WQCSD0298_Response to NOV-2021-DV-0420_20211213

U.S. Department of Justice
Federal Bureau of Prisons
Federal Correctional Complex
Federal Medical Center
P. O. Box 1600
Butner, North Carolina 27509
December 13, 2021
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Re: Notice of Violation NOV-2021-DV-0420
Dear Mr. Vinson,
Please accept this response from the Federal Correctional Complex Butner (FCC Butner)
regarding the incident referenced inNOV-2021-DV-0420, dated October 05, 2021. This response is
to demonstrate our commitment to ensuring a safe and environmentally conscious work place, free of
recognized hazards for our staff, inmates, and the environment. It is the position of FCC Butner that
no civil penalty is appropriate in this case for the reasons outlined below.
The specific incident referenced was:
1. Sanitary Sewer Overflow that occurred on August 06, 2021.
Investigation Findings/Observations:
FCC Butner's sewage collection system consists of manholes, gravity fed sewer lines, and
one debris lift station. The sewer overflow event occurred at the #6 manhole, which only receives
sewage from the Federal Medical Center (FMC) facility within FCC Butner. The FMC's gravity
fed sanitary sewer extends south from the FMC and crosses to the southern side of Old HWY 75.
The sewer main then runs east, parallel to Rte. 75, for approximately 2,850 linear feet ending at the
Sanitary Sewer Debris Lift Station. From the Rte. 75 crossover to the lift station there are 5
manhole access points, labeled as manholes #2-6. Each manhole is located approximately 3-12 feet
from the road's southern edge.
On August, 6, 2021 at 7:50 am, a sewer system overflow was discovered at the #6 manhole,
which is approximately 1,500 ft. from where the FMC sewer line crosses Rte. 75 (See Attachment

A). Upon discovery, an outside contractor, Vision -NC LLC, was immediately contacted to provide
vacuuming and sewer line jet flushing services. At approximately 12:O0pm the line was cleared
and normal operations were resumed. During the jet flushing of the sewer line a large piece of
concrete approximately 10-12 inches in diameter was found in the pipe. No other unusual or
unexpected debris was found. Due to the damage of the manhole concrete base and the adjacent
wooden warning bollard, staff believe that a possible equipment strike to the manhole by the state
mowing crews had likely dislodged this piece of concrete and caused the sewage backup.
The blockage caused an estimated 15,000 gallons of untreated water to spill into the wooded
area across from the FMC, of which 5,000 of the gallons contacted the small stream that flows
south from the Federal Prison Camp across HWY 75 to the game land wooded area. From Manhole
#6 the spill extended south along the eastern side of the game land old entrance trail. Along the
trail side, the water contacted an abandoned drainage culvert that runs west under the entrance trail
and ended at the small stream. During the spill, hay bales were placed to divert water from the
drainage culvert and the area was treated with lime to provide for disinfection.
After clearing the blockage and gaining control of the spill, the manhole's concrete base was
repaired, the yellow wooden bollard was replaced, all manholes were painted yellow, and foliage
around the manholes was removed to provide greater visibility (see Attachment B). Since the
previously reported December 2020 SSO, FCC Butner has implemented weekly inspections of
each of the manhole covers to check for damage and to ensure that the covers are still in place (see
Attachment C). There have been no deficiencies noted on any of the weekly inspections. In
addition to the repairs, FCC Butner submitted a public press release in the local Creedmoor, NC
newspaper and contacted the NCDOT Granville County maintenance department for approval to
install protective guardrails or steel bollards around the manholes. Unfortunately, due to the close
proximity to HWY 75, they were unable to grant approval and recommended replacement of the
wooden bollard.
As outlined above, FCC Butner acted promptly in responding to the Sanitary Sewer
Overflow that occurred on August 6, 2021 and has taken numerous steps to help prevent future
incidents such as this. For these reasons, it is the position of FCC Butner that no civil penalty
should be assessed in this case.
I hope this helps address any concerns regarding this issue. If there is any additional
information or documentation required, please do not hesitate to contact Farnon Dix, Environmental
and Safety Compliance Administrator, 919-575-3900 extension 5348, or Michael Klattenberg, Safety
Compliance Specialist, 919-575-3900 extension 5352.
In
W.'
T. Scar. tino, Complex Warden

ATTACH M ENT A

ATTACHMENT B
Painted Manhole #6
Game Land Entrance Trail

Abandoned Drainage Culvert
Painted Manhole #5

ATTACHMENT C

FBOP WOPM 10337
Preventive Maintenance 212212015
BUT CU14 FCC Chief -
WO Description: WEEKLY LIFT STATION Site: FPC
Asset 9: MSEW-1.BUT Building: Lit Station
Description: SEWAGE LIFT STATION Location: Lift Station
Make: Inetltudon Acquired: 11111979
Model: Physical Condition: 3 - Poor
Serial NONin:
If Applicable. ensure all safety precautions are followed to Include but not limited to "Lockou (ragout, Confined Space Entry. & Fall Protection"
IEnsure all equipment has a MWI label affixed that is In clear view and legible. Ensure ell MWI Information is correct.
Schedule: 6016
sit Noe # ME
❑ W 13561
NSPECT SEWAGE LIFT STATION . ENSURE CLEANLINESS.
Inspect motors and pumps for proper lubrication and operation
Spray and Wash down area with water
Ensure Lift Station and surrounding area is clear of debris.
CLEAN AUGER DRAIN SCREEN
Inspect and exercise all valves.
TEST LEVEL ALARMS
CHECK SEWAGE LINE FROMFMC TO LIFT STATION
ENSURE DRAIN COVERS PROPERLY FIT
PUMP 1: HRS
PUMP 2: HRS
LIST BELOW COMMENTS AND ALL MATERIAL USED.
Act. Staff Hours:
Material Cost:
Date Completed:
0.50
212312015
Staff Signature
1