WQCS00312_DV-2019-0150_20191231

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c,, CITY OF ARCHDALE
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� 307 BALFOUR DRIVE RECEIVED
P.O. BOX 14068 JAN 13 2020
st, _ ARCHDALE, NORTH CAROLINA 27263
NCDEQ/DWR/NPDES
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December 31, 2019
Mr. Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
450 West Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
Subject: Request for remission/mitigation of civil penalty
Case No. DV-2019-0150
SanitarySewer Overflows — August 2019
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Collection System Permit No. WQCS00312
Archdale Collection System
Randolph County
I acknowledge receipt of your Notice of Violation and Assessment of Civil Penalty
regarding an SSO event on August 8th, 2019. The NOV, dated 11/22/19, was received
12/13/19. The City of Archdale acknowledges and agrees that a violation occurred.
However, based on several factors outlined below, I ask that you consider
remission/mitigation of the penalty at this time.
Incident Number 201901343: Thursday, August 8, 2019
The City of Archdale believes that it takes a very proactive approach to the management
and maintenance of its sewer collection system. Based on the Justification for Remission
Request sheet, we ask that the following factors be taken into consideration:
(b) the violator promptly abated continuing environmental damage resulting from the
violation
(c) the violation was inadvertent or the result of an accident

(b) the violator promptly abated continuing environmental damage resulting from
the violation.
An observant citizen and an amazing response by the City's Public Works
Department minimized what could have been a much larger SSO event. The City
has worked to educate the public on how and where to report bad smells or
observed sewer overflows. Thankfully this citizen took action and called in a sewer
leak. The afterhours on-call supervisor responded to the scene and quickly
diagnosed the steps needed to repair an apparent leak on the 14" force main.
Most of the Public Works staff was called in to perform the repair work and handle
traffic control along Weant Road. City of High Point staff members were called to
assist as they do much of the maintenance on the nearby pump station.
Additionally, a contracted environmental vacuum service was brought in to
minimize spill volumes during the repair and had two trucks onsite throughout the
event.
Once the site was excavated, the problem became clear. There was a hole on the
bottom of the 14" pressurized line. This was problematic because the wastewater
was under pressure both when the pumps were running AND when they were off
due to the head pressure of more than 1.5 miles of force main uphill from the leak's
location (see included map).
On a side note, it is important to note that the City is currently constructing a $1.3M
parallel 16"force main so that maintenance can be completed in the future without
having to turn off the pumps. Additionally, 2 valves are included on this new line so
that head pressure can be limited when there are maintenance issues. There are no
such valves on the current 14"line.
With equipment and personnel onsite, staff moved forward with the repair. High
Point staff communicated with radios about the pump station levels while the
pumps were turned off. Archdale staff utilized a band (purchased proactively for
this exact possibility) to quickly make the needed repair in time to avoid a
secondary overflow at the pump station. One vacuum truck helped keep the
excavated site clean and remove the dirty soil; the other vacuum truck proved
unnecessary.
From there, clean soil was used for fill and hydrated lime was applied down the
ditch line where the overflow had occurred as set out in the Sewer Overflow
Response Plan. All in all, it was the City's view that this action was swiftly taken,
and a major overflow was avoided.
(c) the violation was inadvertent or the result of an accident
The SSO on August 8, 2019 was the result of a pipe failure along a pressurized 14"
sewer line. There was no prior indication that an issue existed on this below
ground line, and repairs were immediately completed. Staff take a proactive
approach to line and pump maintenance, but failure of this pipe was unexpected.
The redundancy afforded by the new 16" line will help minimize the potential for
SSO's and mitigate the size of any future SSO event.

