WQ0029169_Response to Notice_NOV-2024-SP-0003_20240412

Kenneth K. Talton, Mayor
Commissioners
Steve Wiggins
Mayor Pro Tempore
Vicky Darden
Deireese Simmons
Barbara Kornegay
Tommy Brown
April 11, 2024
W q 0 61�'2cl1b9
Tel — 919-658-5561
Tel — 919-658-9539
Fax — 919-658-5257
Jammie Royall
Town Manager
Sherry Davis
Town Clerk
RECENED/NCDENR/DWR
Robert Tankard, Assistant Regional Supervisor
Water Quality Regional Operations Center
Washington Regional Office APR 12 2024
Division of Water Resources
943 Washington Square Mall Water Qualfty
Washington, NC 27889 Regional Operations Sectlon
Washington Regional Office
Re: Town of Mount Olive Notice of Violation & Intent to Assess Civil Penalty NOV-2024-SP-0003, SOC EMC
WQ S20-002
Dear Mr. Tankard:
The Town of Mount Olive is responding to your Notice of Violation & Intent to Assess Civil Penalty letter
dated March 19, 2024 regarding milestones not met per the terms of our Special Order By Consent EMC SOC WQ
S20-022.1. We greatly appreciate your guidance and assistance throughout this process. We would like to request
that no fines be levied against the Town of Mount Olive. The Town has invested in excess of $180,000.00 in the
Waste Water system. Any fines levied against the Town could create hardship and reduce the funding needed for
future upgrades and operations.
1) On or before March 31, 2022, update and submit a map of the collection system which includes pipe size, pipe
material, pipe location, flow direction, pipe age and each pump station identification, location and capacity and
submit a Capital Improvements Plan (CIP).
Our GIS Mapping software was not compatible with the mapping software used by NC DEQ. It was not user
friendly and it was difficult for the state to view our files. Therefore, the town was unable to provide this
documentation in the format preferred by the NC DEQ. In January 2024 the town purchased the Diamond Maps
software which is more compatible, user friendly and has more mapping features than the GIS Mapping software.
The MAPS GIS has been uploaded and is up and running on Diamond Maps. We have a meeting with Viable
Utilities Caroline Bari on Friday, April 12, 2024. After the meeting she will sent the documents.
The Capital Improvements Plan was completed in the AIA and submitted before the March 31, 2022 deadline.
2) On or before, April 30, 2022, a soil evaluation shall be submitted per permit conditions. 1. Schedules, items 4
and 5. Per Permit No. WQ0029169 -
The soil evaluation was received by the Town on April 25, 2022 and sent to the state on April 27, 2022. We are
unable to locate a return receipt. A copy of the April 25, 2022 soil evaluation can be forwarded to the state upon
request. January 31,2022 the town was notified of the need for additional soil testing. A contract was drafted and
signed by the town June 6, 2022 after it was determined the town would have to pay for the testing. The town had to
invest an additional $19,000.00 for soil studies not covered in the contract. The areas in question had been designed
and a portion of the system installed in these areas now referred to as R Zones. The town later learned it would have
to do a Hydrogeologic Study at a cost of over $80,000.00 to be paid by the town and not under the contract. The
town has invested an extra $100,000.00 in contract L On October 12, 2023 the town received a permit
(WQ0029169) for a non -discharge system. The permit refers back to soil sample reports from April 25, 2022 and
November 15, 2022.
3) WWTP repairs or modifications which includes new reclaim water irrigation mains and spray guns, new field
control valve stations (3 total)

