NC0025071_Report_20180524

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EDEN
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May 21, 2018
City of Eden
P. O. Box 70
Eden, NC 27289
[phone] Option 4
FAX [phone]
Mr. Jay Zimmerman, Director
Division of Water Resources
NC Department of Environment and Natural Resources
1601 Mail Service Center
Raleigh, NC 27699
Semi -Annual Progress Report — Report #2 May 2018
EPA Administrative Order on Consent
CWA-04-2017-4753
Dear Mr. Zimmerman:
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Please accept the enclosed Semi -Annual Progress Report as required by our EPA
Administrative Order on Consent CWA-04-2017-4753. As this is our first submittal of this
report, please advise of any issues in its preparation or formatting or the information
contained herein.
Sincerely,
Terry Shelton
Public Utilities Director
Office 336-612-8055
Email tshelton@eder
CC: Ms. Laurie Jones, EPA Region 4, Environmental Engineer
Brad Corcoran, City Manager
www.EdenNC.us and www.ExploreEdenNC.com

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EDEN
NORTH CA^RO LINh
May 21, 2018
City of Eden
P. 0. Box 70
Eden, NC 27289
[phone] Option 4
FAX [phone]
Denisse D. Diaz, Chief
Clean Water Enforcement Branch
Water Protection Division
Attn: Ms. Laurie Jones
U. S. Environmental Protection Agency, Region 4
61 Forsyth Street, S. W.
Atlanta, Georgia 30303-8960
Semi -Annual Progress Report — Report #2 May 2018
EPA Administrative Order on Consent
CWA-04-2017-4753
Dear Ms. Jones,
Eden
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2011
Please accept the enclosed Semi -Annual Progress Report as required by our Administrative
Order on Consent CWA-04-2017-4753. As this is our first submittal of this report, please
advise of any issues in its preparation or formatting or the information contained herein.
Sincerely,
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Ter
ry helton
Public Utilities Director
Office 336-612-8055
Email [e-mail]
CC: Jim Zimmerman, Director Division of Water Resources NCDENR
Brad Corcoran, City Manager
www.EdenNC.us and www.ExploreEdeuNC.com

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City of Eden Eden
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P. O. Box 70a
Eden, NC 27289
[phone]
FAX [phone]
EPA Administrative Order on Consent - Semi -Annual Progress Report No. 2, May 2018
May 18, 2018
RE: EPA Administrative Order on Consent (Issued April 19, 2017)
Docket No. CWA-04-2017-4753
Item IV. Documentation and Report Submittal 23. The City Shall Submit to the EPA Written Semi -
Annual Progress Reports
This Semi -Annual Report is submitted to the EPA by the City of Eden, North Carolina, to comply with
the requirements of the Administrative Order on Consent. This report is prepared and submitted
specifically to comply with Item IV., Paragraph 23.
The City's primary plan to stop SSOs is based on the Wastewater Collection and Transmission
Systems Remediation Plan (WCTSRP), as well as utilization of the MOM (Management, Operation
and Maintenance programs) that was developed during our first Administrative Order. The
remediation plan contains detailed information of the places where Eden has had recurring SSOs and
developed remediation measures in those locations to stop SSOs. The City of Eden was awarded
$33 million in grants and loans from the North Carolina Department of Environment and Natural
Resources, through the Division Water Infrastructure (DWI) in the spring of 2017. The City is also
providing match funding of $1.6 million. All of this funding is designated to rehabilitate the City's aging
sewer collection and treatment system to keep and maintain compliance with all current federal and
state regulatory standards. The WCTSRP contains an aggressive five-year capital project plan to
address issues in our collection and treatment system.
Administrative Order on Consent Item IV Paragraph 23.
The City shall begin to submit these Semi -Annual Reports to the EPA within thirty (30) days after the
end of the first six (6) months after the effective date of this Order on Consent and shall continue to
submit such reports every six (6) months thereafter until the submission of the Final Report as set
forth below.
The City shall submit to the EPA written semi-annual progress reports (Semi -Annual Reports) that
include:
EPA Administrative Order on Consent - Semi Annual Progress Report No. 2
1 of 6 Pages

