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HomeMy WebLinkAboutWQCS00018_Report_20190520 Eden �'a��oon�B City of Eden �� EDEN P. o. Box 70 NORTH CAROLINA Eden,NC 27289 (336) 612-8055 FAX(336) 623-4041 2011 May 15, 2019 Ms. Linda Culpepper, Director D Division of Water Resources NC Department of Environment and Natural Resources MAY 2 0 2019 1601 Mail Service Center Raleigh, NC 27699 DIVISION OF WATER RESOURCES DIRECTOR'S OFFICE Semi-Annual Progress Report— Report#4 May 2019 `- EPA Administrative Order on Consent CWA-04-2017-4753 Dear Ms. Culpepper: Please accept the enclosed Semi-Annual Progress Report as required by our EPA Administrative Order on Consent CWA-04-2017-4753. This is our fourth submittal of this report, please advise of any issues in,its preparation or the information contained herein. Sincerely, Terry Shelton Public Utilities Director Office 336-612-8055 Email tshelton@edennc.us CC: Ms. Laurie Jones, EPA Region 4, Environmental Engineer Brad Corcoran, City Manager www.EdenNC.us and www.ExploreEdenNC.com City of Eden Eden Ill-America City EDEN P. o. Box 70 1NORTH CAROLINA Eden,NC 27289 (336) 612-8055 FAX(336) 623-4041 2011 May 15, 2019 Mary Jo Bragan, Chief Water Enforcement Branch Enforcement and Compliance Assurance Division Attn: Ms. Laurie Jones U. S. Environmental Protection Agency, Region 4 61 Forsyth Street, S. W. Atlanta, Georgia 30303-8960 Semi-Annual Progress Report— Report#4 May 2019 EPA Administrative Order on Consent CWA-04-2017-4753 Dear Ms. Jones, Please accept the enclosed Semi-Annual Progress Report as required by our Administrative Order on Consent CWA-04-2017-4753. As this is our fourth submittal of this report, please advise of any issues in its preparation or the information contained herein. Sincerely, Terry Shelto Public Utilities Director Office 336-612-8055 Email tsheltonCwedenrn_ CC: Linda Culpepper, Director Division of Water Resources NCDEQ Brad Corcoran, City Manager www.EdenNC.us and www.ExploreEdenNC.com City Eden of Eden P. O. Box 70 AFAMMIca EDEN Eden, NC 27289 NORTH CAROLINA 1� (336) 612-8055 FAX (336) 623-4041 2011 EPA Administrative Order on Consent-Semi-Annual Progress Report No. 4, May 2019 May 15, 2019 RE: EPA Administrative Order on Consent (Issued April 19, 2017) Docket No. CWA-04-2017-4753 Item IV. Documentation and Report Submittal 23. The City Shall Submit to the EPA Written Semi-Annual Progress Reports This Semi-Annual Report is submitted to the EPA by the City of Eden, North Carolina, to comply with the requirements of the Administrative Order on Consent. This report is prepared and submitted specifically to comply with Item IV. Paragraph 23. The City's primary plan to stop SSOs is based on the Wastewater Collection and Transmission Systems Remediation Plan (WCTSRP), as well as utilization of the Management, Operation and Maintenance programs (MOM) that developed during our first Administrative Order. The Remediation Plan contains detailed information of the places where Eden has had recurring SSOs and developed remediation measures in those locations to stop SSOs. The City of Eden was awarded $31.6 million in grants and loans from the North Carolina Department of Environment and Natural Resources, through the Division of Water Infrastructure (DWI) in the spring of 2017. The City is also providing match funding of over$2 million. All of this funding is designated to rehabilitate the City's aging sewer collection and treatment system to keep and maintain compliance with all current federal and state regulatory standards. The WCTSRP contains an aggressive five-year capital project plan to address issues in our collection and treatment system. Funding for the Remediation Plan projects and daily operational problems has been appropriated. We currently believe we have financing in place to complete the Remediation Plan projects based on current cost estimates. Administrative Order on Consent Item IV. Paragraph 23. The City shall begin to submit these Semi Annual Reports to the EPA within 30 days after the end of the first 6 months after the effective date of this Order on Consent and shall continue to submit such reports every 6 months thereafter until the submission of the Final Report as set forth below. The City shall submit to the EPA written semi-annual progress reports (Semi-Annual Reports)that includes: (a) A description of the actions, which have been taken toward achieving compliance with this