are not limited to any discharge resulting from: 1. Unusual spillage ofmaterials resulting directly or indirectly from processing operations; 2. Breakdown ofprocessing or accessory equipment; 3. Failure or taking out ofservice some or all ofthe treatment works; and 4. Flooding or other acts of nature. L Reports ofNoncompliance The permittee shall report any noncompliance which may adversely affect state waters or may endanger puhlic health. 1. An oral report shall be provided within24hours from the time the permittee becomes aware of the circumstances. The following shall be mcluded as mformation which shall be reported within24 hours under this paragraph: a. Any unanticipated bypass; and b. Any upset which causesadischarge to surface waters. 2. A written report shall be submitted within^days and shall contain: a. Adescription of the noncompliance and its cause; b. The period ofnoncompliance, including exact dates and times, and it^the noncompliance has not been corrected, the anticipated time it is expected to continue; and c. Steps taken or planned to reduce, eliminate, and prevent reoccurrence ofthe noncompliance. The Board may waive the written report onacase-by-case basis for reports of noncompliance under Fart 11.1.if the oral report has been received within24 hours and no adverse impact on state waters has been reported. 3. The permittee shall report all mstancesofnoncompliance not reported under Farts 11, l.l.or 1.2., in writing, at the time the next monitoring reports are submitted. The reports shall contain the information listed in Fart 11.1.2. NOTE: The immediate(within24hours)reports required in Farts 11, 0.,fl.and 1.may he made to the Deparm^ Northern Regional Office at (703)583-3800 or online at httn^/www.deti.vir^inia.gov/Fro^rams/FollutionResponseFreparedness/Makin^aRe^ort.aspx. For reports outside normal workmg hours, leaveamessage and this shall fulfill the immediate reporting requirement. For emergencies, the Virginia Department ofEmergency Services maintainsa24-hour telephone service atl-800-4688892 VA0090689 Fartll Fage4of8 Notice ofFlanned Changes 1. The permittee shall give notice to the Department as soon as possible ofany planned physical alterations or additions to the permitted facility. Notice is required only when: a. The permittee plans alteration or addition to any building, strucmre,facility,or installation from which th^ or may headischarge of pollutants, the construction of which commenced: 1) After promulgation of standards of performance under Section 306 ofCleanWater Act which are applicable to such source; or 2) Afterproposalofstandardsofperformance in accordance with Section 306 ofClean Water Act which are applicable to such source, hut only ifthe standards are promulgated in accordance with Section 306 within 120 days of their proposal; b. The alteration or addition could significantly change the nature or increase the quantity of pollutants discharged. This notification applies to pollutants which are subject neither to effluent limitations nor to notification requirements specified elsewhere in this permit; or c. The alteration or addition results inasignificant change in the permittee's sludge use or disposal practices, and such alteration, addition, or change may^ustify the application ofpermit conditions that are different from or absent in the existing permit, including notification ofadditional use or disposal sites not reported during the permit application process or not reported pursuant to an approved land application plan. 2. The permittee shall give advance notice to the Department ofany planned changes in the permitted facility activity which may result in noncompliance with permit requirements. R. Signatory Requirements 1. Applications. All permit applications shall be signed as follows: a. Foracorporation:byaresponsible corporate officer. For the purpose ofthis section,aresponsible corporate officer means: 1) Apresident,secretary,treasurer, or vice-president of the corporation in charge ofaprincipal business function, or any omer person who performs similar policy-or decision-making functions fbrthe corporation, or 2) The manager ofone or more manufacturmg, production, or operatmg facilities, provided the manager is aumorized to make management decisions which govern the operation ot^the regulated tacility including having the explicit or implicit duty ofmakingma^or capital investment recommendations, and initiating and directing other comprehensive measures to assure long term environmental compliance with environmental laws and regulations; the manager can ensure that the necessary systems are established or actions taken to gather complete and accurate information for permit application requirements; and where authority to sign documents has been assigned or delegated to the manager in accordance with corporate procedures; b. Foraparmership or sole proprietorship: byageneralparmer or the proprietor,respectively; or c. Foramunicipality,state, federal, or other public agency: by eitheraprmcipal executive officer or ranking elected official. For purposes of this section,aprincipal executive officer ofapublic agency includes: 1) The chief executive officer of the agency,or 2) Asenior executive officer having responsibility for the overall operations ofaprincipal geographic unit of the agency. VA0090689 Partll Page5of8 2. Reports, etc. All reports required by permits, and other information requested by the Board shall he signed bya person described in Part l l . K . l , o r byaduly authorized representative ofthat person. A person isaduly authorized representative only if: a. The authorization is made in writing byaperson described in Part 11.K.I.; b. The authorization specifies either an individual oraposition having responsibility for the overall operation of the regulated facility or activity such as the position of plant manager, operator ofawellorawell field, superintendent, position of equivalent responsibility,or an individual or position having overall responsibility for environmental matters for the company. (A duly authorized representative may thus be eitheranamed individual orany individual occupyinganamed position.); and c. The written authorization is submitted to the Department. 3. Changes to authorization. If an authorization under Part 1 1 . i s no longer accurate becauseadifferent individual or position has responsibility for the overall operation ofthe facility,anew authorization satisfying the requirements ofPartll.K.2.shall be submitted to the Department prior to or together with any reports, or information to be sign^ by an authorized representative. 4. Certification. Any person signingadocument under Parts 11, K.l.or shall make the following certification: "1 certify under penalty oflaw that this document and all attachments were prepared undermy direction or supervision in accordance withasystem designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry ofthe person or persons who manage the system,or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete, lam aware that there are significant penalties for submim'ng false mformation,including the possibility offine and imprisorunent for knowing violations." L. Duty to Comply The permittee shall comply with all conditions ofthis permit. Anypermitnoncomplianceconstimtesaviolation ofthe State Water Control Law and the Clean Water Act, except that noncompliance with certain provisions ofthis permit may constituteaviolation of the State Water Control Law but not the CleanWater Act. Permit noncompliance is grounds for enforcement action; for permit termination, revocation and reissuance, or modification; or denial ofapermit renewal application. The permittee shall comply with effluent standards or prohibitions established under Section 307(a)ofthe Clean Water Act for toxic pollutants and with standards for sewage sludge use or disposal established under Section 405(d) of me Clean Water Act withm the time providedmthe regulations mat establish these standards or prohibitions or standard sewage sludge use or disposal, even if^this permit has not yet been modified to incorporate the requirement. IvL Duty to Reapply Ifthe permittee wishes to contmue an activity regulated by this permit afier the expiration date ofthis permit, the permittee shall apply for and obtainanew permit. All permittees withacurrently effective permit shall submitanew application at leastl^O days before the expiration date of the existing permit, unless permission foralater date has been granted by the Board. The Board shall not grant permission for applications to be submitted later than the expiration date ofthe existing permit. N. Effect ofaPermit This permit does not convey any property rights in either real or personal property or any exclusive privileges, nor does it authorize any injury to private property or invasion of personal rights, or any infringement of federal, state or l o c a l s or regulations. Partll Page6of8 O. State Law Nothing in this permit shall he construed to preclude the institution ofany legal action under, or relieve the permittee from any responsibilities, liabilities, or penalties established pursuant to any other state law or regulation or under authority preserved by Section^lOofthe dean Water Act. Except as provided in permit conditions on "bypassing" (Part ll.U.), and "upset" (Part ll.V.)nothing in this permit shall be construed to relieve the permittee fr^ criminal penalties tor noncompliance. P. Oil and Hazardous Substance Liability Nothing in this permit shall he construed to preclude the institution ofany legal action or relieve the permittee fr^ responsibilities, liabilities, or penalties to which the permittee is or may be subject under Sections 62.1-44.34:14tftrough 62.1-44.34:23 ofthe State WaterControl Law. Q. Proper Operation and Maintenance The permittee shall at all times properly operate and maintain all facilities and systems oftreatment and control(and related appurtenances)which are mstalled or used by the permittee to achieve compliance with the conditions of this permit. Proper operation and maintenance also includes effective plant performance, adequate funding, adequate staffing, and adequate laboratory and process controls, including appropriate quality assurance procedures. This provision requires the operation ofback-up or auxiliary facilities or similar systems which are installed by the permittee only when the operation is necessary to achieve compliance with the conditions ofthis permit. R Disposal ofSolids or Sludges Solids, sludges or other pollutants removed in the course oftreatment or management ofpollutants shall he disposed of inamanner so as to prevent any pollutant from such materials from entering state waters. S. DutytoMitigate The permittee shall take all reasonable steps to minimize or prevent any discharge or sludge use or disposal in violation ofthis permit which hasareasonahle likelihood of adversely affecting human health or me environment. T. NeedtoHaltorReduceActivitynotaDefense It shall not beadefenseforapermittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions ofthis permit. U. Bypass 1. "Bypass" means me intend The permittee may allow any bypass to oeenrwhleh does not eanseelTlnent limitations to be exceeded, but only If It also essential mamtenanee to assure eftielent operation. These bypasses are not subject to the provisions ofParts 11, andU.3. 2 Notice a. Anticipated bypass. Ifthe permittee imows in advance ofthe need tbrabypass, prior n ifpossibie at ieast ten days before the date ofthe bypass. b. Unanticipated hypass. The permittee shaii submit notice ofan unanticipated bypass as required in Part i i . i . 3. Prohibition ofbypass. a. Bypass is prohibited, and the Board may take enforcement action againstapermittee for bypass, unless: 1) Bypass was unavoidable to prevent loss ofiife, personal in^ury,or severe property damage; VA0090689 Partll Page7of8 2) There were no feasible alternatives to the bypass, such as the use ofauxiliary treatment facilities, retention ofuntreated wastes, or maintenance during normal periods of equipment downtime. This condition is not satisfied ifadequate back-up equipment should have been installed in the exercise of reasonable engineering^udgment to preventabypass which occurred during normal periods of equipment downtime or preventive maintenance; and 3) The permittee submitted notices as required under Part 11.U.2. b. The Board may approve an anticipated bypass, after considering its adverse effects, ifthe Board determines that it will meet the three conditions listed above in Part ll.l^.^.a. V. Upset 1. An upset constimtes an affirmative defense to an action brought for noncompliance with technology based permit effluent limitations ifthe requirements ofPartll.V.2.are met. A determination made during administrative review of claims that noncompliance was caused by upset, and before an action for noncompliance, is notafinal administrative action subject to^udicial review. 2. A permittee who wishes to establish the affirmative defense ofupset shall demonstrate, through properly signed, contemporaneous operating logs, or other relevant evidence that: a. An upset occurred and that the permittee can identify the cause(s)of the upset; h. The permitted facility was at the time being properly operated; c. The permittee submitted notice ofthe upset as required in Part 11.1.; and d. The permittee complied with any remedial measures required under Part U.S. 3. In any enforcement proceeding, the permittee seeking to establish the occurrence ofan upset has the burden of proof. W. Inspection and Entry The permittee shall allow the Director, or an authorized representative, upon presentation of credentials and o documents as may be required by law,to: 1. Enter upon the permittee's premises wherearegulated facility or activity is located or conducted, or where records must be kept under the conditions ofthis permit; 2. Have access to and copy,at reasonable times, any records that must he kept under the conditions of this permit; 3. Inspect at reasonable times any facilities, equipment (including monitoring and control equipment), practices, or operations regulated or required under this permit; and 4. Sample or monitor at reasonable times, for the purposes ofassuring permit compliance or as otherwise authorized hy the Clean Water Act and the State Water Control Eaw,any substances or parameters at any location. Por purposes ofthis section,the time for inspection shall be deemed reasonable during regular business hours, and whenever the facility is discharging. Nothing contained herein shall make an inspection unreasonable during an emergency. ^ Permit Actions Permits may he modified, revoked and reissued, or terminated for cause. The filing ofarequest by the permittee fbra permit modification,revocation and reissuance, or termination, oranotificationofplanned changes or anticipated noncompliance does not stay any permit condition. VA0090689 Partll Page8of8 Y. Transfer of permits 1. Permits are not transferable to any person except after notice to the Department. Except as provided in Part 11.Y.2., apermit may be transferred by the permittee toanew owner or operator only if the permit has been modified or revoked and reissued, oraminor modification made, to identify the new permittee and incorporate such other requirements as may be necessary under the State Water Control Eaw and the CleanWater Act. 2. As an alternative to transfers under Part 11.^.1.,this permit may be automatically transferred toanew permittee if: a. The current permittee notifies the Department at least 30 days in advance ofthe proposed transfer ofthe title to the facility or property; b. The notice includesawritten agreement between the existing and new permittees containingaspecific date for transfer of permit responsihility,coverage,and liability between them; and c. The Board does not notify the existing permittee and the proposed new permittee ofits intent to modify or revoke and reissue the permit. Ifthis notice is not received, the transfer is effective on the date specified in the agreement mentioned in Part ll.Y.^.b. Severability The provisions ofthis permit are severable, and ifany provision ofthis permit or the application ofany provision ofthis permit to any circumstance is held invalid, the application ofsuch provision to other circumstances, and the remainder of this permit, shall not be affected thereby. Hill Mobile Home Park STP (VA0090689) Compliance Evaluation Inspection Exhibit Log Exhibit 2 Plant O&M Manual OPERATION & MAINTENANCE MANUAL ADENDUM PREPARED FOR: HILL MOBILE HOME PARK STP #2 VA0090689 PREPARED BY: CULPEPER ENGINEERING, PC culpeng@gemlink.com 540 423 9706 ADENDUM DATE: 7-28-20 1 INTRODUCTION This Operation & Maintenance Manual Addendum is for the Hill Mobile Home Park STP #2 owned by Six-O-Five Mobile Home Group, LLC. The Wastewater Treatment Plant is located in Caroline County, near the intersection of Lakewood Road and A.P. Hill Boulevard in Bowling Green. This O & M Manual Addendum provides information for the operation and maintenance of the plant to meet the requirements of the issued VPDES Permit, VA0090689. The manual provides information detailing the state discharge requirements, a description of the routine operation of the plant, a description of the installed equipment and the routine maintenance of the equipment, sampling and laboratory requirements and procedures, and plant safety. The purpose of this manual addendum is to provide guidelines, procedures and objectives to the operator on the operation and maintenance procedures of the wastewater treatment facilities. The operator may use this manual to perform his duties in an efficient and competent manner. The O & M Manual should be kept current (maintain copy of current permit with the Manual); the manual should be considered "operational" and as such, should be updated as appropriate to reflect plant operational procedures employed at the facility. The Operations and Maintenance requirements portion of this manual provides a minimum schedule of functions that should be performed in order to prevent major problems and insure the highest quality effluent possible for this facility. Copies of the permit, blank forms, equipment literature/reference information are also included. The addendum should be utilized with the existing manual that was provided by the treatment 2 plant supplier. Detailed information regarding installed equipment is available in the equipment literature. STATE DISCHARGE REQUIREMENTS The Virginia Department of Environmental Quality has issued the facility VPDES Permit No. VA0090689. The design flow of the treatment plant is 0.005 MGD. The discharge point (001) is to an unnamed tributary to Maracossic Creek. The reporting requirements for the facility are specified in the issued permit. A copy of the issued permit has been included as an attachment to this document. A current copy of the VPDES Permit will be maintained with this Manual in the future. The following requirements have been excerpted from the issued VPDES Permit. These excerpts detail permit requirements associated with reports of unauthorized, unusual, or extraordinary discharges and reports on noncompliance requirements 3 4 The following is a list of terms which may appear in the issued permit. Definitions of the terms have been provided as a reference for facility personnel. 