WQCS00011_NOV-2021-DV-0055 RSP_20210425

ROCKY MOUNT
WA;i;R RESO's.RRC'-S
i 1 .Y F- '• II A.
April 12, 2021
Brenton Bent
Director of Water Resources
City of Rocky Mount
331 South Franklin Street
Rocky Mount, NC 27804
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
13800 Barrett Drive.
Raleigh, NC 27609
Re__Spon se_ by e
¶eetl CCL,
Subject: Notice of Violation & intent to Issue Civil Penalty
Tracking No.-NOV 2021-DV-0055 & NOV-2021-DV-0179
Collection System Permit No. WQCS000I
Dear Mr. Vinson,
I received the Notices of Violation from the DWR dated Marcie 2 3.2021 and March 29.202 1 as
identified by the subject tracking numbers regarding the sanitary sewer overflow (SSO) events
that occurred on 12/24/2021, 12/31 /2020. 2/ 13 /2021, 2/ 15/2021, 2/16/2021, 2/19/2021, and
2127r2021.The city of Rocky Mount takes these incidents very seriously and continues to take
steps to minimize the potential for such overflows within our sewer collection system.
Consistent with previous responses, the city continues to investigate. evaluate. and invest 111 the
sewer collection system to Mitigate these incidents. As you are aware, these overflows occurred
primarily when Rocky Mount received heavy sustained rainfall causing flash flooding of'streets,
drainage ditches and streams. The collection system can become hydraulically overloaded from
inflow and infiltration. In addition, the city has wholesale wastewater purchase agreements with
neighboring systems such as the town of Nashville. town of Whitakers, town of Sharpsburg.
town of Dortches. Nash County and Edgcconlbe County and these systems are also contributing
increased (lows during rain events.
• 2) 972-11?1 / 331 S (rankl!rn Si., PO 6o i it80, Rocky Mount, NC 27802•1160 / v..wr(36.vnrmnurc cloy

The city currently maintains in excess of 435 miles of sanitary sewer collection lines. Over the
past year, the Water and Sewer Division has engaged in many projects to alleviate inflows,
infiltration and improve flow capabilities to the treatment plant. The city recently completed two
major projects to assist in these efforts. These are the relining of approximately 1.7 miles of a
27" sewer outfall line and the replacement of two old screw pumps. The latter will increase
conveyance capabilities by 20 million gallons per day. The city has also continued the annual
appropriation of funds to our sewer rehab program which targets the resurfacing of manholes
that are of older masonry construction or found to have leaking joints. The other scope of our
rehab program is relining sewer mains identified to have breaks, cracks, or root intrusions.
On 2/22/2021, the city signed a Task Order and prepared a Purchase Order with Green
Engineering PLLC in the amount of $ 177,100 to plan, design, permit, and bid for replacing the
Old Mill Road sewer pump station and force main to improve pumping capacity in that basin.
The city continued to smoke test the collection and conduct repairs as soon as intrusion points
are identified. In addition, we continued our diligent daily maintenance, repair, video inspection
and cleaning of our system to prevent further SSOs or system interruptions.
Please be assured that the city of Rocky Mount is working with great care and perseverance to
reduce the number of sanitary sewer overflows in the collection system and this effort will
remain a top priority into the foreseeable future. As you can see, we are taking the necessary
steps to address the integrity of our entire collection system and our hope is that the Division of
Water Resources will favorably consider these efforts as you deliberate on any further actions
regarding these incidents.
If you have any questions, or require any additional information, please do not hesitate to contact
me at 252-972-1299 or email at [e-mail]
rockmountnc.gov
Sincerely,
Brenton Bent, Director of Water Resources
1252) 972-13251 331 S. Franklin St, PO Box 1180, Rocky Mount, INC 27802-1180 / www rockymountnc.go 2

