wq0014306_NOV-2022-PC-0009 AND 0010 Response_20220127

SANDLER UTILITIES AT MILL RUN, LLC
January 24, 2022
Robert Tankard, Assistant Regional Supervisor
Water Quality Regional Operations Section
Washington Regional Office
Division of Water Resources, NCDEQ
Subject: Sandler Utilities at Mill Run, LLC
Eagle Creek WWTP
Permit No. WQ0014306
Notice of Violations:
NOV-2022-PC-0009
NOV-2022-PC-0010
Mr. Tankard,
Sandler Utilities at Mill Run, LLC ("Sandler Utilities") appreciates the opportunity to respond to the
Assessments of Civil Penalty dated January 10, 2022, in the above -referenced violations. This letter shall
serve as Sandler Utilities' response, and it is our hope that the information provided will result in a
remission of the assessed penalties by the Division.
Violation(s):
Discharged to Incident
Location Estimated Quantity Surface Water Date Type of Violation
Tertiary Filter 800 gallons No 11/29/2021 Unauthorized Bypass
Tertiary Filter 500 gallons No 12/10/2021 Unauthorized Bypass
As described above, in both instances the plug came out of the overflow pipe for the sand filters. The
overflow pipe feeds into a small lift station that could not keep pace with the flow. The lift station
overflowed; however, all water was retained onsite at the plant. The overflow did not reach surface
water and did not leave the site. The plug was replaced, and a new pump was installed in the filter
system. Since completion there has not been another occurrence and is checked on a daily basis for
proper operation.
As DWR is no doubt aware, Sandler Utilities has expended substantial resources in improving the
wastewater collection and treatment systems at Eagle Creek (more than $530,000 since September
2020). Without the prospect of recouping these expenditures, Sandler Utilities has invested significant
time and resources at Eagle Creek. The extent of the work performed (and to be performed) and
progress in staffing and operations are well understood to DWR.
448 Viking Drive, Suite 220, Virginia Beach, Virginia 23452
Mailing Address: Post Office Box 8790, Virginia Beach, Virginia 23450
Telephone [phone] / Telefax 757-463-3358

January 24, 2022
Page 2
Sandler Utilities has limited resources and has nonetheless invested heavily at Eagle Creek to improve
the operations for the customers and to comply with environmental mandates. Sandler Utilities will
continue to invest as it continues to update and improve the existing system, even though transfer to
another owner is in process. In light of Sandler Utilities' limited resources, it is in both the State's and
the customers' interest to allow for Sandler Utilities' resources to be invested in the Eagle Creek system
rather than payment of civil penalties. Accordingly, Sandler Utilities respectfully requests that the civil
penalties are entirely waived.
Sincerely,
Brittney M. Willis, P.E. — Project Manager
Sandler Utilities at Mill Run, LLC
Cc:
Envirolink
448 Viking Drive, Suite 220, Virginia Beach, Virginia 23452
Mailing Address: Post Office Box 8790, Virginia Beach, Virginia 23450
Telephone [phone] / Telefax 757-463-3358