NC0024325_Clean Water Act_20170118

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. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
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REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
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ATLANTA; GEORGIA 30303-8960
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JAN 18 2017
CERTIFIED MAIL 7016 0600 0000 3846 7985 RECEIVEDUDENWR
RETURN RECEIPT REQUESTED JAN 2 3 2017
City of Greensboro Permitting Section
Attn.: Mr. Steven Drew
Director, Water Resources Department
2602 South Elm -Eugene Street
P.O. Box 3136
Greensboro, North Carolina 27402-3136
Re: Information Request — Section 308 of the Clean Water Act
National Pollutant Discharge Elimination System Permit Nos.: NC0047384, NCO024325
Greensboro T.Z. Osborne Wastewater Treatment Plant
North Buffalo Creek Wastewater Treatment Plant
Dear Mr. Drew:
Pursuant to Section 308 of the Clean Water Act (CWA), 33 U.S.C. § 1318, the U.S.
Environmental Protection Agency hereby requests the City of Greensboro (the City) to provide
the information set forth in Enclosure A regarding the Wastewater Treatment Facilities
(WWTFs) noted above and their associated Wastewater Collection and Transmission Systems,
The City is required to respond to this information request within 30 days of its receipt of this
letter. The response should be directed to:
Ms. Laurie Jones
U.S. Environmental Protection Agency, Region 4
NPDES Permitting and Enforcement Branch
61 Forsyth Street, S.W.
Atlanta, Georgia 30303-8960
The EPA is issuing this information request to determine the City's progress in developing
and implementing written Management, Operations, and Maintenance programs and progress
towards eliminating SSOs as described in the Notice of Violation issued to the City on
February 3, 2014.
The City's response to this information request should specifically reference the particular
section and number of the request and should be organized for the purpose of clarity. In addition,
all information submitted must be accompanied by the following certification signed by a
responsible City official in accordance with 40 C.F.R. § 122.22:
Internet Address (URL) • http://www.epa.gov
Recycled/Recyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer)

L A
"I certify under penalty of law that this document and all attachments were prepared
under my direction or supervision in accordance with a system designed to assure that
qualified personnel properly gather and evaluate the information submitted. Based on my
inquiry of the person or persons who manage the system, or those persons directly
responsible for gathering the information, the information submitted is, to the best of my
knowledge and belief, true, accurate, and complete. I am aware that there are significant
penalties for submitting false information, including the possibility of fine and
imprisonment for knowing violations."
Failure to comply with this information request may result in enforcement proceedings under
Section 309 of the CWA, 33 U.S.C. § 1319, which could result in the judicial imposition of civil
or criminal penalties or the administrative imposition of civil penalties. In addition, there is
potential criminal liability for the falsification of any response to the requested information.
The City shall preserve until further notice all records (either written or electronic) which exist at
the time of receipt of this letter that relate to any of the matters set forth in this letter. The term
"records" shall be interpreted in the broadest sense to include information of every sort. The
response to this information request shall include assurance that these record protection
provisions were put in place, as required. No such records shall be disposed of until written
authorization is received from the Chief of the NPDES Permitting and Enforcement Branch at
the U.S. EPA, Region 4.
If you believe that any of the requested information constitutes confidential business
information, you may assert a confidentiality claim with respect to such information except for
effluent data. Further details, including how to make a business confidentiality claim, are found
in Enclosure B.
If you have questions regarding this notice and information request, please feel free to contact
Ms. Laurie Jones at [phone].
cerely,
Denisse D. Diaz, Chief
NPDES Permitting and Enforcement Branch
Water Protection Division
Enclosures (2)
cc: Mr. Jeff Poupart
North Carolina Department of Environmental Quality