Order on Consent during the previous 6 months; The City of Eden is taking the following actions to prevent, reduce and stop SSOs in our Collection System. The implementation or enhancement of our programs that we developed in our first Administrative Order is now part of routine operations. The MOM have been our daily guide to preventive work to avoid SSOs and establish stronger improved system maintenance programs. The WCSTRP is now our overall plan in our long-term approach to address our SSOs issues. Our Collection and Distribution crews have been working on point sources inflow and infiltration that occur in rain events and other illicit sources that are found during daily operations. Our crews had unprecedented rain induced opportunities during high flow periods to inspect and monitor inflow from multiple suspected point sources such as inflow into a manhole near the Railroad Pump Station, the Meadow Greens outfall, and the Long Street outfall. Problems found have been noted and scheduled for rehab or mitigated. The City of Eden Collection and Distribution (C&D) work crews have continued to identify and eliminated several significant sources of inflow and infiltration beyond what the Remediation Plan is designed to eliminate. They are doing smoke testing during dry weather and identify potential point sources of inflow to be checked during rainfall. The I&I crew continues to be aggressive in their investigative efforts, conducting flow monitoring and working during rain events, to identify additional inflow point sources. Record-breaking rain events from July 2018 through April 2019 have given the inspection crews an unprecedented opportunity to evaluate the success of previous repairs already completed as well as to find problem point sources previously unidentified. During 2018, rainfall across the City broke all previous records for rainfall in a single year as well as the State of North Carolina. The C&D repair crew has continued investigating sewer lines near the Railroad Pump Station located at 11540 NC Hwy 770, for additional sources of Inflow and Infiltration (I & 1) beyond what was found during our last AOC Semi-Annual Report. Flow monitoring during rain events indicates that there are still point sources of inflow to be found. In addition, during current rain events the crews are out looking for inflow sources both in and around the Long Street Outfall, Meadow Greens Pump Station Outfall, Covenant Branch Pump Station Outfall, and other areas that have shown higher than expected flows during rainfall events. During the last six months the current sewer Remediation Plan projects for the Administrative Order on Consent work on design is near complete and the bidding phase is beginning. Our project design submittals were divided into groups and phases. Because of the size of the projects in the Remediation Plan, the NC Division of Water Infrastructure (DWI) and the City agreed that the projects could be submitted for review and approved with multiple submittal dates. The dates are spread out from October 2018 through June of 2019 to avoid inundating DWI with so many projects to review at one time. The first project, the Mebane Bridge Digestion Improvements, has been bid and the bid has been approved by the Eden City Council. We are awaiting authorization by DWI to release funding to begin construction of the Mebane Bridge Digestion Improvements. The City and contractor are expected to execute a signed contract on or about June 1. Notice to proceed is expected to be given by mid- June 2019. This project will be the first to enter the construction phase and the rest of the projects are expected to bid out and construction contracts awarded by November 2019. This is a list of the major phases/groups the Projects of which the Remediation Plan is divided into: Grouping - Phase • 1 a — N/A-- Mebane Bridge Digestion Improvements • 1 b — N/A--Junction Basin Pump Station and Bridge Street Basin Pump Station Rehabilitation • 3 -- 10—System-wide Rainfall Dependent Inflow and Infiltration Reduction • 3 -- 11 — Bridge Street Basin Replacement and Rehabilitation • 3 -- 12 -- Dan River Outfall Upsize EPA Administrative Order on Consent- Semi-Annual Progress Report No. 4 2 of 12 pages • 2 -- 13—Glovenia/Spruce/Chestnut Street Sewer Relocation • 2 -- 14/15—Junction Pump Station Basin Replacement and Rehabilitation/Smith River Outfall Rehabilitation and Siphon Replacement • 