NC0043176_NOV-2020-LV-0357_20200527 (2)

north ayor
Mayor Pro Tem
Chuck Turnage
LW.DUNN Council Members
J, Wesley Sills
city of dunn April L. Gaulden
Frank McLean
OST OFFICE BOX 1065DUNN, NORTH•
Steven Neuschafet
May 27, 2020
Mark Brultley, Assistant Regional Supervisor
Water Quality Regional Operations Section
Fayetteville Regional Office
Division of Water Resources, NCDEQ
225 Green Street — Suite 714
Fayetteville, NC 28301-5043
RE: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
TRACKING NO.: NOV-2020-1,Vt0357
W WTP Effluent Flow — February 2020
Permit No. NC0043176
Dunn WWTP
Harnett County
Dear Mr. Allen,
The City of Dunn appreciates the opportunity to respond to the Notice of Violation dated April
30, 2020, for a monthly average now exceedance that occurred in February 2020. It is our intent
that this response will provide sufficient additional information regarding the incident and that
the Division will decide not to pursue further enforcement action.
Cause of non-compliance:
During the month of February, the City of Dunn measured 593 inches of rainfall with
4.32 inches of rain falling on February 6" and 7w which caused localized flooding in the
area and combined with high groundwater levels resulted in the plant experiencing
higher than average flows.
Remedial Action Taken:
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.

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 has been completed. Flow
monitors were installed on April 27, 2020 and smoke testing will soon follow.
o The City of Dunn has an ongo ng collection system cleaning and TV inspection
program. Inflow and Infiltration issues that are repairable by City employees are
addressed immediately.
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. The aeration project is scheduled to be
completed in November 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 when deciding
on further enforcement. Please contact myself or Heather Adams if you have any further
questions or concerns.
Sincer
Steven Neuschafer
City Manager
DUNN
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