In short, the City of Archdale acknowledges that a violation took place with Incident
Number 201901343; an SSO occurred. But quick action was taken to minimize the impact
and repair the pipe. The City takes the requirements of a sewer collection permit
seriously. A reorganization of the City's Public Works Department took place in January
2019. One of the driving reasons for this shift was a desire to have better accountability
for Archdale's Water Distribution and Sewer Collection permits. In addition to these
changes, several large expenditures are under contract/planned for the sewer system,
including:
• A $430,000 contract for electrical and safety improvements to our largest pump
station and add a permanent generator to another pump station.
• The $1.3M parallel force main along Weant Road.
• Annual pump station maintenance exceeding $100,000 for PM and pump repair.
• Annual pump replacements budgeted (10 pump stations owned/maintained by
Archdale).
With the above mitigating factors in mind, however, the City requests the $750 civil penalty
to be considered for remission/mitigation.
Should you have questions or need further information about this matter, please let me
know. I can be reached by telephone at [phone] or by email at
zholden(a�archdale-nc.qov.
Sincerely,
Zeb Holden
City Manager
Cc: Lloyd Wilson, Interim Public Works Director
Chris Davis, Sewer System Supervisor, ORC
Phillip Yates, Water System Supervisor

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
COUNTY OF RANDOLPH
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
) STIPULATION OF FACTS .r".
City of Archdale ) rr� ��
Archdale Collection System ) t:f .00
PERMIT NO. WQCS00312 ) CASE NO. DV-2019-0150
Having been assessed civil penalties totaling$875.72 for violation(s)as set forth in the assessment document of the Division
of Water Resources dated November 22,2019,the undersigned,desiring to seek remission of the civil penalty,does hereby
waive the right to an administrative hearing in the above-stated matter and does stipulate that the facts are as alleged in the
assessment document. The undersigned further understands that all evidence presented in support of remission of this civil
penalty must be submitted to the Director of the Division of Water Resources within thirty(30)days of receipt of the notice
of assessment. No new evidence in support of a remission request will be allowed after(30)days from the receipt of the
notice of assessment.
Y This the 3/i day of /t ,20 /7
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o��b1� SIGNATURE
ADDRESS
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TELEPHONE
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JUSTIFICATION FOR REMISSION REQUEST
Case Number: DV-2019-0150 County: Randolph
Assessed Party: City of Archdale
Permit No.: WQCS00312 Amount Assessed: $875.72
Please use this form when requesting remission of this civil penalty. You must also complete the "Request For Remission,
Waiver of Right to an Administrative Hearing, and Stipulation of Facts"form to request remission of this civil penalty.
You should attach any documents that you believe support your request and are necessary for the Director to consider in
evaluating your request for remission. Please be aware that a request for remission is limited to consideration of the five
factors listed below as they may relate to the reasonableness of the amount of the civil penalty assessed. Requesting
remission is not the proper procedure for contesting whether the violation(s)occurred or the accuracy of any of the factual
statements contained in the civil penalty assessment document. Pursuant to N.C.G.S. § 143B-282.1(c),remission of a civil
penalty may be granted only when one or more of the following five factors apply. Please check each factor that you
believe applies to your case and provide a detailed explanation,including copies of supporting documents,as to why the
factor applies(attach additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C.G.S. 143B-282.1(b)were wrongfully applied to the
detriment of the petitioner(the assessment factors are listed in the civil penalty assessment document);
J (b) the violator promptly abated continuing environmental damage resulting from the violation(i.e., explain the
steps that you took to correct the violation and prevent future occurrences);
(c) the violation was inadvertent or a result of an accident(i.e., explain why the violation was unavoidable or
something you could not prevent or prepare for);
(d) the violator had not been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary remedial actions (i.e., explain
how payment of the civil penalty will prevent you from performing the activities necessary to achieve
compliance).
EXPLANATION: /�t aSL Se( u 7e'✓1

ATTACHMENT A
City of Archdale
CASE NUMBER: DV-2019-0150
PERMIT NO: WQCS00312 REGION: Winston-Salem
FACILITY: Archdale Collection System COUNTY: Randolph
Other Violations
INCIDENT VIOLATION TOTAL VOLUME PENALTY
NUMBER DATE VIOLATION TYPE VIOLATION DESCRIPTION (GALLONS) AMOUNT
201901343 8/8/2019 CSO/SSO(Sewer Overflow) Discharge without valid permit 7,200 $750.00

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