WQCS00376_NOI_NOV2020DV0018_Response_20200117

EXECUTIVE DIRECTOR
Nicole Johnston
SECRETARY
Anita Darnell
TREASURER
Wayne Moore
January 17, 2020
Mr. Lou T. Snider
Assistant Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
North Carolina Division of Water Resources, NCDEQ
450 West Hanes Mill Road
Suite #300
Winston Salem, North Carolina 27105
Re: Notice of Violation & Intent to Issue Civil Penalty
Tracking No: NOV-2020-DV-0018
Sanitary Sewer Overflows — October 29, 2019
Collection System Permit No. WQCS00376
Yadkin Valley Sewer Authority WWTP
Surry County
Dear Mr. Snider:
CHAIRMAN
Wayne Moore
VICE-CHAIRMAN
Woody Faulk
BOARD OF DIRECTORS
Anita Darnell
Victor Varela
Tommy Wheeler
IJC Department of
Environmental Quality
Received
JAN 21 2020
Winston-Salem
Regional Office
I am responding to the Certified Mail Notice dated January 10, 2020, that we received on January 16,
2020, with regards to the "Notice of Violation & Intent to Issue Civil Penalty" for Tracking # NOV-2020-
DV-0018. With regards to the ten (10) business days' response that is required upon receipt of this
notice, we are submitting this written request to provide explanation of the noncompliance issues noted.
As for the incident cited as Incident Number 201901705 (1/2 of a mile from the Regional Pump Station
on Hwy 268), a Notice of Intent (NOD was provided as the DWR Action.
For this incident, please review the following information to explain what happened during the time of
this occurrence as well as corrective action that has been implemented to correct for this sanitary sewer
overflow:
1) Staff at the WWTP noticed a drop in flow around 8:30 am on Tuesday, October 291, 2019 and
immediately notified the YV SA Collections Staff due to a 90% drop in flow to the W WTP.
2) Upon receipt of this notification by the ORC at the W WTP, staff responded immediately by
heading out and monitoring the situation. At which time the Staff found the force main rupture
for the Regional Pump Station within 15 minutes at the property of Freddy Davis which is'/ of a
mile from the Regional Pump Station on Hwy 268. Throughout the day the flow remained at
"Low Level Flow."
500 NC Hwy 268 W — Elkin, NC 28621
Phone: [phone] — www.wsa.org — Fax: [phone]

3) Suez Staff contributed approximately 3 hours of their time contacting the following downstream
treatment plants:
a. King Water Plant;
b. Davie County Water Plant;
c. Northwest Water Plant.
4) Staff noticed the spill'/z of a mile from the Regional Pump Station on Hwy 268 started to spill at
8:30 am and continued until 11:00 am. The SSO was a direct result of pipe failure.
5) The volume of this SSO reported to NCDEQ was 15,000 gallons that discharged into the
Dutchman Creek. Total Volume of the spill was 27,000 gallons.
6) ***Please be advised that the YVSA Board and staff would like to stress that this SSO was
definitely inadvertent (or involuntary). It -is the intent of the YVSA staff to continue in a
multifaceted manner to address all sanitary sewer overflows and work towards preventing such
incidents in the future with regards to the Collections System.
I have attached a Cost Analysis sheet of including the emergency response time by staff as well as the
hauler used, Repair & Excavation, Couplings and Pipe, lime, straw and (2) types of gravel utilized to
address this SSO along with cost for publication into the local newspaper. [See `Cost Analysis for
10/29/19 SSO.] The total amount spent for regular pay plus overtime, hauler used, Repair & Excavation,
Couplings and Pipe, lime, straw, gravel, and publication affidavit was $19,013.29.]
***I have also attached the flow charts for the WWTP from Saturday, October 26's thru Thursday,
October 311. Our permitted flow for the W WTP is 1.8 MGD. Our normal flow is around 700,000
gallons per day. Flow for 10/26/19 was 0.801 MGD; by 10/27/19, the flow remained close to that at
0.907 MGD, and by 10/28/19 was 0.714 MGD. As for 10/29/19, our flow was 0.592 MGD; by 10/30/19,
the flow had increased to 1.878 MGD. By 10/31/19, the flow was 1.709 MGD. For the flows from
flowed to the WWTP (please see enclosed receipt tape with flow charts). I also attached a copy of the
press release showing publication of the SSO, which was published at a rate of $94.20.
For your convenience, we have also supplied you with an updated `YADICIN VALLEY SEWER
AUTHORITY PROJECT FUNDING SUMMARY' (from the time of YVSA's inception and
updated as of January 14, 2020). Please note that the total cost for all projects total $17,435,710.
(Furthermore, through the due diligence of staff and our engineering firm, we have been able to
successfully obtain $9,872,430 of this total amount in GRANT monies! The remaining amount total
for local matches and/or 0% loans is $7,563,280.] Anyways, this total funding amount of $17,435,710
has come around since the YVSA started operations on July 1, 2010. These projects included past
projects as well as more upcoming and `in process' projects such as these:
a. SW Elkin Collection System Improvements - $1,316,189 (COMPLETE);
b. Collection System Rehabilitation Project Phase II (Pump Stations) - $1,408,955
(COMPLETE);
c. Historic Jonesville TAG Grant - $50,000 (COMPLETE);
d. PGW Sewer Improvements - $2,702,375 (COMPLETE);
e. Sewer Extension for Weyerhaeuser - $1,170,637 (COMPLETE);
f. 2015 WWTP Upgrades - $2,396,944 (100% complete) — this includes a new clarifier
installation along with a new laboratory building;
g. 2017 Collection System Rehabilitation (RFQs — Request for Qualifications received by
Engineering firm) - $2,688,489 (47% complete);
h. 2017 WWTP Improvements (RFQs received by Engineering firm) - $1,321,322 (70%
complete);
i. North Bridge Street Sewer Repairs - $244,783 (COMPLETE) — this included multiple
repairs of service lines and manholes that were sources of I & I;
500 NC Hwy 268 W — Elkin, NC 28621
Phone: [phone] — www.yysa.org —Fax: [phone]

