WQCS00220_NOI_NOV2020DV0342_Response_20200819

Town of Jefferson
ALDERMEN
302 East Main Street
MAYOR
Cathy Ballou
PO Box 67
Bluferd Eldreth
Charles Caudill
Jefferson, NC 28640
TOWN MANAGER
Mark Johnston
Cathy L. Howell
Wes Williams
Phone [phone]
FINANCE OFFICER
Max Yates
Fax [phone]
Anna M. Brooks
Tax ID # 56-0896625
August 19, 2020
I
NC Department of
Environmental Quality
Received
Mr. Lon T.
Snider, Regional Supervisor
�O�
Water Quality Regional Operations Section r ,
AUG 2 0 2020
Winston-Salem Regional Office
Winston-Salem
Division of
Water Resources, NCDEQ
Regional Office ff
SUBJECT:
NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Tracking No.: NOV-2020-DV-0342
Sanitary Sewer Overflows — May 2020
Collection System Permit No. WQCS00220
LAS � �{ F I C H E
Jefferson Collection System
Ashe County
Dear Mr. Snider:
This is the response to the Notice of Violation listed above.
In regard to the 5-day report for the SSO of May 21, 2020, our Water Resources Director, Mr.
Tim Church informs me that a hard copy of the 5-day report was sent to the Winston-Salem
Regional Office on June 8 by Certified Mail. Mr. Church had attempted to report the incident by
phone to the Regional Office on May 22, but was unable to speak with anyone in person due to
a number of the staff working from home because of COVID 19 restrictions. He was able to
contact Mr. Gary Hudson on his cell phone that day. A follow-up email was also sent that day.
Mr. Church had misplaced his login information and was unable to access the BIMS network.
The Town of Jefferson appreciates the assistance and patience given by Mr. Ron Boone to
provide a new password to us. Mr. Church has recorded the BIMS login information in his
Collection System file and saved it on his computer at the wastewater plant and is prepared to
respond appropriately to future events.
The tracking number on the Certified Mail receipt indicates the hard copy of the 5-day report
for the May 2151 SSO was received at the Winston-Salem Regional Office on Wednesday June
10, 2020. Please see the cover letter of the 5-day report that includes the Certified Mail receipt
and tracking information sheet. The 5-day report is also included within this correspondence.

In regard to the sanitary sewer overflow, the Town of Jefferson is preparing to mitigate the
introduction of inflow and infiltration into the sanitary sewer system from future storm events
by undertaking measures including, but not limited to the following procedures.
• The budget for 20-21 includes $20,000.00 allocated toward the location and removal of
inflow and infiltration sources.
• A video inspection camera and recording unit has been purchased by the Town. The
OUTPOST system by Envirosight is capable of viewing 200 feet into a sewer line and
video recording the integrity of the pipe.
• The Town will be increasing the use of its smoke testing equipment. Because the use of
the video system and the smoke testing process is somewhat labor intensive, the public
works maintenance crew will be assisting Mr. Church and his operator in this work. The
North Carolina Rural Water Association has also expressed their willingness to commit
equipment and manpower to this project.
• A mapping system has been completed by Mr. Church that segregates the Town's
sanitary sewer collection system into four mini -systems, each with one manhole being
identified as a collection point for the entire flow of that sub -system. As funding allows
the Town hopes to temporarily place flow/velocity meters in each of those manholes to
totalize flows during heavy rainfall events in order to evaluate areas that are
contributing the greater amounts of inflow and infiltration.
• Manhole # 197 on North Main Street has been identified as a definite indicator of
serious 1/1 at some point upstream. It will serve as the initial point of remediation.
• Oversight of the Collection System duties required by Permit WQCS00220 will now be
shared on a greater level with the Town of Jefferson Public Works crew. This group
maintains a more active and frequent presence in the collection system and therefore
should be made more knowledgeable and responsible toward recognizing and removing
threats to the integrity of its components.
If you have comments or require additional information please contact Mr. Tim Church at the
letterhead address, by email at [e-mail], or at [phone].
Respectfully,
G�,t �- Q
Cathy Howell
Jefferson Town Manager