�DMslon of Wrier Resources
State of North Carolina
Department of Environment and Natural Resources
Division of Water Resources
Collection System Sanitary Sewer Overflow Reporting Form
Form CS-SSO
PART I:
This form shall be submitted to the appropriate DWQ Regional Office within five business days of the first knowledge of the
sanitary sewer overflow (SSO).
Permit Number: WQCS00011 (WQCS# if active, otherwise use WQCSD#)
Facility: Rocky Mount Collection System Incident #: 202100038
Owner: City of Rocky Mount
City: Rocky Mount
County: Edgecombe _ Region: Raleigh
Source of SSO (check applicable): 0 Sanitary Sewer ❑ Pump Station / Lift Station
SPECIFIC location of the SSO (be consistent in description from past reports or documentation - i.e. Pump Station 6,
Manhole at Westall 8 Bragg Street, etc): OLD MILL RD MANHOLE # H105-32
Manhole #: H105-032
Latitude (Decimal Degrees): Longitude {Decimal Degrees):
Incident Started Dt: 12/31/2020 Time: 11 30 pm Incident End Dt: 01/01/2021 Time: 10:00 am
(mm-dd-yyyy)
(hh:mm AM/PM) (mm-dd-yyyy) (hh:mm AM/PM)
Estimated Volume of the SSO: 18,000 gallons Estimated Duration (Round to nearest hour): 10:30 hours
Describe how the volume was determined: VISUAL FLOW REFERENCE/ TIME LAPSE
Weather conditions during the SSO event:
HEAVY SUSTAINED RAINFALLICAUSING FLASH FLOODING
Did SSO reach surface waters? Q Yes ❑ No ❑ Unknown Volume reaching surface waters (gals): 18200
Surface water name: Maple Swamp
Did the SSO result in a fish kill? ❑ Yes 0 No ❑ Unknown If Yes, what is the estimated number of fish killed?
SPECIFIC cause(s) of the SSO:
0 Severe Natural Conc [l Inflow and Infiltration
24 hour verbal notification (name of person contacted ): Todd Green
❑ DWR 0 Emergency Mgmt Date (mm-dd-yyy): 01/01/2021 Time (hh:mm AM/PM): 03:43:00 pm
If an SSO is ongoing, please notify the appropriate Regional Office on a daily basis until SSO can be stopped.
Per G.S. 143-215.1C(b), the responsible party of a discharge of 1,000 or more of untreated wastewater to surface waters
shall issue a press release within 24-hours of first knowledge to all print and electronic news media providing general
coverage in the county where the discharge occurred. When 15,000 gallons or more of untreated wastewater enters surface
waters a public notice shall be published within 10 days and proof of publication shall be provided to the Division within 30
days. Refer to the reference statute for further detail.
The Director, Division of Water Resources, may take enforcement action for SSOs that are required to be reported to
Division unless it is demonstrated that:
1) the discharge was cause by sever natural conditions and there were no feasible alternative to the discharge; or
2) the discharge was exceptional, unintentional, temporary and caused by factors beyond the reasonable control of the
Permittee and/or owner, and the discharge could not have been prevented by the exercise of reasonable control.
Part II must be completed to provide a justification claim for either of the above situations. This information will be the basis
WHETHER OR NOT PART III IS COMPLETED, A SIGNATURE IS REQUIRED AT THE END OF THIS FORM
CS-SSO Form
Page: 1

PART II:
ANSWER THE FOLLOWING QUESTIONS FOR EACH RELATED CAUSE CHECKED IN PART I OF THIS FORM AND
INCLUDE THE APPROPRIATE DOCUMENTATION AS REQUIRED OR DESIRED
COMPLETE ONLY THOSE SECTONS PERTAINING TO THE CAUSE OF THE SSO AS CHECKED IN PART I
(In the check boxes below, NA = Not Applicable and NE = Not Evaluated)
A HARDCOPY OF THIS FORM SHOULD BE SUBMITTED TO THE APPROPRIATE DWR REGIONAL OFFICE UNLESS IS
Severe Natural Condition
Describe the "severe natural condition" in detail?
IMPACTED AREA RECEIVED APPROXIMATELY 2" OF RAIN OVER NIGHT FALLING ONTO PREVIOUSLY HEAVILY
SATURATED SOILS. THE LATTER QUICKLY PUSHED STREAMS AND DRAINAGE DITCHES ONTO STREETS AND L
LYING PROPERTIES CAUSING FLASH FLOODING.
How much advance warning did you have and what actions were taken in preparatio
for the event?
NONE
Comments:
nflow and Infiltration
Are you under an SOC (Special Order by Consent) or do you have a schedule in any ❑ Yes IIZ No ❑ NA ❑ NE
permit that addresses I/1?
Explain if Yes:
What corrective actions have been taken to reduce or eliminate I & I related overflow
at this spill location within the last year?
WE HAVE RECENTLY SMOKE TESTED 17 SQ MILES OF THE SEWER SHED IN THE VICINITY OF THIS SITE. THE
LATTER EFFORT RESULTED IN REPAIR /REPLACEMENT OF OVER 50 SEEWR CLEAN OUTS IN LOW AREAS,
REPAIR OF TWO MANHOLES WITH OFFSET CASTING IN PROXIMITY TO DITCH- LINE.
Has there been any flow studies to determine I/1 problems in the collection system at ❑ Yes No fl NA ❑ NE
the SSO location?
If Yes, when was the study completed and what actions did it recommend?
Has the line been smoke tested or videoed within the past year? I71 Yes ❑ No ❑ NA ❑ NE
If Yes, when and indicate what actions are necessary and the status of such actions:
SMOKE TESTING WAS CONDUCTED IN OCTOBER OF 2020. AS INDICATED ABOVE ALL FOUND DEFISIENCIES
HAVE BEEN CORRECTED.
Are there 1/1 related projects in your Capital Improvement Plan? M Yes ❑ No ❑ NA ❑ NE
If Yes, explain:
THE 5 YEAR CIP INCLUDES ANNUAL ALLOCATIONS FOR CONTINUED MANHOLE REHAB TO REMEDIATE LEAKIN
MANHOLES AND RELINING OF IDENTIFIED SEWER MAINS.
;S-SSO Form Page: 2

