WQ0032515_NOV-2024-PC-0183 Response _20240416

WATER MANAGEMENT
CITY OF DURHAM
April 16, 2024
Mr. Michael Hall, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, DEQ
RE: Notice of Violation
NOV-2024-PC-0183; Permit No. WQ0032515; North Durham WRF Reclaim
Dear Mr. Hall,
APR 16 2024
On March 27, 2024, the City of Durham received the referenced Notice of Violation. The letter references a
missing Non -Discharge Monitoring Report (NDMR) for the North Durham Water Reclamation Facility (NDWRF)
for the month of November 2023. The City of Durham Department of Water Management (DWM) respectfully
requests a recension of the NOV for a missing NDMR.
In support of this request, DWM would like to provide the following information to mitigate the one-time
detection:
• The November 2023 NDMR was submitted electronically by NDWRF Superintendent Brian Merritt on
December 20, 2023. A copy of the NDMR has been included as an attachment to this letter.
• An email was sent on December 20, 2023 by Mr. Merritt to me confirming that he had submitted the
NDMR in which he included a screenshot of the report submittal. A copy of this email has been included
as an attachment to this letter.
• An email was sent on March 28, 2024 from Mr. Merritt to [e-mail] providing the
aforementioned documents as a response to NOV-2024-PC-0183. A copy of this email has been included
as an attachment to this letter.
NDWRF staff responded in an appropriate manner by completing and submitting the required NDMR prior to
the submittal due date. We feel that the documentation provided proves that and believe that NOV-2024-PC-
0183 should be rescinded.
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 Brain Merritt ([e-mail]) or myself ([e-mail]) if you have
any additional questions or concerns.

Page 2 of 2
Best regards,
11�Y_
John Young, PE
Assistant Director- Plant Operations and Maintenance
Department of Water Management
City of Durham
Enclosures:
APR 16 2024
1. NDWRF November 2023 Non -Discharge Monitoring Report
2. Email dated December 20,2023 sent by Brian Merritt to John Young confirming submittal of NDMR with
screenshot showing report submittal.
3. Email dated March 28,2024 sent by Brian Merritt to [e-mail] in response to NOV-2024-
PC-0183.

FORM: NDMR 05-16 NON -DISCHARGE MONITORING REPORT (NDMR) Page I of 3
eFacility
Name: North Durham WRIF
115111111111111111
,
13
m
,: „
oo���®�®�®�m•e����

.m
Z
O
0
cn
n
G)
m
9
O
Z
O
A
Z
M
m
v
O
M
z
0
3
A

FORM: NDMR 05-16 NON -DISCHARGE MONITORING REPORT (NDMR) Page 3 of 3
Sampling Person(s) Certified Laboratories
Name: North Durham Operations Staff Name: City of Durham Water/Wastewater-176
Name: Name:
Does all monitoring data and sampling frequencies meet the requirements in Attachment A of your permit? Ocamplent ❑Ion -compliant
If the facility is non -compliant, please explain in the space below the reason(s) the facility was not in compliance. Provide in your explanation the date(s) of the non-compliance and describe the corrective
action(s) taken. Attach additional sheets if necessary.
B1 Countable MF with <20 colonies. Reported value is estimated: calculated by totaling the counts on all filters and reported per 100 mL.
11/12/23 BOD NO Influent
VD Effluent G6, Of 1 1. All OC requirements were not met -
>_. The calculated seed correction is outside the 0.6 to 1.4 mg/L range and seed was inadvertently left out of one of the three required GGAs analyzed. GGA result was based on the average of the two with
3. All other QC criteria were met and the data is valid.
11/14/23
11/16/23
11/21/23
11/28/23
BOD NO Influent
NO Effluent G5 1. All QC requirements were not met
2. GGA recovery was out of range.
Operator in Responsible Charge (ORC) Certification 11 Permittee Certification
ORC: Brian Merritt
Certification No.: 993638
Grade: 4 Phone Number: 919-560-4384
Has the ORC changed since the previous NDMR? ❑yes Ono
Signature Date
By this signature. I certify that this report's accunate and complete to the best of my knowledge.
Permittee: City of Durham
Signing Official: John Young
Signing Official's Title: Assistant Director
Phone Number: 919-5604381
Signature
Permit Expiration: 1/31/2028
a0— a3
Date
I mdfy. ,order Wholly of laa. that this documem and all attactvmerts were prepared nailer my direction or supenah on In
aCCpdan a With a System designed to easWe that all QlRllrlad personnel primarily (fathered and evaluated the information
sudnilledeased on my inquay of the person or persons who manage the system, or hose persons directly resporsible for
gathering the adormalton, the information submitted is, to the best of my knpwledge and belief, True, accurale. and complete. I am
aware that there are significant Mies for subm'nting false information, Including the possibility of fires and imprisonment for
knowi g vlolatbns.
Mail Original and Two Copies to:
Division of Water Resources
Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617

