NC0047597_NOV2017PC0541 Request for Resission_20170829

DURHAM
1869
CRY OF MEDICINE
CITY OF DURHAM
DEPARTMENT OF WATER MANAGEMENT
101 CITY HALL PLAZA • DURHAM, NC 27701
919-560-4381•FAX [phone]
August 29, 2017
Mr. S. Jay Zimmerman, Director
Division of Water Resources
NC Department of Environmental Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
RECEIVEDINCDEWWR
SEP 0 5 2017
Water Quality
Pe,rmiIiAing Section
RE: Notice of Violation NOV-2017-PC-0541 Issued August 11, 2017
Dear Mr. Zimmerman,
Administration
919-560-4381
Customer Billing Services
919-560-4412
Laboratory Services
919-560-4386
Plant Maintenance
919-560-4388
Utility Engineering
919-560-4381
Wastewater Treatment
North -919-560-4384
South -919-560-4386
Water Supply & Treatment
Williams - 919-560-4348
Brown - 919-560-4362
Water & Sewer Maintenance
919-560-4344
The City of Durham respectfully requests rescission of the Notice of Violation
referenced above which was issued for failure to submit electronic discharge
monitoring reports for the South Durham Water Reclamation Facility (WRF). The
notice states "per the terms or your NPDES permit, you were required to register
for, and begin using, the eDMR system by December 21, 2016." However, this is not
a requirement of the South Durham WRF's permit which is currently in effect.
The South Durham WRF's NPDES permit, number NC0047597, expired on April 30,
2016. The renewal application package was hand delivered on October 30, 2015
meeting the required 180 days prior to the expiration (receipt included). To date,
the permit has not been reissued. City staff has made several inquiries to DEQ staff
regarding the status of the permit renewal process; DEQ staff has consistently stated
to Durham staff that we should "keep operating in accordance with that permit until
a new permit is issued." As noted, the expired permit for South Durham WRF does
not require eDMR submittals.
In addition to the inquiries, City staff has interacted with DEQ staff from both the
Regional Office as well as DWR Central Office and at no time has the requirement for
eDMR been noted. The most recent onsite inspection by DEQ staff occurred on
February 1, 2017. In the follow-up letter dated February 20, 2017, DEQ Regional
Office staff reiterated "The subject permit became [effective] February 1, 2013 and
expired April 30, 2016. Please continue to operate under the last issued permit until
a new permit is issued" [number 1 in the attached letter]. Later in the same letter
[number 5] the letter states "Discharge Monitoring Reports (DMRs) for the period
September 2015 through December 2016 were reviewed for compliance
Durham — Where Great Things Happen

Page -2-
J Zimmerman
with permit limit and monitoring requirements. There were no violations. Lab
bench sheets were compared with the data submitted on the DMR for December
2016. No discrepancies were noted." No mention of the requirement to begin
electronic submittals was made during the site visit or in the follow-up letter. Please
note this letter was directed to the City of Durham's Public Works Director and
neither the facility ORC nor the director of Water Management was copied on this
letter.
The facility ORC/Superintendent, Charles Cocker, reached out to you by email on
August 16, 2017 when he received a copy of the violation forwarded to him from the
City Manager's office (please note that neither the facility ORC nor director of Water
Management was copied on the NOV). In your response, you stated that you would
forward to staff for review and response. On August 21, 2017 Brianna Young in DWR
responded referencing a) the EPA publication of the NPDES Electronic Reporting
Rule and b) a letter that had been directed to City of Durham Mayor Bell in a letter
dated May 25, 2016. She included a link to the referenced letter on the DEQ
website. The letter was never received by Department of Water Management staff
and, as noted regarding other correspondence; neither the facility ORC nor the
director of Water Management — or any other City staff - were copied on this very
important letter.
For the reasons noted above, we are requesting that the Notice of Violation be
rescinded. We are working to implement the eDMR process at the South Durham
WRF and ' anticipate submitting the August 2017 DMR electronically. We also
propose filing eDMRs for the months of November 2016 through July 2017 so that
the SDWRF data is electronically captured in your database.
Please feel free to contact either Vicki Westbrook (Assistant Director) at 919-560-
4381, ext. 35266 or email at [e-mail] or Charles Cocker (ORC
and SDWRF Superintendent) at 919-560-4386, ext. 35532 or email at
[e-mail] should you have questions about this issue.
Regards,
Donald F. Greeley, PE
Director
C: Thomas Bonfield, City Manager
William B. Ferguson, Deputy City Manager
Charles Cocker, ORC/Superintendent, South Durham WRF
Vicki Westbrook, Assistant Director, Water Management
Danny Smith, Regional Supervisor, DEQ/Raleigh Regional Office
Enclosures
Durham — Where Great Things Happen

