WQCS00012_NOV-2020-DV-0081 Response_20200319

M
N= Cape Fear
Public Utility Authority
Stewardship. Sustalnabllity. Service.
March 16, 2020
Tom Tharrington
Asst. Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
127 Cardinal Drive Extension
Wilmington, North Carolina 28405
Subject: Notice of Violation NOV-2020-DV-0081
Sanitary Sewer Overflows — December 2019
Dear Mr. Tharrington:
Frank C. Styers, PE
Assistant Executive Director
235 Government Center Drive
Wilmington, NC 28403
910-332-6670
f ra n k.stvers@dpua. ora
RECEIVED/NCDENR/DWR
MAR 19 2020
Water Quality Regional
Operations Section
Wilmington yepional Office
I am in receipt of your March 5, 2020 Notice of Violation (NOV) letter related to the sanitary
sewage overflow (SSO) from the failure of the CFPUA Smith Creek Pump Station (Pump Station
10). The SSO occurred on December 17, 2019 and allowed approximately 2.44 million gallons of
sewage to enter the receiving waters of Smith Creek. The cause of the failure appears to have
been corrosion of the ductile iron discharge pipe directly outside of the pump station, likely due
to the accumulation of hydrogen sulfide gas.
CFPUA staff initiated its response on December 17th at 8:30 am immediately after being
notified that an SSO was occurring at the pump station. When staff arrived and observed
conditions at the station, CFPUA crews and our contractors worked around -the -clock on two
important fronts — to limit the extent of the spill and to stop it.
Within about an hour of the first report, CFPUA vactor trucks were at the scene, to be joined by
others from a contractor. Pump and haul operations were conducted for the duration of the
event. In total, about 500,000 gallons of wastewater were recovered from either upstream of
the pump station site or the SSO site, minimizing the volume of untreated wastewater that was
released.
To stop the spill, crews initially attempted a bypass with standby equipment onsite. When that
was unsuccessful, they constructed a 600-foot temporary bypass force main using high -density
polyethylene pipe to route the wastewater from the failed pipe to a new force main that had

March 16, 2020
Page Two
recently been installed as part of our ongoing project to build a replacement for Pump Station
10. Just before 1:00 am on Thursday, December 19th, the temporary bypass was completed
and successfully put into operation, stopping the SSO.
Once the temporary bypass was operational, repair of the failed pipe began. The repair was
completed late Sunday, December 20th, and the station was placed back into operation the
following morning. The temporary bypass pumps and piping will remain onsite and available to
the greatest extent possible until construction of the replacement pump station is complete.
Additional system modifications are underway to prevent future SSO's from occurring. Our
ongoing investment in our wastewater collection system includes the $8.9 million project
underway near the SSO site to build a complete replacement for the current Pump Station 10.
The replacement station is due to come online and be operational as early as August. CFPUA's
10-year Capital Improvement Plan (CIP) focuses on aging infrastructure and includes strategies
to proactively investigate and prioritize the rehabilitation and/or replacement of aging
infrastructure. An example is our "Find it, Fix it" program, which involves CCTV inspection and
in -place lining of pipes in our collection system. The total capital investment in the approved
10-year CIP is $272,160,000, with the largest share — 73.2 percent or $199,230,000 — going
toward rehabilitation and replacement of aging infrastructure.
CFPUA also has an Odor and Corrosion Control program that provides for chemical treatment
within the sewer collection system to prevent the formation of corrosive sewer gas within the
system which will help avoid the recurrence of similar situations.
The NOV also refers to the SSO that resulted from damage to a four -inch CFPUA sewer force
main near 1422 Halcyon Lane. The SSO occurred on December 9, 2019 and allowed
approximately 500 gallons of sewage to enter the receiving waters of the Intracoastal
Waterway. The force main was struck and damaged by a contractor, Rainstorm Solutions,
performing stormwater system modifications, likely on behalf of the development's
Homeowner Association.
CFPUA informs outside contractors of the location of underground utility lines through NC 811.
Contractors engaging in excavation are required by law to contact NC 811 prior to working.
Rainstorm Solutions did not properly contact NC 811 or CFPUA prior to the work. The sewer
force main was not marked, and the contractor failed to investigate for existing utilities prior to
excavation.

March 16, 2020
Page Three
Upon notification of the damage, CFPUA immediately turned off the pump station to stop
wastewater from flowing to the broken force main. The SSO was stopped approximately 50
minutes from the time of first knowledge. CFPUA vactor trucks were mobilized to capture
sewage that was escaping from the broken force main before it reached surface waters. This
effort recovered approximately 400 gallons of sewage that had been released. CFPUA crews
also repaired the force main and cleaned the area. CFPUA billed the contractor for
reimbursement for damages and expenses incurred.
CFPUA makes efforts to prevent the recurrence of similar situations by promoting and
improving the effectiveness of its participation with NC 811. CFPUA typically attends regular
monthly meetings of the Utilities Coordinating Committee of the Lower Cape Fear. The purpose
of the committee is to bring together NC 811 representatives with utility owners and
excavators. Meeting topics include review of NC 811 procedures, opportunities to improve
coordination, and collaboration on specific projects.
It is unfortunate that these SSOs occurred. The scale and intensity of our response speaks to the
seriousness with which we take our role as stewards of the environment. CFPUA recognizes the
seriousness of this violation. Based on the information presented in this letter, we respectfully
request that CFPUA not be assessed a civil penalty for the NOV issued on March 5, 2020.
I would be glad to meet with you to discuss this further or to provide additional information.
Sincerely,
Frank C. Styers, PE
Deputy Executive Director