WQCS00075_NOV-2019-DV-0356 Response_20191002

CITY OF MARION
PUBLIC WORKS DEPARTMENT OFFICE OF THE
P.O. Drawer 700 PUBLIC WORKS DIRECTOR
Marion, NC 28752
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September 26, 2019
Mr. G. Landon Davidson, P.G., Regional Supervisor
Water Quality Regional Operations Section, NCDEQ
Asheville Regional Office
2090 U.S. Highway 70
Swannanoa, North Carolina 28778
Dear Mr. Davidson:
OCT - 2 2019
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Subject: Notice of Violation and Notice of
Intent to Assess Civil Penalty
Tracking #: NOV-2019-DV-0356
Marion Collection System
Permit No. WQCS00075
McDowell County
I am writing in response to your letter dated September 13, 2019 and received by the City of
Marion on September 20, 2019, requesting, within 15 business days of the receipt of the letter, an
explanation of a violation that occurred within the City of Marion's Wastewater Collection
System. The violation (incident number 201901404) was a sanitary sewer overflow (SSO) of
approximately 799 gallons to surface water that occurred on August 26, 2019.
In response to the Notice of Violation, the SSO was caused by the failure (horizontal crack) of a
PVC force main pipe located at the intersection of Forsythe Street and Virginia Road. The leak
was discovered by an employee of the Wastewater Treatment Plant (WWTP) while he was
performing a visual inspection of the force main, creek bank, and Clinchfield Lift Station. Said
inspection is performed daily, seven days per week, by WWTP personnel because of the close
proximity of the line to a creek.
Upon discovering the leak at 9:50 A.M. on 8/26/19, the employee immediately proceeded to turn
off the pumps at the lift station, thereby stopping the SSO and allowing only four minutes to pass
from the time the SSO was discovered until the time it was stopped. The cracked force main was
repaired by replacing a 26 inch section of PVC SDR-21 pipe with PVC C-900 pipe.
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As shown above, City personnel took remedial action very quickly with regard to the referenced
SSO. They stopped the SSO immediately upon discovery and repaired the broken pipe in a short
amount of time, with minimal wastewater discharge to the tributary water body. The City takes a
proactive approach to the maintenance of its collection system, as is evidenced by the daily
inspections that are performed on the force main alignment and creek. In addition, we are
currently considering plans to replace approximately 1,420 feet of the force main from
Clinchfield Lift Station, in an attempt to prevent future SSO's from the same line. Though this
line has not been the source of frequent SSO's (only two since the line was installed
approximately 9 years ago), we have identified two locations on the line that could potentially
become problematic. The 1,420 feet of line that we are considering for replacement includes
both of these locations.
For the reasons cited above, I respectfully request that a civil penalty not be issued for the
violation, in order to allow the City to continue investing funds in proactive collection system
maintenance and SSO prevention. Your consideration of this request is greatly appreciated. If
you have any further questions or need additional information, please contact me at (828) 652-
4224 or bsikeskmarionne.org.
Thank you in advance for your time and consideration.
Sincerely,
J. Brant Sikes
Public Works Director
cc: Bob Boyette, City Manager
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