# Have there been any grant or loan applications for Ill reduction projects? F Yes [7 No NA (— NE
If Yes, explain:
Do you suspect any major sources of inflow or cross connections with storm sewers" Yes [fl No ❑ NA ❑ NE
If Yes, explain:
Have all lines contacting surface waters in the SSO location and upstream been
inspected recently?
If Yes, explain:
171 Yes L' No DNA ONE
What other corrective actions are planned to prevent future VI related SSOs at this
location?
CONTINUED SMOKE TESTING TO COMPLETE ENTIRE SEWER SYTSTEM IN VICININTY TO SSO SITE.
Comments:
System Visitation
ORC
[7 Yes
Backup r Yes
Name:
NATHANIEL WILLIAMS
Cert#
989593
Date visited:
1/01/2021
Time visited:
12:15 A.M
How was the SSO remediated (i.e. Stopped and cleaned up)?
SSO CEASED AS COLLECTION SYSTEM STABILIZED.THERE WERE NO SOLIDS ONLY HEAVILY DILUTED WATER
DISHARGED. NO CLEAN UP WAS FEASABLE/DISCHARGE WAS INTO FLOODED DRAINAGE DITCH UNDER HEAV'
FLOW.
CS-SSO Form Page: 3

ks a representative for the responsible party, 1 certify that the information contained in this report is true and accurate to the
est of my knowledge.
'erson submitting claim: Nathaniel Williams Date: 01/06/21 07:52 am
signature: Title:
e:ephone Number:
kny addition information desired to be submitted should be sent to the appropriate Division Regional Office within five days of 1
nowledge of the SSO with reference to the incident number (the incident number is only generated when electronic entry of th
orm is completed, if used).
CS-SSO Form Page: 4

AEA
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Water Quality Programs
Pat McCrory Thomas A. Reeder John E. Skvarla, III
Governor Director Secretary
October 1, 2013
Charles W. Penny; City Manger
City of Rocky Mount
P.O. Box 1180
Rocky Mount, NC, 27802.1180
Subject: Permit No. WQCS00011
City of Rocky Mount
Rocky Mount Collection System
Edgecombe County
Dear Mr. Penny:
In accordance with your application received April 25, 2013 we are forwarding herewith Permit
No.\VQCS0001 1, dated October 1, 2013, to the City of Rock. Mount for the operation and
maintenance of the subject wastewater collection system.
This permit shall be effective from October 1, 2013 until September 30, 2021 and shall be
subject to the conditions and limitations specified herein. It is your responsibility to thoroughly
review this permit. Please pay particular attention to the monitoring and reporting requirements
in this permit and any compliance schedules shown in hold.
1'or purposes of permitting, the collection system is considered to be any existing or newly
installed system extension up to the \vastewater treatment facility property or point of connection
with a separately owned seIkcr system. '1 he collection system is considered all gravity lines,
pump stations, force plains, low pressure sewer systems. S I FP systems, vacuum systems. etc.
and associated piping, \ alves and appurtenances that help to collect, manage and transport
wastewater to a wastewater treatment plant under the Perinitlee's ownership or maintained and
operated by the Pcrmittee through a perpetual legal agreement. Satellite systems are systems
tributary to the Perp)Ittee's collection system but those collection systems are not owned or
maintained by the Pcrmittee. The system description provided on Page 1 of` this permit is meant
to provide a general idea about the size of the system and may not be all inclusive of the
collection system at the time of permit issuance or afterward.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St, Raleigh, North Carolina 27604
Phore: 919.807-6300 t FAX. [phone]
Internet: !rm., ncwaterouality orq
01;C
North Caroli na
Natural/