(a) A description of the actions which have been taken toward achieving compliance with this
Order on Consent during the previous six (6) months;
The City of Eden is taking the following actions to prevent, reduce and stop SSOs in our
Collection System.
The implementation or enhancement of our programs that we developed in our first Administrative
Order is now part of routine operations. The Management, Operation, and Maintenance Programs
(MOM) have been our daily guide to preventive work to avoid SSOs and establish stronger improved
system maintenance programs. The Wastewater Collection and Transmission Systems Remediation
Plan TRP is now our overall plan in our long-term approach to address our SSOs issues. Our
Collection and Distribution crews have been working on point sources inflow and infiltration that occur
in rain events and other illicit sources that are found during daily operations.
Funding for the Remediation Plan projects and daily operations problems has been appropriated. We
currently believe we have sufficient financing in place to complete the Remediation Plan projects
based on current cost estimates.
Our engineering firm, W. K. Dickson (WKD), prepared the Engineering Report (ER) that was
submitted to DWI to meet the first Milestone Date of June 1, 2017, as per our funding requirements.
WKD has been in constant contact with DWI to discuss and answer questions regarding the ER. Due
to the complexed nature of the Remediation Plan that DWI required more time than normal to
complete their review of the projects and required extensive explanation and revision of some
projects. DWI completed their approval of the ER on April 9th, 2018. WKD has proceeded with as
much design work as possible before the approval of the ER. The design work on three major projects
(Junction Pump Station Rehab, Bridge Street Pump Station Rehab, and the Digester
rehab/replacement at the Mebane Bridge Wastewater Treatment Plant) has moved forward for these
critical assets. The rest of the projects in the remediation plan are underway at this time. The
following is our Milestone Dates for performing planning and engineering steps toward beginning
construction to meet funding requirements. After November 2017, milestone dates have been revised
by DWI to reflect the date (April 9, 2018) when the Engineering Report Funding Approval was issued
by letter.
EPA Administrative Order on Consent and Water Improvement Projects Milestone Dates:
Engineering Report Submittal
June 1, 2017
Engineering Report Approval by Water Infrastructure
November 1, 2017
Bid and Design Package Submittal
October 1, 2018 (revised)
Bid and Design Package Approval by Water Infrastructure
February 1, 2019 (revised)
Advertise Project, Receive Bids, Submit Bid Information, and
Receive Authority to Award
June 1, 2019 (revised)
Execute Construction Contracts
July 1, 2019 (revised)
During the last ten months, while the Engineering Report has been in review with DWI, while limited
design work was continued by WKD, none of the physical repairs or construction of in the
Remediation Plan have been started. However, during this time the City of Eden Collection and
Distribution work crews have identified and eliminated several significant sources of inflow and
infiltration. Our Video Camera and Inspection crews have been very aggressive in their continued
investigative efforts, working during rain events and doing flow measurements and identifying
additional potential point sources.
EPA Administrative Order on Consent - Semi Annual Progress Report No. 2
2 of 6 Pages

During the last six months the City of Eden's Collection and Distribution division repaired the following
source of 1/1:
On April 5, 2018, crews repaired a gap that had formed in an 8-inch sewer outfall line off of Rivercrest
Drive. This line is in the floodplain of the Dan River. During Storm events and especially during
flooding this section of sanitary sewer line has been taking on a lot of water. This inflow source has
been stopped.
During the last six months, contractor Sam W Smith, Inc. completed the following major sewer project
to help the City deal with inflow during storm events involving four primary pump stations. The
Covenant Branch -Meadow Greens Force Main Relief project was for practical purposes was
completed and operating by January 2018. This engineered project was designed to alleviate excess
flow from an overloaded force main and redirect into another by operation of remotely controlled
valves that allows flow from a small force main to be diverted into a large Force Main with more
capacity. Since its completion, this bypass relief system appears to have reduced the likelihood of
overflows at both the Covenant Branch and the Meadow Greens Pump Stations. When a recent
storm event a storm event deposited 1.5 inches of rain within twenty-four hours, neither station had
overflow where previously under the same conditions one would have been imminent.
Progress on the Remediation Plan by our Engineering Firm WKD during the last six months:
WKD is approximately 50% complete with all design activities of the Remediation Projects. Design
activities were slowed because of the longer review period of the Engineering Report. The original
approval date was anticipated on November 1, 2017, but DWI did not issue the Letter of Approval until
April 9, 2018. Advancement of the final design has cautiously progressed between November 1, 2017,
and April 9, 2018, to deter redesign or duplication of efforts in the event DWI requested or directed
revisions or alterations to the design basis of the Engineering Report. Because of the longer review,
WKD and the City of Eden negotiated a revised design and bid schedule. Although the design
schedule has been lengthened, this schedule adjustment does not jeopardize the overall objective of
the Remediation Projects being completed and in operation within the five years allowed by the
Administrative Order on Consent.
An updated and detailed schedule is shown as Attachment A in this progress report. The updated
schedule reflects the grouping of projects to facilitate a phased regulatory review/approval, bid and
construction approach. The grouping of projects has been formulated based on project type, size and
bid availability (how soon the project will be ready to bid).
EPA Administrative Order on Consent Remediation Projects Milestone Dates have been revised as
follows (revisions are italicized):
Engineering Report Submittal June 1, 2017 (Completed)
Engineering Report Approval by Water Infrastructure April 8, 2018 (Completed)
EPA Administrative Order on Consent - Semi -Annual Progress Report No. 2
- 3 of 6 Pages