5 Definition of Terms: Ammonia N (NH3-N): A form of nitrogen that is produced largely by deamination of organic nitrogen containing compounds and by hydrolysis of urea. Carbonaceous Biochemical Oxygen Demand (cBOD5): The measure of the quantity of oxygen required by bacteria while stabilizing, digesting or treating (biochemical oxidation) the organic matter under aerobic conditions during a five-day period at 20oC under laboratory conditions while in the presence of a chemical inhibitor to block nitrification. Commonly expressed in mg/l. Total Suspended Solids (TSS): The amount of matter contained in the liquid that will be filtered out by a porous filter with a pore size of 1 micron. Total Kjeldahl Nitrojen (TKN): Total Kjeldahl nitrogen or TKN is the sum of organic nitrogen + ammonia (NH3)nitrogen and ammonium (NH4)nitrogen. NO2 (nitrite)+ NO3 (nitrate) as Nitrogen - Nitrate + Nitrite may be reported as a combined sum. The test procedure allows the sample to be preserved for analysis which extends the holding time. pH: A term used to describe the acid/base balance in the wastewater. It is defined as the negative logarithm of the hydrogen ion concentration. Total Residual Chlorine (TRC): The amount of total chlorine contained in the effluent after disinfection. Chlorine residual is measured in two locations. One measurement is taken at the end of the contact chamber to assure adequate disinfection of the wastewater is being achieved. Another measurement is taken after dechlorination to assure that the chlorine is being removed from the effluent stream prior to discharge. Dissolved Oxygen (DO): Molecular oxygen dissolved in wastewater. Grab Sample: An individual sample collected over a period of time not to exceed 15 minutes. Escherichia coli, usually abbreviated to E. coli, is one of the main species of bacteria that live in the lower intestines of mammals.. They are necessary for the proper digestion of food and are part of the intestinal flora. Its presence in groundwater is a common indicator of fecal contamination. It belongs among the Enterobacteriaceae, and is commonly used as a model organism for bacteria in general. E. coli. bacteria testing is applicable to monitoring for pollution control. 6 Quantification Level (QLs): The lowest concentration used to calibrate a measurement system in accordance with procedures published for the approved monitoring method. DESCRIPTION OF WASTEWATER TREATMENT FACILITY The facility is a privately owned treatment works which serves a mobile home park. The flow to the treatment facility is domestic wastewater. Preliminary treatment includes bar screens in manholes where coarse screening occurs prior to flow from the MHP entering a prior septic tank that serves as a pump tank and provides some equalization. Flow is pumped from the tank to the "package plant". The package treatment plant is a Fluidyne ISAM Sequencing Bath Reactor. The "Installation Bill of Materials" details the Fluidyne installation. 7 Following the SBR, treatment includes tablet chlorine disinfection and dechlorination. There is post aeration provided. The discharge is to an unnamed tributary to Maracossic Creek within the Chesapeake Bay watershed. The permit fact sheet includes information related to the Chesapeake Bay TMDL. 8 The Permit Fact Sheet also notes the receiving stream is characterized as a swamp/marsh area with no defined flow channel. The following information is included regarding the TKN limitation. The following is a Fluidyne diagram of the ISAM unit and description of the plant/process. 9 10 Below is the tie down information specified by Fluidyne: 11 Each cycle (batch) is counted and flow is determined based on the number of batches. A batch discharge volume of ~500 gal./batch may be used (operator may verify). 12 13 14 Jet Aspiration is used to aerate the SBR. Liquid from below the surface is pumped through a specially designed nozzle. In passing through the nozzle, the liquid flow increases in velocity. Air is drawn into the low pressure zone in the aspirator and mixes with the liquid in an outer nozzle, forcing oxygen to transfer into solution. The jet plume then discharges through the liquid into the basin and mixes the oxygenated liquid in the plume with the bulk of the basin liquid. There are two aspirator pumps provided: ABS - AFP1040M28/4-12-60 3.7 HP (230/1/60). 15 The ABS Manual is included in the original O & M Manual from the equipment supplier (attached). A Fluidyne detail of the jet Aspirator is provided for reference (Detail from O & M Manual). 16 A detail of the Fluidyne fixed decanter is provided for reference (from O & M Manual) along with Fluidyne literature regarding the decanter. 17 18 19 20 21 22 Prior to discharge, the effluent is disinfected by chlorine; post aeration is available (blower to be upgraded to Roots 22) and dechlorination follows prior to discharge. Final discharge is to an UT of Maracossic Creek. In summary, the Hill STP is a sewage treatment plant which relies upon the activated sludge treatment process to stabilize the influent domestic wastewater from the mobile home community (MHC). The SBR provides biological treatment (aeration/settling) in a batch operation. Following decanting, the flow is directed to facilities for chlorination, post aeration and dechlorination prior to final discharge. TREATMENT UNIT OPERATIONS Screening and Pumping The influent wastewater from the mobile homes flows through bar screens for removal of coarse solids prior to being delivered to the influent pump tank. The tank provides a location which collects influent from the collection system and allows for the pumped transfer to the SBR treatment plant. The tank may be considered to provide a function similar to a equalization basin. The bar screens and pump tank should be routinely inspected and managed. Sequencing Batch Reactor (SBR) The basic treatment is an activated sludge process. The SBR is a fill and draw activated sludge treatment system. In a SBR, wastewater is added to a batch reactor where the flow is treated to remove "undesirable constituents" such that the best treatment possible is achieved. In a SBR time is utilized for operation control with the UNIT serving as the basin for all unit operations including equalization, aeration and clarification. Operations 23 during treatment will cycle. As noted above aeration will start/stop during treatment prior to the batch entering the settle cycle. Once the settle phase has ended, decant is initiated and the cycle repeats. 24 25 26 The unit processes of the SBR and conventional activated sludge systems are the same. The operator maintains an environment that allows the biomass to treat the wastewater. As necessary, soda ash may be added to adjust basin pH and the control panel may be adjusted as desired to achieve the desired treatment control (aeration/static timers). The difference between the SBR and conventional activated sludge is that the SBR system operates in time rather than in space. The basin affords the settling zone for clarification. To assist clarification, the facility may rely on the addition of alum. A chemical feed system is provided for chemical addition. A waste cycle is provided for biomass control. The operator may adjust wasting as necessary to maintain desired MLSS. SBRs afford significant operating flexibility and as with any plant, operator 27 familiarity with the system is necessary. The controls afford the operator ability to monitor the plant and make desired adjustments to achieve a high degree of treatment. SBR (time control) treatment eliminates the need for separate primary and secondary clarifiers which should result in reduced operations and maintenance requirements. In addition, RAS pumps are not required. It is also noted that in conventional biological nutrient removal systems, anoxic basins, anoxic zone mixers, and internal MLSS nitratenitrogen recirculation pumps may be necessary. With the SBR, processes can be accomplished in one reactor using aeration/mixing equipment, which will minimize operation and maintenance requirements otherwise needed for clarifiers and pumps. 28 Chlorine Disinfection & Dechlorination The installed disinfection equipment is tablet chlorination and a contact chamber to provide contact time. To achieve disinfection it is necessary to provide adequate contact time to achieve the required reduction of pathogens. Adequate time to achieve disinfection (CT) is provided in the contact tank. The final effluent from the treatment plant requires the removal of total chlorine in the effluent stream prior to discharge. Chlorine is removed by tablet (sodium sulfite tablets) dichlorination. A tablet dechlorination unit is provided following the contact tank (on discharge line). The tablet, dechlorination feeder is near the discharge point. Post Aeration The wastewater is reaerated prior to discharge. A blower provides the air supply. Small air bubbles are introduced into the flow stream to transfer dissolved oxygen into the effluent prior to final discharge. PERSONNEL RESPONSIBILITIES The Hill Mobile Home Park STP is owned by Six-O-Five Mobile Home Group, LLC. The managing member is James Benson. Jr. Mr. Benson is the responsible entity for the facility. Management has elected to utilize a contract operator for the facility. The contract operator is responsible for the routine, day to day operation of the facility. In addition to the contract operator, the facility relies upon the park maintenance staff for site maintenance (mowing of the plant grounds and routine upkeep). The maintenance staff is available to support the contract operator if necessary. 29 The contract operator is in daily attendance at the facility (hours may vary based on need) and may be contacted for emergency assistance if necessary. Operation of the Wastewater Plant An appropriately certified (minimum Class III) operator is employed/contracted by the owners to provide routine, daily operation of the facilities. The certified operator directs the daily operation of the facility. The operator is in responsible charge of the facility and makes the required, routine operational decisions. The operator is responsible for routine monitoring including daily laboratory testing; sample collection for outsourced laboratory testing; routine record keeping; and submission of the Discharge Monitoring Report to the State. The operator assures there is sufficient inventory on-hand for the operation of the plant including an adequate supply of chemicals and the required laboratory monitoring reagents/equipment. The operator notifies the PM when chemical purchases are required. Daily tasks performed by the operator may include but are not necessarily limited to the following: 1. Check/clean bar screens and manage removed materials; 2. Check operation of aeration systems; 3. Observe SBR and make any operational modifications deemed appropriate; 4. Hose down the walls of tanks and skim as necessary; 5. Record the plant daily flow in daily log; 6. Check Chlorination & dechlorination systems and perform chlorine residual(contact & final) monitoring; 7. Clean treatment units if necessary; 8. Collect effluent sample for pH and analyze and record in daily log 9. Monitor effluent Dissolved Oxygen and record; 10. Clean as necessary to maintain a neat an orderly condition; 11. Observe discharge point at stream and record observations. 30 Per the permit (or any DEQ directive) the operator shall routinely collect samples per the type and frequency included in the permit (or DEQ directive): Required Monitoring As detailed in the permit, monitoring includes onsite monitoring and the collection of samples that are monitored offsite. All compliance samples shall be collected and preserved as set forth in Guidelines Establishing Test Procedures for the Analysis of Pollutants Under the Clean Water Act as published in the Federal Register (40 CFR 136). For samples monitored offsite by a 31 VELAP Certified contract laboratory, the operator shall prepare an appropriate chain of custody form and deliver the samples to the contract laboratory. In addition, once per week a sample for E. coli shall be collected and transported to the contract laboratory (maximum holding time is 6 hours) for analysis (40 CFR 141.21). Monthly the operator shall inventory on hand supplies for the facility. Arrange to have any required supplies ordered and verify delivery of requested materials. Necessary materials include sample containers and forms provided by the contract laboratory. It is necessary to maintain transport coolers to assure sample temperature requirements are met. Plant Operation Normal day-to day operations include routine adjustments, routine monitoring and recording of results, and routine plant cleaning. An hour or more per day is required for the routine and necessary "housekeeping" and plant monitoring/observation of the numerous unit operations. Routine reporting (eDMR) and required record keeping are necessary. Record management and reporting may include dedicated operations time offsite, similar to time for sample delivery. When the plant is running and performing well and is properly adjusted, the overall appearance will be as follows: 1. The screened influent will be free of trash and large solids. Unobstructed flow will be entering the plant (manually cleaned bar screen cleaned daily). 2. The SBR (when under aeration) will be a rich chocolate brown in appearance and will have a musty odor. 32 3. The SBR (when settling/decanting) will be relatively free of particulate matter and the surface should be relatively free of floatables. 4. The flow leaving the SBR should be clear. The feed crock (in building) should be adequately supplied with alum feed solution (alum is to aid settling) and installed pump should be functional. 5. The effluent should have good clarity 6. The tablet feeders (chlorine and dichlorination) should be stocked. 7. The chlorine contact tank discharge shall have a residual >/= 1.0 ppm prior to dichlorination. 8. The final discharge should have a ND (non-detect) chlorine residual. 9. Post aeration should be active. 10. The discharge to the receiving stream should have minimal foam and be free of floating solids (trace only). The stream should be free of visible accumulation of sludge. Operating Routine The operating staff must check the plant on a daily basis to assess performance and determine if the plant is operating correctly. The operator must be aware of any changes that occur in the nature of the influent flow and respond accordingly. It is important that the operator develop a routine to keep abreast of conditions at the plant. A typical operating routine has been provided below as a guide in development of a personal routine. The operator will develop a familiarity with the plant and the conditions that may impact the plant (including temperature/weather impacts on the facility) and respond 33 accordingly. The operator has a familiarity with the plant and should be able to adjust his routine accordingly to accommodate any special needs of the plant. A checksheet is provided as a guide. This checksheet should be used in addition to the Operator's Log Book. The checksheet may be maintained electronically (if the form can be uploaded to a smart phone). It is necessary to assure all daily operations are properly recorded and available thus a paper copy at the facility would be the preferred measure and serve as a valuable reference. A copy of the suggested log is provided. 34 35 Maintenance Routine maintenance of the facility is provided by the contract operator. The staff checks the plant daily to verify operability of installed plant equipment. The contract operator checks all of the functional components of the plant to verify operation while in daily attendance at the plant. If any facility equipment is inoperable or not performing as it should and is in need of maintenance, the operator will attempt to remedy and as necessary notify the Project Manager (PM) if he requires assistance. Should there be a need for offsite maintenance of any plant equipment the PM will make the required contact for repair and arrange for any required assistance to remove a component. The staff will deliver or arrange delivery of equipment to the "shop" for required (offsite) repair. Should a service call to the plant be necessary, the director will make the necessary arrangements for such service. If routine maintenance is being provided at the plant by staff and the attendant requires additional assistance, the PM will be contacted (assistance may be provided from additional staff or by a service representative). Maintenance Schedule: Two maintenance file records are maintained for treatment plant equipment. The equipment record is the Bill of Materials provided by Fluidyne based on material delivery 10-23-2002 for the project. Fluidyne may be contacted for support as necessary. They are available for onsite consultation. Upon installation, Fluidyne provided an O & M Manual. Fluidyne has recently provided an electronic copy of the Manual. This Manual has been attached for reference (Original O & M Manual). 