NC0026051_NOD-2024-PC-0187 Response to Notice_20241101

Engineering and
CUPEnvironmental Services
Utilities Division
November 1, 2024
Ms. Vanessa Manuel
NCDEQ— Division of Water Resources
Attn: Raleigh Regional Office
VIA EMAIL
RE: Notice of Deficiency, NOD-2024-PC-0187
Dear Ms. Manuel:
This is in response, which is not required, to the Notice of Deficiency dated October 17, 2024.
The letter states Durham County is receiving the Notice of Deficiency due to an unauthorized
bypass of the grit classifier that violated NC General Statute 143-215.1(a)(1) and Part II Section
C. 4.(c) of NPDES Permit NCO026051.
I understand how this is considered a violation of the section of the NC General Statute referenced
because a nonpermitted discharge did occur. I am unsure how this is a violation of the section
referenced in NPDES Permit NCO026051. Per Part II Section C. 4.(c)(1)(A), a bypass is prohibited
unless there is no feasible alternative to the bypass. In this case, there was no feasible alternative
to the bypass as the grit classifier auger was clogged and could not be repaired until the bypass
occurred. By bypassing the system as quickly as possible, it limited the volume of wastewater
discharged into stormwater outfall 005. The system was on bypass for four hours or less, allowing
maintenance staff time to report to the site, deploy the equipment to the location, jet the line to
unclog the auger, and place the grit classifier back in service.
TWWTP is an exceptionally performing facility, reporting was conducted in a timely manner as
required, and repairs were made quickly. If you have any questions, contact me at
sbrixey(d)dconc. , og_v or 919-560-9034.
Sincerely,
Stephanie Brixey
Deputy Director of E&ES/POTW Director
Cc: Jay Gibson, Director of E&ES (via email)
Wade Shaw, Utilities Superintendent/ORC (via email)
5926 NC Highway 55 East, Durham, North Carolina 27713
[phone] 1 fax [phone] dconc.gov
Equal Employment/Affirmative Action Employer