2 -- 16— Kuder Street Basin Replacement and Rehabilitation • 2 -- 17— Dry Creek Basin Replacement and Rehabilitation • 1 b -- 18— Dogwood Drive and Fourth Street Pump Station Replacements • 1 b -- 19— Bear Slide Pump Station and Indian Hills Pump Station Permanent Standby Generator and Automatic Transfer Switch Installation All projects should be bidding no later than July and August with the issuance of construction contracts executed by November. An updated schedule is shown below in this progress report. This schedule meets the EPA Administrative Order on Consent Remediation Plan Projects Milestone Dates (revised by DWI on August 27, 2018). • Engineering Report Re-Submittal May 30, 2018 • Engineering Report Approval by Water Infrastructure August 15, 2018 • Submission of All Designs to NCDEQ, USACE, DWI, NCDOT, and Duke Energy (high voltage transmission crossings) May 1, 2019 • Submission of Design Revisions to NCDEQ, DWI and NCDOT June 1, 2019 • Receipt of Approvals (On or Around) July 15, 2019 • Advertisement July 15, 2019 • Bid Opening August 29, 2019 • Bid Evaluation and City Approval of Award September 17, 2019 • Bid Submission to DWI for Authority to Award September 24, 2019 • Authority to Award October 1, 2019 • Issue Construction Contracts November 4, 2019 There are three exceptions to the Submission of Designs based on mitigating issues, listed below: 1. Phase 10 -Warehouse Drive Sewer Relocation-Due to several challenges with the initially proposed route, unanticipated utility conflicts, reports of unmarked graves and less than minimum sewer slopes, the design is being adjusted to mitigate these challenges. 2. Phase 11 - Mill Branch Sewer—The original design is functional, but field conditions revealed a more desirable relocation option to eliminate existing sewer near a deteriorating culvert across Washington Street, which likely will fail or be replaced by NCDOT. In the original design, failure or replacement of the culvert would then require the new sewer to be relocated away from the culvert by NCDOT at the City's expense. The redesigned location should eliminate the need to relocate the sewer in the event of culvert failure or replacement. The City also identified a failing sewer adjacent to Mill Branch that needs to be included in the project design and bid with this work. Should bids be favorable, the City will request the opportunity to utilize available loan funds to fix this sewer. If funds are not available, the City will consider paying for this repair separately, but hopefully realizing some savings from economies of scale. EPA Administrative Order on Consent- Semi-Annual Progress Report No. 4 3 of 12 pages 3. Phase 14/15 - Smith River Outfall -The outfall relocation at Kings Highway will require an aerial crossing to avoid a conflict with a large culvert/conflict box. It also will entail two additional lateral relocations that were previously thought to be connected to a portion of this outfall that would remain in service. These laterals will now have to be rerouted to the proposed relocation section. WKD is on schedule to complete all design activities for the Remediation Plan projects and have all project work out to bid or awarded by August 1, 2019. WKD and their team have continued survey data collection, fieldwork to address data gaps, and design calculations for progressing design work to 100% complete. WKD and the City Staff are currently working to secure easements and all required permits for the construction. (b) An assessment of the effectiveness of such actions in eliminating SSOs; During the last six months of our semi-annual reporting period, design work on the sewer Remediation Plan projects for the Administrative Order on Consent is almost totally complete. Plan and Specifications for each group/phase of projects has been submitted to the North Carolina Division of Water Infrasructure and have been approved or are in stages of the approval process. Bidding of all Remediation Project work should be completed by November 2019. None of these physical repairs or construction in the Remediation Plan has been implemented to date. However, during this time the City of Eden Collection and Distribution work crews have identified and eliminated several significant sources of inflow and infiltration. The City's C&D crews have taken advantage of the continuing unusually heavy rainfall that has persisted for the last 12 months. Our I&I