WQ0014306_NOV-2022-LV-0324 Response_20220705

SANDLER UTILITIES AT MILL RUN, LLC
July 5, 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
NOV-2022-LV-0324
Mr. Tankard,
Sandler Utilities at Mill Run, LLC ("Sandler Utilities") appreciates the opportunity to respond to the
Notice of Violation dated May 16, 2022, for limit violations for the month of January 2022. This letter
shall serve as Sandler Utilities' response, and it is our hope that the information provided will result in
no further action by the Division.
LIMIT VIOLATIONS:
Effluent:
Fecal Coliform
Total Suspended Solids
Daily/Monthly Average Exceeded
Daily Maximum Exceeded
High fecal and TSS results were due to the filter basin not being cleaned out. Due to staffing shortages
Granville Farms had been back logged in their processes. They have since been on site and will continue
to haul sludge from the plant.
As well there was an electrical issue with one bank of the UV bulbs. The flow was diverted from this bank
while repairs were completed. Diverting the flow to one UV trough caused inadequate disinfection of the
effluent.
OTHER VIOLATIONS:
Multiple Days:
Facility did not meet fecal limits and did not transfer effluent to high rate
pond as required in Condition 111.21 of the permit.
The flow was not diverted due to the labs delay in getting the results back in a timely manner.
As DEQ is aware, staffing shortages are company -wide in all industries. However, in this case Envirolink
had no choice but to terminate the operator therefore taking remedial actions.
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

July 5, 2022
Page 2
Sandler Utilities has expended substantial resources in improving the wastewater collection and
treatment systems at Eagle Creek without the prospect of recouping these expenditures. The extent of
the work performed (and to be performed) and progress in staffing and operations are well understood
to DWR.
Sandler Utilities will continue to invest as it continues to update and improve the existing system until
the final transfer of ownership. As such, 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; therefore, we request the state take no further action.
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