NC0043176_NOV-2021-LV-0307_20210521

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POST OFFICE BOX 1065 • DUNN, NORTH CAROLINA 28335
[phone] • FAX [phone]
www.dunn-nc.org
May 21, 2021
Trent Allen, 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-2021-LV-0307
Monthly Flow Exceeded -February 2021
Permit No. NC0043176
Dunn WWTP
Harnett County
Dear Mr. Allen,
Mayor
William P. Elmore Jr.
Mayor Pro Tem
Dr. David Bradham
Council Members
J. Wesley Sills
April L. Gaulden
Frank McLean
Billy Tart
Chuck Turnage
City Manager
Steven Neuschafer
The City of Dunn appreciates the opportunity to respond to the Notice of
Violation and Intent To Issue Civil Penalty dated April 29, 2021, for the
permitted flow violation that occurred in February 2021. It is our intent that this
letter will provide sufficient additional information regarding the monthly flow
violation.
Cause of non-compliance:
6.26 inches of rainfall was reported for the month of January and 7.02 inches of
rainfall was reported in the month of February. This has been one of the wettest
years in history, causing the system to be inundated with higher than normal
winter weather flows.

Remedial Action Taken:
o The City recently completed the $2.95 Million upgrade to replace the
aeration piping and blowers at the WWTP. The plant was returned to full
capacity on December 8, 2020 so the plant was better equipped to handle
higher peak flows.
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.
The City worked with WithersRavenel on this project and completed the
assessement in November 2020.
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, flow testing, and smoke testing has been completed to
date. The City applied for an additional $313,586 to repair approximately
2,230 LF of sewer main that was found to be contributing significant
amount of inflow and infiltratation. Golden LEAF awarded the additional
funds in August 2020. The repair project is currently in bidding phase
with WithersRavenel with an estimate completion date of October 2021.
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. From January 1, 2020 to December 31, 2020, the
City has cleaned approximately 63,966 LF and inspected 16,187 LF with
the mainline camera.
o In July 2020, the City replaced approximately 360 LF of 8" sewer main on
South McKay Ave that had collapsed at a cost of $60,401.86. In August
2020, the City replaced approximately 330 LF of 8" sewer main on E.
Vance Street at a cost of approximately $8,000. The City completed
repairing defects found during smoke testing such as broken cleanouts at
a cost of approximately $1,500. On November 18th a portion of the 24"
Juniper Creek outfall line collapsed on E. Pope Street. This was a costly
repair for the City that is estimated at approximately $130,000. On January
28, 2021, a significant source of I&I was found on Cresent Drive. The City
immediately repaired the defect and plant flows dropped approximately

200,000 gallons per day. There is also a significant amount of flow on the
12" line that extends down McKay Avenue. Crews are actively searching
and located a significant groundwater source of approximately 50,000-
75,000 gpd at McKay and Vance. Due to the depth of the sewer main, it is
the City's intention to have the rehab contractor perform CIP during the
Golden Leaf Project.
o In March 2021, USDA awarded $2,636,000 for collection system rehab.
Approximately 9,135 LF of gravity clay pipe, associated manholes, and
service connections are expected to be replaced as a result of past
collection system evaluations. The project is currently in design with
Davis Martin and Powell and construction is expected to start in the Fall
of 2021.
o In April 2021, the City was recently awarded a $1,999,129 CBDG-I grant
to replace approximately 13,625 LF of clay sewer lines, associated
manholes and service connections in the low to moderate income areas of
Dunn.
o In April 2021, the City submitted an SRF application for WWTP
improvements to include rehabilitation of a clarifier, addition of a clarifer,
addition of associated piping, and an additional chlorine contact basin in
an effort to reduce the flow restrictions between the aeration basins and
the effluent pump station. The cost estimate for this project is $3,700,000.
o In April 2021, the City submitted an SRF application for collection system
rehabilitation work to include the replacement of clay pipe in the western
part of the City and the Northern Outfall Line. This project is estimated at
$2,000,000
o On April 15, 2021, the City met with Fayetteville Regional office to discuss
a forthcoming SOC application. The City plans to request a modest
interim increase in the NPDES flow limit as part of the SOC process. To
support this request the City is also undertaking a WWTP Evaluation
which will include a review of long-term discharge alternatives that
would allow the City to increase the permitted effluent capacity, either by
an increase in the capacity of the effluent pumping system or by relocation
of the discharge to the Black River. Future process upgrades to meet the
more stringent limits anticipated (including nutrient reduction) in either
alternative will also be developed as part of the evaluation.

As demonstrated, Operation and Maintenance personnel were responsive and
took immediate action to respond to the overflow. With the amount of rain that
was recorded in 2020 along with this rainfall, the water table was high and the
ground was saturated, which negatively impacted flows and highlighted
capacity issues. However, we believe this letter shows the investment and
commitment the City is making to resolve failing infrastructure, and we hope
that the Division recognizes these efforts.
Sincerely,
Heather Adams
Public Utilities Director
DUNN
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