Water Resources
ENVIRONMENTAL QUALITY
August 11, 2017
CERTIFIED MAIL 7015 0640 0007 9833 8739
RETURN RECEIPT REQUESTED
Thomas Bonfield, City Manager
City of Durham
101 City Hall Piz
Durham, NC 27701
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. JAY ZIMMERMAN
DG ector
Subject: Notice of Violation NOV-2017-PC-0541
Failure to Submit Electronic Discharge Monitoring Reports (eDMRs)
South Durham WRF
NPDES Permit NCO047597
Durham County
Dear Mr. Bonfield:
Per the terms of your NPDES permit, you were required to register for, and begin using, the eDMR system
by December 21, 2016. Our records indicate that as of the date of this letter, the subject facility has
registered, but is not submitting data electronically.
Failure to begin submitting reports electronically is a violation of the terms of your permit, subjecting you to
a possible assessment of civil penalties. In order to reduce the risk of receiving additional enforcement
action, you must complete your registration and submit your August 2017 DMR electronically on or before
October 31, 2017.
The Division has prepared a website devoted to all aspects of eDMR, including registration for its use,
obtaining an eDMR user account, and answers to frequently asked questions. You are encouraged to visit the
website at: http://deg.ne.aov/about/divisions/water-resources/edmr. Should you have further questions
regarding eDMR after reviewing the website's content, or have need of further assistance, you should contact
Brianna Young at 919-807-6333 or [e-mail].
Thank you for your cooperation in this matter.
//,Sin hely,
(r
S. Jay Zimmerman, P.G.
Director, Division of Water Resources
cc: -NPDES File
Central Files
Raleigh Regional Office — DWR WQ Regional Operations
State of North Carolina I Enviroinnental Quality I Water Resources
1617 Mail Service Center j Raleigh, North Carolina 27699-1617
919-707-9000

February 20, 2017
Marvin G. Williams, Director of Public Works
City of Durham
101 City Hall Plaza Ste. 3100
Durham, NC 27701
Subject: Compliance Evaluation Inspection
South Durham WRF
NPDES Permit NCO047597
Durham County
Dear Mr. Williams:
ROY COOPER
Go;�ei nor
MICHAEL S. REGAN
Secrelaq
S. JAY ZIMNIERMAN
Arerlor
On February 9, 2017, Mitch Hayes of the Raleigh Regional Office conducted a compliance evaluation
inspection on the subject facility. The assistance provided by Charles Cocker, Plant Superintendent, of the
facility was appreciated. Findings developed from the inspection are listed below:
1. The subject permit became February 1, 2013 and expired April 30, 2016. Please continue to
operate under the last issued permit until a new permit is issued.
2. The 20 MGD facility consists of the following units: two (2) mechanical influent bar screens
operated on timers; influent pump station with four (4) pumps; four (4) mechanical grit collectors;
four (4) primary settling basins; scum handling facilities with two (2) pumps; scum concentrator;
two (2) anoxic tanks; eight (8) aeration basins; chemical and polymer feed system; six (6)
secondary effluent clarifiers; three (3) return activated sludge pump stations; four (4) effluent
flocculation basins (not used); four (4) dual -media traveling bridge sandfilters; UV disinfection
facility with six (6) channels; six foot effluent Parshall flume with ultrasonic flow meter; effluent
post aeration; two (2) gravity belt sludge thickeners; two (2) anaerobic digesters with floating
covers; one (1) 50,000 cubic feet gas holder tank; two (2) aerobic digesters; two (2) blend tanks;
three (3) belt filter presses; two (2) reactor clarifiers; SCADA configured plant; thirty-six (36) sand
drying beds; on-site generators to provide back-up power.
3. At the time of inspection, two out of four influent pumps were in operation; one mechanical bar
screen and two grit chambers were being operated and two out of four primary clarifiers were in
use; the scum concentrator was operating normally; the two small and the two large aeration
basins were in use, the other basins were down for cleaning and due to low inflow; two out of
three RAS pump stations were being operated; two out of six secondary effluent clarifiers were
being operated due to low inflow; three out of four traveling bridge sandfilters were in operation,
one
'"NothftV Compal es_--;,
Division of Water Reso-urces, Raleigh Regiuial Office, Water Ouality Operations Section http:,/portal.nc(tenr.org/wet)twq/aps
t6'_'8 Mail Service Center, Raleigh, NC 27699-1628 Phone- [phone]
Location; 3800 Barrett Drive, Raleigh, NC 27609 Fax: [phone]

