WQCS00012_Response to Notice_20180911

IMCapeftar
Public 911111V Authority
Stewardship. Sustainability. Service.
September 11, 2018
Morella Sanchez -King
Acting Regional Supervisor
Water Quality Regional Operations Section
Wilmington Regional Office
Division of Water Resources, NCDEQ
127 Cardinal Drive Extension
Wilmington, North Carolina 28405
Subject: Notice of Violation
Tracking Number: NOV-2018-DV-0246
Sanitary Sewer Overflows —July 2018
Collection System Permit No. WQCS00012
CFPUA Collection System
New Hanover County
Dear Ms. Sanchez -King:
Frank C. Styers, PE
Chief Operations Officer
235 Government Center Drive
Wilmington, NC 28403
910-332-6670
frau k.stve rs@cf pua.ore
am in receipt of your August 28, 2018 Notice of Violation which cited seven sanitary sewer
overflows that occurred during July 2018.
In July, Wilmington recorded its wettest summer on record since the National Weather Service
(NWS) began keeping records in 1874. As of July 31, the NWS reported 57.14 inches of rain had
fallen this year to date since January 1, 2018. A significant amount of this record rainfall
occurred during July leading up to and contributing to all the subject SSO incidents cited except
two, which were caused by a private contractor conducting sewer bypass pumping operations
as part of a private development project. CFPUA has taken proactive steps towards minimizing
the volume of sewer released from its collection system during each event. Steps such as
bypass pumping to increase system hydraulic capacity or conducting pump and haul operations
during a sanitary sewer overflow caused by excessive stormwater infiltration such as these
events reduces the volume of sewer released from the system.
Two SSOs noted are the result of a private contractor's activities related to a sewer bypass
operation being managed by the developer. Subsequent to these events CFPUA met with the
contractor and reinforced the significance and potential tangible and intangible costs

September 11, 2018
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that may result from these or future events. Supplemental details related to each SSO event
are provided below for your consideration.
July 17, 2018 — One Tree Hill Way PS No. 10
CFPUA staff responded to pump station #10 July 17, 2018 at 8:25 am after being notified of an
SSO that was occurring in Shirley Road Park. When staff arrived and observed conditions within
the station, several circuit breakers, including the main station disconnect, were tripped and
variable frequency drive #2 was found to have experienced a short circuit failure.
All alarm conditions are recorded in the alarm log in the station programmable logic controller.
The log showed that at approximately 11:49 pm on July 16, 2018, every alarm parameter on all
three drives were activated simultaneously, all electrical power was lost, and all pump
operation ceased, presumably as a result of lightning from a storm in the area.
The station is equipped with a permanently installed auxiliary generator, designed to start
automatically and provide electrical power necessary to keep the station operational when
commercial power is unavailable. During this event, the generator failed to start because one
of the two batteries that provide power to start the generator failed. The remaining battery
lacked both the voltage and sufficient cranking amps to start the generator. All standby
generators are tested on a monthly basis. The generator at this station had been previously
tested under a load only four days prior to this event. On July 13, 2018 the generator ran the
station for a period of approximately eight hours following a power outage in the area. There
was previously no reason to suspect or believe that the batteries were weak or had failed, as
the generator had started automatically and run the station without incident within less than
one week prior to this event.
The failed battery was replaced on the day the SSO occurred. Because of this SSO, a program
has been implemented to replace batteries which have reasonably reached the end of their
service life. Battery service life will be tracked through the CFPUA's computerized
maintenance and management system.
Operations staff are typically notified of abnormal conditions that occur at pump stations such
as high-water alarms, or pumps or generators or other equipment that fails to run through text
messages that are sent to their individual cell phones through the Authority's Supervisory
Control and Data Acquisition System (SCADA). The night prior to this event, the Information
Technology Department ran a six -hour process to transfer 24 servers from the Authority's
Disaster Recovery facility to its Primary Datacenter. Verification was made that the pump
station SCADA server was working. There is a file that requires 76 manual changes to be made
so that all the CFPUA's SCADA servers are pointing to the correct resources within the primary
datacenter. This file was incorrectly configured, which resulted in staff not receiving fault
alarms from the pump station. Because of this incident, the Information Technology
Department has developed a script that will execute all 76 changes without requiring manual
input, then log and report whether each change was successful. Additionally, there has been a