36 A service record should be maintained for mechanical equipment to detail a record of work/service performed, date and name of service provider. These records may be maintained electronically for ease of access. Routine Maintenance An abbreviated schedule of routine maintenance performed at the Hill STP is presented below: Daily - Observe all mechanical components and verify operating condition Weekly: Empty solid waste containers, including screenings receptacle. Quarterly: Blowers - Grease bearings, check oil and as required change oil; check belts (replace as required) Manual Valves - Verify operation/ service as required Verify operation of all installed floats Semi-Annual: Blowers - check air filters and replace as necessary. Annual: Assess Plant for any necessary repairs and to verify integrity Seasonal: Remove snow which prohibits access or poses a hazard. As Required Repair piping or replace Check pumps for clogging Corrective/Emergency Maintenance Contact project manager (PM) for assistance. Major purchases are processed by the project manager who can authorize or make arrangements for non-routine expenditures. 37 HILL MOBILE HOME PARK STP 38 Maintenance & Repair Contacts - Most components are serviced/repaired by the O & M Contractor staff. Repair components may be purchased and installed by staff. The Contractor Contact is Matthew Raynor Phone: 919 270 4831 Maintenance/ Repair Contacts & Suppliers Fluidyne: Motors/Blowers: Electrical: EEE - Richmond, Virginia USA Blue Book (www.usabluebook.com) Dick Sibert Office Phone: 804 796-4784 Shop Phone: 804 796-6564 Pumps or Special Needs: Atlantic Pump & Equipment 301 Jefferson Davis Hwy. Richmond, VA 23224 804 233 4396 USA Blue Book (www.usabluebook.com) PLANT TOOLS & SPARE PARTS Laboratory Equipment is provided by the contract operator. The following equipment is available for use at the H-ill STP pH Meter - Oakton/Hach/Thermo Scientific or equal (Plant Pro/Pocket Pro) and buffers (3 buffers available - 4, 7 & 10). 39 Dissolved Oxygen - YSI Model 550 DO Meter (or equal). Miscellaneous glassware is available at the plant or the contract operators office (located at Indian Acres of Thornburg site) for use as required. Miscelaneous Tool Inventory The following tools should be available at the plant: Water hose Skimmers Long handled brush The contract operator maintains a maintenance facility nearby (Thornburg). The maintenance staff has a complete shop which is fully equipped with hand and power tools. The following list is a sampling of the tools which are available for use at the Hill STP: 1. Socket Sets 2. Pipe wrenches 3. Crescent Wrenches 4. Pliers 5. Needlenose pliers 6. Channel lock pliers 7. Screwdriver set 8. Hacksaw 9. Hammer 10. Hand truck 11. Portable pump for decanting sludge holding 12. Assorted power tools including a backhoe Should the maintenance staff require a specific tool not currently available in the shop, for use at the plant, the supervisor purchases the necessary equipment. Spare Parts Inventory The following equipment is used for replacement of inoperable plant equipment. The inoperable equipment is repaired or replaced and returned to "stock" for use as needed. Spare parts may be inventoried onsite or at the maintenance shop. The contract operator may also maintain emergency repair equipment for his immediate use. 40 1. Spare tubing for chemical pump 2. Spare feed pump 3. Kop Kit 4. Belts 5. Grease & Oil 6. Air Filters 7. O Ring Assortment 8. Assorted Pipe 9. Assorted plumbing fittings 10. Replacement float 11. Replacement feeder tubes 12. Utility pump Process Chemicals The following chemicals are maintained on-site for routine plant operation: 1. Alum 2. Soda ash 3. Chlorine Tablets 4. Dechlorination Tablets The alum is used for enhancing clarification and soda ash is available for SBR pH adjustment as necessary. The chemicals are stored dry. General PLANT SAFETY Plant safety is the act of performing routine and emergency operating and maintenance procedures in a safe working manner. Many of the safety rules for operating and maintaining a wastewater treatment plant in a safe manner are common sense, while other procedures have more technical backgrounds. Most accidents occur due to a careless act. To institute plant safety, it is necessary to have each employee thinking safety. When employees are continuously aware that their employer demands safe working procedures, the employees are much more likely to think safety and to carry out their daily tasks in a safe manner. 41 The safety hazards which may be associated with the operation of the Glenwood STP, are primarily associated with physical injuries and infections or exposure to infectious diseases. Operators must be safety conscious as they enter the plant site; if they are, most injuries and accidents can be avoided. General Safety Rules 1. All written or verbal safety rules shall be observed and particular job associated hazards recognized. 2. A job shall not be initiated until proper instructions have been received and are understood. 3. Any hazardous conditions, unsafe equipment, or unsafe practice shall be reported to the regional manager. 4. Any and all accidents/injuries shall be reported to the regional manager. 5. Any and all water in the plant/used at the plant is non-potable other than the lab sink and should only be used for plant operation. 6. Walk do not run on the plant grounds. 7. Safety devices/safety guards shall be installed on all equipment with moving parts (ie: blowers). 8. Hand tools and any special equipment shall be kept clean and in good repair. 9. Use the correct tool for a job in the proper manner. 10. Avoid wearing loose clothing which may "catch" on equipment. 11. Practice good housekeeping. 12. Observe personal hygiene rules to avoid infection. Routinely wash hands with soap and water at the lab sink. 13. Practical jokes and "horseplay" are forbidden. 14. Reporting to work under the influence of drugs or alcohol are forbidden. 15. Never sacrifice safety for speed in performing duties. 16. No job is considered finished until the safety of the next person to use the facility or equipment has been maximized. 17. No smoking allowed at plant site. Safety Evaluation The most common physical injuries applicable to the operation of this facility are cuts, bruises, strains and sprains. Injuries may be caused by moving machinery, improper lifting techniques, or slippery surfaces. Falls from or into the tanks can be disabling or fatal. Most of these may be avoided by the proper use of ladders, hand tools, and safety equipment and by using common sense. Safety precautions include the following: 42 1. Bar screen - when manually cleaning screen, be sure to have a clean, firm footing and wear protective gloves when using rake. Return rake to storage location. Never place rake down on the ground with prongs up. 2. Plant tanks - Assure that footing is on a clean, firm surface when hosing units or performing maintenance Use protective gloves when working around tanks or operating valves in tanks. 3. Chemical Feed Equipment - PPE shall be used when working in the plant vicinity. Additional precaution shall be taken when managing chemical supplies. Chemicals can cause skin and or eye irritation, safe handling procedures shall be employed. As with all lifting, lift with your legs not your back if equipment/supplies are moved. 4. Electric Panel/Control Panel - Only a qualified electrician may service, repair or troubleshoot the electrical system. The electric panel box has 240 Volts - it is hazardous and should not be tampered with by anyone not fully qualified. Call for service. Infections and Infectious Diseases Personal hygiene is the best protection against the risk of infections and infectious diseases. Immunizations (tetnus, hepatitis, etc. as recommended by physician) should be kept up to date for all employees working at the plant. Protective gloves should be worn when in contact with wastewater or sludge. Thoroughly wash hands with soap and potable water after working at the plant or after using any of the plant equipment or tools. Housekeeping Good housekeeping can prevent many accidents. The following practices shall be employed at the plant: 1. Tools and equipment shall be stored in their proper place when not in use. 2. Clean up all spills of oil, grease, wastewater or sludge. 3. Place all trash in covered trash receptacle and routinely (weekly) empty. 4. Keep work area clear of snow and ice as needed. Provide safe access to plant. A clean work area will reduce the risk of injury and infections. Emergency Assistance/Accident Reporting For emergency help, dial 911. Should an accident occur, notify the project manager as soon as possible (919 270-4831) a written accident report should be prepared. 43 Monitoring SAMPLING, LAB PROCEDURES & REPORTING All of the routine monitoring (other than flow monitoring) required by the issued VPDES Permit for the Hill MHP STP involves the collection of grab samples. A "Grab Sample" is an individual sample collected over a period of time not to exceed 15 minutes. The sample thus represents the composition of the wastewater at that time and place. For the facility, flow is reported based on daily readings of the water supply flow meters and reporting the quantity of water used during the intervening period. The facility is required to collect grab samples for the specified parameters at the indicated frequency: 44 The required monitoring points for the given parameters are at the discharge point (effluent) unless otherwise (after contact). In addition to the required routine monitoring, the licensed operator in charge performs in-plant monitoring of operational parameters, such as settling test, SBR pH and in-plant D.O., to routinely assess plant performance. These tests are discretionary and performed as needed to evaluate plant performance. 45 The performance tests performed at the facility are the daily tests and compliance monitoring that is performed onsite (pH, DO & chlorine residuals). The operator collects and monitors these parameters onsite. Equipment use and calibrations are performed per the equipment manuals. The equipment manuals are maintained by the contract operator for reference regarding equipment use, maintenance and service. The manuals contain detailed information regarding use; these manuals should be used to perform all required equipment calibration prior to use for monitoring. All laboratory practices (including onsite compliance monitoring) shall be performed in accordance with Title 40 CFR Part 136. All other testing (offsite analyses) is performed by a contract laboratory (VELAP Certified). Sample containers are provided by the contract laboratory for the specified tests. The operator collects the samples in the provided containers, places the samples in an iced cooler and delivers them directly to the lab. All samples collected and delivered to the laboratory are accompanied by a chain of custody form. A copy of the form is retained in the plant records. All monitoring shall be conducted according to procedures approved under Title 40 Code of Federal Regulations Part 136 or 141.21. As necessary, sample containers are pre-preserved and the laboratory verifies compliance prior to logging samples into processing (Sample Acceptance Procedures). It is necessary that the facility ensure proper quality assurance/quality control (QA/QC) protocols are followed during sampling and analytical procedures. QA/QC information shall be documented to confirm that appropriate analytical procedures have been used 46 and the required Quantification Levels (QL's) have been attained. The issued permit includes the following specific QL's: Samples and measurements taken as required by the issued VPDES Permit shall be representative of the monitored activity. As noted above, monitoring shall be conducted according to the procedures under Title 40 CFR Part 136 (or alternative procedures approved by the USEPA), unless procedures are specified in the permit (E. coli. - 40 CFR 141.21 with a maximum 6 hour holding time). The permittee shall verify that only VELAP Certified laboratories are used for reporting monitoring results conducted offsite. The facility shall be responsible for performing onsite monitoring and analyses of pH and dissolved oxygen. The facility shall verify appropriate QA/QC practices are routinely performed (including equipment calibration and maintenance procedures) on all monitoring and analytical instrumentation at intervals that assure accuracy of measurements. Records Records of monitoring information shall include: The date, exact place, and time of sampling or measurements; The individual(s) who performed the sampling or measurements; The date(s) and time(s) analyses were performed; The individual(s) who performed the analyses; 47 The analytical techniques or methods used; and The results of such analyses. Except for records of monitoring information required by this permit related to the permittee's sewage sludge use and disposal activities, which shall be retained for a period of at least five years, the permittee shall retain records of all monitoring information, including all calibration and maintenance records, copies of all reports required by the permit, and records of all data used to complete the application for the permit, for a period of at least 3 years from the date of the sample, measurement, report or application. This period of retention shall be extended automatically during the course of any unresolved litigation regarding the regulated activity or regarding control standards applicable to the permittee, or as requested by the Board. Reporting Monitoring Results. The permittee shall submit the results of the monitoring required by the permit not later than the 10th day of the month after monitoring takes place. Monitoring results shall be submitted to: Department of Environmental Quality - Northern Virginia Regional Office (DEQ-NVRO) 13901 Crown Court Woodbridge, VA 22193. Monitoring results shall be reported on the eDMR online reporting system. If the permittee monitors any pollutant specifically addressed by this permit more frequently than required by this permit using test procedures approved under Title 40 of the Code of Federal Regulations Part 136 or using other test procedures approved by the U.S. Environmental Protection Agency or using procedures specified in this permit, the 48 results of this monitoring shall be included in the calculation and reporting of the data submitted in the eDMR. Calculations for all limitations which require averaging of measurements shall utilize an arithmetic mean unless otherwise specified in this permit. In accordance with the issued VPDES Permit, the following guidance shall be used for Compliance Reporting:. 49 Daily Logs In addition to the submission of the facility eDMR to the DEQ, the operator shall maintain a daily log of operation. The operator is required to record the day-to-day plant activities and events (sampling, testing, etc.). operation of equipment, maintenance, housekeeping, etc. The operator records daily results of monitoring results on a data sheet, the sheet should indicate the following information: The date, exact place, and time of sampling or measurements; The individual(s) who performed the sampling or measurements; The date(s) and time(s) analyses were performed; The individual(s) who performed the analyses; The analytical techniques or methods used; and The results of such analyses. In addition, visual observations of the discharge and the receiving stream shall be rcorded. A suggested form for recording daily monitoring has been included in this Manual; a copy is provided below. The monthly data is the basis for the required DMR determinations for monthly average, minimum and maximum results for the daily testing performed at the plant. This data sheet shall be filed in the plant office. The operator should record his daily operational activities as well as any repair work or maintenance activity performed. Accident listings and any visitors to the facility are also recorded in the daily log. The date and time of each activity are recorded in the log as well as the operator's initials. The maintenance staff should keep a record of any equipment maintenance performed in the separate equipment service record. These records may be maintained electronically for ease of reference. Electronic records should be transmitted routinely to the manager to assure a complete set of electronic records is 50 maintained. Records may also include maintenance staff time sheets detailing service by staff at the plant 51 52 SOLIDS MANAGEMENT Solids, sludges or other pollutants removed in the course of treatment or management of pollutants shall be disposed of in a manner so as to prevent any pollutant from such materials entering state waters. Coarse screenings removed from the treatment plant headworks shall be disposed of in a covered/closed receptacle and the accumulated waste shall be managed as solid waste. The collected waste shall be routinely managed (place in dumpster for disposal) so as not to create a nuisance condition. Solids which accumulate in the sludge holding are removed by a septage hauler and treated as septage. The facility will rely on the services of a licensed Septic Service to remove accumulated, waste sludge from the facility. Waste sludge is transported to the Town of Bowling Green WWTF (VA0020737) for additional treatment and final management. SPILLS & UNUSUAL DISCHARGE PROCEDURES The Hill MHP STP serves a residential community. The possibility of an unusual discharge associated with noxious waste is remote. In accordance with the issued permit the following information (exerpted from the issued permit) is provided. 