WQCS00312_NOI_NOV2020DV0263_Response_20200615

CITY OF ARCHDALE
307 BALFOUR DRIVE
P.O. BOX 14066
ARCHDALE, NORTH CAROLINA 27263
PHONE: [phone] FAX: [phone]
June 15, 2020.
Mr. Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional -Office (((
Division of Water Resources, NCDEQ
450 West Hanes Mill Road, Suite-300
Winston-Salem, NC 27105
NC Department of
Environmental Quality
Received
JUN 18 2020
Winston-Salem
Regional Office
Subject: Response to Notice of Violation & Intent to Issue Civil Penalty
Tracking No.: NOV-2020-DV-0263
Sanitary Sewer Overflows — March 2020
Collection System Permit No. WQCS00312
Archdale Collection System
Randolph County
I acknowledge receipt of your Notice of Violation & Intent to Issue Civil Penalty regarding
an SSO event on March 12, 2020. The NOV, dated 6/3/2020, was received 6/9/2020.
The following bullet points, narrative, and attachments have been included to explain the
cause of this event and the actions being taken to prevent future similar overflows.
Incident Number 202001009: Thursday, March 12, 2020
• A sewer smell was reported by employees of a business along Cheyenne Drive.
They were concerned there may be a sewer backup at their facility.
• Staff reported to the scene and discovered that an overflow was occurring on the
outfall line behind the business. Staff went to work diagnosing the situation and
making repairs.
When the overflow ended, City staff cleaned the immediate area and applied
hydrated lime as required by the City of Archdale's Sewer Overflow Response Plan.

N
Narrative:
Employees of a local business called about a sewage smell and explained they believed
their facility was experiencing a sewer backup. They asked for assistance in determining
what to do next. Staff reported to the building and ultimately discovered that the source of
the smell was an overflow occurring at a manhole on the outfall line behind the business.
The Public Works Director, Sewer System Supervisor (ORC), and necessary staff began
the process of minimizing the impact of the overflow. Equipment was brought onsite to
excavate a holding pond to limit the amount of overflow reaching the nearby creek.
Meanwhile, the manhole was opened, and the line cleared to get the wastewater flowing.
It was determined that roots had entered the line and caused the backup. In the process
of clearing the vegetation, staff also found bricks (origin unknown) inside of the manhole.
Staff utilized safety harnesses to enter the manhole and remove the bricks and remaining
roots. Once the manhole was again operational, the holding pond was pumped back into
the sewer line: The area was cleaned, and hydrated -lime was applied.
When debriefing with staff after the SSO event, it was learned that we were unaware of
this manhole prior to the overflow. The City's mapping showed this manhole further south
than it is in reality. Additionally, the outfall line follows a Piedmont Natural Gas easement
which is very well maintained year-round (picture included). Almost all of the manholes on
this stretch are elevated cones rising 2'-4' above grade level. This manhole, and one
directly adjacent are currently at grade and a few feet off of the mowed easement. It is
unclear why these two manholes were not raised when constructed in the 1980's, as they
are close to a tributary of Muddy Creek. In any case, vegetation had grown into the sewer
system, which led to this SSO.
In order to avoid this issue in the future, the locations of these two manholes have been
updated in our GIS mapping system and specifically noted in our easement mowing
schedule. Additionally, once the area has dried enough to access it appropriately, both
manholes will be raised to increase visibility and limit potential impacts on the nearby
stream during flood events.
It was disappointing to learn that this backup could have been prevented. However, it
highlights the fact that the City wishes to update our utility mapping. Great steps have
been taken in our GIS over the years, but a full scale effort to map the water and sewer
systems is in order. The City has applied 2 timesin recent years for AIA funding to assist
with these costs. In the FY21 budget, we have included $50,000 as leverage towards our
next application for funding assistance, and we hope to be successful. Ironically, one
factor working against the City in prior applications was a lack of SSO events to report. In
recent years, we have encountered more issues than ever in this regard and expect to
score 'better as a result.
It is also worth mentioning that the City continues to take an aggressive approach to
maintaining existing sewer lines and pump stations. A quick review of our budget shows
our commitment to maintaining what we have as a priority over adding new water and/or
sewer lines. All pumps and generators receive annual PM, replacement pumps are
planned for annually in the CIP, and temporary bypass pumps are brought in when
deemed necessary due to pump station issues or when extreme weather events are
forecasted.

A reorganization of the City's Public Works Department took place in January 2019. One
of the driving reasons for this change was a desire to have better accountability for
Archdale's Water Distribution and Wastewater Collection permits. Inaddition to these
organizational changes, several large expenditures are planned for the sewer system. For
example, projects like a $300-400k electrical upgrade to the Weant Road pump station
and the addition of a permanent generator at the Oak Forest pump station are nearing
completion.
Additionally, a $1.3M force main (16") is almost complete which will parallel the current 14"
force main. This redundancy is imperative as the Weant Road pump station sends most
of Archdale's wastewater along this route to High Point for treatment. And, it is just that, a
redundant effort that specifically does not add new customers or revenue. It simply offers
better options for maintenance, keeps our staff safe when doing work, and minimizes the
chance of a major SSO in the event of a failure. The size of that investment for a
community Archdale's size (with no revenue in return), should signal our good intentions
to properly meet the requirements of the collection permit.
Should you have questions or need further information about this matter, please let me
know. I can be reached by telephone at [phone] or by email at
[e-mail].
Sincerely,
X14
Zeb Holden
City Manager
Cc: Lloyd Wilson, Public Works Director
Chris Davis, Sewer System Supervisor, ORC
Phillip Yates, Water System Supervisor
Attachments:
1) Picture of easement maintenance.
2) Aerial image showing FEMA blue line stream and location of SSO.
3) Map of outfall line and manholes.

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=e .. Disclaimer. Ibis map was compiled from recorded deeds, plats, and other public records and data. Users of this data are hereby notified that Map Scale
= the aforementioned public information sources should be consulted for verification of the information. Randolph County, its agents and 1 inch = 333 feet
employees make no warranty as to the accuracy ofthe ih formation on this map. 6/16/2020

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