NC0043176_LV-2019-0350_20191230

north carolina
iwDUNN
city of dunn
POST OFFICE BOX 1065 • DUNN, NORTH CAROLINA 28335
[phone] • FAX [phone]
www.dunn-nc.org
December 30, 2019
Wastewater Branch
Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Mayor
Oscar N. Hams
Mayor Pro Tern
Frank McLean
Council Members
Buddy Maness
Dr. Gwen McNeill
Billy Tart
Chuck Turnage
Dr. David L. Bradham
City Manager
Steven Neuschafer
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RE: NOTICE OF VIOLATION & ASSESSMENT OF CIVIL 1%1EAW=jZ/NPDES
Request for Remission
Case NO: LV-2019-0350
WWTP Effluent Flow — December 2018
Permit No. NCO043176
Dunn WWTP
Harnett County
To Whom it may concern,
The City of Dunn appreciates the opportunity to respond to the Notice of Violation and
Assessment of Civil Penalty dated December 6, 2019, for a monthly average flow
exceedance that occurred in December 2018. It is our intent that this response will
provide sufficient additional information regarding the incident and that the Division
will concur with our request for remission.
Cause of non-compliance:
During the month of December, the City of Dunn measured 6.65 inches of
rainfall with 2.5 inches falling on December 101h and an additional 1.2 inches
falling on December 141h. In the past, when there were heavy rainfall events, the
collection system flows would spike but would quickly recover and return to

normal conditions after a couple of days. After Hurricane Florence, the City of
Dunn has not seen the flows return to "normal". Even with drier conditions
during the month of May and June 2019, the average dry weather flows have
increased from 1.5 MGD to 2.0 MGD. Average flows increased from 1.8 MGD to
3.0 MGD and maximum flows increased from 2.75 MGD to 5.0 MGD. The Dunn
Monthly WWTP Effluent Flows Chart points out that Hurricane Florence had a
negative affect and may have caused extensive damage to the sewer
infrastructure.
Remedial Action Taken:
o A $150,000 Wastewater Asset Inventory and Assessment grant was
awarded in March 2019 to assist with the funding needed to plan current
and future collection system and WWTP Capital Improvement Projects.
o As a result of damage we feel was sustained to the collection system
during Hurricane Florence, the City applied and received $142,500 in
October 2019, to assist with conducting a sanitary sewer evaluation
including smoke testing, flow monitoring, and CCTV inspection. CCTV
inspection work is scheduled for the 4f quarter of 2019.
o The City of Dunn has an ongoing collection system cleaning and TV
inspection program. I&I issues that are repairable by City employees are
addressed immediately. Since January 1, 2019, the City has cleaned 53,125
LF and video inspected 9,000 LF of gravity sewer mains.
o The City recently received a State Reserve Loan in the amount of
$2,750,000 to upgrade the deteriorated aeration piping and blowers at the
WWTP. Due to the deteriorated air piping, the WWTP limits the amount
of flow through the plant in an effort to minimize damaging the aearation
piping any further. Therefore, once the 3MG equalization tank reaches
capacity, the collection system will surcharge at manhole# BRE8 on the
Black River Outfall line. Notice to proceed was issued to the Contractor on
11-11-19. Construction is expected to begin the 1st quarter of 2020.
o The City's Engineer, Davis Martin and Powell, is currently preparing a
Prelimianry Enigineering Report and Environmental Review in order to
pursue Rural Development Grant/Loan funding for collection system
rehab projects. Once the Collection System Rehab Project phases have
been finalized, it will be presented to Council for their consideration.

We believe this letter shows the investment and commitment the City is making
to resolve failing infrastructure, and hopes that the Division recognizes these
efforts. Therefore, we respectfully request that the Division consider these efforts
and concur with the request for remission based on the steps that the City has
taken to further reduce the flows to the treatment plant. Please contact myself or
Heather Adams if you have any further questions or concerns.
Sincerel ,
Steven Neuschafer
City Manager
CC: Heather Adams, City of Dunn
Donrie Dukes, City of Dunn
Trent Allen, NCDEQ
DUNN
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RECEIVED
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NCDEQIDWRINPDES
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8 MGD
7 MGD
6 MGD
5 MGD
4 MGD
3 MGD
2 MGD
1 MGD
0 MGD
Dunn Monthly WWTP Effluent Flows
�6.7 MGD SSO
Jul, 2017 Ju12017 Aug 2017 Sep 2017 Oa 2017 Nov 2017 Dec 2017 Jan 201E Fab 2018 Mar 2018 Apr 2018 May 2018 tun 2018 Ju12018 Aug 2019 Sap 2018 Oct 2019 Nov 2018 Dec 2019 Jan 2019 F.62019 Mar 2019 Apr 2019 May 2019 Jun 2019
g� Avenge Flow(Month) Mea Flow(Day) ® Min Flow(Daily) —R—Wl(Month) •••••• 6 per. Mm. Avg.(A—,p Flow (Month)) •••••• 6 pet. Mm. Avg.(Max Flow(Day)) •- 6 per. Mm. Avg.(Min Flow(Dally))

JUSTIFICATION FOR REMISSION REQUEST
Case Number:
LV-2019-0350
Assessed Party:
City of Dunn
Permit No.:
NCO043176
County: Harnett
Amount Assessed: $1,628.28
Please use this form when requesting remission of this civil penalty. You must also complete the 'Request For Remission,
Waiver of Right to an Administrative Hearing, and Stipulation of Facts" form to request remission of this civil penalty.
You should attach any documents that you believe support your request and are necessary for the Director to consider in
evaluating your request for remission. Please be aware that a request for remission is limited to consideration of the five
factors listed below as they may relate to the reasonableness of the amount of the civil penalty assessed. Requesting
remission is not the proper procedure for contesting whether the violation(s) occurred or the accuracy of any of the factual
statements contained in the civil penalty assessment document. Pursuant to N.C.G.S. § 143B-282.1(c), remission of a civil
penalty may be granted only when one or more of the following five factors apply. Please check each factor that you
believe applies to your case and provide a detailed explanation, including copies of supporting documents, as to why the
factor applies (attach additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C.G.S. 143B-282.1(b) were wrongfully applied to the
detriment of the petitioner (the assessment factors are listed in the civil penalty assessment document);
X (b) the violator promptly abated continuing environmental damage resulting from the violation (i.e., explain the
steps that you took to correct the violation and prevent future occurrences);
(c) the violation was inadvertent or a result of an accident (i.e., explain why the violation was unavoidable or
something you could not prevent or prepare for);
(d) the violator had not been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary remedial actions (i.e., explain
how payment of the civil penalty will prevent you from performing the activities necessary to achieve
compliance).
EXPLANATION:

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
COUNTY OF HARNETT
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
City of Dunn )
Dunn WWTP )
PERMIT NO. NCO043176 ) CASE NO. LV-2019-0350
Having been assessed civil penalties totaling $1,628.28 for violation(s) as set forth in the assessment document of the
Division of Water Resources dated December 06, 2019, the undersigned, desiring to seek remission of the civil penalty, does
hereby waive the right to an administrative hearing in the above -stated matter and does stipulate that the facts are as
alleged in the assessment document. The undersigned further understands that all evidence presented in support of
remission of this civil penalty must be submitted to the Director of the Division of Water Resources within thirty (30) days
of receipt of the notice of assessment. No new evidence in support of a remission request will be allowed after (30) days
from the receipt of the notice of assessment.
This the
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