WQ0019755_NOV-2019-PC-0160_20190311

JPC Utilities , LL
1692 NC Hwy 68 North, Suite F Phone: (336) 644-7942
Oak Ridge, NC 27310 Fax: (336) 644-7906
E-mail address:
philip@weyhi I Icompa mes.com
March 11, 2019
Ms. Lori Snider Sent via Certified Mail
Assistance Regional Supervisor Return Receipt Requested
Water Quality Regional Operations Section
NC Department of Environmental Quality
Division of Water Resources, Winston-Salem Regional Office
450 Hanes Mill Road, Suite 300
Winston-Salem, NC 27103
Dear Ms. Snider:
We are in receipt of your letter dated March 4, 2019 with the subject being, "Notice of Violation/Notice
of Intent to Enforce NOV-2019-PC-0160."
As the Permittee I take these issues at our system very seriously and am disappointed that we have
forced your office to issue the Notice. Broadly, we want to be the site that is operated in full compliance
of the Permit and one the Division holds up as.anexample of how to run aspray irrigation system .
correctly.
During the past year, we have taken numerous steps to assist us in reaching our goal of being the
positive example I mention above. We've hired additional staff whose primary job duties are to work
with the Operator in Charge and the Backup Operator and to assist them in the day to day operations of
the facility and to help bring the facility into full compliance . With their help and working with Rebecca
Chandler, who has been great to work with, we truly feel we are moving in the right direction . Many of
the improvements at the plant that were noted in the inspection summary dated 1/31/19 were the
result of meeting with Ms. Chandler, understanding her concerns, and fixing them . We will continue this
course.
Obviously, while heading in the right direction, we must do more quickly as your Notice cites violations
and continued violations . These have our full attention and we propose the following actions:
1 . Permit Condition 111 .5 — We have discontinued all spray irrigation at this time . We
propose to sew in the areas noted, and with special attention to Zones 2 & 3, wetland
grasses that will grow in shady conditions. We propose sewing a mix of Lurid Sedge, Fox
Sedge, Soft Rush, Big and Little Blue Stem Rush with some Annual Rye. The wetland
seeds may take 30 to 45 days to germinate so by adding the Annual Rye we hope to
improve the ground cover a little faster. We will spread the seed and add matting to
help give the seeds a chance to germinate. Of course, we need some dry weather to
enable us to perform this work. We will only use small equipment while performing this
work to minimize any further compacting of the soils or additional ruts in the ground .

We may need to add some silt fencing or upslope berms to ensure there is no runoff
into the areas in Reuse Zones 2 & 3 where the ponding is occurring. We would need the
help of Ms. Chandler and/or any other staff to help us determine what may be
appropriate .
2 . Permit Condition 111 . 6 — As I mentioned above, we have completely discontinued spray
irrigation activities but we recognize we cannot continue this for long. We propose to
reprogram irrigation times to daytime irrigation times and to only start irrigating by
manually starting the system . Our reasoning for this is this will allow our on-site
personnel to determine if the weather conditions are appropriate by physically entering
the fields to check field conditions and/or if your office feels we need to use a soil
moisture probe or do some other field test we are open to doing so. Also, we will
observe the spray activities to ensure the heads are working correctly, and if any
ponding or run-off is observed we can immediately turn off the system . Also, we
propose to turn off Reuse Zones 2 and 3 until such time that a suitable ground cover is
established and no ponding is evident . We hope to fix the rutting and erosion in these
two zones while we sew the grasses mentioned in q1 above.
3 . Permit Condition 111 . 7 — We've already proposed only manually starting irrigation which
should ensure no irrigation during inclement weather. We do not have a reasonable
explanation why any irrigation occurred during December, 2018. This is unacceptable
and we recognize that it never should have been allowed to occur. In the short term
manually starting the irrigation should ensure this does not happen again . Long term,
we believe by having on-site staff present daily and understanding how thesystem
should work we will be able to avoid this from occurring in the future. Finally, by spray
irrigating the fields during the summer and fall months on a more rigorous schedule,
assuming the weather conditions allow, should give us more free board during the
winter months and allow the irrigation systems to be cut off. The past year has been
unusually wet.
4. 15A NCAC 08G .0204 — We will have our on-site staff work under the direction of the
Operators to inspect the irrigation system before each irrigation event to make certain
the weather is appropriate for irrigation activities and to inspect the fields (as discussed
above) during the irrigation event to make certain the irrigation equipment is working
properly and to also look for any signs of ponding or run-off. If signs of ponding or run-
off are evident, we will immediately cease irrigation activities in those Zones. If we
notice the irrigation equipment not operating properly and it is causing the irrigation to
not occur properly, we will shut down the irrigation event and repair the malfunctioning
equipment. We will do this until we are confident the ground cover is adequate and that
the Zones where we conduct irrigation activities in are suitable to receive irrigation.
Again, we will conduct manual irrigation until we have demonstrated to Ms . Chandler
that we believe irrigation can occur in an automated environment and meet the
requirements in our Permit and she concurs.
5 . 15A NCAC 08G .0205 — Mr. Bradley Flynt will be designated the Operator in Responsible
Charge for the Reclaim system and the paperwork to designate him as such will be sent

