WQCS00057_NOI2020DV0207_Response_20200514

City of Thomasville
Thomasville, North Carolina 27360
Lon T. Snider
Regional Supervisor
WQROS, WSRO, DWQ, NCDEQ
450 W. Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
RE: Intent to Enforce Letter Response
Incident Number 202000021
\)U\M- VOO `
-as\O- r1-. -1
Utilities Department
u&l;iarLrliE:iit «? RCB-20210128-Recommend NFA due to
Environmental O.uafity
ecewed relatively small amount and conditions
beyond their control.
8 2020
Winston-Salem
Regional 0-M...
Lon-NFA
14 May 2020
Dear Mr. Snider,
In response to the letter of Intent to Enforce of 07 May 2020 the City of Thomasville asks that
the following be taken into consideration:
Regarding incident # 202000021: CIPP lining of the Hanks Branch outfall main line had been.
mostly completed as part of the Hank's Branch Phase 1 Rehabilitation when this incident occurred. This
rehabilitation work has served not only to reduce infiltration, but also to reduce exfiltration from the
main Hanks Branch Outfall pipe. Upstream of the CIPP lined outfall pipe rainfall runoff entered the
collection system through multiple means such as leaky pipe joints, broken taps and cleanouts, and
leaking manholes during an extreme precipitation event. The increased volume of the main outfall for
transmitting flow to the pump station (due to the cleaning which removed a large amount of debris)
combined with the better sealed system led to reduced exfiltration of the I&I water and overwhelmed
the pump station.
This event consisted of two smaller events at the same location that were combined, but
covered the time span between 16:30 and 20:45. Enclosed are 2 charts reflecting hourly rainfall totals
as measured at 2 monitoring points upstream of the event site. Both charts reflect a large amount of
precipitation between 13:00 and 19:00 on the date of the event.
The total volume of wastewater spilled was nominal, much of the water that spilled was rain
water, and there were no known impacts to public health, fish kills, or recreational area closures as a
result. There is a second phase of this project planned that has been under reviewed by DWR and DWI
staff for quite some time now, delaying its eventual implementation. Phase 2 of the Hank's Branch
Outfall Rehabilitation will address several upstream sections of laterals that discharge into the Hanks
Branch main outfall that have I&I issues by a combination of pipe replacement and CIPP lining where
appropriate. It is anticipated that Hanks Branch Outfall Phase 2 will have the desired effect of reducing
I&I and thus reducing the chances of further overflows at the Northside pump station.
The City of Thomasville asks that the circumstances surrounding this event, the lack of
demonstrable environmental impact, as well as the ongoing efforts to upgrade all aspects of the
sanitary sewer collection system be taken into account with any enforcement action considered.
Sincerely,
CC: Kelly Craver
Morgan Huffman
Public Services Director
City of Thomasville
336-475-4220

Golf Course PS
Rainfall from 1/1/2020 to 1/5/2020
Device Time Rainfall Amount (inches)
1/3/2020 0:00 0.09
1/3/2020 1:00 0.01
1/3/2020 2:00 0.02
1/3/2020 3:00 0
1/3/2020 4:00 0
1/3/2020 5:00 0.01
1/3/2020 6:00 0
1/3/2020 7:00 0
1/3/2020 8:00 0
1/3/2020 9:00 0
1/3/2020 10:00 0
1/3/2020 11:00 0
1/3/2020 12:00 0.02
1/3/2020 13:00 0.18';
1/3/2020 14:00 0.481
1/3/2020 15:00 0.07
1/3/2020 16:00 0.09
1/3/2020 17:00. 0.01
1/3/2020 18:00 0.14
1/3/2020 19:00 0.10j
1/3/2020 20:00 0
1/3/2020 21:00 0.01
1/3/2020 22:00 0
1/3/2020 23:00 0
Total:: 1.23

