WQCS00064_NOV-2019-DV-0313 Response_20190823

WATER RESOURCES DEPARTMENT
NC Dept of Environmental Quality
August 23, 2019
Mr. Rick Bolich, L.G., Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
1628 Mail Service Center
Raleigh, NC 27699-1628
Re: Response to NOV from Water Resources Dated August 13, 2019
Tracking No.: NOV-2019-DV-0313
Sanitary Sewer Overflows- April, June 2019
Incident Numbers: 201900685, 201901102
Collection System Permit No. WQCS00064
Apex Collection System
Town of Apex, NC
Wake County
Dear Mr. Bolich:
AUS302019
Raleigh Regional Office
This letter is in response to the Notice of Violation/Notice of Intent to Enforce (NOVINOI) received on
August 13, 2019, from the North Carolina Department of Environmental Quality (NCDEQ) Division of
Water Resources (DWR) concerning sanitary sewer overflow (SSO) incident number 201900685 and SSO
incident number 201901102.
Incident Number 201900685
This SSO was reported to the Town of Apex (Town) Water Resources Department at approximately 2:00
PM on Sunday, April 7, 2019, and our maintenance staff was dispatched to the site located near 1204
Shakleton Drive in the Lexington Subdivision. Once on site, Town staff confirmed an active SSO coming
from manhole number SEMH808. The blockage was caused by "flushable" wipes and other debris that
had clogged the downstream gravity sewer line.
Upon discovery, the sewer line was promptly jetted from a downstream manhole to clear the clog and
restore normal flow. Town staff performed site remediation, including raking, bagging, and disposing of
solids. Based on the topography of the site, it appears that only a small percentage of the spill actually
made it into the stream. Lime and straw were applied to disinfect the area where the sewage had traveled
overland. Assessment of the site revealed that all aquatic species seemed to be unaffected as no "fish kill"
had occurred and no distressed species were seen at the discharge location or further downstream.
Staff conducted follow-up inspection of the sewer Iine where the clog occurred to ensure there was a smooth
transition into the manhole so that a remaining "snag" could not contribute to future build-up of debris. It
TOWN OFApEx
The Peak of Good Living
PO Box 25o, Apex, NC 27502 1 [phone] 1 www.apexnc.org

Mr. Rick Bolich
August 23, 2019
Page 2 of 3
should be noted that the town's routine maintenance of its system included CCTV inspection of 86,000 feet
and cleaning of 136,000 feet of gravity sewer last year to identify and correct such defects.
So-called flushable wipes are a major problem for all sanitary sewer systems. The town of Apex has been
consistent and diligent our efforts to mitigate this problem in our sewer system by educating our citizens
about the environmental and economic impacts of (non-) flushable wipes. This is evidenced by the enclosed
photo of the Water Resources Department's educational booth. This booth is set-up and manned at several
town festivals and events throughout the year (including the Peak Academy - a course offered to Apex
citizens on the inner -workings of town government) to promote environmental responsibility among our
citizens. We also provide educational materials via social media and an annual newsletter that is included
with our utility bill mailing. Additionally, targeted, door-to-door outreach is employed when "problem"
areas are discovered through routine sanitary sewer inspections.
The town had not experie►tced a SSO attribttted to wipes in over five years. We believe this is in no small
part due to our public education and outreach efforts. We take pride in these efforts; however, we intend
to further emphasize the "flushable" wipes problem moving forward.
Incident Number 201901102
This SSO was reported to the town by a citizen at 4:20 PM on Monday, June 24, 2019. Our maintenance
staff was discharged to the site where they quickly discovered the culprit of this backup was an illegal sewer
plug and began bypass pumping operations, set up confined -space entry equipment, and removed the lodged
plug to restore normal flow.
The SSO was exiting the system through a small gap between the locked manhole lid and ring, therefore
no solids were present in the overflow. Additionally, the overflow stream followed natural drainage
patterns of the site which led to a silt fence outlet that filtered the overflow stream. Downstream of the silt
fence outlet, the overflow stream collected in a low-lying area. Most of the spill appeared to be contained
to the low-lying area. All aquatic species seemed to be unaffected, no fish kill occurred, and no distressed
species were observed. To remediate the SSO after the sewer system was placed back in operation, the
Town pumped the volume that had collected in the low lying area, ensured there were no solids, and spread
lime to disinfect the area where the sewer had traveled overland.
Based on our investigation, it was determined that a contractor's wing -type sewer plug with no tag identifier
had been illegally placed into the sewer system by an outside party without a Town permit for an unknown
reason. The Town investigated and was unable to determine who had placed the plug in the manhole. Our
inspector's records show that a plug was installed with a permit prior to the SSO; however, the records also
show that the plug was removed on October 11, 2018. The plug that was found to have caused the SSO
had no identification tags and had not been properly secured, evidence that the plug had been installed
without the town's knowledge.
Going forward, the town will no longer allow the ttse of plrtgs in its sewer system The town is changing
its standards to only allow brick and mortar to block off new phases of construction until acceptance. We
expect this to be met with some resistance from the development community due to the relative ease of
using sewer plugs; however, we see this action as necessary in order to do everything in our power to
prevent future SSOs. AIthough this will not prevent all future illegal tampering with town -owned facilities,
we believe completely disallowing sewer plugs will be an effective deterrent, since any sewer plug on a
TOWN OF APEX
The Peak of Good Living
PO Box 250, Apex, NC 22go2 1 (919) 2,49-3400 1 www.apexnc.org

Mr. Rick Bolich
August 23, 2019
Page 3 of 3
construction site within the town of Apex will be known to be illegal. Contractors are being made aware
of our new policy in preconstruction meetings.
We trust the information provided herein verifies that the spills in question were not intentional, no money
was saved by non-compliance, there were no impacts to public health, and no fish kills or other wildlife
impacts were identified. The Town respectfully asks that the information in this letter be taken into account
when considering enforcement. If you have any questions, please feel free to contact me at [phone]
or ma .sue tone;aaexnc.ora�.
Sincerely,
Town of Apex
Marty tone, PE
Water Resources Director
Enclosures as stated.
c: Mr. Mitchell Hayes, N.C. Water Quality Section
Mr. Drew Havens, Manager, Town of Apex
Mr. David Hughes, Town of Apex
TOWN OF APEX
The Peak of Good Living
PO Box 25o, Apex, NC z7502 1 (919) 249-340o i www.apexnc.org