WQ0032515_NOV-2023-LV-0045_Resp Rcv_20230322

WATER MANAGEMENT
CITY OF DURHAM
March 22, 2023
Ms. Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, DEQ
RE: Notice of Violation & Intent to Assess Civil Penalty
NOV-2023-LV-0045; Permit No. WQ0032515; North Durham WRF Reclaim
Dear Ms. Manuel,
NC Dept of Environmental Quality
MAR 2 2 ?O73
Raleigh Regional Office
On March 8, 2023, the City of Durham received the referenced Notice of Violation & Intent (NOV/1) to Assess
Civil Penalty. The letter references a review of the August 2022 Non -Discharge Monitoring Report (NDMR) for
the North Durham Water Reclamation Facility (NDWRF) which reported a limit violation for exceeding the daily
maximum for fecal coliform (in the reclaim system) on August 9, 2022. The City of Durham Department of Water
Management (DWM) respectfully requests a recension of the NOV/1 for the August 9, 2022, daily maximum
exceedance for fecal coliform in the reclaim system.
In support of this request, DWM would like to provide the following information to mitigate the one-time
detection:
• Reclaim water has not been distributed outside of the DWM facility at 1905 East Club Blvd, Durham NC
for over a year. The reclaim water is primarily used onsite for maintenance purposes.
• The two samples taken the previous week (August 2, 2022 and August 3, 2022) and the two taken
immediately following the August 9, 2022 sample (August 10, 2022 and August 11, 2022) measured less
than detectable for fecal coliform.
• The average chlorine residual for the day of the violation, August 9, 2022, was 1.85mg/I.
NDWRF staff responded in a timely and appropriate manner immediately following the receipt of the 8/9/22
fecal coliform test results. Treatment systems were checked and verified to be working properly. Follow up fecal
coliform samples were collected for the two days following the exceedance to verify that reclaim water was in
compliance for fecal coliform. Based on these factors, we respectfully request that you rescind the NOV/1 for the
August 9, 2022, daily maximum exceedance for fecal coliform.
Thank you in advance for your thoughtful consideration of our request. We look forward to continuing our long
history of exemplary compliance and cooperation with DEQ. Please feel free to reach out to NDWRF
Superintendent John Dodson ([e-mail]) or myself (lohn.youna @durhamnc.¢ov) if you have
any additional questions or concerns.

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Best regards,
4,- Tku\r�
John Young, PE
Assistant Director- Plant Operations and Maintenance
Department of Water Management
City of Durham