WQ0032515_NOV-2024-MV-0011_20240308

WATER MANAGEMENT
CITY OF DURHAM
March 8, 2024
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-2024-MV-0011; Permit No, WQ0032515; North Durham WRF Reclaim
Dear Ms. Manuel,
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On February 16, 2024, the City of Durham received the referenced Notice of Violation & Intent (NOV/I) to Assess
Civil Penalty. The letter references a review of the August 2023 Non -Discharge Monitoring Report (NDMR) for
the North Durham Water Reclamation Facility (NDWRF) which reported a frequency violation for monitoring the
parameter Turbidity, HCH Turbidimeter (00076) (in the reclaim system) for the dates August 1-5, 2023 and
August 7-31, 2023. The City of Durham Department of Water Management (DWM) respectfully requests a
recension of the NOV/1 for the August, 2023, monitoring frequency for turbidity 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.
• Previous NDWRF plant superintendent had received direction from NC DEQ that inclusion of daily
reclaim water turbidity was not required in monthly NDMR until offsite distribution of reclaim water
began. This is documented in the attached email from Molly Nicholson, dated March 15, 2022.
• While reclaim water piping from NDWRF to DWM headquarters at 1600 Mist Lake Dr., Durham NC (Mist
Lake) has been installed, distribution of reclaim water to Mist Lake has not begun. DWM is still waiting
on mechanical components required for this service; distribution to Mist Lake will not begin until these
components are received and installed.
NDWRF staff currently monitors reclaim turbidity and are taking steps required to ensure proper reporting of
this parameter when off site distribution begins, which is our understanding of the requirement.
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 Brian Merritt ([e-mail]) or myself ([[e-mail]) if you have
any additional questions or concerns.

Page 2 of 2
Best regards,
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John Young, PE
Assistant Director- Plant Operations and Maintenance
Department of Water Management
City of Durham
Enclosures
Email Dated March 15, 2022 Molly Nicholson, NC DEQ to John Dodson, City of Durham

Young,John
From: Nicholson, Molly <[e-mail]>
Sent: Tuesday, March 15, 2022 2:40 PM
To: Dodson, John
Subject: RE: [External] Re: WO0032515 Turbidity Question
Thank you very much for your quick response. That clears things up
Best,
Molly Nicholson
Environmental Specialist I
Raleigh Regional Office
N.C. Division of Water Resources
N.C. Department of Environmental Quality
984-365-9360 Cell
919-791-4240 Office
[e-mail]
3800 Barrett Drive, Raleigh, NC 27609
From: Dodson, John <John.Dodson @durhamnc.gov>
Sent: Tuesday, March 15, 2022 2:38 PM
To: Nicholson, Molly <[e-mail]>
Subject: [External] Re: WQ0032515 Turbidity Question
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
No not currently that project is currently underway and we're not currently pumping any water to Mist lake we're only
still giving it out as bulk distribution
Sent from my Verizon, Samsung Galaxy smartphone
Get Outlook for Android
From: Nicholson, Molly <[e-mail]>
Sent: Tuesday, March 15, 2022 2:36:49 PM
To: Dodson, John <[e-mail]>
Subject: WQ0032515 Turbidity Question
Good afternoon,

I am currently conducting NDMR reviews and noticed that the North Durham WRF permit requires turbidity monitoring
per event for PPI —002 until an on-line turbidimeter is installed, which should be prior to PPI003 — Mist Lake distribution.
I wanted to check in and find out if an on-line turbimeter has been installed or not at this time. Thank you.
Best,
Molly Nicholson
Environmental Specialist I
Raleigh Regional Office
N.C. Division of Water Resources
N.C. Department of Environmental Quality
984-365-9360 Cell
919-791-4240 Office
mollv.nicholson@ncdenr.¢ov
3800 Barrett Drive, Raleigh, NC 27609
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