53 54 55 In addition to notifying the Department of Environmental Quality, the operator shall also provide notification of unusual discharges to the Virginia Department of Health, Office of Drinking Water. The ODW contact(s) for Caroline County is in Richmond Field Office and may be reached at 804 864 7409 or 804 864 7408. This notification allows that Division to act upon any real or potential threat to a drinking water supply. 56 ATTACHED TO THIS MANUAL ARE THE FOLLOWING DOCUMENTS FLUIDYNE O & M MANUAL MANUAL PROVIDED WITH PLANT EQUIPMENT DETAILS AND LITERATURE FOR MATERIALS PROVIDED AT TIME OF INSTALLATION VPDES PERMIT 57 Inputs/Outputs Hiway Mobile Home Community, LLC WWTP (VA0074942) Compliance Evaluation Exhibit Log Exhibit 3 ICIS Database DMR Data (July 2016 - September 2020) NPDES ID VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 Mon. Period End Date 09/30/2020 09/30/2020 09/30/2020 09/30/2020 09/30/2020 09/30/2020 09/30/2020 09/30/2020 09/30/2020 09/30/2020 08/31/2020 08/31/2020 08/31/2020 08/31/2020 08/31/2020 08/31/2020 08/31/2020 08/31/2020 08/31/2020 08/31/2020 07/31/2020 07/31/2020 07/31/2020 07/31/2020 07/31/2020 07/31/2020 07/31/2020 07/31/2020 07/31/2020 07/31/2020 06/30/2020 06/30/2020 06/30/2020 06/30/2020 06/30/2020 06/30/2020 06/30/2020 06/30/2020 06/30/2020 06/30/2020 05/31/2020 05/31/2020 05/31/2020 05/31/2020 05/31/2020 05/31/2020 05/31/2020 05/31/2020 05/31/2020 05/31/2020 04/30/2020 04/30/2020 04/30/2020 04/30/2020 04/30/2020 04/30/2020 04/30/2020 04/30/2020 04/30/2020 04/30/2020 03/31/2020 03/31/2020 03/31/2020 03/31/2020 03/31/2020 03/31/2020 03/31/2020 03/31/2020 03/31/2020 03/31/2020 02/29/2020 02/29/2020 02/29/2020 02/29/2020 02/29/2020 02/29/2020 02/29/2020 02/29/2020 02/29/2020 02/29/2020 01/31/2020 01/31/2020 01/31/2020 01/31/2020 01/31/2020 01/31/2020 01/31/2020 01/31/2020 01/31/2020 01/31/2020 12/31/2019 12/31/2019 12/31/2019 12/31/2019 12/31/2019 12/31/2019 12/31/2019 12/31/2019 12/31/2019 12/31/2019 12/31/2019 12/31/2019 11/30/2019 11/30/2019 11/30/2019 11/30/2019 11/30/2019 11/30/2019 11/30/2019 11/30/2019 11/30/2019 11/30/2019 10/31/2019 10/31/2019 10/31/2019 10/31/2019 10/31/2019 10/31/2019 10/31/2019 10/31/2019 10/31/2019 10/31/2019 09/30/2019 09/30/2019 09/30/2019 09/30/2019 09/30/2019 09/30/2019 09/30/2019 09/30/2019 09/30/2019 09/30/2019 08/31/2019 Parameter Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Nitrogen, total [as N] Nitrite + Nitrate total [as N] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] Worst % exced. Quantity 1 Quantity 2 Quantity Units 630 .56 .73 kg/d 478 .11 .19 kg/d .0018 .0027 MGD 67 .11 .18 kg/d 685 .5 .52 kg/d 388 .1 .16 kg/d .0025 .0035 MGD .05 .06 kg/d 440 .72 .9 kg/d 33 .05 .08 kg/d 96 .0035 .0035 MGD 10 .14 .2 kg/d 620 .84 .84 kg/d 160 .13 .13 kg/d .0056 .0216 MGD 120 .26 .26 kg/d .09 .09 kg/d .06 .06 kg/d .004 .006 MGD .13 .13 kg/d .14 .14 kg/d 41 .006 .006 kg/d .004 .004 MGD .13 .13 kg/d 190 .43 .43 kg/d 235 .15 .15 kg/d .004 .004 MGD .12 .12 kg/d 40 .21 .21 kg/d .04 .04 kg/d .004 .004 MGD .06 .06 kg/d 108 .24 .24 kg/d 453 .18 .18 kg/d 98 .003 .003 MGD 100 .22 .22 kg/d 140 .036 .036 kg/d 614 .31 .31 kg/d .004 .004 MGD .13 .13 kg/d 110 .23 .23 kg/d .027 .027 kg/d .003 .003 MGD .022 .022 kg/d 410 .386 .386 kg/d 372 .1 .1 kg/d .002 .002 MGD .05 .05 kg/d .049 .049 kg/d .005 .005 kg/d 124 .003 .003 MGD NODI B NODI B kg/d Concentration 1 6 6.7 1.02 5.2 7.1 1.06 5.5 6.8 1.05 6 7.3 1.03 6.65 7.5 1.2 8.3 8 1.6 8.1 7.5 1 8.9 7 1 8.2 7.5 1.2 7.8 7.5 1 7.1 7 1.2 6.6 6.5 1 5.2 7 1.5 6.1 Concentration 2 73 14.69 1.31 NODI B 15 15 78.5 14.18 1.9 NODI B 11 8 54 3.98 3.92 NODI B 51 11 72 7.79 1.54 NODI B 71 22 6 2 .38 NODI B 6 9 9 4.23 .2 NODI B 1 5 29 10.06 1.61 NODI B 43 8 14 2.4 2 NODI B 16 .4 20.8 16.58 3.95 NODI B 5 20 NODI **X** NODI B 24 21.42 .68 NODI B 2 9 21 2.45 1 NODI B 9 2 51 14.16 .97 NODI B 18 7 4.4 .49 4.48 NODI B 2 NODI B Concentration 3 8.6 101.4 26 NODI B 25 8.2 85 21.95 NODI B 8 8.1 68 5.93 NODI B 15 8.4 72 7.79 NODI B 22 8 6 2 NODI B 9 8 9 4.23 NODI B 5 8 29 10.06 NODI B 8 8 14 2.4 NODI B 4 8 20.8 16.58 NODI B 20 8 24 21.42 NODI B 9 8 21 2.45 NODI B 2 8 51 14.16 NODI B 7 8 4.4 .49 NODI B NODI B Concentration Units mg/L SU mg/L mg/L mg/L mg/L mg/L #/100mL mg/L mg/L SU mg/L mg/L mg/L mg/L mg/L #/100mL mg/L mg/L SU mg/L mg/L mg/L mg/L mg/L #/100mL mg/L mg/L SU mg/L mg/L mg/L mg/L mg/L #/100mL mg/L mg/L SU mg/L mg/L mg/L mg/L mg/L #/100mL mg/L mg/L SU mg/L mg/L mg/L mg/L mg/L #/100mL mg/L mg/L SU mg/L mg/L mg/L mg/L mg/L #/100mL mg/L mg/L SU mg/L mg/L mg/L mg/L mg/L #/100mL mg/L mg/L SU mg/L mg/L mg/L mg/L mg/L #/100mL mg/L mg/L mg/L mg/L SU mg/L mg/L mg/L mg/L mg/L #/100mL mg/L mg/L SU mg/L mg/L mg/L mg/L mg/L #/100mL mg/L mg/L SU mg/L mg/L mg/L mg/L mg/L #/100mL mg/L mg/L SU mg/L mg/L mg/L mg/L mg/L #/100mL mg/L mg/L VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 08/31/2019 08/31/2019 08/31/2019 08/31/2019 08/31/2019 08/31/2019 08/31/2019 08/31/2019 08/31/2019 07/31/2019 07/31/2019 07/31/2019 07/31/2019 07/31/2019 07/31/2019 07/31/2019 07/31/2019 07/31/2019 07/31/2019 06/30/2019 06/30/2019 06/30/2019 06/30/2019 06/30/2019 06/30/2019 06/30/2019 06/30/2019 06/30/2019 06/30/2019 05/31/2019 05/31/2019 05/31/2019 05/31/2019 05/31/2019 05/31/2019 05/31/2019 05/31/2019 05/31/2019 05/31/2019 04/30/2019 04/30/2019 04/30/2019 04/30/2019 04/30/2019 04/30/2019 04/30/2019 04/30/2019 04/30/2019 04/30/2019 03/31/2019 03/31/2019 03/31/2019 03/31/2019 03/31/2019 03/31/2019 03/31/2019 03/31/2019 03/31/2019 03/31/2019 02/28/2019 02/28/2019 02/28/2019 02/28/2019 02/28/2019 02/28/2019 02/28/2019 02/28/2019 02/28/2019 02/28/2019 01/31/2019 01/31/2019 01/31/2019 01/31/2019 01/31/2019 01/31/2019 01/31/2019 01/31/2019 01/31/2019 01/31/2019 12/31/2018 12/31/2018 12/31/2018 12/31/2018 12/31/2018 12/31/2018 12/31/2018 12/31/2018 12/31/2018 12/31/2018 12/31/2018 12/31/2018 11/30/2018 11/30/2018 11/30/2018 11/30/2018 11/30/2018 11/30/2018 11/30/2018 11/30/2018 11/30/2018 11/30/2018 10/31/2018 10/31/2018 10/31/2018 10/31/2018 10/31/2018 10/31/2018 10/31/2018 10/31/2018 10/31/2018 10/31/2018 09/30/2018 09/30/2018 09/30/2018 09/30/2018 09/30/2018 09/30/2018 09/30/2018 09/30/2018 09/30/2018 09/30/2018 08/31/2018 08/31/2018 08/31/2018 08/31/2018 08/31/2018 08/31/2018 08/31/2018 08/31/2018 08/31/2018 08/31/2018 07/31/2018 07/31/2018 07/31/2018 07/31/2018 pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Nitrogen, total [as N] Nitrite + Nitrate total [as N] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] 7.5 73 .26 .26 kg/d .02 .02 kg/d .004 .004 MGD 1.2 NODI B NODI B kg/d 5.8 7 7795 15 14 kg/d .02 .02 kg/d 96 .003 .003 MGD 1.6 NODI B NODI B kg/d 6 6.7 .0795 .0795 kg/d .0082 .0082 kg/d .003 .0045 MGD 1.08 20 .0833 .2044 kg/d 7 7 .0121 .0121 kg/d .0038 .0038 kg/d .0032 .0032 MGD 1.07 .0246 .0246 kg/d 7 7.1 .0121 .0121 kg/d .0076 .0076 kg/d .0032 .0032 MGD 1.22 .0242 .0242 kg/d 7 7.4 .0363 .0363 kg/d .0044 .0044 kg/d .0032 .0032 MGD 1.2 .0242 .0242 kg/d 7 7.2 .0121 .0121 kg/d .0046 .0046 kg/d .0032 .0032 MGD 1.2 .0242 .0242 kg/d 7 7 .0121 .0121 kg/d .0046 .0046 kg/d .0032 .0032 MGD 1.22 .0242 .0242 kg/d 7 7.1 .0121 .0121 kg/d .0021 .0021 kg/d .0032 .0032 MGD 1.2 .0242 .0242 kg/d 7 7.2 .0121 .0121 kg/d .0024 .0024 kg/d .0032 .0032 MGD 1.07 .0242 .0242 kg/d 7 7.2 .0121 .121 kg/d .0029 .0029 kg/d .0032 .0032 MGD 1.2 .0242 .0242 kg/d 7 7.2 .0121 .0121 kg/d .0172 .0172 kg/d .0032 .0032 MGD 1.09 .0242 .0242 kg/d 7 7.1 .0121 .0121 kg/d .0036 .0036 kg/d .0032 .0032 MGD 1.12 .0848 .1453 kg/d 6.8 7.1 .0121 .0121 kg/d .0016 .0016 kg/d 17.3 1.53 .41 NODI B 1 NODI B 14 1.91 3.91 NODI B 2 NODI B 7 .72 .28 NODI B 1 7 1 .31 .03 NODI B 1 2 1 .63 1.22 NODI B 2 2 3 .36 .02 NODI B 1 2 1 .38 1.83 NODI B 1 2 1 .38 .06 NODI B 1 2 .34 .18 1 .18 .06 NODI B 1 2 1 .2 .06 NODI B 1 2 1 .24 .2 NODI B 1 2 1 1.42 .06 NODI B 1 2 1 .31 .07 NODI B 5 7 1 .13 8.5 17.3 1.53 NODI B NODI B 8 14 1.91 NODI B NODI B 7.9 7 .72 NODI B 18 7.6 1 .31 NODI B 2 7.6 1 .63 NODI B 2 7.6 3 .36 NODI B 2 7.7 1 .38 NODI B 2 7.7 1 .38 NODI B 2 7.6 1 .18 NODI B 2 7.6 1 .2 NODI B 2 7.7 1 .24 NODI B 2 7.6 1 1.42 NODI B 2 7.7 1 .31 NODI B 12 7.6 1 .13 SU mg/L mg/L mg/L mg/L mg/L #/100mL mg/L mg/L SU mg/L mg/L mg/L mg/L mg/L #/100mL mg/L mg/L SU mg/L mg/L mg/L mg/L mg/L #/100mL mg/L mg/L SU mg/L mg/L mg/L mg/L mg/L #/100mL mg/L mg/L SU mg/L mg/L mg/L mg/L mg/L #/100mL mg/L mg/L SU mg/L mg/L mg/L mg/L mg/L #/100mL mg/L mg/L SU mg/L mg/L mg/L mg/L mg/L #/100mL mg/L mg/L SU mg/L mg/L mg/L mg/L mg/L #/100mL mg/L mg/L mg/L mg/L SU mg/L mg/L mg/L mg/L mg/L #/100mL mg/L mg/L SU mg/L mg/L mg/L mg/L mg/L #/100mL mg/L mg/L SU mg/L mg/L mg/L mg/L mg/L #/100mL mg/L mg/L SU mg/L mg/L mg/L mg/L mg/L #/100mL mg/L mg/L SU mg/L mg/L mg/L mg/L mg/L #/100mL mg/L mg/L SU mg/L mg/L VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 07/31/2018 07/31/2018 07/31/2018 07/31/2018 07/31/2018 07/31/2018 06/30/2018 06/30/2018 06/30/2018 06/30/2018 06/30/2018 06/30/2018 06/30/2018 06/30/2018 06/30/2018 06/30/2018 05/31/2018 05/31/2018 05/31/2018 05/31/2018 05/31/2018 05/31/2018 05/31/2018 05/31/2018 05/31/2018 05/31/2018 04/30/2018 04/30/2018 04/30/2018 04/30/2018 04/30/2018 04/30/2018 04/30/2018 04/30/2018 04/30/2018 04/30/2018 03/31/2018 03/31/2018 03/31/2018 03/31/2018 03/31/2018 03/31/2018 03/31/2018 03/31/2018 03/31/2018 03/31/2018 02/28/2018 02/28/2018 02/28/2018 02/28/2018 02/28/2018 02/28/2018 02/28/2018 02/28/2018 02/28/2018 02/28/2018 01/31/2018 01/31/2018 01/31/2018 01/31/2018 01/31/2018 01/31/2018 01/31/2018 01/31/2018 01/31/2018 01/31/2018 12/31/2017 12/31/2017 12/31/2017 12/31/2017 12/31/2017 12/31/2017 12/31/2017 12/31/2017 12/31/2017 12/31/2017 12/31/2017 12/31/2017 11/30/2017 11/30/2017 11/30/2017 11/30/2017 11/30/2017 11/30/2017 11/30/2017 11/30/2017 11/30/2017 11/30/2017 10/31/2017 10/31/2017 10/31/2017 10/31/2017 10/31/2017 10/31/2017 10/31/2017 10/31/2017 10/31/2017 10/31/2017 09/30/2017 09/30/2017 09/30/2017 09/30/2017 09/30/2017 09/30/2017 09/30/2017 09/30/2017 09/30/2017 09/30/2017 08/31/2017 08/31/2017 08/31/2017 08/31/2017 08/31/2017 08/31/2017 08/31/2017 08/31/2017 08/31/2017 08/31/2017 07/31/2017 07/31/2017 07/31/2017 07/31/2017 07/31/2017 07/31/2017 07/31/2017 07/31/2017 07/31/2017 07/31/2017 06/30/2017 06/30/2017 06/30/2017 06/30/2017 06/30/2017 06/30/2017 06/30/2017 Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Nitrogen, total [as N] Nitrite + Nitrate total [as N] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua .0032 .0032 MGD 1.04 .0242 .0242 kg/d 7 7 .0121 .0121 kg/d .0079 .0079 kg/d .0032 .0032 MGD 1.01 .0242 .0242 kg/d 7 7 .0121 .0121 kg/d .0024 .0024 kg/d .0032 .0032 MGD 1.06 .0242 .0242 kg/d 7 7 .0121 .0121 kg/d .0042 .0042 kg/d .0032 .0032 MGD 1.07 .0242 .0242 kg/d 7 7.6 .0121 .0121 kg/d 0 0 kg/d .0032 .0032 MGD 1.07 .0242 .0242 kg/d 7 7.4 .0121 .0121 kg/d .0028 .0028 kg/d .0032 .0032 MGD 1.18 .0242 .0242 kg/d 7 7.4 .0121 .0121 kg/d .009 .009 kg/d .0032 .0032 MGD 1.14 .0242 .0242 kg/d 7 7.6 .0121 .0121 kg/d .0015 .0015 kg/d .0032 .0032 MGD 1.23 .0242 .0242 kg/d 7 7.6 .0121 .0121 kg/d .0012 .0012 kg/d .0032 .0032 MGD 1.17 .0242 .0242 kg/d 7 7.6 .0484 .0484 kg/d 0 0 kg/d .0032 .0032 MGD 1.29 .0242 .0242 kg/d 7 7.6 .0363 .0363 kg/d .0014 .0014 kg/d .0032 .0032 MGD 1.24 .0242 .0242 kg/d 7 7.1 .0121 .0121 kg/d .0028 .0028 kg/d .0032 .0032 MGD 1.07 .0242 .0242 kg/d 7 7.1 .0121 .0121 kg/d .0017 .0017 kg/d .0032 .0032 MGD 1.1 .0242 .0242 kg/d 7 7.6 .0121 .0121 kg/d .0164 .0164 kg/d .0032 .0032 MGD .06 NODI B 1 2 1 .21 .11 NODI B 1 2 1 .2 .05 NODI B 1 2 1 .35 .05 NODI B 1 2 1 0 .17 NODI B 1 2 1 .23 .18 NODI B 1 2 1 .74 .05 NODI B 1 2 .81 .39 1 .12 NODI B NODI B 1 2 1 .1 .14 NODI B 1 2 4 0 .18 NODI B 1 2 3 .12 .11 NODI B 1 2 1 .23 .15 NODI B 1 2 1 .14 .17 NODI B 1 2 1 1.35 .23 0 NODI B 2 7.7 1 .21 NODI B 2 7.6 1 .2 NODI B 2 8 1 .35 NODI B 2 7.6 1 0 NODI B 2 7.6 1 .23 NODI B 2 7.6 1 .74 NODI B 2 7.6 1 .12 NODI B 2 7.9 1 .1 NODI B 2 7.6 4 0 NODI B 2 7.6 3 .12 NODI B 2 7.6 1 .23 NODI B 2 7.6 1 .14 NODI B 2 7.6 1 1.35 0 mg/L mg/L mg/L #/100mL mg/L mg/L SU mg/L mg/L mg/L mg/L mg/L #/100mL mg/L mg/L SU mg/L mg/L mg/L mg/L mg/L #/100mL mg/L mg/L SU mg/L mg/L mg/L mg/L mg/L #/100mL mg/L mg/L SU mg/L mg/L mg/L mg/L mg/L #/100mL mg/L mg/L SU mg/L mg/L mg/L mg/L mg/L #/100mL mg/L mg/L SU mg/L mg/L mg/L mg/L mg/L #/100mL mg/L mg/L mg/L mg/L SU mg/L mg/L mg/L mg/L mg/L #/100mL mg/L mg/L SU mg/L mg/L mg/L mg/L mg/L #/100mL mg/L mg/L SU mg/L mg/L mg/L mg/L mg/L #/100mL mg/L mg/L SU mg/L mg/L mg/L mg/L mg/L #/100mL mg/L mg/L SU mg/L mg/L mg/L mg/L mg/L #/100mL mg/L mg/L SU mg/L mg/L mg/L mg/L mg/L #/100mL mg/L mg/L SU mg/L mg/L mg/L mg/L VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 VA0090689 06/30/2017 06/30/2017 06/30/2017 05/31/2017 05/31/2017 05/31/2017 05/31/2017 05/31/2017 05/31/2017 05/31/2017 05/31/2017 05/31/2017 05/31/2017 04/30/2017 04/30/2017 04/30/2017 04/30/2017 04/30/2017 04/30/2017 04/30/2017 04/30/2017 04/30/2017 04/30/2017 03/31/2017 03/31/2017 03/31/2017 03/31/2017 03/31/2017 03/31/2017 03/31/2017 03/31/2017 03/31/2017 03/31/2017 02/28/2017 02/28/2017 02/28/2017 02/28/2017 02/28/2017 02/28/2017 02/28/2017 02/28/2017 02/28/2017 02/28/2017 01/31/2017 01/31/2017 01/31/2017 01/31/2017 01/31/2017 01/31/2017 01/31/2017 01/31/2017 01/31/2017 01/31/2017 12/31/2016 12/31/2016 12/31/2016 12/31/2016 12/31/2016 12/31/2016 12/31/2016 12/31/2016 12/31/2016 12/31/2016 11/30/2016 11/30/2016 11/30/2016 11/30/2016 11/30/2016 11/30/2016 11/30/2016 11/30/2016 11/30/2016 11/30/2016 10/31/2016 10/31/2016 10/31/2016 10/31/2016 10/31/2016 10/31/2016 10/31/2016 10/31/2016 10/31/2016 10/31/2016 09/30/2016 09/30/2016 09/30/2016 09/30/2016 09/30/2016 09/30/2016 09/30/2016 09/30/2016 09/30/2016 09/30/2016 08/31/2016 08/31/2016 08/31/2016 08/31/2016 08/31/2016 08/31/2016 08/31/2016 08/31/2016 08/31/2016 08/31/2016 07/31/2016 07/31/2016 07/31/2016 07/31/2016 07/31/2016 07/31/2016 07/31/2016 07/31/2016 07/31/2016 07/31/2016 Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] Oxygen, dissolved [DO] pH Solids, total suspended Nitrogen, Kjeldahl, total [as N] Phosphorus, total [as P] Flow, in conduit or thru treatment plan Chlorine, total residua Chlorine, total residua E. coli BOD, carbonaceous [5 day, 20 C] 1.26 1 .0242 .0242 kg/d 2 7 7 .0121 .0121 kg/d 1 .0039 .0039 kg/d .32 .41 .0032 .0032 MGD 0 1.06 1 .0242 .0242 kg/d 2 7 7 .0121 .0121 kg/d 1 .0013 .0013 kg/d .11 .41 .0032 .0032 MGD 0 1.2 1 .0242 .0242 kg/d 2 7.3 7.6 .0121 .0121 kg/d 1 0 0 kg/d 0 .08 .0032 .0032 MGD 0 1.09 1 .0242 .0242 kg/d 2 7 7.6 .0121 .0121 kg/d 1 0 0 kg/d 0 .42 .0036 .0045 MGD 0 1.24 1 .0242 .0242 kg/d 2 6.9 7.6 .0121 .0121 kg/d 1 .0016 .0016 kg/d .13 .41 .0033 .004 MGD 0 1.17 1 .0242 .0242 kg/d 2 7 7.6 .0121 .0121 kg/d 1 .0024 .0024 kg/d .2 .25 .0032 .0032 MGD 0 1.1 1 .0242 .0242 kg/d 2 7 7.5 .0145 .0145 kg/d 1 0 0 kg/d 0 .39 .0032 .0032 MGD 0 1.2 1 .0242 .0242 kg/d 2 7 7.4 .0121 .0121 kg/d 1 0 0 kg/d 0 .42 .0032 .0041 MGD 0 1.48 1 .0242 .0242 kg/d 2 7 7.5 .0121 .0121 kg/d 1 .0016 .0016 kg/d .13 .09 .0036 .0045 MGD 0 1.11 1 .0242 .0242 kg/d 2 6.9 7.4 .0136 .0136 kg/d 1 0 0 kg/d 0 .08 .0036 .0054 MGD 0 1.17 1 .0273 .0273 kg/d 2 7 7.5 .0102 .0102 kg/d 1 .0015 .0015 kg/d .15 .4 .0034 .0045 MGD 0 1.19 1 .0204 .0204 kg/d 2 mg/L #/100mL 2 mg/L mg/L 7.6 SU 1 mg/L .32 mg/L mg/L 0 mg/L mg/L #/100mL 2 mg/L mg/L 7.7 SU 1 mg/L .11 mg/L mg/L 0 mg/L mg/L #/100mL 2 mg/L mg/L 7.7 SU 1 mg/L 0 mg/L mg/L 0 mg/L mg/L #/100mL 2 mg/L mg/L 7.7 SU 1 mg/L 0 mg/L mg/L 0 mg/L mg/L #/100mL 2 mg/L mg/L 7.8 SU 1 mg/L .13 mg/L mg/L 0 mg/L mg/L #/100mL 2 mg/L mg/L 7.8 SU 1 mg/L .2 mg/L mg/L 0 mg/L mg/L #/100mL 2 mg/L mg/L 7.6 SU 1 mg/L 0 mg/L mg/L 0 mg/L mg/L #/100mL 2 mg/L mg/L 7.7 SU 1 mg/L 0 mg/L mg/L 0 mg/L mg/L #/100mL 2 mg/L mg/L 7.7 SU 1 mg/L .13 mg/L mg/L 0 mg/L mg/L #/100mL 2 mg/L mg/L 7.6 SU 1 mg/L 0 mg/L mg/L 0 mg/L mg/L #/100mL 2 mg/L mg/L 7.7 SU 1 mg/L .15 mg/L mg/L 0 mg/L mg/L #/100mL 2 mg/L Hiway Mobile Home Community, LLC WWTP (VA0074942) Compliance Evaluation Exhibit Log Exhibit 4 VDEQ Warning Letters (September 2019 - November 2019) Matthew J. Strickler Secretary of Natural Resources COMMONWEALTH of VIRGINIA DEPARTMENT OF ENVIRONMENTAL QUALITY NORTHERN REGIONAL OFFICE 13901 Crown Court, Woodbridge, Virginia 22193 (703) 583-3800 Fax (703) 583-3821 www.deq.virginia.gov September 30, 2019 David K. Paylor Director Thomas Faha Regional Director WARNING LETTER Mr. Jimmy Benson Manager Member Six-O-Five Mobile Home Group, LLC dba SMG, LLC. 5805 Staples Mill Road Richmond, VA 23228 RE: WL No. W2019-09-N-1013 Hill Mobile Home Park 2 - STP VA0090689 Caroline County VIA E-MAIL: Jimmy@JimmyBenson.com Dear Mr. Benson; The Department of Environmental Quality (DEQ), Northern Regional Office (NRO), has reason to believe that the Six O Five Mobile Home Group, LLC. may be in violation of State Water Control Law 62.1-44 and the Virginia Pollutant Discharge Elimination System (VPDES) Permit regulation 9 VAC 25-31-50.A et seq at the Hill Mobile Home Park 2 - Sewage Treatment Plant (STP) facility. This letter addresses conditions at the facility named above, and also cites compliance requirements of the State Water Control Law and Regulations. Pursuant to Va. Code 62.1-44.15 (8a), this letter is not a case decision under the Virginia Administrative Process Act, Va. Code 2.2-4000 et seq. The Department requests that you respond within 20 days of the date of this letter. OBSERVATIONS AND LEGAL REQUIREMENTS Facility staff are required to submit discharge monitoring reports (DMRs) and documents to DEQ NRO, including the following relevant data results. The following describe DEQ NRO staff factual observations and identify the applicable legal requirements. 