NC0020443_NOV-2019-PC-0677 Response_20191015

Town of Columbia
'A Heart's Delight" founded in 1793
103 Main Street • P.O. Box 361
Columbia, NC 27925
252.796.2781(P) • 252.796.0082 (F)
October 15, 2019
Mr. Robert Tankard, Assistant Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, DCDEQ
Washington Regional Office
943 Washington Square Mall
Washington, NC 27889
RE: Notice of intent, # NOV-2019-PC-0677
Permit No. NCO020443
Columbia WWTP
Mr. Tankard:
This letter is in response to your letter dated October 7, 2019, received October 9, 2019, indicating your
intent to access a civil penalty to the Town of Columbia Waste Water Treatment System. This letter is
intended to provide additional information regarding the noted violation that we hope you will take in
consideration in any future actions.
First , we believe that the unreported spill noted in your letter should be considered within the context
of Hurricane Dorian which was bearing down on the North Carolina coastal areas during the week of
September 1-7, 2019. In fact Tyrrell County was placed under a State of Emergency early in the week in
anticipation of a full blown hurricane with flooding, high winds and power outages.
During this time the Town's Water/Sewer employees (T.J. Davenport and Kenneth Coleson) along with
Contractor Tim Oliver, prepared for the hurricane. This included testing generators, topping off fuel

tanks, positioning vehicles, assigning tasks and responsibilities, etc. As the hurricane approached with
rising flood waters, employees made observations every few hours at the Waste Water Treatment Plant,
the Effluent Plant and at pumping stations. They also kept an eye out for manholes that might be leaking
under the pressure of the storm and resulting infiltration and inflow.
As effects of Hurricane Dorian began to be felt on Thursday, September 5, the Town went into a safety
mode while watching increasingly high water. Friday morning daylight brought flooding of streets, yards,
homes and businesses. At about 7:AM on the 6`h, the Town lost electrical power. Communication losses
followed — SCADA, phone service, cell phones and the internet was non-existent for hours stretching
into Saturday, September 7. The town's internet service was not function until near mid -day Sunday,
September 8.
T.J. Davenport made it to the Water Treatment Plant on Light Street at about 6:AM, Friday. After
checking on water production, he waded west to the Effluent Plant and activated that auxiliary
generator which had failed to come on as required (it ran well in earlier tests). He then waded to Lift
Station # and silenced that high water alarm.
After returning to the Light Street location he pulled on waders and made the treck to the Waste Water
Treatment Plant on north Road Street Extended. There he found another generator that had not
activated when electrical power was lost. He reset the generator, checked for obvious problems and
waded back to the Water Plant on Light Street. During this entire time winds were increasing and water
was rising. Although the high ground at the Waste Water Treatment Plant site did not flood, the lower
areas inside and near the perimeter fencing were flooded as was the corn field to the north and area of
tall grass on the west side of the fence.
T.J. Davenport went beyond the normal expectation of duty on behalf of his employer. The Town of
Columbia Board of Aldermen commended Mr. Davenport for his outstanding efforts during their
meeting on October 7.
Later Friday (about 4:PM) Tim Oliver visited the Waste Water Treatment Plant and noted what he
thought was a small spill near the north west corner of the site. Flood waters had not receded enough to
determine the extent of the spill of partially treated waste water.
Saturday's events are documented in memos from Robbie Bullock dated September 13, September 17
and the above referenced letter dated October 7, 2019.
Second, please note that the spill was not raw sewage. We are aware of several hurricane related spills
in eastern North Carolina that involved raw sewage in even much larger quantities. This spill was
partially treated waste water. Also note that the 198,000 gallon estimate was just that, an up- front
estimate that was based upon visual inspection of an area that still included standing flood waters.
Subsequent cleanup work leads us to believe that the actual spill was less than the initial estimate.

Third, not only was electrical power down, but cell service and internet was down or at best
intermittent. Mr. Bullocks Saturday attempt to send me the wording necessary to place a notice in the
local newspaper of record was unsuccessful as I did not have internet service until about mid -day on
Sunday. I did get cell service by early -evening, Saturday, and took a dictated wording of the notice from
Mr. Bullock. I was still unable to send the notice or the written spill report on Saturday.
Sunday, after church services, I returned to the office and with restored cell service was able to send the
report of spill and the notice of spill. At Mr. Bullock's direction we placed a paid ad in the Coastland
Times as well as a news release notice. We also sent releases to the Scuppernong Reminder and the
Chowan Herald, both having limited circulation in the Town of Columbia.
Third, cleanup efforts began immediately and have been costly. We secured the services of a septic tank
service and used town employees plus inmates who began cleaning on Monday, running through the
next weekend. Total contracted cost plus lime that was spread totaled $17,687.00. For a small Town
with limited resources, that is already a hefty penalty.
Since the events of early September we have worked closely with Mr. Oliver to make certain we are
operating within permit requirements. We are fortunate that we have the services of Mr. Oliver who
knows the Columbia Waste Water Treatment Plant better than anyone. He was knowledgeable of the
earlier version and was present during construction and upgrades of the expanded system.
We respectfully request that you forgo a civil fine in any action that you may take in this matter.
Please feel free to contact me if you have questions.
Yours sincerely,
Rhett B. White, Manager
CC/ Robbie Bullock