Install lines on the spray fields started in fields 5 through 8. It was after completion of the 4 fields total it was
discovered the contractor installed the wrong gaskets. At the time of repairing the gaskets it was discovered
retaining rings where also installed incorrectly. Confusion on the proper repair method and what would be
acceptable delayed the ordering of parts. Once an agreement was reach on the method of repair there was a shortage
in parts agreed on this delayed the repairs to these field further.
A letter was received November 22, 2021 filed Force Majeure. In one letter it states pipe will not be manufactured
until December 2022. This caused delays in the construction of Contract I. Once pipe was received due to failing
joints and connections pressure testing failed on a large portion of the lines.
After repairs had been made to the leaking joints spray heads where installed. When system was put in operation
for testing of the spray heads a problem was noted with drain valves. Rain bird automatic drains installed on PVC
pipe would break off in the ground due to movement of the heads. The spray head risers and drains had to be
redesigned. All heads had to be unearthed and the drains repaired. Because of the redesign there was a delay due to
confusion over who would cover the cost of the contractor doing this work. After repairs system was put back in
operation for testing. It was discovered spray head risers where mounted on PVC where were the plans called for
ridged materials. Once again the spray heads had to be unearthed for repairs.
The system was put back online for testing. When the town operators begin testing the system it was noted spray
heads not covering design area, spray heads in ditches, spraying off permit area, spray across property lines,
ponding, runoff, and operational problems. The system could not be operated and meet permit guidelines. The
engineer was notified for the project to be reviewed. Town staff tried different methods of operation which failed.
To date the system cannot be operated due to the ongoing problems with system design and construction. The town
has been advised by legal counsel not to sign substantial completion documents. The engineers will not certify the
system substantial completion has been signed.
4) On or before June 30, 2022, repair all broken or uncapped cleanouts, broken lines, unsealed manholes, connect
storm drains and culverts and unknown defects outlined in Appendix A of the AIA Report prepared by McGill dated
April 2021.
Funding was an issue due to the costs and size of this project. The unsealed manhole had to be repaired and the total
length of the connecting pipe had to be replaced. We were unable to tear out one section only and had 42.5 sections
in total that had to be torn- out and replaced. This particular manhole tied into the existing sewer main across the
street and a leak was discovered and cracked under the storm drain. This causes all storm drains on that block to
smoke when tested. The town did have to workforce available to make these repairs at that time.
In order to complete this item, it was included in the CDBG-I 20-1-3610 Infrastructure Grant. This created a delay
until the materials, funding and equipment were available through the grant. The project tore the road and replace
d170 feet of sewer main 8" VCP pipe with SDR 35.
Ninety percent of this work was completed last year. The remaining ten percent was completed on March 1, 2024. A
complete report is being prepared by the Town and Caroline Bari for submittal.
5) On or before February 28, 2023, complete construction of Contract II on the WWTP repairs or modifications
were required.
Contract II equipment was not received before the completion deadline. Due in part to the control PLC for the
irrigation system. The Allen Bradley PLC required different components that where on back order. The analog 8
point input module had the longest lead time. An email received June, 13, 2022 stated the part lead time was
February 2023. Once the part was received and the PLC had to be constructed then it had to be sent for programing.
As with most new equipment many glitches had to be worked out once the system was installed. Flow meters and
pressure indicators not functioning properly. False reading cause system shutdowns on the irrigation system as well
as the transfer pump station and transfer station valve. High PSI shut down irrigation system. High GPM causing
transfer pumps to shut down. Turbidity meter is was not talking to the PLC which cause the storage and upset pond
valve not to work. The self- adjusting valve from the holding pond failed causing the irrigation system wet well to
overflow. New flow meter not talking to the UV system causing the LTV not to operate in auto. Some of the
problems are on going. The new effluent flow meter giving false flows or no flow reading. Water backing up into
the effluent causes false high flow readings. Concerns have been sent to the engineer. The town has been told some
of these concerns are not covered under the contract. The town has been advised by legal counsel not to sign
substantial completion documents. The engineers will not certify the system substantial completion has been signed.

6) On or before May 31, 2023, achieve compliance with permit conditions in Permit No. WQ0029169
Due to delays in the construction of both contract I and 11 the system cannot be operated. The town cannot meet the
flow to the stream as required by permit NC0020575. Contract I stated out with 12 fields and a total of 160 +/-
acres. That was reduced to 132 +/- acres when the R zones had to be removed from operation. With the R Zones off
field 7 and 9 will not operate due to high PSI from the reduced number of heads in each field. Heads that have been
labeled inactive have been capped off causing field 4 to shut down as well. At this time the town has gone from a
total of 12 fields 160+/-acres to 9 fields 109 +/- acres. The engineer design call for the operation of 1 zone 4 fields
per day. This failed the town has tried multiple variations of field operation including all 12 field per day. All
methods resulting in ponding, runoff, or other problems that cause system to be noncompliant. The town has been
advised by legal counsel not to sign substantial completion documents. The engineers will not certify the system
substantial completion has been signed.
7) On or before May 31, 2023, repair all offset pipe connections, plugged inverts and cracked pipes per Appendix B
of the AIA study.
Appendix B was completed prior to May 31, 2023 and submitted but in the GIS Maps format. The exception to
completion for the entire item is the intersection of Johnson and Nelson Streets which is being engineered by McGill
Engineering and RSM Harris Associates as part of the CDBG-120-I-3610 grant. The anticipated completion date is
December 2024.
8) On or before March 31, 2023, twenty percent of collection system shall be smoke tested and videoed. (Note
twenty percent shall include line that has not been smoke tested or videoed during the AIA study or for item 13).
The smoke testing was completed on or before March 31, 2023 but was submitted in the GIS Maps Format. The
town's sewer camera had software issues and the fiber optic lines on the camera had to be replaced. We were unable
to obtain footage required for the twenty percent line inspection The camera had to be sent to Sumter, South
Carolina and was out of service for the months of April, May and of 2023. This was the earliest they could work on
the camera.
This remaining work has been completed and is being added to the Master Report that we are working on with
Viable Utilities Reserve employee Caroline Bari.
9) On or before July 31, 2023, repairs shall address all problems found for item 13 of the schedule.
The town's sewer camera was returned from repair in June 2023, however the software problem remained an issue.
On June 29, 2023. we received a quote from Pipe Logics for new software. The town purchased new software in
September of 2023. The town was in contact with NC DEQ regarding this problem.
This item has been completed and will be added and to the master report from the Town and Viable Utilities
Reserve.
10) On or before January 31, 2024, twenty percent of the collection system shall be smoke tested and videoed (Note:
twenty percent shall include line that has not been smoke tested or videoed during the AIA study or for item 13).
The sewer camera software was only allowing read only mode. Town staff reached out to Pipe Logics and in
January 2024 a representative was sent to assist. At this time they are assisting town staff in exporting previous data
and new data to the Diamond Maps software.
The anticipated completion date is currently June of 2024.
Respec p\
J oyall
Town anager