Crew has continually been working to find sources of Inflow and Infiltration during rainfall events of the last six months in places where any high flows were observed. Point sources that our crews are finding outside the scope of planned work in the current Remediation Plan are repaired or scheduled for rehab as they are found. Our 1/1 crew has been investigating the old National Textiles building that is now a warehouse located at 136 Gant Road. It is connected to the City of Eden's Railroad Pump Station located at 11540 NC Hwy 770. The I&I crew was trying to determine if the pond on the property was a source of inflow since it has an indirect connection to the sanitary sewer main. It was checked during a storm event and a manhole located in the rear parking lot was draining storm water into the sanitary sewer. This was a minor point source compared to what the City of Eden was hoping to find. Downstream from the Angleboard Plastics Recycling plant which is located at 11511 NC Hwy 770, there is a sanitary sewer main that is located in a stream that flows by the Railroad Pump Station into Dry Creek. This sewer main intersects with the sewer mains coming from the National Textiles Building. Sometime following the impact of Tropical Storm Michael on October 11, 2018, a manhole frame and cover were found to be missing and the rock from the railroad trestle abutment crossing the stream had been washed and had created a dam downstream raising the water level over 18 inches. After this occurred any significant rain event would raise the water level enough for the stream to flow directly into the open manhole. Also unknown at the time were two manholes downstream from the trestle, located beside the stream that had also been affected. The dam created by the torrent caused by Tropical Storm Michael now forced the flood waters from the stream to flow over top of these manholes and directly into the sanitary sewer leading into the pump station. All three manholes now EPA Administrative Order on Consent- Semi-Annual Progress Report No. 4 4 of 12 pages have new, watertight, bolt-down frames and covers while the dam created by the flood has been opened up to allow flow through. Further examination of the manholes and sewer pipe revealed inflow through apparent storm caused damage. We are currently working with FEMA representatives to obtain funding assistance to repair the damaged manholes and the sewer line and/or reroute the sewer line and manholes out of the creek due to the Hurricane Michael produced damaged. The repair work completed by the City's Collection and Distribution crews should have a significant impact on Inflow and Infiltration and should reduce the duration, volume and impact SSOs in the area near Railroad Pump Station and tributary to the Meadow Greens Pump Station. Until the remediation measures defined in the WCTSRP are constructed, performance of SSO reduction cannot be truly assessed. Until the Remediation Plan is fully implemented and construction measures defined in the WCTSRP are constructed, performance of SSO reduction cannot be fully assessed. No construction has begun yet on the Projects in the Remediation Plan to date. All WCTSRP Project Construction Contracts should be executed by November 1, 2019. (c) A list, which shall include the date and time, location, cause, ultimate destination, and volume of SSOs that occurred during the previous six(6) months; Overflow for Friday. October 26, 2018 Railroad Pump Station, 11540 NC Hwy 770, Eden, NC From 5:38 PM Friday, October 26, 2018 until 8:05 AM Saturday, October 27, 2018. Inflow and Infiltration. 8,000 Gallons to Dry Creek which flows into the Dan River. Overflows for Monday, November 12. 2018 Railroad Pump Station, 11540 NC Hwy 770, Eden, NC From 7:50 PM Monday, November 12, 2018 until 8:46 AM Tuesday, November 13, 2018. Inflow and Infiltration. 2,330 Gallons to Dry Creek which flows into the Dan River. Covenant Branch Pump Station, 699 Lake Street, Eden, NC From 8:33 PM Monday, November 12, 2018 until 6:01 AM Tuesday, November 13, 2018. Inflow and Infiltration 2,840 Gallons to Covenant Branch which flows into the Dan River. New Street Pump Station, 409 New Street, Eden, NC From 8:57 PM Monday, November 12, 2018 until 6:15 AM Tuesday, November 13, 2018. Inflow and Infiltration 1,104 Gallons to an unnamed stream which flows into the Dan River. Overflows for Thursday November 15 2018 Railroad Pump Station, 11540 NC Hwy 770, Eden, NC EPA Administrative Order on Consent- Semi-Annual Progress Report No. 4 5 of 12 pages From 9:40 AM Thursday, November 15, 2018 until 10:00 PM the same day. Inflow and Infiltration. 