WQCS00329_NOV-2021-DV-0125 Response_20210304

Town Of a!5b ittc
BRENDA BROWN
MAYOR
RANDY LANSING
TOWN MANAGER
March 4, 2021
Mr. Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources
N.C. Department of Environmental Quality
Raleigh, N.C. 27699-1628
Subject: NOV-2021-DV-0125, Permit No. WQCS00329
Town of Nashville Collection System, Nash County
Dear Mr. Vinson,
TOWN COUNCIL
LOUISE W. HINTON
KATE C. BURNS
LYNNE HOBBS
LARRY D. TAYLOR
This letter is in response to your letter (received on February 26, 2021) concerning the Notice of Violation — failing to
effectively manage, maintain, and operate the subject collection system so there is no SSO to the land or surface waters
and making an outlet to waters of the State for purposes of G.S.143-215.1(a)(a), for which a permit is required. The
Town takes the operation and maintenance of its sewer collection system seriously and has made strides in recent years
to purchase proper maintenance equipment and pursue proper preventative maintenance programs. Our sewer
collection system contains approximately 39.3 miles of sewer mains. The size, age of the system, and limited staff
makes it challenging to operate our system in such a manner as to prevent SSOs from occurring. Despite this challenge,
the Town is committed to do its best to comply with all the terms of our sewer collection permit.
The following is the information you requested, by incident.
Post Office Box 987 . Nashville, North Carolina 27856 . Telephone: [phone] . Fax: [phone]

Town of -flaM itle
Incident Number 202100376: 803 South Creek Drive:
An SSO occurred near 803 South Creek Drive on January 31, 2021. The initial report was made to the NCDEQ at 3:15 pm,
the next day. The visually estimated spill rate was 5 gallons per minute for approximately 2200 minutes, with a reported
total of 25,200 gallons being discharged. Weather conditions were cool, with lingering showers after a significant rain
event. The SSO discharged to a nearby open stormwater ditch which flows to an unnamed pond. A fish kill did not occur.
In addition to the summary above please accept the following information as it relates to this incident:
■ Causes of noncompliance:
The SSO has been attributed to inflow and infiltration due to severe natural conditions as the area received over 2
inches of rain, causing severe flooding. The point of the SSO was a low-lying manhole located on the bank of the
stormwater ditch. This section of the system flows to our South Creek Lift Station and when inundated with inflow
and infiltration forces pumps to their maximum efforts and at times the pumps are barely able to keep up.
■ Remediation action:
The discharge was relieved after the lift station wet -well pumps caught up. After the relief, the local manholes were
inspected, the area was remediated, washed with fresh water and the system appeared to be operating as intended.
• All actions taken to prevent re -occurrence:
This section of sewer main was then visually inspected after the discharge was relieved on February 2, 2021. No
previous history is available.
Through the winter of 2019 we made a significant effort in smoke testing our system to assist in combating inflow
and infiltration. We identified and repaired 112 points of inflow.
On June 19, 2020 we contacted a local wastewater engineering firm and met with them on July 2, 2020 to discuss
assisting the Town with studying the flume and nearby interconnection. This study has recently come to an end and
we are awaiting the firm's findings and recommendations.
All portions of the collection system that flow to the South Creek lift station are currently being cleaned and will be
visually inspected with a camera crew beginning March 16, 2021. This assessment will help guide our next steps.
Whether flood conditions exist or not we are aware of the constant effects that FOG can have on a collection
system. The Town has a Fats, Oils, and Grease PowerPoint posted to its website to help educate residents about the
negative effects of FOG. http://www.townofnashville.com/home/showdocument?id=1697
It is our intent to operate our system in such a manner as to meet all the requirements of our permit. We welcome the
opportunity to meet with you and your staff to review our Sewer Rehabilitation Program and discuss ways to improve
and enhance it. If you have any questions or need any additional information, please do not hesitate to contact me at
[phone] or via email at lee. brown (@townofnashviIIenc.aov.
Sincerely,
A 0
Lee Brown
Director of Public Works
Cc: Randy Lansing, Town Manager
Lou Bunch, Director; Human Resources
Post Office Box 987 . Nashville, North Carolina 27856. Telephone: [phone] . Fax: [phone]