WQ0019755_Additional Information Request #1_20220318

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
PHILIP COOKE — MANAGER
JPC UTILITIES LLC
POST OFFICE BOX 345
OAK RIDGE, NORTH CAROLINA 27310
Dear Mr. Cooke:
NORTH CAROLINA
Environmental Quality
March 18, 2022
Subject: Application No. WQ0019755
Additional Information Request
Oak Ridge Commons WWTP
Reclaimed Water Generation,
Dedicated Utilization, and
Wastewater Irrigation System
Guilford County
Division of Water Resources' Central and Regional staff has reviewed the application package
received December 22, 2021. However, additional information is required before the review may be
completed. Please address the items on the attached pages no later than the close of business on April 19,
2022.
Please be aware that you are responsible for meeting all requirements set forth in North Carolina
rules and regulations. Any oversights that occurred in the review of the subject application package are
still the Applicant's responsibility. In addition, any omissions made in responding to the outstanding items
in Sections A through H, or failure to provide the additional information on or before the above requested
date may result in your application being returned as incomplete pursuant to 15A NCAC 02T .0107(e)(2).
Please reference the subject application number when providing the requested information. All
revised and/or additional documentation shall be signed, sealed and dated (where needed), with an
electronic response submitted to my attention at: https://edocs.deq.nc.gov/Forms/NonDischarge-Branch-
Submittal-Form-Ver2.
If you have any questions regarding this request, please contact me at [phone] or
[e-mail]. Thank you for your cooperation.
Sincerely, -DocuSigned by:
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-A167AEB7F4A546F...
Poorva Mokashi, Engineer I
Division of Water Resources
cc: Winston Salem Regional Office, Water Quality Regional Operations Section (Electronic Copy)
John Phillips, PE — Diehl & Phillips, PA (Electronic Copy)
Laserfiche File (Electronic Copy)
Permit Application File WQ0019755
=D.E
NORTH CAROLINA
Department of Environmental Duality
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1617
919.707.9000

Mr. Philip Cooke
March 18, 2022
Page 2 of 3
A. Cover Letter:
1. As per 15A NCAC 02U .0402(g) "By-pass and overflow lines shall be prohibited." Even though
the reclaimed water that bypasses the filter is combined with filtered water and is being disinfected,
the bypassed water contains solids which can hamper the disinfection process. The reclaimed water
needs to be filtered through either of the dual tertiary filter before it can be chlorinated. The
overflow from the tertiary filter influent trough to inlet trough of tablet chlorinator cannot be
permitted and should be removed. Please modify the Engineering Plans accordingly and resubmit
those pages.
B. Reclaimed Water Project Information Form (FORM: RWPI 06-16):
1. No comments.
C. Reclaimed Water Generation (FORM: RWG 06-16) Application:
1. No comments.
D. Engineering Plans:
1. Please provide engineering plans for the sludge holding tank and the 14,000 gallon septic tank and
demonstrate that they are adequately sized to receive the filter back wash water from the mudwell.
Please have these plan set pages signed, sealed and dated by a North Carolina licensed Professional
Engineer. [15A NCAC 02U .0201(c)(1)]
2. The overflow from the tertiary filter influent trough to inlet trough of tablet chlorinator cannot be
permitted and should be removed, refer to comments in A.1. Please modify the Engineering Plans
accordingly and resubmit those pages. Please have these plan set pages signed, sealed and dated by
a North Carolina licensed Professional Engineer. [15A NCAC 02U .0201(c)(1)]
E. Engineering Calculations:
1. It is stated that the originally permitted filter media has been changed from 12 inches of sand and
12 inches anthracite to 36 inches of coarser sand media. Please provide engineering calculations
signed, sealed and dated by a North Carolina licensed Professional Engineer for design of new
filter, including hydraulic and pollutant loading, hydraulic profile, determination of filter depth,
filtration rate, back wash velocity, etc. Additionally, please provide data indicating that pre- and
post- filter modification there was an improvement in treatment performance. [15A NCAC 02U
.0201(c)(3)]
2. Please provide engineering calculations signed, sealed and dated by a North Carolina licensed
Professional Engineer to demonstrate that the septic tank of the 6,000 GPD Wastewater Irrigation
System is adequately sized to receive the filter back wash water from the mudwell. The calculations
should address hydraulic and pollutant loading, percent of solids removal in the septic tank and
show that the septic system is not being overloaded because of the additional flow and solids from
the partially treated reclaimed water. [15A NCAC 02U .0201(c)(3)]

Mr. Philip Cooke
March 18, 2022
Page 3 of 3
3. Please provide engineering calculations signed, sealed and dated by a North Carolina licensed
Professional Engineer to demonstrate that the sludge holding tanks are designed to handle the
additional flow of filter back wash water from the mudwell. Please note that if used for residuals
storage, the sludge holding tank must provide at the minimum a 30 days storage capacity for
dedicated reclaimed water utilization systems. [15A NCAC 02U .0402(j)]
F. Operation & Maintenance Plan:
1. Please provide an updated Operation and Maintenance Plan as required by 15A NCAC 02U
.0801(a) which addresses any operation and maintenance activity changes following the installed
modifications including any diversions and flow changes. This plan should address operation and
maintenance changes, safety measures including restriction of access to the site and equipment with
contact information for plan personnel, emergency responders, and regulatory services.
G. Specifications:
1. Please provide specifications for the sludge holding tank and the 14,000 gallon septic tank and
demonstrate that they are adequately sized to receive the filter back wash water from the mudwell. [15A
NCAC 02U .0201(c)(2)]
H. Additional documentation:
1. The Condition I.1. of the current permit required that the volume of effluent flow diverted from the
reclaimed water treatment system to the 5-day upset pond be measured and included on daily flow
reporting for the non -reclaimed wastewater irrigation (PPI 002).
As per the data on `Upset Volume and Reclaimed Volume' for January, 2021 to October 2021,
provided to the Winston Salem Regional Office, the upset volumes seem quite high, which
indicates that there might be inherent problems with the reclaimed water treatment system. Please
state the reason for the high upset volumes and specify which treatment units are contributing to
the upset volume.
2. Please specify the amount of partially treated reclaimed water (in GPD) to be diverted from the
mudwell to the sludge holding tanks and the amount of water to be diverted to the 14,000 gallon
septic tank of the 6,000 GPD Wastewater Irrigation System.
3. Although permitted under the same permit, the 30,000 GPD reclaimed water generation system and
the 6,000 GPD wastewater irrigation system have been permitted separately. Since the pumps in
the dosing tank had to be raised, it is quite possible that the pipe from the mudwell was inadvertently
connected to the dosing tank instead of the septic tank. Or another possibility is that the solids from
the reclaimed generation facility's backwash water are overloading the 6,000 GPD Wastewater
Irrigation System. Please clarify why the pumps had to be raised. If the operator deems this
modification essential, then sufficient data must be provided to indicate that the performance of the
6,000 GPD Wastewater Irrigation System is not being compromised because of the said diversion
and raising the pumps.