Ivey Creek PS
Rainfall from 1/1/2020 to 1/5/2020
Device Time Rainfall Amount (inches)
1/3/2020 0:00 0.03
1/3/2020 1:00 0.02
1/3/2020 2:00 0.01
1/3/2020 3:00 0
1/3/2020 4:00 0.01
1/3/2020 5:00 0
1/3/2020 6:00 0
1/3/2020 7:00 0
1/3/2020 8:00 0
1/3/2020 9:00 0
1/3/2020 10:00 0
1/3/2020 11:00 0
1/3/2020 12:00 0.02
1/3/2020 13:00 0.23
1/3/2020 14:00 0.44
1/3/2020 15:00 0.09
1/3/2020 16:00 0.06
1/3/2020 17:00 0.01
1/3/2020 18:00 0.18
1/3/2020 19:00 0.05
1/3/2020 20:00 0
1/3/2020 21:00 0.01
1/3/2020 22:00 0
1/3/2020 23:00 0
Total: 1.16

1cckz00`i
- O D
City of Thomasville
Thomasville, North Carolina 27360
Utilities Department
RCB-20210128-Recommend minimal CPA due to relatively large
amount but conditions beyond their control.
Lon T. Snider
Regional Supervisor
WQROS, WSRO, DWR, NCDEQ
450 W. Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
14 May 2020
RE: Notice of Intent Letter Response
Incident Number 202000168
Dear Mr. Snider,
In response to the letter of Notice of Intent of 07 May 2020 the City of Thomasville asks that
the following be taken into consideration:
Regarding incident # 202000168: Rainfall on the date of the event was over 1.5" throughout the
area as reflected in the attached graph of precipitation throughout January, 2020. We are aware of and
have continued to pursue identification and remediation of I&I issues on the collection system leading
into the Rains Road pump station. This incident occurred after rain fell for a second period on already
saturated ground. As reflected on the enclosed tables of rainfall amounts measured at two locations,
one upstream of and one in the vicinity of the Rains Road pump station, there was precipitation earlier
in the day on the date of the event that served to pre -saturate the ground reducing the ability of the
ground to absorb the large amount of precipitation that fell later in the day. Given the saturation
already evident when the additional 1.1+ inches of rain fell between 17:00 and 00:00 inflow entered the
already full collection system and caused this overflow. Given the duration of the event it is also
probable that infiltration from the by then completely saturated ground continued to enter the
collection system and extend the event.
First, a recap of information previously submitted, but still relevant:
We have been and will continue to pursue identification and remediation of the sources of I&I
in a logical manner. There are two main outfalls that lead into this station, Hunts Fork Creek and Hasty
Creek.
KRG Utilities has completed cleaning and video inspection of -9,030 linear -feet of 18" and 21"
RCP pipe on the Hunts Fork Creek Outfall, one of the two main outfalls that lead into this station, at a
cost of over $80,000. Overall, the Hunts Fork Creek Outfall pipe appears to be in very good condition
for a 60-year-old concrete pipe carrying sewer. The only sources of inflow found thus far are located at
the few direct taps into this line. These will be repaired.
KRG Utilities has also completed cleaning and video inspection of the main Hasty Creek Outfall
line, 15,375 linear feet of 8" to 15" VC and DI line at a cost of $57,821.00. There are 6 segments of this
line that will require plugging and re -inspecting to complete inspection due to the high water levels
encountered. Several small sources of infiltration were identified and remediation options are being
explored.
Smoke testing of 108,447 linear -feet of these outfalls and 547 manholes leading into this
station was completed by Consulting Engineering firm Alley Williams Carmen and King and resulted in
the location and repair of 122 cleanouts. Twenty-three manholes, mostly located on the lower Hasty
Creek outfall were identified in the report as possible sources of I&I in need of attention. Manhole

