WQCS00329_NOV-2023-DV-0006_20230118

Eoirr of .JaEiibitte
BRENDA BROWN
MAYOR
RANDY LANSING
TOWN MANAGER
January 18, 2023
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-2023-DV-0006, 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 January 12, 2023) concerning the Notice of Violation & Intent to
Issue Civil Penalty for 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 44 miles of gravity 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 doing 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]

aim of Pailbbitte
Incident Number 202201830: 610 Western Ave:
An SSO occurred near 610 Western Ave on December 18, 2022. The initial report was made to the NCDEQ Emergency
Management Office at 12:35 pm, the same day. The visually estimated spill rate was 15 gallons per minute for
approximately 150 minutes, with a reported total of 2,250 gallons being discharged. Weather conditions were cool, and
clear. The SSO discharged to nearby Stoney Creek, a tributary of the Tar River. 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 significant grease build-up.
• Remediation action:
The discharge was relieved and the sewer main was jetted with a cleaned an appropriate nozzle and vacuum truck.
After the relief, the local manholes were inspected, the area was remediated by raking and removing solids,
carefully placing lime around the manhole and applying straw to the affected area. Once remediation was complete
the system was inspected and appeared to be operating as intended.
• All actions taken to prevent re -occurrence:
In late November and early December of 2022 our crews completed cleaning of the surrounding sewer mains that
discharge to the affected outfall. These streets include Industry Ct., Sarah Dr., Haley Dr., and Amerson Ct.
The Town has contracted with Mac Gay and Associates to conduct an Asset and Inventory Assessment. Throughout
this process we've identified many manholes that need to be addressed and have already re -lined 12 and are
scheduled for another 12 this spring. Additionally, when MGA were on site, they observed several areas that
required immediate response with the jetter and for which we were able to respond — thus preventing an SSO.
In January 2023 the Department of Public Works has created an Environmental Programs Superintendent position
that will dedicate approximately 50% of their time to FOG Program enforcement and management, Sewer System
Health, Sewer Outfall and manhole inspections.
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 . We also have added
another brochure to educate our residents on the importance of sewer system health.
https://www.townofnashville.com/home/showpublisheddocument/2595/637993513235770000
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 [e-mail].
Lee Brown
Director of Public Works
Post Office Box 987 . Nashville, North Carolina 27856 . Telephone: [phone] . Fax: [phone]

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Certified Mail # 7020 3160 0000 4115 5696
Return Receipt Requested
Preston Mitchell
Town of Nashville
PO Drawer 987
Nashville, NC 27856
NORTH CAROLINA
Environmental Quality
January 09, 2023
SUBJECT: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Tracking No.: NOV-2023-DV-0006
Sanitary Sewer Overflows - December 2022
Collection System Permit No. WQCS00329
Nashville Collection System
Nash County
Dear Mr. Mitchell:
A review has been conducted of the self -reported Sanitary Sewer Overflows (SSO's) 5-Day Report/s submitted by
Town of Nashville. The Division's Raleigh Regional Office concludes that the Town of Nashville violated Permit
Condition I (2) of Permit No. WQCS00329 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 Raleigh Regional Office is providing the Town of Nashville an opportunity to provide evidence and justification
as to why the Town of Nashville should not be assessed a civil penalty for the violation(s) that are summarized
below:
Total Vol
Incident Start Duration Total Surface
Vol Water
Number Date (Mins) Location Cause (Gals) (Gals) DWR Action
202201830 12/18/2022 150 610 Western Ave, Grease 2,250 2,250 Notice of Violation -
Nashville, NC, 27856 Notice of Intent
North Carolina Department of Environmental Quality 1 Division of Water Resources
Raleigh Regional Office 13800 Barrett Drive I Raleigh, North Carolina 27609
919.791.4200

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 10 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 Mitchell Hayes with the Water Quality Section in
the Raleigh Regional Office at 919-791-4200 or via email at [e-mail].
Sincerely,
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Cc: Raleigh Regional Office - WQS File
Central Files, Water Quality Section
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office 13800 Barrett Drive I Raleigh. North Carolina 27609
919.791.4200