WQCSD0059_Response to Notice_20180829

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CITY OF SALUDA
NORTH CAROLINA
Wednesday, August 29, 2018
G.Landson Davidson, P.G., Regional Supervisor
Attn: Mikal Willmer
2090 U.S. 70 Highway
Swannanoa NC, 28778
Dear G. Landson Davidson,
I am in receipt of your letter dated August 21, 2018 with a subject line of Notice of Violation &
Intent to Issue Civil Penalty, NOV-2018-DV-0229. This letter is intended to provide additional
information to the self-reported Sanitary Sewer Overflows (SSO’s) 5-Day report. This additional
information is provided with the intent to provide evidence and justification as to why the City
of Saluda should not be assessed a civil penalty.
In May of 2018, Polk County including Saluda received significant rainfall. This rainfall created
flooding, landslides and significant damage across Polk County. Polk County unsuccessfully
sought federal disaster designation because of the damage. The City of Saluda received flooding
and landslides within the city limits. As a result of this the city found gravel and road base in
manholes located on the trunk line which services Main Street as well as large residential areas
in Saluda.
The City of Saluda worked with the City of Hendersonville to bring in cameras, jetters and their
vacuum truck to clear gravel found in three lines and one manhole. Other manholes and lines
were cleared by city staff using shovels and jetters. Lines were cleared of debris as far as could
reasonably be anticipated or suspected. On 7/24/2018, city staff discovered the manhole in this
SSO was overflowing sewage. The manhole is shown below as figure 1.
MAYOR
Fred Baisden
CITY MANAGER
Jonathan Cannon
COMMISSIONERS
Mark Oxtoby
Paul C. Marion
Stan Walker
Leon Morgan
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Figure 1

It is undetermined as to how long the manhole was overflowing. The location of the manhole is
not an area where public works or the public would necessarily see it on a daily basis. Public
works staff used a jetter to clear the line. The manhole was cleared with a shovel. The jetter
was used to clear the line upstream and downstream of the manhole. A camera was place in
the downstream line and discovered an unknown manhole. The discovered manhole is shown
in figure 2 below. It has already been buried again by the scrap plow of NCDOT. The City of
Saluda will need to work on exposing this manhole and keeping it exposed.
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Figure 2

The discovered manhole was buried under NCDOT gravel and roadbase from years of road
scraping and ditch maintenance. Public works then used the jetter to clear all debris from the
downstream lines from the clogged manhole all the way to the waste water treatment plant.
Gravel was collected from all downstream manholes and from the outlet of the lines into the
first collection chamber of the waste water treatment plant.
The type of debris found in the line corresponds with debris discovered during the major storm
events in May. This overflow is most likely a result of gravel and road base which inflowed into
the line because of the storm and damage on the line. The City of Saluda attempted efforts
both during the storm event and after the storm event to ensure that debris was completely
collected and found. Even so, the efforts did not collect all of the gravel and road base that
must have surely inflowed into the lines during the storm. The result two months later was a
plugged manhole and line with gravel and road base. The City of Saluda is confident that every
attempt possible has been made to remove debris from the lines and manholes.
During the cleanup of the lines on main street, two possible inflow points were discovered.
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Figure 3

One - is between the Whistle Stop and the railroad tracks. The point of inflow was located
underneath a large maple tree. The City had to work with the railroad and SPRINT to remove
the tree and repair the line. This was completed approximately two or three weeks prior to this
letter. Figure 3 above shows the repaired area.
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Figure 4

Two – is located within US 176 in front of the Whistle Stop. Possible inflow point two is shown
in figure 4 and is below the asphalt between the end of the asphalt patch and the centerline of
the road. NCDOT has a large hand stacked stone channel crossing underneath 176 and then
under the deck of the Whistle Stop. We have been monitoring this channel as the Whistle Stop
deck, while under construction, damaged the stone channel. The damage completly blocked
the channel and caused storm water overflows on the street and under the deck. NCDOT and
the Whistle Stop property owner debated as to responsibility of the repair work. Recently the
Whistle Stop property owner repaired the damage and water once again flows through a
controlled channel. A city sewer line which flows towards the manhole involved herein crosses
perpendicular to this rock channel. This sewer line received a repair two years ago in a location
downstream of this channel. The repair eliminated some compromised terra cota pipe. The line
has been camered more than once since the repair and has proven to be stable since the repair.
However, during this most recent inspection it was discovered the old line near the mentioned
rock storm water channel has settled. This creates a possible inflow point for gravel and road
base. I anticipate the now free flowing rock channel was damaged during the May storm and is
feeding storm water along the sewer line. This water movement more than likely has caused
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the settlement in the sewer line. I have been in contact with NCDOT. They have indicated the
desire to be involved as I work to open the street and work in proximity to this channel.
Surveyors have already collected data in this location. Planning is underway to make the repair
and scheduling with NCDOT for the partial closure of US 176 through downtown Saluda is yet to
be coordinated.
In conclusion, the SSO was not a result of willful neglect. The City of Saluda has worked to
maintain the lines and manholes involved both before, during and after the storm event which I
believe caused the overflow. In my thoughts, the point of civil penalties is to catch the attention
of the municipality and provide funds to a state agency if necessary to do remediation on behalf
of the municipality when they will not do it on their own. I believe the City of Saluda has proven
that any money available will be used to make repairs and correct sewer issues. A civil penalty
will only slow down the work that is being completed by the city to fix and prevent the
possibilities of SSO events.
Thank you for your consideration in the matter at hand and I look forward to hearing from you.
Please do not hesitate to contact me if you have any questions or comments.
Sincerely,
Jonathan Cannon
City Manager
Office: [phone]
Fax: [phone]
Email: [e-mail]
Website: www.cityofsaludanc.com
Address:
6 E. Main St.
PO Box 248
Saluda NC, 28773