rehabilitations will be scheduled pending receipt of results of additional cleaning and video inspection
currently taking place on the Hasty Creek Outfall. The entire main Hasty Creek outfall has been cleaned
and video inspected by KRG Utilities, but there were several segments of the lower Hasty Creek outfall
that could not be video inspected properly due to the volume of water in the pipes and are currently
scheduled to be plugged upstream and re -inspected by video. These segments have still not been re-
inspected due to the continued high volume of water in the pipes — presumably due to the high amount
of precipitation we have experienced and high ground water tables. Pending the results of these
inspections the determination will be made as to if any and if so how much of the lower Hasty Creek
outfall needs rehabilitation by relining of pipes and manhole rehabilitation.
One of the sub -basins that feed into the Hasty Creek outfall has been cleaned and video
inspected and only one section of damaged pipe has been found. This pipe section, while damaged, did
not appear to be an active source of inflow, but it will be repaired now that we are aware of it. Repair
of this section of pipe will require the removal of a concrete driveway and is being scheduled.
The entire main line of the Hunt's Fork Creek outfall was cleaned and video inspected previous
to investigation of the Hasty Creek outfall due to its age (1969) and material composition (RCP) and was
found to be in surprisingly good shape. The only sources of I&I located were three or four break-in
service taps that had inflow at the connection. Contractors are currently pricing out the repair of these
service taps.
Continuing information:
Alley Williams Carmen and King is still working on a flow study of the entirety of the drainage
areas that discharge into both the Rains Road Pump Station and the next downstream pump station,
Northside Pump Station. Preliminary results were expected near the end of February/beginning of
March to help us narrow down whether the causative problem is more closely aligned with excessive
I&I or undersized pump stations to meet the existing sewershed area demand, but the as of the date of
this letter the results have not been finalized.
New information:
The City of Thomasville has scheduled the installation of flow meters on the discharge force
mains at our four largest pump stations, Rains Road being one. The flow meters are scheduled to be
installed the week of May 18, 2020 and it is anticipated that having verifiable, live flow data will aid in
determining the causative factors in the repeated SSO's at this location.
The City of Thomasville has spent, and will continue to spend, millions of dollars to protect the
environment by identifying and correcting deficiencies in the collection system. There were no known
impacts to public health, fish kills, or recreational area closures as a result of this spill.
The City of Thomasville asks that the ongoing efforts and expenditures to identify and
remediate the sources of I&I in the sanitary sewer collection system be taken into account with any
enforcement actions considered.
Sincerely,
CC: Kelly Craver
Morgan Huffman
Utilities Director
City of Thomasville
336-475-4220

Ivey Creek PS
Rainfall from 1/1/2020 to 1/27/2020
Device Time Rainfall Amount (inches)
1/24/2020 0:00 0
1/24/2020 1:00 0
1/24/2020 2:00 0
1/24/2020 3:00 0
1/24/2020 4:00 0
1/24/2020 5:00 0.13
1/24/2020 6:00 0.10
1/24/2020 7:00 0.08
1/24/2020 8:00 0.05
1/24/2020 9:00 0.01
1/24/2020 10:00 0
1/24/2020 11:00 0
1/24/2020 12:00 0
1/24/2020 13:00 0
1/24/2020 14:00 0
1/24/2020 15:00 0
1/24/2020 16:00 0
• 1/24/2020 17:00 0.14'',
1/24/2020 18:00 0.15
1/24/2020 19:00 0.63
1/24/2020 20:00 0.10
1/24/2020 21:00 0.03'.
1/24/2020 22:00 0.06
1/24/2020 23:00 0.061
1/25/2020 0:00 0.01
1/25/2020 1:00 0
1/25/2020 2:00 0
1/25/2020 3:00 0
1/25/2020 4:00 0.01
Total: 1.56

Golf Course PS
Rainfall from 1/1/2020 to 1/25/2020
Device Time Rainfall Amount (inches) Temperature (°F)
1/24/2020 0:00
1/24/2020 1:00
1/24/2020 2:00
1/24/2020 3:00
1/24/2020 4:00
1/24/2020 5:00
1/24/2020 6:00
1/24/2020 7:00
1/24 20 8:00
1/24/2020 9:00
1/24/2020 10:00
1/24/2020 11:00
1/24/2020 12:00
1/24/2020 13:00
1/24/2020 14:00
1/24/2020 15:00
1/24/2020 16:00
1/24/2020 17:00
1/24/2020 18:00
1/24/2020 19:00
1/24/2020 20:00
1/24/2020 21:00
1/24/2020 22:00
j 1/24/2020 23:00
Total:
O 0
O 0
0 0
0 0
0.01 0
0.11 0
0.12 0
0.09 0
0.05! 0
0.01 0
0 0
0 0
O 0
O 0
0 0
0 0
O 0
0.15', 0
0.20 0
0.52! 0
0.091 0
0.041 0
0.051 0
0.05 0
1.49