Young,John
From: Merritt, Brian
Sent: Wednesday, December 20, 2023 11:51 AM
To: Jones, Tammy; Cocker, Charles
Cc: Hicks, Reginald; Young, John
Subject: RE: Signed November DENR Reports for Electronic Submission
The ND NDMR report has been submitted
ILI

QQ Atlas Loads Odober-June 2023. X M North Camlina(NO eDMR Repo X Sign In X', Thank you x }
F C'j Q f'I ht�l`s:/'eda<s.deq.ncgovf m.. �;io-.m'orort ._
e], ImPor[fa.M. ® ® Nexgen AM M RaplEldentRy S- Saea Talen6paae ® Lagin J!Aa,en © Slgnln Hub-Munrslardin... IndeaoflC\DEPARL. ® 192,168,60.208 'M NaMCamlina(NC7... d Alias Loafs O=be...
® Print Email

From: Jones, Tammy <[e-mail]>
Sent: Wednesday, December 20, 2023 11:13 AM
To: Cocker, Charles <[e-mail]>; Merritt, Brian <[e-mail]>
Cc: Hicks, Reginald <[e-mail]>; Young, John <[e-mail]>
Subject: RE: Signed November DENR Reports for Electronic Submission
Thank you, Charlie.
Tammy Jones
Administrative Specialist
Utility Engineering
City of Durham
Department of Water Management
1600 Mist Lake Drive
Durham, NC 27704
919-560-4381, ext.35216
Tammy.Jones@Durham NC.eov
CITY OF
DURHAM
From: Cocker, Charles <[e-mail]>
Sent: Wednesday, December 20, 2023 11:06 AM
To: Jones, Tammy <[e-mail]>; Merritt, Brian <[e-mail]>
Cc: Hicks, Reginald <[e-mail]>; Young, John <[e-mail]>
Subject: Re: Signed November DENR Reports for Electronic Submission
I have submitted the South Durham report.
-Charlie
From: Jones, Tammy <[e-mail]>
Sent: Wednesday, December 20, 2023 10:38 AM
To: Cocker, Charles <[e-mail]>; Merritt, Brian <[e-mail]>
Cc: Hicks, Reginald <[e-mail]>; Young, John <[e-mail]>
Subject: Signed November DENR Reports for Electronic Submission
Good Morning Charlie and Brian,
Here are the links to the signed November 2023 NDMRs for South Durham WRF and North Durham WRF.
I am also attaching PDFs of them in case the links don't work.
North Durham Report:
ND 11-2023 NDMR
South Durham Report:
SD 11-2023 NDMR
Please let me know when they have been submitted electronically so I can mark them sent in the file at the front desk.
If there is anything else you need, please let me know.
yy

Thank you,
Tammy Jones
Administrative Specialist
Utility Engineering
City of Durham
Department of Water Management
1600 Mist Lake Drive
Durham, NC 27704
919-560-4381, ext.35216
Tammv.Jonesl@Durham NC.eov
CITY OF
DURHAM

Young,John
From:
Merritt, Brian
Sent:
Thursday, March 28, 2024 9:17 AM
To:
[e-mail]
Cc:
Young, John; Hicks, Reginald
Subject:
North Durham NDMR-November 2023
Attachments:
RE: Signed November DENR Reports for Electronic Submission; 11-23 N Durham
NDMR.pdf
Mr. Hall
Our office received a Notice of Violation for the November 2023 NDMR, permit number: WQ0032515. The NOV stated
the report was missing and not submitted. Attached you will find a confirmation email that was sent internally along
with the PDF for the NDMR report. Can you please verify the records and let me know if the NOV was sent in error and if
any further action is needed from us.
Thank you for your assistance.
Briam Marritt
JNteriat Swpariwtandamf
NortR Dw"m WRF
O: [phone]
Q [phone]
1