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Town of Jefferson Watw 1Ze4~ce,,k
1233 Highway 16 South P.O. Box 67 Jefferson, NC 28640 336.246.2165
dune 8-2020_:j
NC Department of Environment and Natural Resources
Division of Water Resources
450 West Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
ATTN: Mr. Ron Boone
SUBJECT: 5-day Report for SSO
Town of Jefferson, WQCS00220
Mr. Boone,
I have enclosed a copy of the 5-day SSO report for an event that occurred on May 21, 2020.
Thank you very much for the assistance you have provided that will now allow me to log into
the BIMS network. I have recorded my login information where it can easily be accessed should
future SSO events occur. I apologize for the difficulty I have had in the past with the login
process. I am confident I will be prepared for the next event.
If you have any questions or require additional information please call me at [phone] or
by email at [e-mail].
Respectfully,
��,ULLLl.G1.J
Tim Church, Water Resources Director
Town of Jefferson
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State of Nortb Carolina
Department of Environment and Natural Resources
R
r Division of Water Resources
Collection System Sanitary Sewer Overflow Reporting Form
Division of Water Resources Form CS-SSO
PART I:
This form shall be submitted to the appropriate DWR Regional Office within five business days of the first knowledge of the
sanitary sewer overflow (SSO).
Permit Number: WQCS00220 (WQCS# if active, otherwise use WOCSD#)
Facility: Jefferson WWTP Incident #: I Owner: Town of Jefferson
Region: Winston-Salem City: Jefferson County: Ashe
Source of SSO (check applicable): ® Sanitary Sewer ❑ Pump Station / Lift Station
SPECIFIC location of the SSO (be consistent in description from past reports or documentation - i.e. Pump
Station 6, Manhole at Westall & Bragg Street, etc.): Manhole at entrance
Manhole #: 2
Latitude (degrees/minute/second): 36 24 37 Longitude (degrees/minute/second): S 1 25 37
Incident Started Dt: 521,20 Time: 1100 Incident End Dt: 5!2120 Time: 1200
(mm-dd-yyyy) (hh:mm) AM/PM (mm-dd-yyyy) (hNmm) AM/PM
Estimated volume of the SSO: 3000 gallons Estimated Duration (round to nearest hour): I hour(S)
Describe how the volume was determined: Estimated
Weather conditions during the SSO event: Heave rain over a 4 day period
Did the SSO reach surface waters? ® Yes ❑ No ❑ Unknown
Volume reaching surface waters: 3000 gallons Surface water name:
Did the SSO result in a fish kill? ❑ Yes ® No ❑ Unknown
If Yes, what 1s the estimated number of fish killed?
SPECIFIC cause(s) of the SSO:
®Severe Natural Conditions ❑ Grease []Roots ®Inflow & Infiltration
❑Pump Station Equipment Failure ❑ Power Outage []Vandalism ❑ Debris in line []Pipe Failure (Break)
❑Other (Please explain in Part 11)
24-hour verbal notification (name of person contacted):
®DWR ❑Emergency Management Date (mm-dd-yyy): 522/20 Time: (hh:mm AM/PM): 9:00 am
Per G.S 143-215 1C(b), the owner or operator of any wastewater collection system shall:
In the event of a discharge of 1,000 gallons or more of untreated wastewater to the surface waters of the State, issue
a press release to all print and electronic news media that provide general coverage in the county where the
discharge occurred setting out the details of the discharge. The press release shall be issued within 24 hours after
the owner or operator has determined that the discharge has reached surface waters of the State.
In the event of a discharge of 15,000 gallons or more of untreated wastewater to the surface waters of the State,
publish a notice of the discharge in a newspaper having general circulation in the county in which the discharge
occurs and In each county downstream from the point of discharge that is significantly affected by the discharge. The
Regional Office shall determine which counties are significantly affected by the discharge and shall approve the form
and content of the notice and the newspapers in which the notice is published.
WHETHER OF NOT PART II IS COMPLETED, A SIGNATURE IS REQUIRED SEE PAGE 13
Forth CS-SSO Page I

In order to submit a claim for justification of an SSO, you must use Part II of form CS-SSO with additional documentation as
necessary. DWR staff will review the justification claim and determine if enforcement action is appropriate.
PART It:
ANSWER THE FOLLOWING QUESTIONS FOR EACH RELATED CAUSE CHECKED IN PART I OF THIS FORM AND
INCLUDE THE APPROPRIATE DOCUMENTATION AS REQUIRED OR DESIRED
COMPLETE ONLY THOSE SECTONS PERTAINING TO THE CAUSE OF THE S$O AS CHECKED IN PART I
(In the check boxes below, NA = Not Applicable and NE = Not Evaluated)
A HARDCOPY OF THIS FORM SHOULD BE SUBMITTED TO THE APPROPRIATE DWR REGIONAL OFFICE UNLESS
IS HAS BEEN SUBMITTED ELECTRONICALLY THROUGH THE ONLINE REPORTING SYSTEM
Form CS-SSO
I'agc 2

Severe Natural Conditions (hurricane tornado etc.)
Describe the "severe natural condition" in detail: Over 10 inches rainfall in the area. 4.5 inches in 24 hours.
How much advance warning did you have and what actions were taken in preparation for the event? 24 hour weather
forecast.
Comments:
MOM CS-SSO
Pagc 3