Water Resources
ENVIRONMENTAL QUALITY
May 25, 2016
William Bell
City of Durham
101 City Hall Plz
Durham, NC 27701-3329
Subject NPDES Electronic Reporting Requirements
South Durham WRF
NPDES Permit Number NCO047597
Dear NPDES Permittee
PAT MCCRORY
Cotiemoi
DONALD R VAN DER VAART
Sea eft v
S JAY ZIMMERMAN
Du ecto/
The U S Environmental Protection Agency (EPA) recently published the National Pollutant Discharge
Elimination System (NPDES) Electronic Reporting Rule The rule requires NPDES regulated facilities to
report information electronically, instead of filing written paper reports The rule does not change what
information is required from facilities It only changes the method by which information is provided (i e,
electronic ratherthan paper-based)
EPA is phasing in the requirements of the rule over a 5 -year period The two phases of the rule, and their
key milestones, are
• Phase 1—Starting on December 21, 2016, regulated entities that are required to submit Discharge
Monitoring Reports (DMRs) will begin submitting these reports electronically If you are currently
reporting your DMR data electronically using eDMR, then you simply need to continue reporting
in the same way as you are now The key change is that, starting on December 21, 2016,
electronic reporting of DMRs will be required, instead of voluntary
• Phase 2—Starting on December 21, 2020, regulated entities that are required to submit certain
other NPDES reports will begin submitting these reports electronically Reports covered in the
second phase include Notices of Intent to discharge in compliance with an NPDES general permit,
Sewer Overflow/Bypass Event Reports, and a number of other NPDES program reports
Upcoming NPDES Permit Reissuance
The NPDES Electronic Reporting Rule requires authorized NPDES programs to incorporate electronic
reporting requirements into NPDES permits beginning December 21, 2015 Under the new rule, the
electronic reporting process supersedes the paper reporting process outlined in your existing permit
According to our records, your NPDES permit is up for renewal If you have submitted your renewal
application, or you are in the process of doing so, and are awaiting your reissued NPDES permit, then this
letter serves to notify you that your reissued permit will include the new electronic reporting
requirements The reissued permit will require electronic reporting in place of paper-based reporting
State of North Carolina I Environmeatal Quality I Water Resources
1617 Mail Service Center I Raleigh, North Carolina 27699 1617
919 807 6300