j. 2018 Collection System Rehabilitation Project - $1,643,010 —this will include more work
on addressing I & I within the Collections System (10% complete);
k. 2018 Pump Stations Rehabilitation Project - $1,051,620 — this will continue work on
upgrading pump stations within the Collections System. ( 10% complete);
1. High Priority Areas Collection System Project - $165,000 — this will include more smoke
testing and identification of problems areas in north Elkin. (50% complete);
in. Dutchman Creek Pump Station Elimination - $785,885 (4% complete);
n. Please note that this Summary does not include the grant and loan amount obtained to
create the YVSA through the Regionalization Project. These amounts total another
$6,275,000, for which $4,000,000 was grant and the remaining amount was from two (2)
loans- $1;000,000 at 2.55% interest and $1,275,000 at 2.9887% interest. [Refer to the
`YVSA ANALYSIS OF FY 2019 - 2020 DEBT SERVICE PAYMENTS' enclosed
attachment that provides the current balances for these two (2) loans entitled `Waste
Treatment Improvements (1)' and Waste Treatment Improvements (2)'.]
Now, the YVSA would like to provide that we are continuously improving our Collections System (as
well as upgrading our W WTP). I have also attached our most recent `Capital Improvement Plan — CIP'
(revised and updated this past June 11', 2019). Please note that there are nearly $16 million dollars still
needed for future rehabilitation, pump station upgrades, etc. still needed. We will continuously strive to
obtain grant and/or low interest loan funding to complete the items needed on this CIP.
Additionally, the following should be noted:
1. YVSA reports every SSO in accordance with its collection system permit.
2. YVSA has spent or has committed to spending over $17 million on capital projects to improve
the entire wastewater system.
3. YVSA has planned for an additional $11 million for near future capital projects (on the current
CIP).
4. Most of the pump stations have been rehabilitated, upgraded, or eliminated such that SSO's due
to equipment failures are now rare.
5. SSO's are now mainly attributable to I/. Much of the focus of current projects is on III reduction.
6. Efforts are still underway to find the sources of I/I, such as the current High Priority Areas AIA
project.
7. Due to the size of the task of identifying and addressing sources of 1/I, YVSA needs as much time
as the State can give it to accomplish this goal.
8. Current projects scheduled to be completed by end of 2021.
Now, please note that the YVSA Board and staff are very aware that the incidents noted above are a
serious infraction of our Collection System NPDES Permit No. WQCS00376. However, please be
advised that the YVSA Board and Staff would like to stress that these SSOs were definitely inadvertent
(or involuntary). It is the intent of the YVSA Staff to minimize such occurrences from happening;
however, there are some severe natural events (conditions) that are beyond our control.
We would also like to mention that the YVSA staff is working attentively to address any and all
corrective actions to prevent future SSOs in the Collections System as noted above. Please feel free to
contact Ms. Nicole Johnston (Executive Director of the YVSA) at 336-835-9819 if you need further
information.
Thank you for your assistance with this `NOV & Intent to Issue Civil Penalty' for the incidents cited
above. We look forward to hearing your response soon.
500 NC Hwy 268 W — Elkin, NC 28621
Phone: [phone] — www.wsa.ore — Fax: [phone]

Sincerely,
Nicole B. Johnston
YVSA Executive Director
A
Wayne Moore
Chairman YVSA Board
500 NC Hwy 268 W — Elkin, NC 28621
Phone: [phone] — www.yvsa.org — Fax: [phone]