to your office immediately. Mr. Leinbach will be Mr. Bradley's primary Back-up
Operator in Responsible Charge .
6, Permit Condition IV. 3 — Chad Leinbach, ORC, offers the following explanation, "at the
time of inspection, the Reclaim Magmeter was off but recording -22 gpm . This being
true, it was not malfunctioning, it was not programmed correctly ( likely it had lost its
original programming several months before and had gone unnoticed) . Today while at
rest it stills displays negative gpms and is assumed to be part of the internal electrical
setup. The Magmeter has been calibrated along with others on a yearly basis around
August each year. Chad Leinbach ORC reprogrammed the meter with the technical
support of the manufacturer in November 2018. It is recording correctly and giving
good data . The problem that the ORC and the Backup ORC had with the meter was
recognized internally and should have been brought to your office. We had Doug Smith
look at the check valves and what was involved with replacing the check valve for the
Reclaim Magmeter. Finally after discussions back and forth with the manufacturer,
calibration contractor, Doug Smith, Bradley and Chad, it was determined to be a
programming issue . We have the ability to track run times and cycles for the Reclaim
irrigation should the Magmeter get hit by lightening or malfunction. Going forward we
expect no questions to arise from irrigation operations."
7 . Permit Condition IV. S — We believe we now accurately track the effluent irrigated
through the correctly programmed Magmeter and the tracking of the irrigation pump
run times. This gives us two methods to track the irrigation which should help us
identify if the Magmeter is not operating properly. Additionally, Chad Leinbach, ORC
says, "the missing rainfall dataon the ReclaimNDARS was reported on the upset pond
NDARs. The data was not transferred by Conner Consulting staff to the Reclaim NDARs.
These Reclaim NDAR reports have been revised and will be resubmitted. Also, the
reclaim operation started using a rain gauge in September 2018 . This resulted in a
misread of the rainfall at the reclaim side on 9/17/18 (>6 inches was typed as 76 inches
and it was missed on review) . To eliminate confusion and to more accurately catch large
rainfall events, the rain gage from the upset side is going to be used at the reclaim side
as the master gage thus providing more accurate event recordings."
Also, both Operators and the on-site staff will track the daily weather conditions and we
will track the weather conditions on days we are not present (weekends and Holidays)
by consulting the weather conditions through the internet. The NDMRs will now be
shared between both Operators and our staff to look for completeness and it will be
reviewed by me before it is submitted to your office. Our hope is that helps ensure the
NDMRs are completed thoroughly and accurately.
8. Permit Condition IV. 11 — We understand this Permit requirement and all of us,
owner/Permittee, on-site staff, and Operators clearly understand that if a violation
occurs it must be reported . We have self-reported one violation since receiving this
Notice . Furthermore, we understand your office is there to assist us with violations that
occur and to assist on how to best operate the system to avoid future violations and
operate the system per the permit requirements. This has been discussed with on-site
staff and the Operators so we hope the lines of communication with your office, even if
not in violation, remain open and transparent.