Cocker, Charles
From: Belnick, Tom <tom.belnick@ncdenrgov>
Sent: Friday, July 08, 2016 10:56 AM
To: Cocker, Charles
Subject: RE: South Durham WRF Permit Renewal NCO047597
Mr Cocker:
This permit renewal has not been started yet. I am currently attempting to fill 3 vacant positions, and hopefully by end
of year we will be back to full staff. Your permit expired 4/30/2016, but you can keep operating in accordance with -that
permit until a new permit is issued. Let me know if you have any additional questions.
Tom Belnick
Supervisor
NPDES Complex Permitting Unit, DWR
North Carolina Department of Environmental Quality
919-807-6390 office
tom.belnick(a ncdenr.aov
512 North Salisbury Street
1617 Mail Service Center
Raleigh, NC 27669
!- ^Nothing Compares--,.,
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Cocker, Charles[mailto:[e-mail]_a.
Sent: Friday, July 08, 201610:09 AM
To: Belnick, Tom <[e-mail]>
Subject: South Durham WRF Permit Renewal NCO047597
Could you give me an update on the permit renewal for the South Durham WRF.
Thank you,
Charlie Cocker
Plant Superintendent, SOWRF
6605 Farrington Road
Chapel Hill, NC 27517
919-560-4386, ext 35532

Westbrook, Vicki
From: Cocker, Charles
Sent: Monday, August 21, 2017 3.39 PM
To: Greeley, Don, Stewart, Steven, Westbrook, Vicki
Cc: Hicks, Reginald, Gunter, Newman
Subject: FW South Durham WRF (NC0047597) Notice of Violation for eDMR
Here's the reply from the State on the NOV
We have contacted CITI to help us build the eDMR for South Durham. They expect to have the form completed before
mid-September. We should be able to meet the October 31, 2017 filing deadline for the August eDMR.
Charlie Cocker
Plant Superintendent, SDWRF
6605 Farrington Road
Chapel Hill, NC 27517
919-560-4386, ext 35532
From: Young, Breanna A[mailto:[e-mail]
Sent: Monday, August 21, 2017 1:07 PM
To: Cocker, Charles
Subject: South Durham WRF (NC0047597) Notice of Violation for eDMR
Good afternoon Mr. Cocker,
I have been informed that you have concerns about a Notice of Violation recently issued for the South Durham WRF
(NC0047597) for failing to submit data electronically within the eDMR system. The U.S EPA published the NPDES
Electronic Reporting Rule requiring that all facilities be registered for and reporting data electronically in the eDMR
system by December 21, 2016 A notice to this effect was sent to Mr. William Bell of the City of Durham in a letter dated
May 25, 2016. A copy of this letter is available for viewing at
http://edocs.deg nc.gov/WaterResources/0/doc/390782/Pagel.aspx. Information on the eDMR system and reporting
requirement, and how to register for and begin using eDMR, is available on the Division's website at
https:Hdeg.nc.gov/about/divisions/water-resources/edmr. If you require assistance in registering for or using the
eDMR system, please let me know.
Please let me know if you have any other questions or concerns.
Regards,
Brianna Young
Environmental Specialist
Division of Water Resources
N C Department of Environmental Quality
Office 919-807-6333
Breanna Young(�ncdenr gov
Mailing address
1617 Mail Service Center
Raleigh, NC 27699-1617

DURHAM
Administration
919-560-4381
Customer Billing Services
CITY OF DURHAM
919-S60-4412
r
DEPARTMENT OF WATER MANAGEMENT
Laboratory Services
101 CITY HALL PLAZA • DURHAM, NC 27701
919-560-4386
J'
919-560-4381 • FAX [phone]
Plant Maintenance
www.durhamnc.gov
919-560-4388
"
Regulatory Compliance
1 869
919-S60-4381
CRY OF MEDICINE
Utility Engineering
919-560-4381
Wastewater Treatment
North - 919- 560-4384
South -919-560-4386
Water Supply & Treatment
Williams - 919-560-4348
Brown - 919-560-4362
Water & Sewer Maintenance
919-560-4344
TO: NPDES Unit
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Date: October 30, 2015
From: Don, Greeley, P.E., P.L.S, Director
Subj: South Durham Water Reclamation Facility
NPDES Permit NCO047597
Permit Renewal Application
received the document addressed to
(please print NAME
Raleigh Regional Office on Friday, October 30, 2015.
�� %vet•_, (' ��`i , � �, � ,
Signature
f
Durham — Where Graaf Things Happen
Date