WQCS00021_NOV-2020-DV-0314 Response_20200812

VC Dept of Environmental Quality
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WILSON
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WATER EESOMCES
Response to Notice of Violation & Intent to Issue Civil Penalty
(Tracking #: NOV-2020-DV-0314)
August 12, 2020
CERTIFIED MAIL #7018 1130 0001 3598 1811
RETURN RECEIPT REQUESTED
Mr. Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
NCDEQ-DWR-RRO
3800 Barrett Drive
Raleigh, NC 27809
Subject: Notice of Violation & Intent to Issue Civil Penalty
Tracking No: NOV-2020-DV-03I4
Sanitary Sewer Overflows — June 2020
Collection System Permit #: WQCS00021
Wilson Collection System
Wilson County
Dear Mr. Vinson:
AUG 17 2020
Neigh Regional Office
This letter serves as written response to your Ietter dated July 13, 2020 as referenced in the subject
description above, but not received by this office until August 6, 2020. While Sanitary Sewer
Overflows (SSO's) did occur within the Wilson Collection System during June 2020, the City of
Wilson has and continues to effectively manage, maintain, and operate its collection system to
prevent SSO's from occurring.
In regards to Incident # 2020018I3 that occurred on 61812020 at 4630 Ward Boulevard & Herring
Avenue, this SSO occurred due to the direct result of a pipe failure. However, the pipe failed
because it was damaged when the ditch bank it is located in gave way due to erosion, which caused
the pipe to rupture. The NC Department of Transportation maintains the ditch and their failure to
maintain the ditch from eroding along the roadway caused the undermining of the pipe. There is
no way the City could have anticipated that severe rainfall events would cause the bank on their
right of way to fail. However, the City of Wilson is working to prevent recurrence of a similar
situation by possibly relocating the sewer line away from the ditch bank.

The City of Wilson is working with Green Engineering of Wilson, NC on this project. Thus far,
Green Engineering has already performed a topographic and as -built survey of the existing sanitary
sewer system located between Gold and Harper Streets and Ward Boulevard. Construction
drawings for the relocation are 90% complete. The Fast -Track Application for Gravity Sewers,
Pump Stations and Force Mains, along with the Two Party Right of Way Encroachment Agreement
for Primary and Secondary Highways are pending submittal. The relocation of the sewer will also
require the acquisition of three (3) easements. The easement surveys have been performed and
contact with the property owners has been made. This has already cost the City in excess of
$20,000. A preliminary cost estimate has been prepared indicating a total project cost of
$322,554.00 including construction, design, permitting, Easement Acquisition, Administration
and Observation. This of course is a very expensive project during very tight budgetary times. This
project if approved will need to be part of the 2021-2022 budget as money is not available in the
current budget and grants are almost impossible to receive for larger, well -run systems.
In regards to Incidents # 202001915 and #202001916 that occurred on 6/17/2020, both of these
incidents occurred in the same neighborhood and were the result of an abnormal "severe natural
condition". ApproximateIy 4.3" of rain were reported and this resulted in localized flooding. The
sewer pipe in both of these areas runs along a local storm water stream that was outside its banks.
Floodwater from the stream was able to enter wastewater collection system piping and overload
the system, resulting in the reported SSO's. This was a first time occurrence of a SSO in this area.
As conditions permit, the City of Wilson will further investigate collection system piping in this
area and perform necessary rehabilitation work in an effort to prevent future SSO's from occurring.
Incident # 20200I917 that also occurred on 6/17/2020, was a result of the same abnormal "severe
natural condition" described above for Incidents # 202001915 and #202001916. Similarly, the
sewer pipe in this area also runs along a local storm water collection stream that was outside its
banks. Floodwater from the stream entered the wastewater collection system piping and
overloaded the capacity of system, resulting in the reported SSO. The City of Wilson will further
investigate collection system piping in this area and perform necessary rehabilitation work in an
effort to prevent future SSO's from occurring.
All three of the incidents that occurred on 6/17/2020 were the direct result of an abnormal "severe
natural condition". The total volume discharged from these three events was reported as 1,740
gallons. All four incidents combined total 6,740 gallons. In comparison, the WWTP treated 346
million gallons of water during June 2020. This loss of 6,740 gallons was only 0.002% of the
volume transported by the collection system during June 2020. For additional consideration, these
four reported spills were the only ones that occurred during the Fiscal Year 2019-2020. During
that time frame, the WWTP treated 3.3 billion gallons of water. This loss of 6,740 gallons was
only 0.0002% of the total volume transported by the collection system for Fiscal Year 2019-2020.
Additionally, the City of Wilson collection system is approximately 363 miles long. With a total
of only four SSO's for Fiscal Year 2019-2020, this equates to a rate of 1.1 SSO's per year for every
100 miles of collection system piping. The City of Wilson's rate of 1.1 is well below the national
average of 4.5 SSO's per year for every 100 miles of pipe. Further, the City of Wilson collection
system serves a population of approximately 50,000 people. Four SSOs per year per 50,000 people
correlates to 8.0 SSO's per year for every 100,000 people which is also well below the national
average of 28.2 SSO's per year for every 100,000 people. We also ask you to take into account
our excellent history of compliance over the last few years and the fact that no harm was caused
downstream of these locations.

City of Wilson SSO History
Fiscal Year
# of SSO's
Volume Released (gallons)
Cause
2015-2016
1
250
Pipe Failure
Pipe Failure & Severe Natural Events
2016-2017
8
20,350
• Hurricane Matthew (>10" Rain)
• Other Rain event (>8" rain)
2017-2018
0
0
None
Severe Natural Event
2018-2019
4
21,300
• Hurricane Florence
Average
3.25
7,950
The City of Wilson makes every reasonable effort to manage, maintain, and operate its collection
system to prevent SSO's from occurring. Incident #202001913 was outside our control because
maintenance of the ditch bank was not performed by NCDOT, and the City of Wilson could not
prevent erosion on a NCDOT ditch. The other three incidents were the result of an abnormal
"severe natural condition" which were also beyond the City of Wilson's control. Based upon the
information provided above, the City of Wilson does not believe that the Notice of Violation, nor
a Civil Penalty are warranted for these incidents. Additionally, the City of Wilson requests that
the Notice of Violation be rescinded for all four incidents. Issuing a civil penalty at this time
would only take away needed funds to complete the projects outlined above and limit funds for
our ongoing routine preventive maintenance.
Please contact us if you have any additional questions or concerns at [phone] or via email
at b arks,wilsonnc.or
Sincerely,
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Barry G. Parks
Director of Water Resources
City of Wilson
Cc: Harry Tyson, Deputy City Manager — City of Wilson
Todd Young, Water Infrastructure Manager — City of Wilson
Jimmy Pridgen, Water Reclamation Manager — City of Wilson