6,000 Gallons to Dry Creek which flows into the Dan River. Covenant Branch Pump Station, 699 Lake Street, Eden, NC From 10:40 AM Thursday, November 15, 2018 until 5:00 PM the same day. Inflow and Infiltration 4,000 Gallons to Covenant Branch which flows into the Dan River. Park Road at Tolbert Street, Eden, NC From 12:35 PM Thursday, November 15, 2018 until 1:10 PM the same day. Inflow and Infiltration 1,104 Gallons to an unnamed stream which flows into the Dan River. Overflow for Sunday, November 18, 2018 813 S Edgewood Road, Eden, NC From 9:30 AM Sunday, November 18, 2018, until 9:42 AM Monday, November 19, 2018. Pipe failure on a sanitary sewer force main 16,600 Gallons to Moir Branch which flows into the Dan River. Overflow for Sunday, November 19. 2018 1907 South Avenue, Eden, NC From 10:30 AM Monday, November 19, 2018, until 10:40 AM Monday, November 19, 2018. Blockage of an unknown type in sewer main 60 Gallons to unnamed stream which flows into the Dan River. Overflows for Thursday. December 13, 2018 999 S Van Buren Road, Eden, NC From 11:22 AM Thursday, December 13, 2018, until 1:53 PM the same day. Pipe failure on a sanitary sewer force main 300 Gallons to an unnamed stream which flows into the Dan River. Covenant Branch Pump Station, 699 Lake Street, Eden, NC From 5:20 PM Thursday, December 13, 2018 until 5:47 PM the same day. Pump Station offline to repair pipe failure on a sanitary sewer force main 250 Gallons to Covenant Branch which flows into the Dan River. Overflows for Friday. December 14, 2018 Railroad Pump Station, 11540 NC Hwy 770, Eden, NC From 7:25 PM Thursday, December 14, 2018 until 10:48 PM Friday, December 15, 2018. Inflow and Infiltration. 12,000 Gallons to Dry Creek which flows into the Dan River. EPA Administrative Order on Consent- Semi-Annual Progress Report No. 4 6 of 12 pages New Street Pump Station, 409 New Street, Eden, NC From 7:46 PM Thursday, December 14, 2018 until 10:35 PM Friday, December 15, 2018. Inflow and Infiltration 3,200 Gallons to an unnamed stream which flows into the Dan River. Overflows for Thursday, December 20 2018 Covenant Branch Pump Station, 699 Lake Street, Eden, NC From 6:57 PM Thursday, December 20, 2018 until 7:41 AM Friday, December 21, 2018. Inflow and Infiltration 7,000 Gallons to Covenant Branch which flows into the Dan River. Railroad Pump Station, 11540 NC Highway 770, Eden, NC From 7:25 PM Thursday, December 20, 2018 until 7:56 AM Friday, December 21, 2018. Inflow and Infiltration, severe natural condition 6,500 Gallons to Dry Creek which flows into the Dan River. Overflows for Friday. December 28. 2018 Railroad Pump Station, 11540 NC Highway 770, Eden, NC From 1:25 PM Friday, December 28, 2018 until 10:28 PM the same day. Inflow and Infiltration, severe natural condition 2,200 Gallons to Dry Creek which flows into the Dan River. New Street Pump Station, 409 New Street, Eden, NC From 1:47 PM Friday, December 28, 2018 until 10:13 PM the same day. Inflow and Infiltration, severe natural condition 1,240 Gallons to an unnamed stream which flows into the Dan River. Covenant Branch Pump Station, 699 Lake Street, Eden, NC From 3:45 PM Friday, December 28, 2018 until 6:21 PM the same day. Inflow and Infiltration, severe natural condition 160 Gallons to Covenant Branch which flows into the Dan River. Overflows for Saturday. February 23, 2019 Covenant Branch Pump Station, 699 Lake Street, Eden, NC From 10:13 AM Saturday, February 23, 2019 until 11:30 PM the same day. Inflow and Infiltration, severe natural condition 17,000 Gallons to Covenant Branch which flows into the Dan River Railroad Pump Station, 11540 NC Highway 770, Eden, NC From 10:30 AM Saturday, February 23, 2019 until 11:20 PM the same day. Inflow and Infiltration, severe natural condition 9,300 Gallons to Dry Creek which flows into the Dan River New Street Pump Station, 409 New Street, Eden, NC EPA Administrative Order on Consent- Semi-Annual Progress Report No. 4 7 of 12 pages From 10:41 AM Saturday, February 23, 2019 until 11:40 PM the same day. Inflow and Infiltration, severe natural condition 6,000 Gallons to an unnamed stream which flows into the Dan River. Overflows for Sunday. February 24. 