WQCS00037_NOV-2020-DV-0352 Response_20221228

Shelb
NORTH CAROLINA
Post Office Box 207 • Shelby, NC 28151-0207
December 28, 2022
Mr. Andrew Pitner, Assistant Regional Supervisor
Division of Water Resources, Mooresville Regional Office
610 East Center Avenue, Suite 301
Mooresville, NC 28115
Re: Notice of Violation
Tracking #NOV-2020-DV-0352
Collection System Permit #WQCSO0037
City of Shelby, Cleveland County
Dear Mr. Pitner:
The City of Shelby received the above referenced Notice of Violation regarding the sanitary sewer
overflow that occurred on November 24, 2022, in the area of 1158 Wyke Rd.
The spill was reported by a citizen at 2:13pm and sewer crews responded immediately arriving on scene
at 2:50pm. Even with the Thanksgiving Holiday four employees responded to the spill including the
Water & Sewer Supervisor. As part of the cleanup and inspection over 3,000 feet of line and manholes
were checked and six sections of sewer line (3 above and 3 below the spill) were rodded. Site
remediation consisted of hauling off solid waste, liming the area and reseeding the area.
This spill was initially thought to be caused by roots only but during the clean-up effort there were
hundreds of latex gloves within the spill along with a large number of wipes, rags and even N95 masks.
The location of this manhole is downstream from several medical facilities, senior living apartments
along with an elementary school and children's day care facility.
City staff hand delivered letters to businesses in the area that may have contributed to the large number
of gloves and other medical disposables to inform and educate them about what can and cannot be
flushed and that flushing those items is also in violation of our City Ordinance. We have asked that they
educate their staff and post notices for all employees and residents. We have also returned to the site
since the spill to check for signs of more non -sanitary sewer items that may be in the line and to see if
any other issues or potential issues were present. No issues were found.
Preventative Maintenance Projects in and around the outfall of the spill since 2017
• 6.4 miles of sewer camera performed
• 18 manhole repairs
• 800 manhole inspections
• 0.75 miles of line underwent acoustic testing
www.cityofshelby.com

Your letter lists ten areas of review in consideration for determining civil penalty amounts for a sanitary
sewer overflow. We have included the following brief responses for each item:
• Volume —12,300 gallons
• Volume reaching surface waters —12,300 gallons
• Duration and gravity — 320 minutes
• Impacts to public health - There were no identified impacts to public health.
• Fish kills - No fish kills were observed following this overflow.
• Recreational area closures - No recreational areas were closed due to this overflow.
• History of spills — There have been no reportable spills at this location
• Cost of rectifying damage — No environmental damage was identified requiring remediation.
City staff performed cleanup and lime application.
• Intentional spill — These overflows were not intentional and were a result of roots and medical
disposables
• Money saved by non-compliance — No money was saved by this non-compliance.
Our track record shows a significant decline in the number of sanitary sewer overflows over the last
twelve years, and we continue to make substantial capital investments to prevent sewer overflows from
occurring. Please see the attached spill charts for your review and consideration. We are currently in
the process of major outfall improvements along the Hickory Creek Outfall which may total more than
$3.8 million dollars by the time the project is complete. We recognize the requirements of our
wastewater collection system permit and the importance to the environment and public health in the
prevention of sanitary sewer overflows and will continue to make improvements to prevent future spills.
The City of Shelby will add this line as a priority area to our FIowGIS work order software due to the
potential of more non -sanitary sewer approved items entering this location and will check it more
frequently for possible clogging to prevent further spills. We will also monitor this area within our Pre -
Treatment department to perform routine checks and educational outreach to prevent the flushing of
non -sanitary sewer items.
Please contact me at anytime regarding any further information or questions you might have regarding
this issue. I can be reached at 704-669-6552 or [e-mail]
Sincerely, j
Brian Wilson
Water Resources Operations Manager
cc: Rick Howell; City Manager
David Hux, Director of Water Resources
Adam Howell; Collection System Crew Supervisor/ORC
www.cityofshelby.com

CITY OF SHELBY - SEWER OVERFLOWS
2022 DATA AS OF DECEMBER 27
Rain/I&I Grease Roots Debris I_ Failure -Total Spills
2010 2011 2012 2013 2014 2015 2016 2017 2018 2019