t v-asat-w- oa�1
City of Thomasville
Thomasville, North Carolina 27360
Utilities Department
RCB-20210128-Recommend minimal CPA due to relatively large
amount but conditions beyond their control.
Lon T. Snider
Regional Supervisor
WQROS, WSRO, DWQ, NCDEQ
450 W. Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
14 May 2020
RE: Intent to Enforce Letter Response
Incident Number 202000166
Dear Mr. Snider,
In response to the letter of Intent to Enforce of 07 May 2020 the City of Thomasville asks that
the following be taken into consideration:
Regarding incident # 202000166: Precipitation during the morning prior to this event had somewhat
saturated the ground, limiting the ground's ability absorb further precipitation, especially at the
intensity that it came, later in the day when the event occurred. Attached is a table from the nearby
Timber Creek pump station site showing the hourly precipitation the day of the event. In the 4 hours
immediately preceding this event 0.13", 0.26", 0.67", and 0.11" of precipitation fell respectively. The
hydraulic saturation of the ground and resultant inflow and infiltration into sanitary sewer collection
system overwhelmed the downstream pump station. There were no known impacts to public health,
fish kills, or recreational area closures as a result of this spill.
Rehabilitation of the South Hamby Creek Outfall.that leads into this station is listed in the city's
Capital Improvement Plan as adopted by Council. This project should help to reduce l&I and the
resultant spills at this pump station. The City of Thomasville has spent and will continue to spend
millions of dollars to protect the environment by identifying and correcting deficiencies in the collection
system.
The City of Thomasville asks that the extremely precipitation that both preceded and occurred
during this event as well as the ongoing efforts to upgrade all aspects of the sanitary sewer collection
system be taken into account with any enforcement action considered.
Sincerely,
CC: Kelly Craver
Morgan Huffman
Public Services Director
City of Thomasville
336-475-4220

Timber Creek
Rainfall from 1/1/2020 to 1/26/2020
Device Time Rainfall Amount (inches)
1/24/2020 0:00 0
1/24/2020 1:00 0
1/24/2020 2:00 0
1/24/2020 3:00 0
1/24/2020 4:00 0.01'.
1/24/2020 5:00 0.11
1/24/2020 6:00 0.09.
1/24/2020 7:00 0.09
1 2472020 8:00- 0.03
1/24/2020 9:00 0.01
1/24/2020 10:00 0.01
1/24/2020 11:00 0
1/24/2020 12:00 0
1/24/2020 13:00 0
1/24/2020 14:00 0
1/24/2020 15:00 0
1/24/2020 16:00 0
1/24/2020 17:00 0.131
1/24/2020 18:00 0.261
1/24/2020 19:00 0.67I
1/24/2020 20:00 - 0.111
1/24/2020 21:00 0.02
1/24/2020 22:00 0.07':
1/24/2020 23:00 0.05
1/25/2020 0:00 0.01
Total:: ' 1.67

