WQCS00075_NOV-2020-DV-0037 Response_20200207

Water Quality Regional Operations
CITY OF MARION Asheville Regional Offlu
PUBLIC WORKS DEPARTMENT OFFICE OF THE
P.O. Drawer 700 PUBLIC WORKS DIRECTOR
Marion, NC 28752
February 4, 2020
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
Subject: Notice of Violation and Notice of
Intent to Assess Civil Penalty
Tracking #: NOV-2020-DV-0037
Marion Collection System
Permit No. WQCS00075
McDowell County
Dear Mr. Davidson:
I am writing in response to your letter dated January 28, 2020 and received by the City of Marion
on January 31, 2020, 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 202000178) was a sanitary sewer overflow (SSO) of
approximately 2,800 gallons to surface water that occurred on January 25, 2020.
In response to the Notice of Violation, the SSO was caused by the failure (horizontal crack) of a
PVC force main pipe located near 99 Forsythe Street. Upon notification, the Interim Utility
Maintenance Superintendent/Backup ORC responded immediately and turned off the pumps at
the Clinchfield Lift Station, thereby stopping the SSO. The pipe was repaired by installing a
wrap -around repair clamp.
As stated in a letter dated September 26, 2019, the City has been considering the replacement of
approximately 1,420 feet of the force main from Clinchfield Lift Station, in an attempt to prevent
future SSO's from the line. The occurrence of this most recent SSO has confirmed that the line
has become problematic, despite the fact that the line is only approximately nine years old.
Therefore, the City is aggressively moving forward with plans to replace at least 1,420 feet of the
line. A cost estimate is currently being prepared and should be complete by February 7, 2020.
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Once the cost estimate is generated, replacement of the line will be a top priority for the City.
Construction of the new line will start as soon as is reasonably possible.
In the meantime, City personnel will continue performing visual inspections of the force main,
creek bank, and lift station on a daily basis. This is a practice that has been performed since the
line was constructed approximately nine years ago and demonstrates the City's commitment to
preventing SSO's whenever possible.
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 bsikes a,marionnc.org.
Thank you in advance for your time and consideration
Sincerely,
J4wz��
. Brant Sikes
Public Works Director
cc: Bob Boyette, City Manager
Gary Cook, Interim Utility Maintenance Superintendent
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