1. Observations: Parameter Total Suspended Solids (TSS), Qty. Ave. (KG/D) TSS, Qty. Max. (KG/D) TSS, Conc. Ave. (mg/L) Total Phosphorus, Conc. Ave. (mg/L) CBOD5, Conc. Max. (mg/L) Observation - DMR Monitoring Period and Relevant Reported Monitoring Results July 2019 15 14.0 14 3.91 June 2019 18 Legal Requirement (Permit, Part I.A.1.b.) 0.19 0.28 10 2.0 15 *This facility had 2.0 points in the Compliance Auditing System at the end of July 2019. ENFORCEMENT AUTHORITY Va. Code 62.1-44.23 of the State Water Control Law provides for an injunction for any violation of the State Water Control Law, any State Water Control Board rule or regulation, an order, permit condition, standard, or any certificate requirement or provision. Va. Code 62.1-44.15 and 62.1-44.32 provide for a civil penalty up to $32,500 per day of each violation of the same. In addition, Va. Code 62.1-44.15 authorizes the State Water Control Board to issue orders to any person to comply with the State Water Control Law and regulations, including the imposition of a civil penalty for violations of up to $100,000. Also, Va. Code 10.1-1186 authorizes the Director of DEQ to issue special orders to any person to comply with the State Water Control Law and regulations, and to impose a civil penalty. Va. Code 62.1-44.32 (b) and 62.1-44.32 (c) provide for other additional penalties. FUTURE ACTIONS After reviewing this letter, please respond in writing to DEQ within 20 days of the date of this letter detailing actions you have taken or will be taking to ensure compliance with state law and regulations. If corrective action will take longer than 90 days to complete, you may be asked to sign a Letter of Agreement or enter into a Consent Order with the Department to formalize the plan and schedule. It is DEQ policy that appropriate, timely, corrective actions undertaken in response to a Warning Letter will avoid adversarial enforcement proceedings and the assessment of civil charges or penalties. Please advise us if you dispute any of the observations recited herein or if there is other information of which DEQ should be aware. In the event that discussions with staff do not lead to a satisfactory conclusion concerning the contents of this letter, you may elect to participate in DEQ's Process for Early Dispute Resolution. Also, if informal discussions do not lead to a satisfactory conclusion, you may request in writing that DEQ take all necessary steps to issue a final decision or fact finding under the APA on whether or not a violation has occurred. For further information on the Process for Early Dispute Resolution, please see Agency Policy Statement No. 8-2005 posted on the Department's website under "Programs," "Enforcement," and "Laws, Regulations, & Guidance" (http://www.deq.virginia.gov/Programs/Enforcement/Laws,Regulations,Guidance.aspx) or ask the DEQ contact below. Please direct written materials regarding this matter to Rebecca Johnson. Written materials may be sent either via the US Postal Service or electronically, via E-mail. DEQ recommends sending electronic responses as an Acrobat PDF or in a Word-compatible, write-protected format. If you have questions or wish to arrange a meeting, please contact Rebecca Johnson at (703) 583-3854 or by e-mail at Rebecca.Johnson@deq.virginia.gov Sincerely, Edward L. Stuart Regional Water Compliance Manager cc via electronic copy: ECM, Compliance Auditor; Compliance Manager - DEQ Matthew J. Strickler Secretary of Natural Resources COMMONWEALTH of VIRGINIA DEPARTMENT OF ENVIRONMENTAL QUALITY NORTHERN REGIONAL OFFICE 13901 Crown Court, Woodbridge, Virginia 22193 (703) 583-3800 www.deq.virginia.gov October 24, 2019 David K. Paylor Director Thomas Faha Regional Director WARNING LETTER Mr. Jimmy Benson Manager Member Six-O-Five Mobile Home Group, LLC dba SMG, LLC. 5805 Staples Mill Road Richmond, VA 23228 RE: WL No. W2019-10-N-1041 Hill Mobile Home Park 2 - STP VA0090689 Caroline County VIA E-MAIL: Jimmy@JimmyBenson.com Dear Mr. Benson; The Department of Environmental Quality (DEQ), Northern Regional Office (NRO), has reason to believe that the Six O Five Mobile Home Group, LLC. may be in violation of State Water Control Law 62.1-44 and the Virginia Pollutant Discharge Elimination System (VPDES) Permit regulation 9 VAC 25-31-50.A et seq at the Hill Mobile Home Park 2 - Sewage Treatment Plant (STP) facility. This letter addresses conditions at the facility named above, and also cites compliance requirements of the State Water Control Law and Regulations. Pursuant to Va. Code 62.1-44.15 (8a), this letter is not a case decision under the Virginia Administrative Process Act, Va. Code 2.2-4000 et seq. The Department requests that you respond within 20 days of the date of this letter. OBSERVATIONS AND LEGAL REQUIREMENTS Facility staff are required to submit discharge monitoring reports (DMRs) and documents to DEQ NRO, including the following relevant data results. The following describe DEQ NRO staff factual observations and identify the applicable legal requirements. 1. Observations: Parameter Total Suspended Solids (TSS), Qty. Ave. (KG/D) TSS, Conc. Ave. (mg/L) TSS, Conc. Weekly Max. (mg/L) Observation - DMR Monitoring Period and Relevant Reported Monitoring Results August 2019 0.26 17.3 17.3 Legal Requirement (Permit, Part I.A.2.) 0.19 10 15 *This facility had 2.2 points in the Compliance Auditing System at the end of August 2019. ENFORCEMENT AUTHORITY Va. Code 62.1-44.23 of the State Water Control Law provides for an injunction for any violation of the State Water Control Law, any State Water Control Board rule or regulation, an order, permit condition, standard, or any certificate requirement or provision. Va. Code 62.1-44.15 and 62.1-44.32 provide for a civil penalty up to $32,500 per day of each violation of the same. In addition, Va. Code 62.1-44.15 authorizes the State Water Control Board to issue orders to any person to comply with the State Water Control Law and regulations, including the imposition of a civil penalty for violations of up to $100,000. Also, Va. Code 10.1-1186 authorizes the Director of DEQ to issue special orders to any person to comply with the State Water Control Law and regulations, and to impose a civil penalty. Va. Code 62.1-44.32 (b) and 62.1-44.32 (c) provide for other additional penalties. FUTURE ACTIONS After reviewing this letter, please respond in writing to DEQ within 20 days of the date of this letter detailing actions you have taken or will be taking to ensure compliance with state law and regulations. If corrective action will take longer than 90 days to complete, you may be asked to sign a Letter of Agreement or enter into a Consent Order with the Department to formalize the plan and schedule. It is DEQ policy that appropriate, timely, corrective actions undertaken in response to a Warning Letter will avoid adversarial enforcement proceedings and the assessment of civil charges or penalties. Please advise us if you dispute any of the observations recited herein or if there is other information of which DEQ should be aware. In the event that discussions with staff do not lead to a satisfactory conclusion concerning the contents of this letter, you may elect to participate in DEQ's Process for Early Dispute Resolution. Also, if informal discussions do not lead to a satisfactory conclusion, you may request in writing that DEQ take all necessary steps to issue a final decision or fact finding under the APA on whether or not a violation has occurred. For further information on the Process for Early Dispute Resolution, please see Agency Policy Statement No. 8-2005 posted on the Department's website under "Programs," "Enforcement," and "Laws, Regulations, & Guidance" (http://www.deq.virginia.gov/Programs/Enforcement/Laws,Regulations,Guidance.aspx) or ask the DEQ contact below. Please direct written materials regarding this matter to Rebecca Johnson. Written materials may be sent either via the US Postal Service or electronically, via E-mail. DEQ recommends sending electronic responses as an Acrobat PDF or in a Word-compatible, write-protected format. If you have questions or wish to arrange a meeting, please contact Rebecca Johnson at (703) 583-3854 or by e-mail at Rebecca.Johnson@deq.virginia.gov Sincerely, Edward L. Stuart Regional Water Compliance Manager cc via electronic copy: ECM; Compliance Auditor; and Compliance Manager - DEQ Matthew J. Strickler Secretary of Natural Resources COMMONWEALTH of VIRGINIA DEPARTMENT OF ENVIRONMENTAL QUALITY NORTHERN REGIONAL OFFICE 13901 Crown Court, Woodbridge, Virginia 22193 (703) 583-3800 www.deq.virginia.gov David K. Paylor Director Thomas Faha Regional Director November 22, 2019 WARNING LETTER Mr. Jimmy Benson Manager Member Six-O-Five Mobile Home Group, LLC dba SMG, LLC. 5805 Staples Mill Road Richmond, VA 23228 RE: WL No. W2019-11-N-1015 Hill Mobile Home Park 2 - STP VA0090689 Caroline County VIA E-MAIL: Jimmy@JimmyBenson.com Dear Mr. Benson; The Department of Environmental Quality (DEQ), Northern Regional Office (NRO), has reason to believe that the Six O Five Mobile Home Group, LLC. may be in violation of State Water Control Law 62.1-44 and the Virginia Pollutant Discharge Elimination System (VPDES) Permit regulation 9 VAC 25-31-50.A et seq at the Hill Mobile Home Park 2 - Sewage Treatment Plant (STP) facility. This letter addresses conditions at the facility named above, and also cites compliance requirements of the State Water Control Law and Regulations. Pursuant to Va. Code 62.1-44.15 (8a), this letter is not a case decision under the Virginia Administrative Process Act, Va. Code 2.2-4000 et seq. The Department requests that you respond within 20 days of the date of this letter. OBSERVATIONS AND LEGAL REQUIREMENTS Facility staff are required to submit discharge monitoring reports (DMRs) and documents to DEQ NRO, including the following relevant data results. The following describe DEQ NRO staff factual observations and identify the applicable legal requirements. 1. Observations: Parameter Total Phosphorous, Conc. Ave. (mg/L) Observation - DMR Monitoring Period and Relevant Reported Monitoring Results September 2019 4.48 Legal Requirement (Permit, Part I.A.2.) 2.0 *This facility had 3.2 points in the Compliance Auditing System at the end of September 2019. ENFORCEMENT AUTHORITY Va. Code 62.1-44.23 of the State Water Control Law provides for an injunction for any violation of the State Water Control Law, any State Water Control Board rule or regulation, an order, permit condition, standard, or any certificate requirement or provision. Va. Code 62.1-44.15 and 62.1-44.32 provide for a civil penalty up to $32,500 per day of each violation of the same. In addition, Va. Code 62.1-44.15 authorizes the State Water Control Board to issue orders to any person to comply with the State Water Control Law and regulations, including the imposition of a civil penalty for violations of up to $100,000. Also, Va. Code 10.1-1186 authorizes the Director of DEQ to issue special orders to any person to comply with the State Water Control Law and regulations, and to impose a civil penalty. Va. Code 62.1-44.32 (b) and 62.1-44.32 (c) provide for other additional penalties. FUTURE ACTIONS After reviewing this letter, please respond in writing to DEQ within 20 days of the date of this letter detailing actions you have taken or will be taking to ensure compliance with state law and regulations. If corrective action will take longer than 90 days to complete, you may be asked to sign a Letter of Agreement or enter into a Consent Order with the Department to formalize the plan and schedule. It is DEQ policy that appropriate, timely, corrective actions undertaken in response to a Warning Letter will avoid adversarial enforcement proceedings and the assessment of civil charges or penalties. Please advise us if you dispute any of the observations recited herein or if there is other information of which DEQ should be aware. In the event that discussions with staff do not lead to a satisfactory conclusion concerning the contents of this letter, you may elect to participate in DEQ's Process for Early Dispute Resolution. Also, if informal discussions do not lead to a satisfactory conclusion, you may request in writing that DEQ take all necessary steps to issue a final decision or fact finding under the APA on whether or not a violation has occurred. For further information on the Process for Early Dispute Resolution, please see Agency Policy Statement No. 8-2005 posted on the Department's website under "Programs," "Enforcement," and "Laws, Regulations, & Guidance" (http://www.deq.virginia.gov/Programs/Enforcement/Laws,Regulations,Guidance.aspx) or ask the DEQ contact below. Please direct written materials regarding this matter to Rebecca Johnson. Written materials may be sent either via the US Postal Service or electronically, via E-mail. DEQ recommends sending electronic responses as an Acrobat PDF or in a Word-compatible, write-protected format. If you have questions or wish to arrange a meeting, please contact Rebecca Johnson at (703) 583-3854 or by e-mail at Rebecca.Johnson@deq.virginia.gov Sincerely, Edward L. Stuart Regional Water Compliance Manager cc via electronic copy: ECM; Compliance Auditor; and Compliance Manager - DEQ Hiway Mobile Home Community, LLC WWTP (VA0074942) Compliance Evaluation Exhibit Log Exhibit 5 VDEQ NOVs (January 2020 through September 2020) Matthew J. Strickler Secretary of Natural Resources COMMONWEALTH of VIRGINIA DEPARTMENT OF ENVIRONMENTAL QUALITY NORTHERN REGIONAL OFFICE 13901 Crown Court, Woodbridge, Virginia 22193 (703) 583-3800 www.deq.virginia.gov David K. Paylor Director Thomas Faha Regional Director January 3, 2019 NOTICE OF VIOLATION Mr. Jimmy Benson Manager Member Six-O-Five Mobile Home Group, LLC dba SMG, LLC. 5805 Staples Mill Road Richmond, VA 23228 RE: Referral NOV No. W2019-12-N-0005 Hill Mobile Home Park 2 - STP VA0090689 Caroline County VIA E-MAIL: Jimmy@JimmyBenson.com Dear Mr. Benson: This letter notifies you of information upon which the Department of Environmental Quality ("Department" or "DEQ") may rely in order to institute an administrative or judicial enforcement action. Based on this information, the DEQ Northern Regional Office (NRO), has reason to believe that the Six O Five Mobile Home Group, LLC. may be in violation of State Water Control Law 62.1-44 and the Virginia Pollutant Discharge Elimination System (VPDES) Permit regulation 9 VAC 25-31-50.A et seq. at the Hill Mobile Home Park 2 - Sewage Treatment Plant (STP) facility. This letter addresses conditions at the facility named above, and also cites compliance requirements of the State Water Control Law and Regulations. Pursuant to Va. Code 62.1-44.15 (8a), this letter is not a case decision under the Virginia Administrative Process Act, Va. Code 2.2-4000 et seq. The Department requests that you respond within 10 days of the date of this letter to arrange a prompt meeting. OBSERVATIONS AND LEGAL REQUIREMENTS Facility staff are required to submit discharge monitoring reports (DMRs) and documents to DEQ NRO, including the following relevant data results. The following describe DEQ NRO staff factual observations and identify the applicable legal requirements. 1. Observations: Parameter Total Suspended Solids (TSS), Qty. Ave. (KG/D) TSS, Qty. Max. (KG/D) TSS, Conc. Ave. (mg/L) TSS, Conc. Max. (mg/L) Total Kjeldahl Nitrogen (TKN), Qty. Ave. (KG/D) TKN, Qty. Max. (KG/D) TKN, Conc. Ave. (mg/L) TKN, Conc. Max. (mg/L) Observation - DMR Monitoring Period and Relevant Reported Monitoring Results October 2019 0.386 0.386 51 51 0.10 0.10 14.16 14.16 Legal Requirement (Permit, Part I.A.2.) 0.19 0.28 10 15 0.06 0.09 3.0 4.5 2. Observation: During the technical inspection conducted on October 9, 2019, DEQ staff observed solids in the receiving stream. DEQ staff did not receive 24-hour notification of the unauthorized discharge from the permittee. Legal Requirement: Permit Condition, Part II. F. and G. "Unauthorized Discharges. Except in compliance with this permit, or another permit issued by the Board, it shall be unlawful for any person to: 1. Discharge into state waters sewage, industrial wastes, other wastes, or any noxious or deleterious substances; or 2. Otherwise alter the physical, chemical or biological properties of such state waters and make them detrimental to the public healthy, or to animal or aquatic life, or to the use of such waters for domestic of industrial consumption, or for recreation or for other uses."...and "Reports of Unauthorized Discharges. Any permittee who discharges or causes or allows a discharge of sewage, industrial waste, other wastes or any noxious or deleterious substance into or upon state waters in violation of Part II.F.; or who discharges or causes or allows a discharge that may reasonably be expected to enter state waters in violation of Part II.F., shall notify the Department of the discharge immediately upon discovery of the discharge, but in no case later than 24 hours after said discovery." 