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HomeMy WebLinkAboutWQCS00057_NOI_NOV2020DV0207_Response_#2_20200514of tv uv - VN - 0a o'j • City of Thomasville Thomasville, North Carolina 27360 Utilities Department 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 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 I&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 Morgan Huffman Public Services Director City of Thomasville CC: Kelly raver 336-475-4220 Ivey Creek PS Rainfall from 1/1/2020to 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 1/1/2020to 1/25/2020 Device Time Rainfall Amount (inches) Temperature (°F) 1/24/2020 0:00 0 0 1/24/2020 1:00 0 0 1/24/2020 2:00 0 0 1/24/2020 3:00 0 0 1/24/2020 4:00 0.01 0 1/24/2020 5:00 0.11 0 1/24/2020 6:00 0.12 0 1/24/2020 7:00 0.09 0 1/24/2020 8:00 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 0.15 0 1/24/2020 18:00 0.20 0 1/24/2020 19:00 0.52 0 1/24/2020 20:00 0.09 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