WQ0019755_NOV-2019-PC-0160_20190416

April 16, 2019

Phillip Cooke
JPC Utilities
1690 NC 68 North
Oak Ridge, NC 27310

SUBJECT: Review of Response to Notice of Violation Response
NOV-2019-PC-0160
Oak Ridge Commons WWTP
Reclaimed Water System and Wastewater Irrigation
Permit No. WQ0019755
Guilford County

Dear Mr. Cooke:

In response to the correspondence received March 11, 2019 and the follow-up sit visit completed on
March 28, 2019 by DWR staff, this office would like to provide feedback to the solutions proposed seeking
to resolve the issues noted in NOV-2019-PC-0160.

1. Permit Condition III.5 – Once the rutting is filled and major ground disturbance is completed, this
office understands that you plan to reseed the exposed soil areas. Furthermore, you plan to
prevent and slow storm runoff through the zone with silt fencing and berms. The proposed
solution of a mixed grass seed with an annual rye addition is satisfactory.

2. Permit Condition III.6 – Your proposal indicates that manual operation of the system will continue
and operate during the day. This office supports this practice to ensure the system is satisfactory
to operate without failure and/or runoff. We will continue to monitor the system to determine if
soil moisture probes may be required in the future.

3. Permit Condition III.7 – This office understands that the plan for manual operation of the system
will help to ensure future violations of this Permit Condition shall not occur.

4. 15A NCAC 08G .0204 – This office is satisfied with the proposed plan to manually irrigate after
prior inspection of the spray zones.

5. 15A NCAC 08G .0205 – The required designation has been completed to prevent future violations
of the Administrative Code.

6. Permit Condition IV.3 – The explanation provided and in addition to the observation of the
Magmeter during the onsite follow-up inspection has satisfied concerns that the equipment could
be continuing to operate improperly.

Oak Ridge Commons – NOV Response
April 16, 2019
Page 2

7. Permit Condition IV.5 – DWR acknowledges the receipt of amended self-monitoring data with the
necessary corrections and missing information made. This office will continue to monitor self-
monitoring data for accuracy and that submitted data includes all required information.

8. Permit Condition IV.11 – This office is satisfied with your response and understands that future
violations of this Permit Condition will be avoided.

9. Attachment A of the Permit – As discussed with DWR staff during the onsite follow-up visit, a
dedicated flow-meter to the “Upset” pond will help to eliminate this Permit violation in the future
and prevent any question of flow exceedances as a result of approximating flow between the
systems.

10. Permitted effluent limits for the following constituents were exceeded as listed on the NDMRs for
the Reclaim system: BOD in December 2017; total suspended solids in August 2017, December
2017, January 2018, and March 2018; fecal coliform in October 2018 and November 2018.

This office understands that occasional system processes may results in Permit limit exceedances.
We will continue to monitor data for chronic exceedance concerns.

11. Permitted effluent limits for the following constituents were exceeded as listed on the NDMRs for
the Upset system: monthly average flow in September 2018.

DWR acknowledges receipt of the amended NDMRs. Please ensure that all future data is correct
to prevent future violations of this Permit limit.

Given your detailed response and significant plans already in place to improve the site and system, this
office is no longer considering pursuing an enforcement case against Permit WQ0019755 at this time.
Should any of the previously documented violations continue to occur, enforcement actions may be
considered. It was indicated during the onsite follow-up visit that this office would be contacted once
significant progress has been made with regard to repairs in the spray zones. Please contact Rebecca
Chandler (336-776-9705) or me (336-776-9700) regarding that follow-up and if you have any questions
regarding this letter.

Sincerely,

Lon Snider
Assistant Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ-WSRO

cc: Doug Smith, via email
Chad Leinbach, via email
Guilford County Environmental Health
DWR Central Office – Permit File WQ0019755
WSRO Files