3. Observations: On October 9, 2019, DEQ staff conducted a compliance site inspection and observed the following: The grass inside the treatment facility fence was overgrown; There was inadequate aeration in the SBR treatment unit; and The biomass in the SBR was gray and had a raw influent aroma. Legal Requirement: Permit Condition Part II. Q. "Proper Operation and Maintenance 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 also includes effective plant performance, adequate funding, adequate staffing, and adequate laboratory and process controls, including appropriate quality assurance procedures. This provision requires the operation of back-up or auxiliary facilities or similar systems which are installed by the permittee only when the operation is necessary to achieve compliance with the conditions of this permit." Provide photo documentation of the items noted above that have been addressed and/or an explanation of how the facility plans to address the items noted above to DEQ-NRO within thirty days of the date of this inspection report." *This facility had 7.2 points in the Compliance Auditing System at the end of October 2019. ENFORCEMENT AUTHORITY Va. Code 62.1-44.23 of the State Water Control Law provides for an injunction for any violation of the State Water Control Law, any State Water Control Board rule or regulation, an order, permit condition, standard, or any certificate requirement or provision. Va. Code 62.1-44.15 and 62.1-44.32 provide for a civil penalty up to $32,500 per day of each violation of the same. In addition, Va. Code 62.1-44.15 authorizes the State Water Control Board to issue orders to any person to comply with the State Water Control Law and regulations, including the imposition of a civil penalty for violations of up to $100,000. Also, Va. Code 10.1-1186 authorizes the Director of DEQ to issue special orders to any person to comply with the State Water Control Law and regulations, and to impose a civil penalty. Va. Code 62.1-44.32 (b) and 62.1-44.32 (c) provide for other additional penalties. FUTURE ACTIONS DEQ staff wishes to discuss all aspects of their observations with you, including any actions needed to ensure compliance with state law and regulations, any relevant or related measures you plan to take or have taken, and a schedule, as needed, for further activities. In addition, please advise us if you dispute any of the observations recited herein or if there is other information of which DEQ should be aware. In order to avoid adversarial enforcement proceedings, the Six O Five Mobile Home Group, LLC. may be asked to enter into a Consent Order with the Department to formalize a plan and schedule of corrective actions and to settle any outstanding issues regarding this matter, including the assessment of civil charges. In the event that discussions with staff do not lead to a satisfactory conclusion concerning the contents of this letter, you may elect to participate in DEQ's Process for Early Dispute Resolution. Also, if informal discussions do not lead to a satisfactory conclusion, you may request in writing that DEQ take all necessary steps to issue a final decision or fact finding under the APA on whether or not a violation has occurred. For further information on the Process for Early Dispute Resolution, please see Agency Policy Statement No. 8-2005 posted on the Department's website under "Programs," "Enforcement," and "Laws, Regulations, & Guidance" (http://www.deq.virginia.gov/Programs/Enforcement/Laws,Regulations,Guidance.aspx) or ask the DEQ contact listed below. Please direct written materials regarding this matter to James Datko. Written materials may be sent either via the US Postal Service or electronically, via E-mail. DEQ recommends sending electronic responses as an Acrobat PDF or in a Word-compatible, write-protected format. Please contact her at (703) 583-3870 or by e-mail at James.Datko@deq.virginia.gov within 10 days of the date of this letter to discuss this matter and arrange a prompt meeting. Sincerely, Edward L. Stuart Regional Water Compliance Manager cc via electronic copy: ECM; Compliance Auditor; and Compliance Manager - DEQ Vincent Lofton, Operator - vincentsevensons@aol.com Matthew J. Strickler Secretary of Natural Resources COMMONWEALTH of VIRGINIA DEPARTMENT OF ENVIRONMENTAL QUALITY NORTHERN REGIONAL OFFICE 13901 Crown Court, Woodbridge, Virginia 22193 (703) 583-3800 www.deq.virginia.gov David K. Paylor Director Thomas Faha Regional Director January 26, 2020 NOTICE OF VIOLATION Mr. Jimmy Benson Manager Member Six-O-Five Mobile Home Group, LLC dba SMG, LLC. 5805 Staples Mill Road Richmond, VA 23228 RE: NOV No. W2020-01-N-0005 Hill Mobile Home Park 2 - STP VA0090689 Caroline County VIA E-MAIL: Jimmy@JimmyBenson.com Dear Mr. Benson: This letter notifies you of information upon which the Department of Environmental Quality ("Department" or "DEQ") may rely in order to institute an administrative or judicial enforcement action. Based on this information, the DEQ Northern Regional Office (NRO), has reason to believe that the Six O Five Mobile Home Group, LLC. may be in violation of State Water Control Law 62.1-44 and the Virginia Pollutant Discharge Elimination System (VPDES) Permit regulation 9 VAC 25-31-50.A et seq. at the Hill Mobile Home Park 2 - Sewage Treatment Plant (STP) facility. This letter addresses conditions at the facility named above, and also cites compliance requirements of the State Water Control Law and Regulations. Pursuant to Va. Code 62.1-44.15 (8a), this letter is not a case decision under the Virginia Administrative Process Act, Va. Code 2.2-4000 et seq. The Department requests that you respond within 10 days of the date of this letter to arrange a prompt meeting. OBSERVATIONS AND LEGAL REQUIREMENTS Facility staff are required to submit discharge monitoring reports (DMRs) and documents to DEQ NRO, including the following relevant data results. The following describe DEQ NRO staff factual observations and identify the applicable legal requirements. 1. Observations: Parameter Total Suspended Solids (TSS), Qty. Ave. (KG/D) TSS, Conc. Ave. (mg/L) TSS, Conc. Max. (mg/L) Observation - DMR Monitoring Period and Relevant Reported Monitoring Results November 2019 0.23 21 21 Legal Requirement (Permit, Part I.A.2.) 0.19 10 15 *This facility had 8.2 points in the Compliance Auditing System at the end of November 2019. ENFORCEMENT AUTHORITY Va. Code 62.1-44.23 of the State Water Control Law provides for an injunction for any violation of the State Water Control Law, any State Water Control Board rule or regulation, an order, permit condition, standard, or any certificate requirement or provision. Va. Code 62.1-44.15 and 62.1-44.32 provide for a civil penalty up to $32,500 per day of each violation of the same. In addition, Va. Code 62.1-44.15 authorizes the State Water Control Board to issue orders to any person to comply with the State Water Control Law and regulations, including the imposition of a civil penalty for violations of up to $100,000. Also, Va. Code 10.1-1186 authorizes the Director of DEQ to issue special orders to any person to comply with the State Water Control Law and regulations, and to impose a civil penalty. Va. Code 62.1-44.32 (b) and 62.1-44.32 (c) provide for other additional penalties. FUTURE ACTIONS DEQ staff wishes to discuss all aspects of their observations with you, including any actions needed to ensure compliance with state law and regulations, any relevant or related measures you plan to take or have taken, and a schedule, as needed, for further activities. In addition, please advise us if you dispute any of the observations recited herein or if there is other information of which DEQ should be aware. In order to avoid adversarial enforcement proceedings, the Six O Five Mobile Home Group, LLC. may be asked to enter into a Consent Order with the Department to formalize a plan and schedule of corrective actions and to settle any outstanding issues regarding this matter, including the assessment of civil charges. In the event that discussions with staff do not lead to a satisfactory conclusion concerning the contents of this letter, you may elect to participate in DEQ's Process for Early Dispute Resolution. Also, if informal discussions do not lead to a satisfactory conclusion, you may request in writing that DEQ take all necessary steps to issue a final decision or fact finding under the APA on whether or not a violation has occurred. For further information on the Process for Early Dispute Resolution, please see Agency Policy Statement No. 8-2005 posted on the Department's website under "Programs," "Enforcement," and "Laws, Regulations, & Guidance" (http://www.deq.virginia.gov/Programs/Enforcement/Laws,Regulations,Guidance.aspx) or ask the DEQ contact listed below. Please direct written materials regarding this matter to James Datko. Written materials may be sent either via the US Postal Service or electronically, via E-mail. DEQ recommends sending electronic responses as an Acrobat PDF or in a Word-compatible, write-protected format. Please contact him at (703) 583-3870 or by e-mail at James.Datko@deq.virginia.gov within 10 days of the date of this letter to discuss this matter and arrange a prompt meeting. Sincerely, Edward L. Stuart Regional Water Compliance Manager cc via electronic copy: ECM; Compliance Auditor; and Compliance Manager - DEQ Vincent Lofton, Operator - vincentsevensons@aol.com Matthew J. Strickler Secretary of Natural Resources COMMONWEALTH of VIRGINIA DEPARTMENT OF ENVIRONMENTAL QUALITY NORTHERN REGIONAL OFFICE 13901 Crown Court, Woodbridge, Virginia 22193 (703) 583-3800 www.deq.virginia.gov David K. Paylor Director Thomas Faha Regional Director March 3, 2020 NOTICE OF VIOLATION Mr. Jimmy Benson Manager Member Six-O-Five Mobile Home Group, LLC dba SMG, LLC 5805 Staples Mill Road Richmond, VA 23228 RE: NOV No. W2020-02-N-0015 Hill Mobile Home Park 2 - STP VA0090689 Caroline County VIA E-MAIL: Jimmy@JimmyBenson.com Dear Mr. Benson: This letter notifies you of information upon which the Department of Environmental Quality ("Department" or "DEQ") may rely in order to institute an administrative or judicial enforcement action. Based on this information, the DEQ Northern Regional Office (NRO), has reason to believe that the Six O Five Mobile Home Group, LLC may be in violation of State Water Control Law 62.1-44 and the Virginia Pollutant Discharge Elimination System (VPDES) Permit regulation 9 VAC 25-31-50.A et seq. at the Hill Mobile Home Park 2 - Sewage Treatment Plant (STP) facility. This letter addresses conditions at the facility named above, and also cites compliance requirements of the State Water Control Law and Regulations. Pursuant to Va. Code 62.1-44.15 (8a), this letter is not a case decision under the Virginia Administrative Process Act, Va. Code 2.2-4000 et seq. (APA) OBSERVATIONS AND LEGAL REQUIREMENTS Facility staff are required to submit discharge monitoring reports (DMRs) and documents to DEQ NRO, including the following relevant data results. The following describe DEQ NRO staff factual observations and identify the applicable legal requirements. 1. Observations: Parameter TSS, Concentration (Conc.) Average (Ave.) (mg/L) TSS, Conc. Maximum (mg/L) Total Nitrogen, As N, Conc. Ave. (mg/L) Total Kjeldahl Nitrogen (TKN) Quantity Avg., (kg/D) TKN, Qty. Max. (kg/D) TKN, Conc. Avg. (mg/L) TKN, Conc. Max. (mg/L) Observation - DMR Monitoring Period and Relevant Reported Monitoring Results December 2019 24 24 X 0.31 0.31 21.42 21.42 Legal Requirement (Permit, Part I.A.2.) 10 15 NL 0.06 0.09 3.0 4.5 2. Observation: The 2019 Annual DMR was due to DEQ-NRO by January 10, 2020 and was received on January 22, 2020. Legal Requirement: Part 2. Section C. No. 1 states: "The permittee shall submit the results of the monitoring required by this permit not later than the 10th of the month after monitoring takes place unless another reporting schedule is specified elsewhere in this permit. Monitoring results shall be submitted to the department's regional office." *This facility had 9.0 points in the Compliance Auditing System at the end of December 2019. ENFORCEMENT AUTHORITY Va. Code 62.1-44.23 of the State Water Control Law provides for an injunction for any violation of the State Water Control Law, any State Water Control Board rule or regulation, an order, permit condition, standard, or any certificate requirement or provision. Va. Code 62.1-44.15 and 62.1-44.32 provide for a civil penalty up to $32,500 per day of each violation of the same. In addition, Va. Code 62.1-44.15 authorizes the State Water Control Board to issue orders to any person to comply with the State Water Control Law and regulations, including the imposition of a civil penalty for violations of up to $100,000. Also, Va. Code 10.1-1186 authorizes the Director of DEQ to issue special orders to any person to comply with the State Water Control Law and regulations, and to impose a civil penalty. Va. Code 62.1-44.32 (b) and 62.1-44.32 (c) provide for other additional penalties. FUTURE ACTIONS DEQ staff wishes to discuss all aspects of their observations with you, including any actions needed to ensure compliance with state law and regulations, any relevant or related measures you plan to take or have taken, and a schedule, as needed, for further activities. In addition, please advise us if you dispute any of the observations recited herein or if there is other information of which DEQ should be aware. In order to avoid adversarial enforcement proceedings, the Six O Five Mobile Home Group, LLC may be asked to enter into a Consent Order with the Department to formalize a plan and schedule of corrective actions and to settle any outstanding issues regarding this matter, including the assessment of civil charges. In the event that discussions with staff do not lead to a satisfactory conclusion concerning the contents of this letter, you may elect to participate in DEQ's Process for Early Dispute Resolution. Also, if informal discussions do not lead to a satisfactory conclusion, you may request in writing that DEQ take all necessary steps to issue a final decision or fact finding under the APA on whether or not a violation has occurred. For further information on the Process for Early Dispute Resolution, please see Agency Policy Statement No. 8-2005 posted on the Department's website under "Programs," "Enforcement," and "Laws, Regulations, & Guidance" (http://www.deq.virginia.gov/Programs/Enforcement/Laws,Regulations,Guidance.aspx) or ask the DEQ contact listed below. Please direct written materials regarding this matter to James Datko. Written materials may be sent either via the US Postal Service or electronically, via E-mail. DEQ recommends sending electronic responses as an Acrobat PDF or in a Word-compatible, write-protected format. Please contact him at (703) 583-3870 or by e-mail at James.Datko@deq.virginia.gov within 10 days of the date of this letter to discuss this matter and arrange a prompt meeting. Sincerely, Edward L. Stuart Regional Water Compliance Manager cc via electronic copy: ECM; Compliance Auditor; Compliance Manager; and Enforcement - DEQ Vincent Lofton, Operator - vincentsevensons@aol.com Matthew J. Strickler Secretary of Natural Resources COMMONWEALTH of VIRGINIA DEPARTMENT OF ENVIRONMENTAL QUALITY NORTHERN REGIONAL OFFICE 13901 Crown Court, Woodbridge, Virginia 22193 (703) 583-3800 www.deq.virginia.gov David K. Paylor Director Thomas Faha Regional Director May 19, 2020 NOTICE OF VIOLATION Mr. Jimmy Benson Manager Member Six-O-Five Mobile Home Group, LLC dba SMG, LLC 5805 Staples Mill Road Richmond, VA 23228 RE: NOV No. W2020-05-N-0007 Hill Mobile Home Park 2 - STP VA0090689 Caroline County VIA E-MAIL: Jimmy@JimmyBenson.com Dear Mr. Benson: This letter notifies you of information upon which the Department of Environmental Quality ("Department" or "DEQ") may rely in order to institute an administrative or judicial enforcement action. Based on this information, the DEQ Northern Regional Office (NRO), has reason to believe that the Six-O-Five Mobile Home Group, Limited Liability Corporation (LLC) may be in violation of State Water Control Law 62.1-44 and the Virginia Pollutant Discharge Elimination System (VPDES) Permit regulation 9 VAC 25-31-50.A et seq. at the Hill Mobile Home Park 2 - Sewage Treatment Plant (STP) facility. This letter addresses conditions at the facility named above, and also cites compliance requirements of the State Water Control Law and Regulations. Pursuant to Va. Code 62.1-44.15 (8a), this letter is not a case decision under the Virginia Administrative Process Act, Va. Code 2.2-4000 et seq. (APA) OBSERVATIONS AND LEGAL REQUIREMENTS Facility staff are required to submit discharge monitoring reports (DMRs) and documents to DEQ NRO, including the following relevant data results. The following describe DEQ NRO staff factual observations and identify the applicable legal requirements. 1. Observations: Parameter TSS, Quantity (Qty.) Average (Avg.) (kg/D) TSS, Qty. Maximum (Max.) (kg/D) TSS, Concentration (Conc.) Avg. (mg/L) TSS, Conc. Max. (mg/L) TKN (N-KJEL), Qty. Avg. (kg/D) TKN (N-KJEL), Qty. Max. (kg/D) TKN (N-KJEL), Conc. Avg. ( mg/L ) TKN (N-KJEL), Conc. Max. ( mg/L ) Observation - DMR Monitoring Period and Relevant Reported Monitoring Results March 2020 0.43 0.43 29 29 0.15 0.15 10.06 10.06 Legal Requirement (Permit, Part I.A.2.) 