September 11, 2018
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revision to the Standard Operating Procedure so that Pump Station staff will be contacted after
confirmation of successful execution of the script, so the alarm system capability can be tested.
CFPUA is currently working to upgrade its entire SCADA software and hardware platform,
including the process the Pump Station server will use to handle alarms, which will increase the
SCADA system reliability. Pump station SCADA system upgrades are planned to be completed
in 2018, with anticipated costs in excess of $170,000.
July 18, 2018 — Water Street at Chestnut Street (River Place)
While conducting routine inspections of work being conducted for River Place, a private
development, a CFPUA Utility Inspector discovered a sanitary sewer overflow from an
unapproved sewer bypass operation. The private contractor had changed locations of the
approved bypass operation and installed a plug in the wrong line causing the sewer to back up
and overflow. CFPUA crews estimated that approximately 150 gallons of untreated sewer
reached a storm water catch basin that flows to the Cape Fear River. CFPUA inspectors
directed the contractor to relocate the sewer plug to a different line before resuming the
bypass operation.
July 24, 2018 — Manhole on Water Street at River Place Development
Barnhill Construction Company, the contractor for the River Place Development, notified CFPUA
of an ongoing SSO at the intersection of Water Street and Chestnut Street at 7:30 pm. CFPUA
staff responded to the site and determined the cause of the SSO was the result of inadequate
maintenance of the sewer bypass pumping operations being conducted by Barnhill
Construction. CFPUA determined that the suction piping screens had become clogged due to a
lack of maintenance by the contractor. Following an investigation and inspection of the
contractor's activities, the contractor was notified by CFPUA to cease construction operations
until deficiencies were corrected to provide for dependable and reliable bypass operations to
CFPUA's satisfaction.
Subsequent to the July 18, 2018 and July 24, 2018 SSO incidents that resulted as a result of
Barnhill Construction Company's negligence, CFPUA, the Developer and Project Manager for
Barnhill Construction met to review current and future construction sequencing and an
improved/more reliable sewer bypass operations plan. The contractor has made the
improvements to the bypass system. The project developer was notified that future incidents
of this nature were unacceptable and could result in damage claims against the developer.
July 25, 2018 — Manhole at 318 Parkway Drive
This incident resulted due to severe wet weather conditions from consecutive rain events over
several days that resulted in elevated groundwater conditions. Pump and haul operations were
conducted to minimize the volume of sewer released from the system and a bypass pumping
system was installed to provide temporary system hydraulic capacity until heavy rains and
elevated groundwater in the area subsided.

September 11, 2018
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July 29, 2018 — 3 manholes along Burnt Mill Outfall near Klein & 21St Street
This incident resulted due to severe wet weather conditions from consecutive rain events over
several days that resulted in elevated groundwater conditions. Pump and haul operations were
conducted.
July 31, 2018 — 5 locations along the Burnt Mill Creek Outfall
This incident resulted due to severe wet weather conditions from consecutive rain events over
several days that resulted in elevated groundwater conditions. Sanitary sewer crews were out
inspecting the pump stations and sewer system due to heavy rains and flooding when several
sanitary sewer overflows along Burnt Mill Creek were identified.
Pump and haul operations were conducted to minimize the volume of sewer spilled.
July 31, 2018-1100 block of Market Street
This incident occurred during a period of heavy rain and area flooding. Grease from residential
homes in the area also contributed to the incident. CFPUA crews conducted pump and haul
operations to minimize the spill volume by capturing 3,000 gallons and re-entering it back into
the sewer system. Educational materials related to fats, oils and grease were distributed to
area customers to prevent future similar occurrences. Historical records do not indicate
previous occurrences of grease identified in this area of sewer.
CFPUA strives for continual improvement in all aspects of its processes and procedures and
takes its commitment to environmental stewardship extremely serious and strives at all times
to minimize environmental damage.
I would be happy to provide additional information or discuss in further detail the sequence of
events that resulted in the above sanitary sewer overflows at your request.
Sincerely,
A45
Frank C. Styers, PE
Chief Operations Officer
Copy: Robert Daughtry, Collections System Superintendent
Beth Eckert, Environmental Management Director
Carel Vandermeyden, Director of Engineering