2019 Behind 343 W Kings Highway, Eden, NC From 7:49 AM Sunday, February 24, 2019 until 3:30 AM Monday, February 25, 2019. Inflow and Infiltration, severe natural condition 20,000 Gallons to the Smith River. Inverted Siphon west of 636 Valley Drive, Eden, NC From 7:51 AM Sunday, February 24, 2019 until 3:30 AM Monday, February 25, 2019. Inflow and Infiltration, severe natural condition 50,000 Gallons to the Smith River. Matrimony Creek Greenway, 1323 Washington Street, Eden, NC From 1:27 AM Sunday, February 24, 2019 until 3:00 AM Monday, February 25, 2019. Inflow and Infiltration, severe natural condition 15,000 Gallons to Matrimony Creek which flows into the Dan River. Overflow for Thursday, February 28, 2019 South of 536 S Fieldcrest Road, Eden, NC From 4:00 PM Thursday, February 28, 2019 until 5:38 PM the same day. A blockage caused by roots and other debris in the sewer line 2000 Gallons to an unnamed stream which flows into the Dan River. Overflow for Friday. March 8, 2019 Southeast of the intersection of Rivercrest Drive and Brentwood Drive, Eden, NC From 5:00 PM Friday, March 8, 2019 until 6:00 PM the same day. A blockage caused by disposable wipes and other debris in the sewer line 250 Gallons to Matrimony Creek which flows into the Dan River. Overflow for Saturday. March 30, 2019 419 Johnsie Billie Harris Street, Eden, NC From 4:20 PM Saturday, March 30, 2019 until 5:15 PM the same day. A blockage caused by grease in the sewer line 7000 Gallons to an unnamed stream which flows into the Smith River. (d)An analysis of the cause of each such SSO; and (e) a description of the City's plan to address and prevent such SSOs from occurring in the future. Analyses and Description of Plans to Address or Prevention Solutions to Stop Future SSOs: EPA Administrative Order on Consent- Semi-Annual Progress Report No. 4 8 of 12 pages Railroad Pump Station overflows D) Analysis: It has been noted that Dry Creek, the stream that flows south of the pump station is at flood stage almost every time there is an overflow. The City has been trying to locate a manhole or other opening in the sewer system that may be allowing the stream to enter the sanitary sewer upstream from here. Manholes located along and in a tributary just west of the pump station may be the culprit and now they have been sealed. The WCTSRP also has identified several critical improvements in this basin with the common objective to significantly reduce 1/I. These improvements include: • Repairs within the collection system related to private and public sources of inflow consisting of cleanout, manhole lid/frame, and lateral defects. • Elimination of several indirect sources of inflow related to sewer main defects in close. • Numerous CIPPL installation of gravity sewer mains in streets, completion of the rehabilitation of the Dry Creek Outfall from Main Street to its terminus near Loparex and replacement of the Eisenhower Court Outfall between Eisenhower Court and Mill Avenue. These sewers are physically degraded containing Pipeline Assessment and Certification Program (PACP) Grade 3, 4 and 5 defects and are anticipated to be repaired utilizing open trench construction (approximately 1,530 LF) and CIPPL installation (14,000 LF). E) Proposed Solution: Complete improvements as defined in the WCTSRP. Covenant Branch Pump Station overflows(with the exception of December 13, 2018) D)Analysis: This pump station receives flows from three other basins including Dan River Pump Station, New Street Pump Station, and Weil McClain Pump Station. Any additional 1/1 from these basins compound the problem for Covenant Branch Pump Station. Ongoing investigations have identified a significant amount of 1/1 in the New Street Basin. The WCTSRP also has identified several repairs needed within the Covenant Branch Basin. Continued reduction of 1/1 will be critical in reducing the peak wet weather flows that this pump station has to handle. Prior analysis in the WCTSRP also revealed the challenges of increasing pump capacity at the Covenant Branch Pump Station without significant force main and pump upgrades. A more economical solution was identified to leverage existing and for the most part, underutilized force main capacity in the 24-inch force main that serves the Railroad and Industrial Park Pump Stations. An interconnection between the Covenant Branch force main and this 24-inch force main was installed to provide additional force main capacity during peak wet weather