WQCS00011_NOV-2024-DV-0017 Response to Notie_20240125

January 25, 2024
Brenton Bent
Director of Water Resources
City of Rocky Mount
331 South Franklin Street
Rocky Mount, NC 27804
Vanessa Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
3800 Barrett Drive,
Raleigh, NC 27609
Subject: Notice of Violation
Tracking No.-NOV 2024-DV-0017
Collection System Permit No. WQCS00011

Dear Ms. Manuel,

I received the Notice of Violation from the DEQ dated January 9, 2024, as identified by the subject tracking number regarding the sanitary sewer overflow (SSO) events on 12/17/2023 and
12/27/2023. 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 in 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. As a result, 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, the
town of Whitakers, the town of Sharpsburg, Nash County, and Edgecombe County. These systems also contribute to increased flows during rain events.
The city currently maintains more than 435 miles of sanitary sewer collection lines. Over the past year, the Water and Sewer Division has engaged in many projects to alleviate inflows
and
infiltration and improve flow capabilities to the treatment plant. The city completed two significant 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 twenty 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 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.
Beginning in June 2023, the city engaged the services of WithersRavenel, Engineering Consultants, to conduct a comprehensive study of the sewer collection system which will also include
a sewer hydraulic model. It is anticipated that upon completion of this project, the city will be better equipped to identify areas of vulnerability and thus able to directly address
the source of the problem. The project is expected to be completed in the summer of 2024. The city continued to smoke-test the collection system and conduct repairs as soon as intrusion
points were 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. This effort will
remain a top priority in the foreseeable future. As you can see, we are taking the necessary steps to address the integrity of our entire collection system, and we hope 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 additional information, please do not hesitate to contact me at 252-972-1299 or [e-mail].

Sincerely,

Brenton Bent, Director of Water Resources