WQCS00018_NOV2021DV0145 Response_20210308 (2)

NORTH CAROL INA
March 8, 2021
Lon Snider, Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NC DEQ
Subject: Notice of Violation & Recommendation for enforcement
Case if NOV-2021-DV-0145
Sanitary Sewer Overflows — November 2020
City of Eden - Collection System Permit No. WQCS00018
Rockingham County
Dear Mr. Snider,
NC aentEnvoniReceiveldQuaoifty
MAR 12 2021
Winston-Salem
Regional Office
This letter is in response to a Notice of Violation with the intent to enforce that has been issued against
the City of Eden Collection System Permit No. WQCS00018.
We understand that an NOV with the intent to enforce is being issued for incident numbers 202003386
and 20203386. These overflows to surface waters occurred on November 30, 2020. The overflows were
caused by inflow and infiltration during a storm event that deposited 2 to 3 inches of rain overnight.
The rain started the previous night around 8:00 PM and by 4:00 AM it had deposited 1.75 inches of rain.
Saturated soils and widespread heavy rain caused Dry Creek and the Dan River to flood adding to the
load of these two pump stations.
Incident number 202003386 occurred at the City of Eden's Covenant Branch Pump Station. During the
previously mentioned weather conditions, an estimated volume of 10,611 gallons of untreated sewage
was released and reached the Dan River.
The City of Eden recognizes that overflows have continued to occur at this pump station despite the
City's efforts to stop them. The City is planning to reroute two pump stations that contribute to
Covenant Branch's total flow, one of them being New Street Pump Station. New Street Pump Station
also overflowed during this event which began shortly before Covenant Branch Pump Station
overflowing. There has been an apparent bid winner for the contract to install a new pump station to

handle this and other flows that currently flow to the Covenant Branch Basin. The City is in negotiation
with the winner in an attempt to get the cost within budget if possible. Once an agreement has been
reached the project should be awarded.
Also, within the past month, another major source of I/1 has been found at New Street Pump Station
itself. It has been determined by the City's I/1 crew, through some creative testing, that a great deal of
runoff is actually entering the pump station directly through the top section of the wet well. City crews
have a plan to get this repaired within the next two weeks in order to prevent further surface water
from entering the wet well.
Incident number 202003387 occurred at the City of Eden's Railroad Pump Station. During the previously
mentioned weather conditions, an estimated volume of 8,964 gallons of untreated sewage was released
and reached Dry Creek.
The City of Eden also recognizes that overflows have continued to occur at this pump station despite the
City's efforts to stop them. Rehabilitation work continues to the sanitary sewer lines of the Dry Creek
Basin, which flows into Railroad Pump Station. As crews with Yates Construction Company were
replacing a section of sanitary sewer on Draper Lane, a manhole located around the corner was
discovered to be taking on a considerable amount of water from the underground flow of a nearby
stream, through the base of the manhole. This manhole has been replaced. Following this overflow, the
I/1 crew also discovered what appears to be a major source of infiltration through a section of sewer
main located behind the First Baptist Church located at 1017 Fieldcrest Road. The line upstream has
been rerouted to flow into Industrial Pump Station. This line does not appear to have any taps on it and
the City plans to plug the line so as to determine if the line can be permanently disconnected from the
sanitary sewer system.
The City of Eden takes preventing sanitary sewer overflows seriously. Please take these facts into
consideration when deciding what action to take.
Sincerely,
Mark Bullins, O.R.C. City of Eden Collection System
Collection & Distribution
City of Eden
CC: Paul Dishmon, Director of Municipal Services
Terry Shelton, Director of Public Utilities
Jon Mendenhall, City Manager