9. Attachment A of the Permit — this mistake has been noted by me and discussed with the
Operators. We have corrected this mistake on all revised NDMRs and should carry
forward to future NDMRs submitted . We hope our review of the NDMRs prior to
submission by multiple people will help correct this problem moving forward .
10. Permitted Effluent Limits exceeded — Mr. Flynt submitted the following explanation in
response to this violation, "The BOD on Dec. 2017, TSS On August 2017, Dec. 2017,
January 2018 and March 2018, 1 feel was all due to the fact that we were struggling to
operate the plant because of the short return lines were not returning the sludge
properly which I feel caused all these exceedances , If you look back to when Doug fixed
those lines, we haven't had any more exceedances. Chad Leinbach, ORC past responses
to these exceedances may not match this scenario because none of us knew about the
short return lines all we knew was that the repaired sand filters were helping but we
were still having problems managing the sludge in the plant. The Fecal coliform on Oct
2018 has no explanation, it could have been contaminated by me as I was pulling it . I try
to be careful to avoid it but it can happen easily because of the difficulty laying down on
the grating and reaching past the v-notch to sample. The November 2018 was sampled
the Day after a 4" rainfall event and everything was wet and the sample probably get
got contaminated, I say contaminated because the CL2 residual during these events was
high enough not to cause any type of fecal reading (2 . 20 MG/1 ) ." We are happy to
discuss this further with your office if needed?
11 , Permitted effluent limits were exceeded for September, 2018 — The Stevens recorder is
located at the Upset Pond operation. We have been reading that meter since May of
2018. The numbers: reported were correctly subtracted and divided by_the-elapsed days
on most reports except the May 2018 Upset NDMR. However, all numbers reported for
the Stevens recorder were off by a factor of 10. Upon closer review, it became apparent
that the Upset Pond sand filter (0, 13 acres) does not have the area to produce tens of
thousands of gallons of rainfall per inch. One inch of rain on the upset sand filter is
approximately 3500 gallons of water. A 6. 65-inch rainfall event would generate only
approximately 23,000 gallons of water. The May 2018 to January 2019 Upset NDMRs
have been revised and will be resubmitted .
Additional Concerns:
1 . Lime added to fields and additional testing wehave committed to Ms. Chandler
to pull a soil sample from each Zone (16 samples) so we can better understand the
make up of the soils and what the agronomist recommends to add to the soils. All
16 samples will be pulled this month ( March, 2019) and sent to the agronomist for
analysis. We will share the results with Ms. Chandler to help us understand what
we need to add to the soils and do so.
2. Calibration of the irrigation system — We understand this condition must be met
before our system comes up for permit renewal. We feel we need to concentrate
our efforts in the items noted above but will begin calibration efforts once we are all

satisfied the irrigation system and fields are performing per the permit
requirements.
Portions of Zones 2 & 3 are very wet. We believe part of this is due to significant rains we have received
but we recognize we must allow these areas to dry out before resuming any irrigation activities . Zone 2
is part of the upset spray area and these heads do not have individual cut-offs for each head . The heads
in Zone 3 have these cut-offs. If the State is comfortable, we'd like to install cut-offs on the heads in
Zone 2 that are in the wet/ponding areas. Once installed, we'd cut off the heads in both Zones 2 & 3
that are in the wet/ponding areas so that no irrigation would occur in those sections of each Zone .
Finally, we'd like your assistance in reviewing all of the above responses before we begin
implementation . We do not want to do anything that would make matters worse or cause any further
permit violations. We will contact Ms . Chandler if we decide to irrigate prior to a response from your
office on our permit violation responses.
We are open to meeting with your office and would like to propose meeting with you on-site if possible
as some of our responses probably need to be demonstrated on-site. Our on-site director, Doug Smith,
is in the Spray Irrigation school in Raleigh the week of March 18-22 . If Ms. Chandler or another staff
member has time to meet with us the following week, we will make ourselves available at the staff's
convenience. We would propose to have both Mr. Bradley Flynt and Mr. Chad Leinbach at this meeting
too .
Sincerely;
Philip M . Cooke
Manager
JPC Utilities, LLC
Cc: Doug Smith, via email
Bradley Flynt, via email
Chad Leinbach, via email