Inflow and Infiltration
Are you under an SOC (Special Order by Consent) or do you have a schedule ❑ Yes ® No DNA ❑ NE
in any permit that addresses I/1?
Explain if Yes'
What corrective actions have been taken to reduce or eliminate I & I related overflows this spill location
within the last year' armholes upstream have been repaired.
Has there been any flow studies to determine IA problems in the
collection system at the SSO location?
If Yes, when was the study completed and what actions did h recommend?
Has the line been smoke tested or videoed within the past year?
If Yes, when and what actions are necessary and the status of such actions:
Are there UI related projects in your Capital Improvement Plan?
❑ Yes © No DNA ❑ NE
❑ Yes ® No DNA ❑ NE
®Yes ❑ No DNA ❑ NE
If Yes, explain 520,000.00 is budgeted annually for FI repair The most recent repair involved polymer sealing of
manhole interiors.
Have there been any grant or loan applications for I/I reduction projects?
If Yes, explain:
Do you suspect any major sources of inflow or cross connections
with storm sewers?
If Yes, explain -
Have all lines contacting surface waters in the SSO location and upstream
been inspected recently?
If Yes, explain
❑ Yes ® No DNA ❑ NE
❑ Yes ® No DNA ❑ NE
© Yes ❑ No DNA ❑ NE
What other corrective actions are planned to prevent future 1/1 related SSOs at this location? The Town plans to continue
searching for and removing sources of Ill as they are located A mobile camera unit has been purchased to video sewer
mains.
Comments:
Form CS-SSO
Page 6

System Visitation
ORC
Backup
Name: Tim Church
Certification Number. 13756
Dale visited: 5/21/20
Time visited: 0730
How was the SSO remediated (i./e. Stopped and cleaned up)?
® Yes
❑ Yes
the SSO ended as the storm subsided. Debris was manually removed from the site.
As a representative for the responsible party I certify that the information contained in this report is Irue and accurate to the
best of my knowledge.
Person submitting claim Tim Church
Date: 6/8r20
Signature: C' l `1! U� Title: l Air I1( gnlly-C.CS I )hrfi
Telephone Number: [phone]
Any additional information desired to be submitted should be sent to the appropriate Division Regional Office within five
business days of first knowledge of the SSO with reference to the incident number (the incident number is only generated
when electronic entry of this form is completed. if used).
Form CS-SSO
Page 13

liOY COOPER
WCHAEU REGAIN
3ecretdry:
S:.DANEL SMITH
Mecca
CERTIFIED MAIL 7018 1130 0000 1612 7819
RETURN RECEIPT REQUESTED
August 10, 2020
Cathy Howell
Town of Jefferson
302 E Main St
Jefferson, NC 28640
SUBJECT: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Tracking No.: NOV-2020-DV-0342
Sanitary Sewer Overflows - May 2020
Collection System Permit No. WQCS00220
Jefferson Collection System
Ashe County
Dear Permittee:
A review has been conducted of the self -reported Sanitary Sewer Overflows (SSO's) 5-Day Report/s submitted by
Town of Jefferson. The Division's Winston-Salem Regional Office concludes that the Town of Jefferson violated
Permit Condition I (2) of Permit No. WQCS00220 by failing to effectively manage, maintain, and operate their
collection system so that there is no SSO (Sanitary Sewer Overflow) to the land or surface waters and the SSO
constituted making an outlet to waters of the State for purposes of G.S, 143-215.1(a)(1), for which a permit is
required by G.S. 143-215.1.
The Winston-Salem Regional Office is providing the Town of Jefferson an opportunity to provide evidence and
justification as to why the Town of Jefferson should not be assessed a civil penalty for the violation(s) that are
summarized below:
Total Vol
Total Surface
Incident Start Duration Vol Water
Number Date (Mins) Location Cause (Gals) (Gals) DWR Action
202001568 5/21/2020 US HWY 16 Severe Natural Notice of Intent
Condition
f

:n
Additionally, the Winston-Salem regional o>iiee never received a 5-day report for this SSO, which is
why the volume columns in the above table are blank. Please note that the Town's failure to submit a
timely 5-day report is a separate violation of your collection system permit. A 5-day report should be
submitted along with your response to this notice.
This Notice of Violation / Notice of Intent to Enforce (NOV/NOI) is being issued for the noted violation. Pursuant
to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) may be assessed
against any person who violates or fails to act in accordance with the terms, conditions, or requirements of any
permit issued pursuant to G.S. 143-215.1.
This office requests that you respond to this Notice, in writing, within 10 business days of its
receipt. In your response, you should address the causes of non-compliance, remedial actions, and all other
actions taken to prevent the recurrence of similar situations. The response to this correspondence will be
considered in this process. Enforcement decisions will also be based on volume spilled, volume reaching surface
waters, duration and gravity, impacts to public health, fish kills or recreational area closures. Other factors
considered in determining the amount of the civil penalty are the violator's history of non-compliance, the cost of
rectifying the damage, whether the spill was intentional and whether money was saved by non-compliance.
If you have any questions, please do not hesitate to contact Ron Boone with the Water Quality Section in the
Winston-Salem Regional Office at 336-776-9800 or via email at [e-mail].
Sincerely,
Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
Cc: Winston-Salem Regional Office - WQS File
Central Files, Water Quality Section
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