events. Hydraulic modeling confirmed that this interconnection would mitigate SSOs that have normally occurred during most frequent occurring storms (I-yearto 2-year reoccurrence interval). The existing 24-inch main is currently well below capacity given the significant reduction of industrial flow within the Railroad and Industrial Park basins. E) Proposed Solution: Reduce the volume of inflow from the other two contributing basins and complete the III repairs as identified in the WCTS SSES. Continued investigations via smoke tests are to be conducted in both the New Street and Dan River Pump Station Basins to identify any additional problems that may have emerged or re-appeared since the last studies were performed. New Street Pump Station, overflows EPA Administrative Order on Consent- Semi-Annual Progress Report No. 4 9 of 12 pages D)Analysis: It has been noted in the past that overflows would occur here with some storm events and not with others for no apparent rhyme or reason. The only difference that might be identified would be the intensity of the storm. Using a hydrant to flow water similarly to high intensity storm, a dye test was conducted and it was discovered that two sanitary sewer services were receiving inflow from the ditch being full. These are located at 305 and 311 New Street. E) Proposed Solution: The two sanitary sewer services previously identified were repaired on April 1st of this year. The sewer service at 305 New Street was especially bad. It is hoped that this will end the overflows at New Street Pump Station and have a positive impact on Covenant Branch Pump Station as well. Park Road at Tolbert Street, overflow from November 15, 2018 D)Analysis: This manhole located at this intersection floods sometimes during extra heavy rains. The sanitary sewer line upstream from this location is in need of rehabilitation. When the creek floods, 1/1 from the flood/rain water gets into the sewer line and excessive flow causes this manhole to overflow. E) Solution: The upstream and downstream sanitary sewer main is to be relined and some sections unsuitable for relining are to be replaced within the next three years so it will not take on water during flood and rain events. Overflow at 813 Edgewood Road from November 18, 2018 D)Analysis: This sanitary sewer overflow occurred when the force main for Covenant Branch Pump Station ruptured. This sewer force main has shown degradation from hydrogen sulfide gas over the past decade and some areas of higher elevation are worse than others due to liquids draining away and exposing the pipe surface to the gases. E) Proposed Solution: The City of Eden is planning avenues by which to replace this force main or possibly reroute the flow to another force main. Overflow for 1907 South Avenue Sunday, November 19, 2018 D)Analysis: This sanitary sewer overflow by a blockage in the sanitary sewer gravity main which backed up out of the cleanout for the sewer service. E) Proposed Solution: This is a fluke incident where flushing the sewer main to remove a blockage caused an overflow from the cleanout into a stream. Operators have been admonished to be more careful in order to prevent this from happening. Overflows for 999 S Van Buren Road and Covenant Branch Pump Station, December 13, 2018 D) Analysis: These sanitary sewer overflows occurred when the force main for Covenant Branch Pump Station ruptured. This sewer force main has shown degradation from hydrogen sulfide gas over the past decade and some areas of higher elevation are worse than others due to liquids draining away and exposing the pipe surface to the gases. Covenant Branch Pump Station was turned off to stop the flow on the force main for repair and that caused the small overflow at the pump station itself. EPA Administrative Order on Consent- Semi-Annual Progress Report No. 4 10 of 12 pages E) Proposed Solution: The City of Eden is planning avenues by which to replace this force main or possibly reroute the flow to another force main. The Meadow Greens and Covenant Branch Force Main Relief project was designed to allow switching over to the Railroad Pump Station Force Main during high flow periods or emergencies such as failure in the last two miles of the Covenant Branch Force Main. We plan to seek funding through loans or grants to replace the sections of the Covenant Branch Force Main that are subject to degradation by hydrogen sulfide gas as soon as