WQCS00371_Request to Delay Cleaning_20200811

Campus Box 7513
Facilities Division
Raleigh, NC 27695-7513
Energy Systems — U&E
P: 919.513.7151
F: 919.513.7230
v .ncsu.edul
August 11, 2020
Mr. S. Daniel Smith
Director, Division of Water Resources
1611 Mail Service Center
Raleigh, NC 27699-1611
Subject: Force Majeure Request to Delay Cleaning of Wastewater Collection System
NC State University, Raleigh, NC
Wastewater Collection System Permit No. WQCS00371
Dear Mr. Smith:
I am writing to request that NC State be allowed to delay the cleaning of its wastewater
collection system (WWCS) until 2021 consistent with EPA Memorandum "COVID-19
Implications for EPA's Enforcement and Compliance Assurance Program" dated March 26,
2020. The WWCS consists of approximately 22.7 miles of gravity sewer. As a condition of
Permit No. WQCS00371, at least 10 percent of our gravity sewer WWCS must be cleaned each
year. Our Utility Distribution (UD) Shop normally begins cleaning the lines every spring and
completes at least 10% of the sewer before the fall semester begins. However, this year, the
required cleaning has yet to start.
Due to the COVID 19 pandemic and the uncertainty as to whether the virus can be transmitted
via exposure to wastewater, particularly the aerosol and droplets resulting from pressurized
flushing of the sewer, compliance with the permit cleaning requirement is not reasonably
practicable. Students, faculty and staff frequently walk near the WWCS access points and thus
could be exposed during the pressurized flushing. A recent National Institute of Health Study
entitled "Transmission of SARS-CoV-2 via fecal -oral and aerosols —borne routes: Environmental
dynamics and implications for wastewater management in underprivileged societies" concludes:
• SARS-CoV-2 may transmit via fecal -oral and virus -laden aerosols -borne routes.
Nevertheless, the intensity of unwanted consequences may vary in different societies
depending on the level of control measures, environmental conditions, and treatment
facilities.

Mr. Smith
Page 2 of 2
Currently established disinfection strategies such as chlorination at WHO recommended
doses might not be sufficient to inactivate the SARS-CoV-2 in places where viral load is
high; therefore, more research is encouraged to decipher the fate of the virus in different
compartments of the environment.
To slow the spread of the coronavirus, NC State only allowed employees whose job is
critically essential to work on campus beginning March 18, 2020. When Phase 2 of the
Governor's Shelter in Place Executive Order went into effect, additional employees returned to
campus as necessary to prepare it for reopening. As part of this preparation, the UD shop
performed unpressurized flushes of sewer lines to verify the water flowed freely from more
than 150 campus buildings and thus prevent potential sanitary sewer overflows. When asked
whether the unpressurized flushing fulfilled permit requirement 11.8, Cheng Zhang, of the
Raleigh Regional Office Operations Section wrote, "After discussion with my coworkers at
RRO, we think that pressurized flushing counts as line cleaning, while unpressurized flushing
does not."
Should you grant us the delay, the UD Shop will attempt to fulfill most of the cleaning
requirement for 2020 after the fall semester ends if they can perform pressurized flushing
safely. Otherwise, at least 20% of the WWCS sewer line will be cleaned in 2021.
If you have any questions, comments, or require additional information regarding this report
please contact Jenny Kelvington [phone].
Sincerely,
W111s4v14a&1
Alan G. Daeke, P.E.
Director Utilities & Engineering Services
cc: Chang Zhang, NC Division of Water Resources, Raleigh Regional Office