WQ0019755_NOV-2021-PC-0324 Mailed Response_20210727

WC -Management, LLC
P.O. Box 345, Oak Ridge, NC 27310
336-669-2724
July 27, 2021
Mr. Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ-WSRO
450 West Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
Re: Notice of Violation (NOC-2021-PC-0324
Oak Ridge Commons
Permit No. WQ0019
Dear Mr. Snider:
Certified Mail/Return Receipt
NC Department of
Environmental Quality
Received
RI 2021
Winston-Salem
Regional Office
We received the NOV and are working with our design engineer, John F. Phillips, to address the
questions and issues the NOV referenced. John's initial response is enclosed.
Sincerely,
Philip M. Cook
Manager
JPC Utilities, LLC
Enclosure
Cc via email:
Ms. Caitlin Caudle
[e-mail]
Mr. John Phillips
Mr. Doug Smith
Mr. Bradley Flynt

DIEHL & PHILLIPS, P.A.
CONSULTING ENGINEERS WILLIAM C. DIEHL, P.E.
1500 Piney Plains Rd, Suite 200 JOHN F. PHILLIPS, P.E.
Cary, North Carolina 27518 ALAN R. KEITH, P.E.
Telephone [phone] — Fax [phone]
July 27, 2021
Mr. Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ-WSRO
450 West Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
Re: Notice of Violation (NOV-2021-PC-0324)
Oak Ridge Commons
Permit No. WQ0019755
Dear Mr. Snider:
Diehl & Phillips, P.A. was furnished a copy of the referenced NOV by JPC Utilities,
LLC. After reviewing the NOV, it is our opinion that item 1 in your letter incorrectly
identifies some of the described piping configurations as bypassing the designed
treatment system. The "upset system" referred to in your letter is actually a 6,000
gpd wastewater treatment system that is permitted to accept and treat wastewater
from Oak Ridge Commons, and to irrigate the treated water onto irrigation zones
that are segregated from the reclaimed water irrigation zones. The permitted 30,000
gpd reclaim treatment plant has always had a permitted pump and pipe in place to
allow a portion of the influent wastewater to the plant to be diverted from the plant's
flow equalization basin to the 6,000 gpd treatment system. Rather than returning the
filter backwash water to the equalization basin and then pumping a mixture of
backwash waters and raw wastewater to the 6,000 gpd treatment system, JPC
Utilities installed a second pipe to the 6,000 gpd system that only conveys the filter
backwash waters to the 6,000 gpd system. Directing the filter backwash waters to
the 6,000 gpd treatment system rather than the 30,000 gpd treatment system is not
bypassing the designed treatment systems. We do agree that your office should have
updated plans and design information that reflects the current piping arrangements,
and a better explanation of the flow path options in the system; whether or not these
modifications rise to the level of requiring a permit modification will be up to your
assessment.

Mr. Lon T. Snider
July 27, 2021
Page 2 of 2
Per your letter, JPC Utilities, LLC will submit plans and specifications/certifications for
the modifications to your office on or before October 1, 2021. This submittal will also
address the deficiencies and items of concern noted in your letter. The Residuals
Management Plan will be submitted to your office in compliance with the schedule
required in your letter.
We look forward to working with your office to clarify or correct the items described
in the Notice.
Yours very truly,
Diehl & Phillips, P.A.
John F. Phillips, P.E.
Cc: Ms. JenniferGraznak
Ms. Caitlin Caudle