Bid and Design Package Submittal
Group 1
Group 2
Group 3
Bid and Design Package Approval by Water infrastructure
Group 1
Group 2
Group 3
Advertise Project, Receive Bids, Submit Bid Information, and
Receive Authority to Award
Group 1
Group 2
Group 3
Execute Construction Contracts
Group 1
Group 2
Group 3
Construction
Group 1
Group 2
Group 3
Project Closeout
September 2018
November 2018
March 2018
October 2018
January 2019
April 2019
November 2018 - January 2019
March 2019 - May 2019
June 2019 - July 2019
January 2019
May 2019
July 2019
February 2019 — February 2021
June 2019 — June 2021
September 2019—September 2021
February 2022
(b) An assessment of the effectiveness of such actions in eliminating SSOs;
Although there is much more work needed to stop our collection system's potential for SSOs in
intense high rainfall events, we have made major progress in stopping low -intensity rainfall events of
up to four inches spread over several days. Projects and spot repairs completed over the last decade
have finally reached a point where positive results can be demonstrated with no SSOs.
Implementation of the all the rehabilitation projects in the Remediation Plan will allow us to improve
our collection and treatment system to where no SSOs should be a very sustainable condition now
and into the future.
(c) A list, which shall include the date and time, location, cause, ultimate destination, and
volume of SSOs that occurred during the previous six (6) months;
The City of Eden had no SSOs during the period of this reporting period in this Second Semi -Annual
Report. From October 22, until April 22, no SSOs occurred in our sewer collection system.
EPA Administrative Order on Consent_- Semi -Annual Progress_ Report No. 2
4 of 6 Pages

(d) An analysis of the cause of each such SSO; and
(e) A description of the City's plan to address and prevent such SSOs from occurring in the
future.
There were no SSOs to report on in this section of the semi-annual report for this reporting period.
The City of Eden will continue working to complete our Remediation Plan projects to rehab our sewer
collection and treatment to prevent SSOs now and in the future. We fully expect to complete the
Remediation Plan Projects by February 2022.
CERTIFICATION
"I certify under the penalty of law that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or persons
who manage the system, or those persons directly responsible for gathering the information, the
information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am
aware that there are significant penalties for submitting false information, including the possibility of
fine and imprisonment for knowing violations."
JIX4 S// 41//81
Terry Shelt n Date
Public Utilities Director
City of Eden
EPA Administrative Order on Consent - Semi -Annual Progress Report No. 2
5 of 6 Pages

Attachment A - Eden Remediation Program, Revised Schedules by Project/Phase (SUMMARY)
Tentative 90%
Tentative 100%
Grouping
Phase
Descri tion Design
Packa a
Design Package
1
N/A
WWTP Digester Upgrades
4/18V18//119
1
NIA
Junction Basin PS
5118
1
N/A
Bridge Street Basin PS
5/18
NIA
8
Additional Planning
N/A
N/A
9
Project Management
N/A
3
10
System -wide Rainfall Dependent Inflow and Infiltration Reduction
7/18
3
11
Bridge Street Basin Replacement and Rehabilitation
9/18
3
12
Dan River Outfall Upsize
9/18
1/19
2
13
Glovenia/Spruce/Chestnut Street Sewer Relocation
5/18
8l18
2
14
1 Junction Street Basin Replacement and Rehabilitation
6/18
9/18
2
15
Smith River Outfall (Junction Basin) Rehabilitation and Siphon
Re lacement
7/18
9/18
2
16
Kuder Street Basin Replacement and Rehabilitation
5/18
8/18
2
17
Dry Creek Basin Replacement and Rehabilitation
4/18
7118
1
18
Dogwood Drive and Fourth Street Pump Station Replacements
5/18
8/18
1
19
Bear Slide Pump Station and Indian Hills Pump Station Permanent
Standby Generator and Automatic Transfer Switch Installation
5/18
8/18
DWI FINAL REVIEW AND APPROVAL
Start Date
End Date
1
N/A
_
DWI Final Review and Approval, Group 1
9/18
10/18
2
NIA
DWI Final Review and Approval, Group 2
11/18
1/19
3
N/A
DWI Final Review and Approval, Group 3
3/19
5/19
BIDDING & CONSTRUCTION PHASES
Start Date
End Date
1
Bidding - Group 1
11/18
1/19
2
20
Bidding - Group 2
3/19
5/19
3
Bidding - Group 3
6/19
7/19
NIA
21
Division of Water Infrastructure Funding Assistance*2/291
N/A
1. 3
22
Construction Administration
9/21
1 - 3
23
Construction Observation
9/21
1
Construction - Group 1
2/21
2
N/A
Construction - Group 2
6/21
3
Construction - Group 3
9/21
1.3
Project Close-out, Documentation
2122
EPA Administrative Order on Consent - Semi -Annual Progress Report No. 2
6 of 6 Pages