WQ0014306_Response to Notice_20231120

SANDLER UTILITIES AT MILL RUN, LLC
November 17, 2023
Mr. David May, Regional Supervisor
Water Quality Regional Operations Section
Washington Regional Office
Division of Water Resources, NCDEQ
Subject: Notice of Violation and Intent to Assess Civil Penalty
Tracking Number: NOV-2023-PC-0558
Permit No. WQ0014306
Eagle Creek WWTP
Currituck County
Mr. May,
Thank you for allowing the Eagle Creek WWTP the opportunity to respond to the following Notice of
Violation issued November 8, 2023; received on November 10, 2023. Below is our response to the findings
that occurred during the inspection performed on October 30, 2023.
Finding: End Use Infiltration. Monitoring wells MWI and MW2 were not locked and did not have Well
ID Labels. This is a violation of condition 11.3 of Permit No. WQ0014306 that
requires the monitoring wells to comply with the Standards for of Construction
for Wells Others Than Water Supply (15A NCAC 02C . 0108).
Corrective Action: Both Monitoring Wells were locked and labeled in accordance with the permit
monitoring well site map. The following images provide evidence of the
corrective action.
Finding: Record keeping. No records of sludge hauling or disposal could be provided by the ORC or
Envirolink. This is a violation of Condition III.13 of Permit No. WQ0014306 that
requires the permittee to dispose of residuals in a Division -approved manner. It
is also a violation of Condition IV.9 of Permit No WQ0014306 that requires the
permittee to maintain a record of all residuals removed from the facility.
Corrective Response: During the inspection, documentation was provided to the inspector which
included the name of the residual's hauler, dates the residuals were removed from
the plant, and the volume of residuals removed. However, it was explained to
the inspector that the sludge hauler did not provide receipts for the hauling, and
the Operator provided the inspector the onsite hauling documentation pictured
below. This documentation was considered acceptable by the inspector.
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

November 20, 2023
Envirolink is actively sourcing further documentation, receipts, and permits from
the third -party sludge hauler to satisfy the record keeping requirements.
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Finding: End Use -Infiltration. The infiltration basin does not have a properly installed staff gauge. The
Current one is not tied to the berm height by a survey and cannot be used to
accurately measure freeboard. This is a violation of condition I.7 of Permit No,
WQ0014306 that requires to permittee to properly install a staff gauge at the
infiltration basin within 60 days after the effective date of the permit (August 4,
2021).
Corrective Action: The existing staff gauge was installed in accordance with the permit and was
in compliance with the required date established in the permit, however,
environmental factors have contributed to the staff gauge being misaligned and
out of position. Upon recommendation of the inspector, Envirolink is actively
seeking quotes to bring the staff gauge positioning back into compliance. Once
the staff gauge is in the proper location and positioning the evidence will be
submitted to your office.
Finding: Treatment. The tertiary filter was non -operational. The ORC stated that it can only be operated
in manual mode and did not contain any filter media. He also stated that it has seen in this
condition since he started operating the system, which is over a year ago. This is a violation
of Condition II.1 and III.1 ofPermit No, WQ0014306 that require the permittee to properly
operate and maintain the facility and to take immediate corrective actions if needed to
return the facility to proper operation.
Corrective Action: As part of a capital improvement plan for the Eagle Creek WWTP, two new
disk filters have been purchased and await installation concluding the sale and
transfer of the utility and all applicable permitting.
Finding: End Use -Infiltration. Woody vegetation was present around the entire perimeter of the
infiltration basin, this is a violation of condition I.10 of Permit No, WQ0014306
that requires to permittee to remove all woody vegetation from around the
infiltration basin within one year after the effective date of the permit (August 4,
2021).
Corrective Action: Envirolink is actively receiving quotes to utilize a contractor to complete this
work. Once vegetation is removed from the facility, documentation will be
provided to the state to prove compliance with this requirement.
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

November 20, 2023
We appreciate the opportunity to clarify these issues. If you have additional questions, please feel free to
contact either Andrew White, Tracy Miller or Daniel Sears.
Sincerely,
Brittney M. Willis, P.E.
CC:
Raymond Gottlieb
Andrew White, Envirolink, Inc.
Daniel Sears Compliance Coordinator
David Pharr, Envirolink, Inc
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