WQ0013808_NOV-2019-PC-0287_20190520

ENVIRONMENTAL - WATER SUPPLY - WASTEWATER - GEOTHERMAL
CONNER CONSULTING, LLC
1284 WINDY RIDGE ROAD, CHAPEL HILL, NORTH CAROLINA 27517
PHONE: [phone]
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May 20, 2019
Ms. Rebecca Chandler
NC DEQ, Division of Water Resources
Winston-Salem Regional Office
450 West Hanes Mill Road, Suite 300
Winston-Salem,North Carolina 27105-7407
Re: Notice of Violation (NOV-2019-PC-0287)
Summerfield Renaissance Center Wastewater Disposal System
Summerfield, Guilford County
Permit#WQ0013808
Dear Ms. Chandler:
On behalf of Kotis Properties, the following responses are warranted for the continued operation
of the wastewater disposal system at Summerfield Renaissance Shopping Center which was
deficient on several items.
1. Having an unusual year of rainfall, it has been a challenge to keep water from
overflowing the wet weather storage pond. The wastewater system has had months were
rainfall has exceeded the permitted flow into the plant without considering any flow from
the shopping center. Several repairs have been made to the irrigation zones and currently
Zone 3 is off and will remain off until the running average comes down. I am only
dosing 2,000 gallons per day to Zones 1 & 2. My goal is to get the wet weather storage
pond down to approximately 7 feet from the lowest point on the berm by September l"
2. Numerous repairs have been made on Zones 1, 2 and 3 to prevent ponding. Also some of
the squirrels responsible for the leaks have been relocated. Traps remain in place to
convince them to move. We are checking the zones weekly to make sure leaks are not
continuing to persist.

. 2 .
3. In the event that a snow or ice storm is expected this winter. We will cut the irrigation
system off or direct persons from Kotis Properties to shut off the irrigation system. I
believe the snow event last year was in between site visits and was overlooked when
reporting since we were only recording weather once a week during our visit. Weather on
a daily basis is being reported now since irrigation is programmed to come on each day.
4. The fencing is in the planning phase. We must consider the new driveway and the best
way to accommodate trucks and heavy vehicles entering during inclement weather. We
are assuming that the fencing along Highway 220 that the DOT put in place is sufficient.
If so we may adapt a similar fence to block off the driveway and put the existing gate up
closer to the wetlands. This task can be done in 60 days or less.
5. The sand filter was shocked with a heavy dose of chlorine to help water travel vertically
in the filter. This treatment did not work but fortunately it did not harm the wetland
plants either. After carefully digging several large access holes in the sand filter to assess
the status of the sand/gravel media and the filter fabric that lies between the sand/gravel
filter media and the underdrain system, it was determined that the filter fabric was
clogged with fines (fine sand and silt). We have installed numerous small holes in the
fabric to get the filter to function as planned(for water to be applied at the top of the filter
and travel vertically down through the filter to the recirculating underdrain system. We
now feel confident that 90 percent of the water is passing through the sand filter as
intended. I cannot be 100% certain until we can actually verify that the area between the
sand filter and the wet weather storage pond dries up and returns to normal. I will
followup with your office on this matter.
6. Freeboard is now in compliance and should remain that way unless we have another
extremely wet fall and winter. We will have more storage for the winter in anticipation
of another year like 2018.
7. Daily weather is being recorded now.
8. The permitting office of DEQ and the owner did not copy me, the ORC, on the permit
renewal which included changes to the lab parameters. However, in January of 20191
went through an internal review of my permits and got copies of the latest versions of
sites I am responsible for. March 2019 should have had all the necessary parameters.

. 3 -
Additional concern:
l. A new staff gauge will be installed in the wet weather storage pond. This task should be
completed in the next two weeks.
2. Septic hauling records for the last five years will be made available from the Kotis
Properties office. Also I will have the leasing manager request 4 years of records from
the grease trap pumper from January 2014 to December 2017 from the corporate office of
Food Lion. I have copies of the grease removal from 2018 up to the present.
Please call with questions and comments.
Sincerely yours,
Chad Leinbach, ORC
Cc: Dan Witcher, Kotis Properties
Bradley Flynt—Backup Operator