0.19 0.28 10 15 0.06 0.09 3.0 4.5 *This facility had 9.0 points in the Compliance Auditing System at the end of March 2020. ENFORCEMENT AUTHORITY Va. Code 62.1-44.23 of the State Water Control Law provides for an injunction for any violation of the State Water Control Law, any State Water Control Board rule or regulation, an order, permit condition, standard, or any certificate requirement or provision. Va. Code 62.1-44.15 and 62.1-44.32 provide for a civil penalty up to $32,500 per day of each violation of the same. In addition, Va. Code 62.1-44.15 authorizes the State Water Control Board to issue orders to any person to comply with the State Water Control Law and regulations, including the imposition of a civil penalty for violations of up to $100,000. Also, Va. Code 10.1-1186 authorizes the Director of DEQ to issue special orders to any person to comply with the State Water Control Law and regulations, and to impose a civil penalty. Va. Code 62.1-44.32 (b) and 62.1-44.32 (c) provide for other additional penalties. FUTURE ACTIONS DEQ staff wishes to discuss all aspects of their observations with you, including any actions needed to ensure compliance with state law and regulations, any relevant or related measures you plan to take or have taken, and a schedule, as needed, for further activities. In addition, please advise us if you dispute any of the observations recited herein or if there is other information of which DEQ should be aware. In order to avoid adversarial enforcement proceedings, the Six O Five Mobile Home Group, LLC may be asked to enter into a Consent Order with the Department to formalize a plan and schedule of corrective actions and to settle any outstanding issues regarding this matter, including the assessment of civil charges. In the event that discussions with staff do not lead to a satisfactory conclusion concerning the contents of this letter, you may elect to participate in DEQ's Process for Early Dispute Resolution. Also, if informal discussions do not lead to a satisfactory conclusion, you may request in writing that DEQ take all necessary steps to issue a final decision or fact finding under the APA on whether or not a violation has occurred. For further information on the Process for Early Dispute Resolution, please see Agency Policy Statement No. 8-2005 posted on the Department's website under "Programs," "Enforcement," and "Laws, Regulations, & Guidance" (http://www.deq.virginia.gov/Programs/Enforcement/Laws,Regulations,Guidance.aspx) or ask the DEQ contact listed below. Please direct written materials regarding this matter to James Datko. Written materials may be sent either via the US Postal Service or electronically, via E-mail. DEQ recommends sending electronic responses as an Acrobat PDF or in a Word-compatible, write-protected format. Please contact him at (703) 583-3870 or by e-mail at James.Datko@deq.virginia.gov within 30 days of the date of this letter to discuss this matter and arrange a prompt meeting. Sincerely, Edward L. Stuart Regional Water Compliance Manager cc via electronic copy: ECM; Compliance Auditor; Compliance Manager; and Enforcement - DEQ Vincent Lofton, Operator - vincentsevensons@aol.com Matthew J. Strickler Secretary of Natural Resources COMMONWEALTH of VIRGINIA DEPARTMENT OF ENVIRONMENTAL QUALITY NORTHERN REGIONAL OFFICE 13901 Crown Court, Woodbridge, Virginia 22193 (703) 583-3800 www.deq.virginia.gov David K. Paylor Director Thomas Faha Regional Director June 15, 2020 NOTICE OF VIOLATION Mr. Jimmy Benson Manager Member Six-O-Five Mobile Home Group, LLC dba SMG, LLC 5805 Staples Mill Road Richmond, VA 23228 RE: NOV No. W2020-06-N-0005 Hill Mobile Home Park 2 - STP VA0090689 Caroline County VIA E-MAIL: Jimmy@JimmyBenson.com Dear Mr. Benson: This letter notifies you of information upon which the Department of Environmental Quality ("Department" or "DEQ") may rely in order to institute an administrative or judicial enforcement action. Based on this information, the DEQ Northern Regional Office (NRO), has reason to believe that the Six-O-Five Mobile Home Group, Limited Liability Corporation (LLC) may be in violation of State Water Control Law 62.1-44 and the Virginia Pollutant Discharge Elimination System (VPDES) Permit regulation 9 VAC 25-31-50.A et seq. at the Hill Mobile Home Park 2 - Sewage Treatment Plant (STP) facility. This letter addresses conditions at the facility named above, and also cites compliance requirements of the State Water Control Law and Regulations. Pursuant to Va. Code 62.1-44.15 (8a), this letter is not a case decision under the Virginia Administrative Process Act, Va. Code 2.2-4000 et seq. (APA) OBSERVATIONS AND LEGAL REQUIREMENTS Facility staff are required to submit discharge monitoring reports (DMRs) and documents to DEQ NRO, including the following relevant data results. The following describe DEQ NRO staff factual observations and identify the applicable legal requirements. 1. Observation: Parameter TKN (N-KJEL), Conc. Avg. ( mg/L ) Observation - DMR Monitoring Period and Relevant Reported Monitoring Results April 2020 4.23 Legal Requirement (Permit, Part I.A.2.) 3.0 *This facility had 6.0 points in the Compliance Auditing System at the end of April 2020. ENFORCEMENT AUTHORITY Va. Code 62.1-44.23 of the State Water Control Law provides for an injunction for any violation of the State Water Control Law, any State Water Control Board rule or regulation, an order, permit condition, standard, or any certificate requirement or provision. Va. Code 62.1-44.15 and 62.1-44.32 provide for a civil penalty up to $32,500 per day of each violation of the same. In addition, Va. Code 62.1-44.15 authorizes the State Water Control Board to issue orders to any person to comply with the State Water Control Law and regulations, including the imposition of a civil penalty for violations of up to $100,000. Also, Va. Code 10.1-1186 authorizes the Director of DEQ to issue special orders to any person to comply with the State Water Control Law and regulations, and to impose a civil penalty. Va. Code 62.1-44.32 (b) and 62.1-44.32 (c) provide for other additional penalties. FUTURE ACTIONS DEQ staff wishes to discuss all aspects of their observations with you, including any actions needed to ensure compliance with state law and regulations, any relevant or related measures you plan to take or have taken, and a schedule, as needed, for further activities. In addition, please advise us if you dispute any of the observations recited herein or if there is other information of which DEQ should be aware. In order to avoid adversarial enforcement proceedings, the Six O Five Mobile Home Group, LLC may be asked to enter into a Consent Order with the Department to formalize a plan and schedule of corrective actions and to settle any outstanding issues regarding this matter, including the assessment of civil charges. In the event that discussions with staff do not lead to a satisfactory conclusion concerning the contents of this letter, you may elect to participate in DEQ's Process for Early Dispute Resolution. Also, if informal discussions do not lead to a satisfactory conclusion, you may request in writing that DEQ take all necessary steps to issue a final decision or fact finding under the APA on whether or not a violation has occurred. For further information on the Process for Early Dispute Resolution, please see Agency Policy Statement No. 8-2005 posted on the Department's website under "Programs," "Enforcement," and "Laws, Regulations, & Guidance" (http://www.deq.virginia.gov/Programs/Enforcement/Laws,Regulations,Guidance.aspx) or ask the DEQ contact listed below. Please direct written materials regarding this matter to James Datko. Written materials may be sent either via the US Postal Service or electronically, via E-mail. DEQ recommends sending electronic responses as an Acrobat PDF or in a Word-compatible, write-protected format. Please contact him at (703) 583-3870 or by e-mail at James.Datko@deq.virginia.gov within 30 days of the date of this letter to discuss this matter and arrange a prompt meeting. Sincerely, Edward L. Stuart Regional Water Compliance Manager cc via electronic copy: ECM; Compliance Auditor; Compliance Manager; and Enforcement - DEQ Matthew Raynor, Environmental Consultant - tarmatt@aol.com Matthew J. Strickler Secretary of Natural Resources COMMONWEALTH of VIRGINIA DEPARTMENT OF ENVIRONMENTAL QUALITY NORTHERN REGIONAL OFFICE 13901 Crown Court, Woodbridge, Virginia 22193 (703) 583-3800 www.deq.virginia.gov David K. Paylor Director Thomas Faha Regional Director August 25, 2020 NOTICE OF VIOLATION Mr. Jimmy Benson Manager Member Six-O-Five Mobile Home Group, LLC dba SMG, LLC 5805 Staples Mill Road Richmond, VA 23228 RE: NOV No. W2020-08-N-0009 Hill Mobile Home Park 2 - STP VA0090689 Caroline County VIA E-MAIL: Jimmy@JimmyBenson.com Dear Mr. Benson: This letter notifies you of information upon which the Department of Environmental Quality ("Department" or "DEQ") may rely in order to institute an administrative or judicial enforcement action. Based on this information, the DEQ Northern Regional Office (NRO), has reason to believe that the Six-O-Five Mobile Home Group, Limited Liability Corporation (LLC) may be in violation of State Water Control Law 62.1-44 and the Virginia Pollutant Discharge Elimination System (VPDES) Permit regulation 9 VAC 25-31-50.A et seq. at the Hill Mobile Home Park 2 - Sewage Treatment Plant (STP) facility. This letter addresses conditions at the facility named above, and also cites compliance requirements of the State Water Control Law and Regulations. Pursuant to Va. Code 62.1-44.15 (8a), this letter is not a case decision under the Virginia Administrative Process Act, Va. Code 2.2-4000 et seq. (APA) OBSERVATIONS AND LEGAL REQUIREMENTS Facility staff are required to submit discharge monitoring reports (DMRs) and documents to DEQ NRO, including the following relevant data results. The following describe DEQ NRO staff factual observations and identify the applicable legal requirements. 1. Observations: Parameter TSS, Quantity (Qty.) Average (Avg.) (kg/D) TSS, Qty. Maximum (Max.) (kg/D) TSS , Concentration (Conc.) Avg. (mg/L) TSS Conc. Max. (mg/L) TKN (N-KJEL), Qty. Avg. (mg/L) TKN (N-KJEL), Qty. Max. (kg/D) TKN (N-KJEL), Conc. Avg. (mg/L) TKN (N-KJEL), Conc. Max. (mg/L) CBOD5, Qty. Avg. (mg/L) CBOD5, Conc. Avg. (mg/L) CBOD5, Conc. Max. (mg/L) Observation - DMR Monitoring Period and Relevant Reported Monitoring Results June 2020 0.84 0.84 72.0 72.0 0.13 0.13 7.79 7.79 0.26 22 22 Legal Requirement (Permit, Part I.A.2.) 0.19 0.28 10 15 0.06 0.09 3.0 4.5 0.19 10 15 *This facility had 6.0 points in the Compliance Auditing System at the end of June 2020. ENFORCEMENT AUTHORITY Va. Code 62.1-44.23 of the State Water Control Law provides for an injunction for any violation of the State Water Control Law, any State Water Control Board rule or regulation, an order, permit condition, standard, or any certificate requirement or provision. Va. Code 62.1-44.15 and 62.1-44.32 provide for a civil penalty up to $32,500 per day of each violation of the same. In addition, Va. Code 62.1-44.15 authorizes the State Water Control Board to issue orders to any person to comply with the State Water Control Law and regulations, including the imposition of a civil penalty for violations of up to $100,000. Also, Va. Code 10.1-1186 authorizes the Director of DEQ to issue special orders to any person to comply with the State Water Control Law and regulations, and to impose a civil penalty. Va. Code 62.1-44.32 (b) and 62.1-44.32 (c) provide for other additional penalties. FUTURE ACTIONS DEQ staff wishes to discuss all aspects of their observations with you, including any actions needed to ensure compliance with state law and regulations, any relevant or related measures you plan to take or have taken, and a schedule, as needed, for further activities. In addition, please advise us if you dispute any of the observations recited herein or if there is other information of which DEQ should be aware. In order to avoid adversarial enforcement proceedings, the Six-O-Five Mobile Home Group, LLC may be asked to enter into a Consent Order with the Department to formalize a plan and schedule of corrective actions and to settle any outstanding issues regarding this matter, including the assessment of civil charges. In the event that discussions with staff do not lead to a satisfactory conclusion concerning the contents of this letter, you may elect to participate in DEQ's Process for Early Dispute Resolution. Also, if informal discussions do not lead to a satisfactory conclusion, you may request in writing that DEQ take all necessary steps to issue a final decision or fact finding under the APA on whether or not a violation has occurred. For further information on the Process for Early Dispute Resolution, please see Agency Policy Statement No. 8-2005 posted on the Department's website under "Programs," "Enforcement," and "Laws, Regulations, & Guidance" (http://www.deq.virginia.gov/Programs/Enforcement/Laws,Regulations,Guidance.aspx) or ask the DEQ contact listed below. Please direct written materials regarding this matter to James Datko. Written materials shall be sent electronically, via E-mail. DEQ recommends sending electronic responses as an Acrobat PDF or in a Word-compatible, writeprotected format. Please contact Mr. Datko at (703) 583-3870 or by e-mail at James.Datko@deq.virginia.gov within 30 days of the date of this letter to discuss this matter and arrange a prompt meeting. Sincerely, Edward L. Stuart Regional Water Compliance Manager cc via electronic copy: ECM; Compliance Auditor; Compliance Manager; and Enforcement - DEQ Matthew Raynor, Environmental Consultant - tarmatt@aol.com Matthew J. Strickler Secretary of Natural Resources COMMONWEALTH of VIRGINIA DEPARTMENT OF ENVIRONMENTAL QUALITY NORTHERN REGIONAL OFFICE 13901 Crown Court, Woodbridge, Virginia 22193 (703) 583-3800 www.deq.virginia.gov David K. Paylor Director Thomas Faha Regional Director September 22, 2020 NOTICE OF VIOLATION Mr. Jimmy Benson Manager Member Six-O-Five Mobile Home Group, LLC dba SMG, LLC 5805 Staples Mill Road Richmond, VA 23228 RE: NOV No. W2020-09-N-0009 Hill Mobile Home Park 2 - STP VA0090689 Caroline County VIA E-MAIL: Jimmy@JimmyBenson.com Dear Mr. Benson: This letter notifies you of information upon which the Department of Environmental Quality ("Department" or "DEQ") may rely in order to institute an administrative or judicial enforcement action. Based on this information, the DEQ Northern Regional Office (NRO), has reason to believe that the Six-O-Five Mobile Home Group, Limited Liability Corporation (LLC) may be in violation of State Water Control Law 62.1-44 and the Virginia Pollutant Discharge Elimination System (VPDES) Permit regulation 9 VAC 25-31-50.A et seq. at the Hill Mobile Home Park 2 - Sewage Treatment Plant (STP) facility. This letter addresses conditions at the facility named above, and also cites compliance requirements of the State Water Control Law and Regulations. Pursuant to Va. Code 62.1-44.15 (8a), this letter is not a case decision under the Virginia Administrative Process Act, Va. Code 2.2-4000 et seq. (APA) OBSERVATIONS AND LEGAL REQUIREMENTS Facility staff are required to submit discharge monitoring reports (DMRs) and documents to DEQ NRO, including the following relevant data results. The following describe DEQ NRO staff factual observations and identify the applicable legal requirements. 1. Observations: Parameter TSS, Quantity (Qty.) Average (Avg.) (kg/D) TSS, Qty. Maximum (Max.) (kg/D) TSS , Concentration (Conc.) Avg. (mg/L) TSS Conc. Max. (mg/L) Total Phosphorous, Conc. Avg. (mg/L) TKN (N-KJEL), Conc. Avg. (mg/L) TKN (N-KJEL), Conc. Max. (mg/L) CBOD5, Conc. Avg. (mg/L) Observation - DMR Monitoring Period and Relevant Reported Monitoring Results July 2020 0.72 0.90 54.0 68.0 3.92 3.98 5.93 11 Legal Requirement (Permit, Part I.A.2.) 0.19 0.28 10 15 2.0 3.0 4.5 10 *This facility had 7.0 points in the Compliance Auditing System at the end of July 2020. ENFORCEMENT AUTHORITY Va. Code 62.1-44.23 of the State Water Control Law provides for an injunction for any violation of the State Water Control Law, any State Water Control Board rule or regulation, an order, permit condition, standard, or any certificate requirement or provision. Va. Code 62.1-44.15 and 62.1-44.32 provide for a civil penalty up to $32,500 per day of each violation of the same. In addition, Va. Code 62.1-44.15 authorizes the State Water Control Board to issue orders to any person to comply with the State Water Control Law and regulations, including the imposition of a civil penalty for violations of up to $100,000. Also, Va. Code 10.1-1186 authorizes the Director of DEQ to issue special orders to any person to comply with the State Water Control Law and regulations, and to impose a civil penalty. Va. Code 62.1-44.32 (b) and 62.1-44.32 (c) provide for other additional penalties. FUTURE ACTIONS DEQ staff wishes to discuss all aspects of their observations with you, including any actions needed to ensure compliance with state law and regulations, any relevant or related measures you plan to take or have taken, and a schedule, as needed, for further activities. In addition, please advise us if you dispute any of the observations recited herein or if there is other information of which DEQ should be aware. In order to avoid adversarial enforcement proceedings, the Six-O-Five Mobile Home Group, LLC may be asked to enter into a Consent Order with the Department to formalize a plan and schedule of corrective actions and to settle any outstanding issues regarding this matter, including the assessment of civil charges. In the event that discussions with staff do not lead to a satisfactory conclusion concerning the contents of this letter, you may elect to participate in DEQ's Process for Early Dispute Resolution. Also, if informal discussions do not lead to a satisfactory conclusion, you may request in writing that DEQ take all necessary steps to issue a final decision or fact finding under the APA on whether or not a violation has occurred. For further information on the Process for Early Dispute Resolution, please see Agency Policy Statement No. 8-2005 posted on the Department's website under "Programs," "Enforcement," and "Laws, Regulations, & Guidance" (http://www.deq.virginia.gov/Programs/Enforcement/Laws,Regulations,Guidance.aspx) or ask the DEQ contact listed below. Please direct written materials regarding this matter to James Datko. Written materials shall be sent electronically, via E-mail. DEQ recommends sending electronic responses as an Acrobat PDF or in a Word-compatible, writeprotected format. Please contact Mr. Datko at (703) 583-3870 or by e-mail at James.Datko@deq.virginia.gov within 30 days of the date of this letter to discuss this matter and arrange a prompt meeting. Sincerely, Edward L. Stuart Regional Water Compliance Manager cc via electronic copy: ECM; Compliance Auditor; Compliance Manager; and Enforcement - DEQ Matthew Raynor, Environmental Consultant - tarmatt@aol.com Hiway Mobile Home Community, LLC WWTP (VA0074942) Compliance Evaluation Exhibit Log Exhibit 6 Discharger Compliance Response Emails and Letters > October 9, 2019 Rebecca Johnson Inspector DEQ 13901 Crown Court Woodbridge VA, 22193 Dear Mrs. Johnson: This communication is about a warning letter for Hills Mobile Park permit number VA0090689 TSS exceedance. During this reporting period, we found that there was a power failure at the facility and the system had to be manually reset as a result of the system being off for a majority of the day coupled with the elevated temperature I think there was some biological die off that resulted in the elevated results for this reporting period. Since then we have had the anoxic tank pumped out and have adjusted the aspirator run times. We also continue to add alum to help precipitate out some of the colloids we also use polymer to aid in floc formation and settling. In conclusion, we are making every attempt to meet permit requirements and appreciate any assistance you can render. Thanks Vincent Lofton Enclosure From: To: Subject: Date: vincentsevensons@aol.com rebecca.johnson@deq.virginia.gov Letter Of Non Conpliance Hill Mobile Home Park Friday, October 11, 2019 4:31:27 AM Good morning Ms.Johnson I am Writing in reference to Hill Mobile Park VA0090689 letter of non compliance for the eDMR submitted for august 2019 The Parks WWTP exceeded the TSS parameters for the monthly reporting period ,I believe that due to a power failure and the SBR system not resetting created a temporary loss of treatment that effected the biomass .We reset the system and began adding supplemental bacteria to aid in recovery. we continue to make adjustments to the system we extended the reaction time/aeration and mixing to aid in recovery . If you have any questions please call 804-909-1993 Thanks Vincent Lofton From: To: Subject: Date: vincentsevensons@aol.com rebecca.johnson@deq.virginia.gov Hill Mobile Park September 2019 Tuesday, October 15, 2019 1:44:03 PM Good afternoon Ms. Johnson I am writing you in reference to Hill mobile park VA0090689 letter of non compliance on total phosphorus limits the test results indicated 4.48 mg/l and the limits are 2.0 mg/l . We recently pumped out the anoxic tank on the system which is the only thing I can think of to attribute the elevated results .Going forward we have increased our alum dose and extended the settling time cycle in the SBR PLC setting I am hopeful that this will correct the elevated readings please let me know if you have any questions. Thanks Vincent Lofton 804-909-1993 From: To: Subject: Date: vincentsevensons@aol.com rebecca.johnson@deq.virginia.gov Hill MHP -VA0090689 Friday, November 15, 2019 4:47:19 PM Good afternoon Mrs. Johnson I am following up on the compliance R-con inspection performed on 11/8/19 as requested we reported per your observations that there was a potential loss of solids that may have entered the receiving stream /Maracossic creek on the DEQ web site after receiving your report as a matter of protocol . We inspected the receiving stream and could not verify any solids loss of the magnitude displayed in the photo and mentioned in the report .But we do acknowledge there are some treatment concerns that have and are being addressed we have stared adding supplemental bacteria to accelerate the recovery of the biomass witch I believe was a toxic shock to the system ,We have checked the aeration settings on the PLC they are at 3 minutes and the residual of dissolved oxygen is well within parameters Averaging 4.0 PPM we have are adding soda ash for ph. adjustments .And have began supplementing the food source with moderate amounts of sugar to aid in the biomass recovery .As always I appreciate any suggestions or help you can render. Thanks Vincent Lofton Vincent Lofton > [Job Title] > [Job Title] December 12, 2019 Rebecca Johnson Water Compliance Inspector Department of Environmental Quality 13901 Crown Court Woodbridge VA.22193 Dear Mrs. Johnson This communication is in response to a warning letter dated 11/22/19 VA0090689WL referencing a reported exceedance for Hill Mobile Home Park for total phosphorus for 9/2019 DMR reporting period. During the time frame we are referencing we had recently had the anaerobic tank pumped out and experienced a minor reduction in treatment our adjustment where to increase alum use to help precipitate out phosphorus and increasing the reaction cycle on the SBR PLC. WE continue to make adjustments to the system, including the addition of cold weather bacteria after meeting with Maryland Biochemical to assist in improving the overall performance of the facility .We have seen encouraging results. Please let me know if you have any questions. [Address 1] [Address 2] [City, ST ZIP Code] [Telephone] [Email] [Website] Sincerely, Vincent Lofton From: To: Cc: Subject: Date: Matthew Raynor "Rebecca Johnson"; "Jimmy Benson" "Datko, Jim" RE: VA0090689 Notice of Violation Tuesday, August 25, 2020 10:05:18 AM Ms. Johnson, In response to your attached NOV for Hill MHC WWTP; We have made numerous changes to correct operating issues with the PLC that controls the SBR. These and other changes are putting the facility on a path to compliance. We had continuing issues in July as well but so far in August we are on track. You have been sent continual reports weekly from the operators. Please contact me or John if you need anything. Matthew Raynor, REE Va. Inc Matthew E. Raynor 524 Meadow Ave. Loop Banner Elk, NC 28604 B (828) 733-5028 C (919) 270-4831 From: Rebecca Johnson <rebecca.johnson@deq.virginia.gov> Sent: Tuesday, August 25, 2020 9:27 AM To: Jimmy Benson <jimmy@jimmybenson.com> Cc: Matthew Raynor <tarmatt@aol.com>; Datko, Jim <james.datko@deq.virginia.gov> Subject: VA0090689 Notice of Violation Good morning, Attached is a copy of the above referenced document. Should you have any questions please feel free to contact me. V/r, Rebecca Johnson Department of Environmental Quality Northern Regional Office Water Compliance Inspector Senior II 13901 Crown Court Woodbridge, VA 22193 Office: (703) 583-3854 Please report all pollution incidents, including SSO's and suspected violations of state environmental law, via the DEQ website: https://www.deq.virginia.gov/Programs/PollutionResponsePreparedness/MakingaReport.aspx From: To: Cc: Subject: Date: Matthew Raynor rebecca.johnson@deq.virginia.gov; jimmy@jimmybenson.com james.datko@deq.virginia.gov Re: VA0090689 Notice of Violation Tuesday, September 22, 2020 10:34:04 AM Ms. Johnson, We have overcome many challenges at the Hill's WWTP. We rectify one issue just to discover another. We hope we are at the bottom of the "issues" barrel. July was full of problems with PLC adjustments, which were wreaking havoc on the biomass. Reseeding bio-mass and trying to constantly restart the plant. The only thing I can say is we never allowed any solids to discharge and spent a load of time make sure we had the plant in operation but we ironed out those issues to only discover new ones. We bombed in August due to problems with the influent line, pumps and tanks. These had to be replaced which took a lot of time to troubleshoot, then come up with solutions. We think we have most of those settled. We remain in high hopes for September. We feel a little like "Sisyphus" but we keep push the rock! Matt -----Original Message----From: Rebecca Johnson <rebecca.johnson@deq.virginia.gov> To: Jimmy Benson <jimmy@jimmybenson.com> Cc: Matthew Raynor <tarmatt@aol.com>; Datko, Jim <james.datko@deq.virginia.gov> Sent: Tue, Sep 22, 2020 9:58 am Subject: VA0090689 Notice of Violation Good morning Jimmy, Attached is a copy of the above referenced document. Should you have any questions please feel free to contact me. V/r, Rebecca Johnson Department of Environmental Quality Northern Regional Office Water Compliance Inspector Senior II 13901 Crown Court Woodbridge, VA 22193 Office: (703) 583-3854 Please report all pollution incidents, including SSO's and suspected violations of state environmental law, via the DEQ website: https://www.deq.virginia.gov/Programs/PollutionResponsePreparedness/MakingaReport.aspx Hiway Mobile Home Community, LLC WWTP (VA0074942) Compliance Evaluation Exhibit Log Exhibit 7 VDEQ October 2019 Compliance Inspection Report COMMONWEALTH of VIRGINIA Matthew J. Strickler Secretary of Natural Resources DEPARTMENT OF ENVIRONMENTAL QUALITY NORTHERN REGIONAL OFFICE 13901 Crown Court, Woodbridge, Virginia 22193 (703) 583-3800 www.deq.virginia.gov David K. Paylor Director Thomas A. Faha Regional Director November 8, 2019 Mr. James Benson Six-O-Five Mobile Home Group, LLC P.O. Box 70367 Richmond, VA 23255-0367 Re: Hill MHP- STP - Permit # VA0090689 Dear Mr. Benson: Attached is a copy of the Inspection Report generated while conducting a Facility Recon Inspection at Hill Mobile Home Park (MHP) Sewage Treatment Plant (STP), on October 9, 2019. This letter is not intended as a case decision under the Virginia Administrative Process Act, Va. Code 2.2-4000 et seq. (APA). Please review the "Request for Corrective Action" section and submit in writing, a narrative outlining how the facility plans to address these items, to the Department of Environmental Quality - Northern Regional Office (DEQ-NRO) within thirty dates from the date of this inspection report. If you have any questions or comments concerning this report, please feel free to contact me at (703) 583-3854 or email at Rebecca.Johnson@deq.virginia.gov Sincerely, Rebecca Johnson Environmental Specialist II cc via electronic copy: ECM; Compliance Manager; Compliance Auditor; and Compliance Inspector - DEQ James Benson; Jimmy@JimmyBenson.com Vincent Lofton, Operator; Vincentsevensons@aol.com Virginia Department of Environmental Quality COMPLIANCE INSPECTION REPORT FACILITY NAME: Hill MHP - STP INSPECTION DATE: INSPECTOR PERMIT No.: TYPE OF FACILITY: VA0073504 Municipal Industrial Federal Major Minor Small Minor PHOTOGRAPHS: Yes REVIEWED BY / Date: No REPORT DATE: TIME OF INSPECTION: TOTAL TIME SPENT (including prep & travel) UNANNOUNCED INSPECTION? PRESENT DURING INSPECTION: 11/8/19 Amy Hagerdon, DEQ October 9, 2019 Rebecca Johnson November 8, 2019 1430 1510 8 Hours Yes No WL # W2019-10-N-1041: Paraphrase Noncompliance issues 1. TSS, Qty. Ave. Exceedance 2. TSS, Conc. Ave. Exceedance 3. TSS, Conc. Weekly Max. Exceedance Reported Cause of Noncompliance: Power failure to SBR effected biomass Corrective Action Taken: Reset system and is feeding bacteria to aid in the recovery INSPECTION OVERVIEW AND CONDITION OF TREATMENT UNITS DEQ staff arrived onsite for an unannounced site inspection and Mr. Lofton, Operator, was not onsite. The purpose of this site visit was to observe the treatment system, outfall and receiving stream. Facility Tour Sequencing Batch Reactor The grass inside the fence was overgrown. The unit was not aerating upon arrival. The activated sludge in this unit was gray and had a raw influent aroma, Photos 1 & 2. The blowers started and aerated the SBR for two minutes and then shut off, Photo 3. There was inadequate aeration in the SBR treatment unit. See Request for Corrective Action. Chlorine Contact Chamber and Tank (CCC and CCT) There were chlorine tablets readily available to disinfect the SBR effluent prior to final effluent discharge, Photo 4. The water in the CCT was green, Photo 5. Outfall 001 The treatment system was not discharging while DEQ staff was onsite. There was a raw influent aroma at the outfall pipe and there were solids in the receiving stream, Photos 6 - 9. See Request for Corrective Action. Operations staff did not report the solids in the receiving stream to DEQ within 24-hours. See Request for Corrective Action. DEQ staff departed at 1510. DEQ form: 06-2011 1 VA DEQ Recon Inspection Report Permit # VA0090689 Flow pH MGD S.U. EFFLUENT FIELD DATA: N/A Dissolved Oxygen mg/L TRC (Contact Tank) N/A Temperature C TRC (Final Effluent) N/A Was a Sampling Inspection conducted? Yes (See Sampling Inspection) No CONDITION OF OUTFALL AND EFFLUENT CHARACTERISTICS: 1. Type of outfall: Shore Based Submerged Diffuser? Yes No 2. Are the outfall and supporting structures in good condition? Yes No 3. Final Effluent (evidence of following problems): Sludge Bar Grease Turbid effluent Visible foam Unusual color Oil sheen 4. Is there a visible effluent plume in the receiving stream? Yes No 5. Receiving stream: No observed problems Indication of problems (explain below) Comments: Solids were observed in the receiving stream. DEQ form: 06-2011 2 VA DEQ Recon Inspection Report REQUEST for CORRECTIVE ACTION: 1. Observation(s): During the October 9, 2019 inspection, sludge solids were observed in the receiving stream. Legal Requirement: Permit Condition Part II, Section F, Unauthorized Discharges, states, "Except in compliance with this permit, or another permit issued by the Board, it shall be unlawful for any person to 1) discharge into state waters sewage, industrial waste, other wastes, or any noxious or deleterious substances; or 2) Otherwise alter the physical, chemical or biological properties of such state waters and make them detrimental to the public health, or to animal or aquatic life, or to the use of such waters for domestic industrial consumption, or for recreation or for other uses. G. Reports of Unauthorized Discharges. Any permittee who discharges or causes or allows a discharge of sewage, industrial waste, other wastes or any noxious or deleterious substance into or upon state waters in violation of Part II.F; or who discharges or causes or allows a discharge that may reasonably be expected to enter state waters in violation of Part II.F, shall notify the Department of the discharge immediately upon discovery of the discharge, but in no case later than 24 hours after said discovery. A written report of the unauthorized discharge shall be submitted to the Department within five days of discovery of the discharge. The written report shall contain: 1. A description of the nature and location of the discharge; 2. The cause of the discharge; 3. The date on which the discharge occurred; 4. The length of time that the discharge continued; 5. The volume of the discharge; 6. If the discharge is continuing, how long it is expected to continue; 7. If the discharge is continuing, what the expected total volume of the discharge will be; and 8. Any steps planned or taken to reduce, eliminate and prevent a recurrence of the present discharge or any future discharges not authorized by this permit. Discharges reportable to the Department under the immediate reporting requirements of other regulations are exempted from this requirement. H. Reports of Unusual or Extraordinary Discharges. If any unusual or extraordinary discharge including a bypass or upset should occur from a treatment works and the discharge enters or could be expected to enter state waters, the permittee shall promptly notify, in no case later than 24 hours, the Department by telephone after the discovery of the discharge. This notification shall provide all available details of the incident, including any adverse affects on aquatic life and the known number of fish killed. The permittee shall reduce the report to writing and shall submit it to the Department within five days of discovery of the discharge in accordance with Part II.I.2. Unusual and extraordinary discharges include but are not limited to any discharge resulting from: 1. Unusual spillage of materials resulting directly or indirectly from processing operations; 2. Breakdown of processing or accessory equipment; 3. Failure or taking out of service some or all of the treatment works; and 4. Flooding or other acts of nature DEQ staff would like to remind the permittee that when solids are observed in the stream, this must be reported to DEQ-NRO within 24 hours of discovery. DEQ form: 06-2011 3 VA DEQ Recon Inspection Report 2. Observations: On October 9, 2019, DEQ staff conducted a compliance site inspection and observed the following: The grass inside the treatment facility fence was overgrown; There was inadequate aeration in the SBR treatment unit; and The biomass in the SBR was gray and had a raw influent aroma. Legal Requirement: Permit Condition Part II. Q. "Proper Operation and Maintenance 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 also includes effective plant performance, adequate funding, adequate staffing, and adequate laboratory and process controls, including appropriate quality assurance procedures. This provision requires the operation of back-up or auxiliary facilities or similar systems which are installed by the permittee only when the operation is necessary to achieve compliance with the conditions of this permit." Provide photo documentation of the items noted above that have been addressed and/or an explanation of how the facility plans to address the items noted above to DEQ-NRO within thirty days of the date of this inspection report. Provide an explanation as to how the permittee plans to address the items noted above to DEQ-NRO within thirty days of the date of this inspection report. None. NOTES and COMMENTS: DEQ form: 06-2011 4 SBR 1) SBR - Overgrown Grass - Poor housekeeping 2) Thin and Gray biomass in SBR 3) SBR Aerating and Overgrown Grass - Poor housekeeping 4) Chlorination Unit - Overgrown Grass - Poor housekeeping Facility name: Hill MHP - STP Site Inspection Date: October 9, 2019 VPDES Permit No. VA0090689 Photos & Layout by: Rebecca Johnson Page 1 of 3 5) Basin Prior to Post Aeration Tank - Green water 6) Outfall 001 Pipe 7) Solids in the receiving stream 8) Solids in the receiving stream Facility name: Hill MHP - STP Site Inspection Date: October 9, 2019 VPDES Permit No. VA0090689 Photos & Layout by: Rebecca Johnson Page 2 of 3 9) Solids in the receiving stream Facility name: Hill MHP - STP Site Inspection Date: October 9, 2019 VPDES Permit No. VA0090689 Photos & Layout by: Rebecca Johnson Page 3 of 3 Hill Mobile Home Park STP (VA0090689) Compliance Evaluation Exhibit Log Exhibit 8 Examples of Plant Documentation and Recordkeeping (Operational Data and Calibration Logs)