City of Thomasville
Thomasville, North Carolina 27360
Lon T. Snider
Regional Supervisor
WQROS, WSRO, DWQ, NCDEQ
450 W. Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
Utilities Department
RCB-20210128-Recommend NFA due to relatively small amount and
conditions beyond their control.
14 May 2020
RE: Intent to Enforce Letter Response
Incident Number 202000167
Dear Mr. Snider,
In response to the letter of Intent to Enforce of 07 May 2020 the City of Thomasville asks that
the following be taken into consideration:
Regarding incident # 202000167: CIPP lining of the Hanks Branch outfall main line had been
largely completed as part of the Hank's Branch Phase 1 Rehabilitation when this incident occurred. This
rehabilitation work has served not only to reduce infiltration, but also to reduce exfiltration from the
main Hanks Branch Outfall pipe. Upstream of the CIPP lined outfall pipe rainfall runoff entered the
collection system through multiple means such as leaky pipe joints, broken taps and cleanouts, and
leaking manholes during an extreme precipitation event. The increased volume of the main outfall for
transmitting flow to the pump station (due to the cleaning which removed a large amount of debris)
combined with the better sealed system led to reduced exfiltration of the l&I water and overwhelmed
the pump station.
Enclosed are 2 charts reflecting hourly rainfall totals as measured at 2 monitoring points
upstream of the event site. Both charts reflect a large amount of precipitation between 17:00 and
23:00 on the date of the event, which occurred between 20:30 and 23:30. Also reflected is significant
rainfall between the hours of 05:00 and 08:00 which served to "pre-soak" the soils, leaving the ground
without the ability to absorb much of the precipitation later in the day, and leading to a large amount of
runoff and inflow.
Of the total volume of wastewater spilled much of the water was rain water, and there were no
known impacts to public health, fish kills, or recreational area closures as a result. There is a second
phase of this project planned that has been under reviewed by DWR and DWI staff for quite some time
now, delaying its eventual implementation. Phase 2 of the Hank's Branch Outfall Rehabilitation will
address several upstream sections of laterals that discharge into the Hanks Branch main outfall that
have I&I issues by a combination of pipe replacement and CIPP lining where appropriate. It is
anticipated that Hanks Branch Outfall Phase 2 will have the desired effect of reducing I&I and thus
reducing the chances of further overflows at the Northside pump station.
The City of Thomasville asks that the circumstances surrounding this event, the lack of
demonstrable environmental impact, as well as the ongoing efforts to upgrade all aspects of the
sanitary sewer collection system be taken into account with any enforcement action considered.
Sincerely, p
CC: Kelly raver
Morgan Huffman
Public Services Director
City of Thomasville
336-475-4220

Ivey Creek PS
Rainfall from 1/1/2020 to 1/27/2020
Device Time Rainfall Amount (inches)
1/24/2020 0:00 0
1/24/2020 1:00 0
1/24/2020 2:00 0
1/24/2020 3:00 0
1/24/2020 4:00 0
1/24/2020 5:00 0.13
1/24/2020 6:00 0.10
1/24/2020 7:00 0.08
1/24/2020 8:00 0.05'
1/24/2020 9:00 0.01
1/24/2020 10:00 0
1/24/2020 11:00 0
1/24/2020 12:00 0
1/24/2020 13:00 0
1/24/2020 14:00 0
1/24/2020 15:00 0
1/24/2020 16:00 0
1/24/2020 17:00 0.14'.
1/24/2020 18:00 0.15
1/24/2020 19:00 0.63!
1/24/2020 20:00 0.10
1/24/2020 21:00 0.03
1/24/2020 22:00 0.06,
1/24/2020 23:00 0.06
1/25/2020 0:00 0.01
1/25/2020 1:00 0
1/25/2020 2:00 0
1/25/2020 3:00 0
1/25/2020 4:00 0.01
Total: 1.56

Golf Course PS
Rainfall from 1/1/2020 to 1/25/2020
Device Time Rainfall Amount (inches) Temperature (°F)
1/24/2020 0:00
1/24/2020 1:00
1/24/2020 2:00
1/24/2020 3:00
1/24/2020 4:00
1/24/2020 5:00
1/24/2020 6:00.
1/24/2020 7:00
1/24/2020 8:00
0 0
0 0
0 0
0 0
0.01 0
0.11 0
0.12 0
0.090
0.05 0
1/24/2020 9:00 0.01 0
1/24/2020 10:00 0 0
1/24/2020 11:00 0 0
1/24/2020 12:00 0 0
1/24/2020 13:00 0 0
1/24/2020 14:00 0 0
1/24/2020 15:00 0 0
1/24/2020 16:00 0 0
1/24/2020 17:00 0.15I 0
1/24/2020 18:00 0.20 0
1/24/2020 19:00 0.52 0
1/24/2020 20:00 0.09j 0
1/24/2020 21:00 0.04' 0
1/24/2020 22:00 0.05, 0
1/24/2020 23:00 0.05, 0
Total: 1.49