possible. Overflow from manhole behind 343 W Kings Highway and at the Inverted Siphon west of 636 Valley Drive on February 24, 2019 D) Analysis: This overflow was caused by severe flooding following a major storm event that deposited over 2.5 inches of rain in less than eleven hours. The primary culprit for these SSOs was from the Dan River rising 23.5 feet, backing up into the Smith River and submerging the siphon inlet box, outlet box and numerous manholes that lay upstream of the siphon. The inflow from the Smith River filled the sewer lines and exceeded the hydraulic capacity of this outfall. This recent event reinforces the WCTSRP's recommendation of this outfall's and the siphon's rehabilitation to reduce 1/1 and improve the hydraulic capacity of the siphon and severely corroded cast iron sewers. E) Proposed Solution: Complete the remediation measures including: Improvements to the outfall between JN_MH-0296 and just upstream of the Junction Pump Station (JPS) and inclusive of the siphon requires immediate rehabilitation by replacement of several segments of sewer that are not suitable for lining (approximately 800 linear feet), installation of a new siphon that meets current standards for accessibility and routine cleaning, and approximately 5,300 linear feet of cured in place pipe lining. The inverted siphon at this location is in poor condition and is to be replaced with sealed service openings at a higher elevation to prevent inundation with flood water. Overflow from manhole located on Matrimony Creek Greenway, 1323 Washington Street on February 24, 2019 D)Analysis: This overflow was caused by severe flooding following a major storm event that deposited over 2.5 inches of rain in less than eleven hours. The primary culprit for these SSOs was from the Dan River rising 23.5 feet, backing up into Matrimony Creek and submerging numerous manholes that lay downstream of this location. The inflow from the Matrimony Creek filled the sewer lines and exceeded the hydraulic capacity of this outfall. E) Proposed Solution: Complete the remediation measures from the WCTSRP's recommendation including the improvements to the Lower Matrimony Creek Outfall and the Dan River Outfall. These include the replacement of sections of sanitary sewer lines, the replacement or repair of several manholes and extensive sanitary sewer pipe relining projects. Overflow from manhole located south of 536 S Fieldcrest Road on February 28, 2019 D)Analysis: This overflow was caused by a blockage that was thought to be roots by the operator on call that evening. E) Proposed Solution: This line has been thoroughly cleaned and it has been videoed to see if there are indeed roots in the line and none were found to be entering the line. The city will need to see if another blockage occurs in this area and try to determine the cause. EPA Administrative Order on Consent- Semi-Annual Progress Report No. 4 11 of 12 pages Overflow from manhole in pasture southeast of the intersection of Rivercrest Drive and Brentwood Drive on March 8, 2019 D) Analysis: This overflow was caused by a blockage of disposable wipes. E) Proposed Solution: There is only one known previous major source of disposable wipes upstream. It has been monitored for years and there have not been any disposable wipes found. The city will monitor manholes upstream from this location in order to find another source. Overflow from manhole at 419 Johnsie Billie Harris Street on March 30, 2019 D) Analysis: This overflow was caused by a blockage of grease. E) Proposed Solution: The City of Eden is monitoring a bakery upstream of the overflow to see if it is the source of the grease. In some SSO events listed above the (E) Solution, responses to correct these issues have been mentioned as forecoming in the near future. Most of these tied to pending design and formal bidding of the repairs as part of the Remediation Plan package that began in January of 2019 and is continuing to be bid through August of 2019. We believe that we are currently on track to complete our Remediation Plan work to eliminate SSOs by the end of the five-year term of the current AOC. The project closeout date for the Remediation Plan is February 2022. CERTIFICATION "I certify under the 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 " Terry Shelto Date Public Utilities Director City of Eden EPA Administrative Order on Consent- Semi-Annual Progress Report No. 4 12 of 12 pages