ENCLOSURE A
SSO PROGRAM
City of Greensboro, North Carolina
Provide the following:
a. The size of the City's Sanitary Sewer Collection System (SSS) (linear feet or
miles);
b. A list of the pump stations in the SSS, including size (gpm), and indicate if back
up power is available and if it is adequate to fully operate the pump station;
C. A list of all constructed overflow points (any unpermitted constructed discharge
points) in the SSS (including pump stations) prior to the headworks of the City's
WWTFs;
d. The average design flow of the City's WWTFs;
e. The peak design flow of the City's WWTFs;
f. The annual average flow of the City's WWTFs; and
g. The population served by the City's WWTFs and their respective SSSS.
2. For purposes of this Information Request, a sanitary sewer overflow (SSO) is an
overflow, spill, release, or diversion of wastewater from the SSS. SSOs include overflows
or releases of wastewater that reach waters of the United States (U.S.); overflows or
releases of wastewater that do not reach waters of the U.S.; and wastewater backups into
buildings that are caused by blockages or flow conditions in a sanitary sewer other than a
building lateral. Wastewater backups into buildings caused by a blockage or other
malfunction of a building lateral that is privately owned is not an SSO.
Provide a listing of all SSOs that occurred from October 2013 to the present. For each
SSO provide the following:
a. Date(s) of the SSO;
b. Time (and Date if other than a. above) when the City was notified that the SSO
event occurred;
C. Time (and Date if other than a. above) when the City (or contractor) crew
responded to the SSO;
d. Time (and Date if other than a. above) when the SSO ceased;
e. Time (and Date if other than a. above) when corrective action was completed;
f. Location of the SSO, including source (pump station, manhole, etc.);
g. Ultimate destination of the SSO, such as surface waterbody (by name, if
available), storm drain leading to surface waterbody (by name, if available), dry
land, building, etc.;
h. Volume of the SSO;
i. Cause of the SSO such as grease, roots, other blockages, wet weather (infiltration
and inflow), loss of power at pump station, pump failure, etc.;
j. Corrective actions taken to stop the SSO; and
k. Corrective actions taken to prevent this or similar SSOs in the future.

If available, please provide the above information in a Microsoft compatible spreadsheet
format.
3. If the City has a formal written plan for responding to, addressing, and reporting SSOs
(i.e., a Sewer Overflow Response Plan ("SORP")), provide a copy of the plan.
4. Provide a copy of any additional City procedures not included in the SORP (as referenced
in Question 3 above) for the following activities:
a. Documenting SSOs;
b. Estimating SSO volume;
C. Identifying root causes of SSOs;
d. Containment and clean-up of SSOs, including any specific procedures addressing
backups into buildings caused by mainline problems;
e. Identifying wet weather related SSOs and reconnaissance of these during rain
events; and
f. All reporting of SSOs to the permitting authority, the State of North Carolina.
5. Provide the name of the person (or position title) responsible for each of the activities
identified in the City's SORP and/or listed in Question 4 above.

ENCLOSURE B
RIGHT TO ASSERT BUSINESS CONFIDENTIALITY CLAIMS
(40 C.F.R. Part 2)
Except for effluent data, you may, if you desire, assert a business confidentiality claim as to any
or all of the information that EPA is requesting from you. The EPA regulation relating to
business confidentiality claims is found at 40 C.F.R. Part 2.
If you assert such a claim for the requested information, EPA will only disclose the information
to the extent and under the procedures set out in the cited regulations. If no business
confidentiality claim accompanies the information, EPA may make the information available to
the public without any further notice to you.
40 C.F.R. §2.203(b). Method and time of asserting business confidentiality claim. A business
which is submitting information to EPA may assert a business confidentiality claim covering the
information by placing on (or attaching to) the information, at the time it is submitted to EPA, a
cover sheet, stamped or typed legend, or other suitable form of notice employing language such
as "trade secret," "proprietary," or "company confidential." Allegedly confidential portions of
otherwise non -confidential documents should be clearly identified by the business, and may be
submitted separately to facilitate identification and handling by EPA. If the business desires
confidential treatment only until a certain date or until the occurrence of a certain event, the
notice should so state.