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NORTH CAROLINA
WATER RESOURCES
Response to Notice of Violation & Intent to Issue Civil Penalty
(Tracking #: NOV-2020-DV-0561)
January 21, 2021
CERTIFIED MAIL
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-0561
Sanitary Sewer Overflows November 2020
Collection System Permit #: WQCS00021
Wilson Collection System
Wilson County
Dear Mr. Vinson:
This letter serves as written response to your letter dated December 16, 2020 as referenced in the
subject description above, but not received by this office until January 19, 2021. While Sanitary
Sewer Overflows (SSO's) did occur within the Wilson Collection System during November
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 Incidents 9 202002999 and ##202003000 that occurred on 11/12/2020, both of these
incidents were the result of an abnormal "severe natural condition". Approximately 7.3" of rain
was reported, and this resulted in severe 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. 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.
In regards to Incident # 202003296, we are not sure what the City or any other Permit holder can
do to stop the addition of rags and Flushable (non-flushable) wipes introduced into the sewer
collection system. The City of Wilson has an active education program and provides notices to
attempt to stop the addition of rags and non-flushable wipes into the system, but they continue to
be dumped by a careless public. We again placed door hangers in the areas upstream of this SSO
with the hopes of slowing future stop -ups in this area. We will also perform regular flushing with
our flusher trucks (we already flush 20-30% of our system, much more than the required 10%),
but rags and wipes are a severe problem for all collection systems. The City of Charleston, S.C.
has recently sued the wipes industry for bringing this plague to their system, and our education
material states plainly that only pee, poo, and toilet paper are supposed to go in the toilet or down
the drain.
For CY 2020, the WWTP treated 3.7 billion gallons of water. This loss of 6,750 gallons for all
three SSOs was approximately 0.00017% of the total volume transported by the collection
system for Calendar Year 2020. This was a bad year for us with double the normal rainfall, but
no industry performs with no incidents, and 99.99983% efficiency equals or exceeds every other
industry other than the airlines industry.
Additionally, the City of Wilson collection system is approximately 363 miles long. The City of
Wilson area received almost 71 inches of rain in 2020, the second highest amount in the past 85
years, and only missed the record by 2 inches. With eight SSO's for CY 2020, this equates to a
rate of 2.2 SSO's per year for every 100 miles of collection system piping. The City of Wilson's
rate of 2.2 is well below the national average of4.5 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. Eight SSOs per year per 50,000 people correlates to 16.0 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 Iast few years and the fact that no harm was caused downstream of these locations.
• SSO History
2015-16 1 SSO 250 gallons total
2016-17 8 SSOs 10,250 gallons total
2017-18 0 SSO
2018-19 4 SSOs 21,300 gallons total
Pipe Failure
All Severe Natural Event related
Hurricane Matthew (>10" Rain)
Other Rain event (>8" rain)
Severe Natural Event
Hurricane Florence

The City of Wilson makes every reasonable effort to manage, maintain, and operate its collection
system to prevent SSO's from occurring. Incident #202003296 was outside our control because
we cannot prevent rags from being dumped into the collection system from hospitals, nursing
homes and from childcare facilities that are all upstream of this site. 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 three
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 bnarksru;wilsonnc.or&
Sincerely,
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