ROY COOPER
Governor
M[CHAEL 5. REGAN
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
£nvifortmeritaf Quality
CERTIFIED MAIL: 7018 1130 0000 1612 7666
RETURN RECEIPT REQUESTED
May 07, 2020
Kelly Craver
City of Thomasville
PO Box 368
Thomasville, NC 27361-0368
SUBJECT: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Tracking No.: NOV-2020-DV-0207
Sanitary Sewer Overflows - January 2020
Collection System Permit No. WQCS00057
Thomasville Collection System
Davidson County
Dear Permittee:
A review has been conducted of the self -reported Sanitary Sewer Overflows (SSO's) 5-Day Report/s submitted by
City of Thomasville. The Division's Winston-Salem Regional Office concludes that the City of Thomasville violated
Permit Condition I (2) of Permit No. WQCS00057 by failing to effectively manage, maintain, and operate their
collection system so that there is no SSO (Sanitary Sewer Overflow) to the land or surface waters and the SSO
constituted making an outlet to waters of the State for purposes of G.S. 143-215.1(a)(1), for which a permit is
required by G.S. 143-215.1.
The Winston-Salem Regional Office is providing the City of Thomasville an opportunity to provide evidence and
justification as to why the City of Thomasville should not be assessed a civil penalty for the violation(s) that are
summarized below:
Incident Start Duration
Number Date (Mins) Location
Cause
Total Vol
Total Surface
Vol Water
(Gals) (Gals) DWR Action
202000021 1/3/2020 255 1002 W. Cooksey Drive Inflow and Infiltration 4,500 4,500 Notice of Intent
202000166 1/24/2020 105 810 Old Emmanuel Severe Natural
Church Rd Condition
22,544 22,000 Notice of Intent
North Ca rams Depa rtrnent of Environmental Quality I division of Water Resources
Winston-Salem Reg onal Office 1450 West H nes M 11 Road, Swte 300 I Winston-Salem, North Carotna 27105
336-776-9300

Incident Start Duration
Number Date (Mins) Location
Cause
Total Vol
Total Surface
Vol Water
(Gals) (Gals) DWR Action
202000167 1/24/2020 180 1002 W. Cooksey Dr Severe Natural 9,000 9,000 Notice of Intent
Condition
202000168 1/24/2020 1,495 566 Rains Road
Inflow and
Infiltration, Severe
Natural Condition
44,850 44,850 Notice of Intent
This Notice of Violation / Notice of Intent to Enforce (NOV/NOI) is being issued for the noted violation. Pursuant
to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) may be assessed
against any person who violates or fails to act in accordance with the terms, conditions, or requirements of any
permit issued pursuant to G.S. 143-215.1.
This office requests that you respond to this Notice, in writing, within 60 business days of its
receipt. In your response, you should address the causes of non-compliance, remedial actions, and all other
actions taken to prevent the recurrence of similar situations. The response to this correspondence will be
considered in this process. Enforcement decisions will also be based on volume spilled, volume reaching surface
waters, duration and gravity, impacts to public health, fish kills or recreational area closures. Other factors
considered in determining the amount of the civil penalty are the violator's history of non-compliance, the cost of
rectifying the damage, whether the spill was intentional and whether money was saved by non-compliance.
If you have any questions, please do not hesitate to contact Ron Boone with the Water Quality Section in the
Winston-Salem Regional Office at 336-776-9800 or via email at [e-mail].
cc: Laserfiche
Sincerely,
DocuSiiggned by:
c.Jn.rjft'
" 145B49E225C94EA...
Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
North Ca rams Department of Environmental Quality I division of Water Resources
Winston-Salem Regional Office 1450 West }Eaves he 11 Road, 5 i to 300 I Winston-Salem, North Coatna 27105
336-776-9300