October 1, 2013
Page 2 of 3
A release of wastewater from the wastewater collection system is referred to herein as a Sanitary
Sewer Overflow (SSO). The evaluation of enforcement options after an SSO will be determined
considering the criteria listed in condition I(3)(a) and I(3)(b) of the permit and all other relevant
information available or requested of the Permittee. Compliance with all conditions of the
permit as well as all statutes and regulations pertaining to the collection system must be
maintained or appropriate enforcement actions may be taken as noted in Condition VI(2).
A reportable SSO is an SSO greater than 1,000 gallons to the ground or an SSO of any amount
that reaches surface water (including through ditches, storm drains, etc.) Below is the procedure
to use for reporting SSOs to the Division:
1. Report by telephone to a Division of Water Resources (DWR) staff member (not email,
facsimile, or voicemail) at your regional I)WR office during regular business hours
(Monday to Friday, 8AM to 5PM) as soon as possible, but in no case more than 24 hours
after the SSO is known or discovered_ To report outside of regular business hours, call
[phone].
2. Follow ups the verbal report by sending a completed written report on the most current
Division approved form within five clays.
To provide a uniform method for all systems covered under this permit and to provide useful and
consistent information pertaining to SSOs, please utilize form CS-SSO consisting of two parts.
Part I serves to provide to the Division the required information that has always been necessary.
Part II serves as an area to provide a justification for the spill, as optional under Condition 1(3) of
your permit. Form CS-SSO can be downloaded from the SSO Reporting area at
http://portal.nedenr.org/web.'wq'swp/ps/cs/ssoreport.
An NOV, civil penalty, and/or a moratorium on the addition of waste to the system niay be
issued if adequate justification for an SSO is NOT submitted to the regional office. In order to
submit a claim for justification of an SSO, you must use form CS-SSO xvith additional
documentation as necessary. I)WR staff will review the justification claim and determine if'
enforcement action is appropriate. Please be advised that the information n;ecfed to justify a spill
is very comprehensive. Begin using this form immediately to report SSOs from the collection
system. Continue to use our old form for reporting bypasses at the wastewater trcatinent plant
until further notice. 'I'Iie time frame for submittal of both Part 1 and Part II, if pertinent, is lure
days.
Failure to abide by the conditions in this permit may subject the Permiuce to cnforeeinwnt action.
If any parts, requirements, or limitations contained in this permit are unacceptable, you have the
right to request an adjudicatory hearing upon written request within thirty days following the
receipt of this permit. This request must be in the form of a written petition, conforming to
Chapter 150B of the North Carolina General Statutes, and filed with the Office of Administrative
I leanings, 6714 Mail Service Center, Raleigh, NC 27699-6714. Unless such demands are made,
this permit shall be final and binding.

October 1, 2013
Page 3 of 3
If you have questions regarding compliance contact your regional office or the Pretreatment,
Emergency Response and Collection Systems Unit of the North Carolina Division of Water
Resources at [phone]. If you need additional information concerning this permit, please
contact Deborah Gore at [phone].
Sincerely,
St-1\\
for Thomas A. Reeder
Division of Water Resources
by Deborah Gore, Supervisor
Pretreatment, Emergency Response, Collection System Unit
enclosure: Permit No. WQCS000I 1
cc: Eclgecombe County Health Department
Wayne Hollowell, Director of Water Resources, via email
Raleigh Regional Office, Surface Water Protection Section
Water Resources Central Files — WQCS00011
Steve Reid, NPDES Compliance & Expedited Permitting Unit (electronic)
PERCS Files (electronic)