WQCS00057_NOI_NOV2020DV0207_Response_#3_20200514

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City of Thomasville
Thomasville, North Carolina 27360
Lon T. Snider
Regional Supervisor
WQROS, WSRO, DWQ, NCDEQ
450 W. Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
RE: Intent to Enforce Letter Response
Incident Number 202000021
Dear Mr. Snider,
1,- v„Nartrgent ui
Environmental Quality
Recei
r Y 18 2020
Winston-Salem
Regional Ofi-?
In response to the letter of Intent to Enforce of 07 May 2020 the City
the following be taken into consideration:
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Regarding incident # 202000021: CIPP lining of the Hanks Branch outfall main line had been
mostly 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.
This event consisted of two smaller events at the same location that were combined, but
covered the time span between 16:30 and 20:45. 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 13:00 and 19:00 on the date of the event.
The total volume of wastewater spilled was nominal, much of the water that spilled 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 AI 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, Morgan Huffman
Public Services Director
City of Thomasville
336-475-4220
CC: Kelly Craver

Golf Course PS
Rainfall from 1/1/2020 to 1/5/2020
Device Time
Rainfall Amount (inches)
1/3/2020 0:00
0.09
1/3/2020 1:00
0.01
1/3/2020 2:00
0.02
1/3/2020 3:00
0
1/3/2020 4:00
0
1/3/2020 5:00
0.01
1/3/2020 6:00
0
1/3/2020 7:00
0
1/3/2020 8:00
0
1/3/2020 9:00
0
1/3/2020 10:00
0
1/3/2020 11:00
0
1/3/2020 12:00
0.02
1/3/2020 13:00
0.18
1/3/2020 14:00
0.48
1/3/2020 15:00
0.07
1/3/2020 16:00
0.09
1/3/2020 17:00
0.01
1/3/2020 18:00
0.14
1/3/2020 19:00
0.10
1/3/2020 20:00
0
1/3/2020 21:00
0.01
1/3/2020 22:00
0
1/3/2020 23:00
0
Total:
1.23

Ivey Creek PS
Rainfall from 1/1/2020to 1/5/2020
Device Time
Rainfall Amount (inches)
1/3/2020 0:00
0.03
1/3/2020 1:00
0.02
1/3/2020 2:00
0.01
1/3/2020 3:00
0
1/3/2020 4:00
0.01
1/3/2020 5:00
0
1/3/2020 6:00
0
1/3/2020 7:00
0
1/3/2020 8:00
0
1/3/2020 9:00
0
1/3/2020 10:00
0
1/3/2020 11:00
0
1/3/2020 12:00
0.02
1/3/2020 13:00
0.23
1/3/2020 14:00
0.44
1/3/2020 15:00
0.09
1/3/2020 16:00
0.06
1/3/2020 17:00
0.01
1/3/2020 18:00
0.18
1/3/2020 19:00
0.05
1/3/2020 20:00
0
1/3/2020 21:00
0.01
1/3/2020 22:00
0
1/3/2020 23:00
0
Total:
1.16

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City of Thomasville
0/ 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 202000166
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 # 202000166: Precipitation during the morning prior to this event had somewhat
saturated the ground, limiting the ground's ability absorb further precipitation, especially at the
intensity that it came, later in the day when the event occurred. Attached is a table from the nearby
Timber Creek pump station site showing the hourly precipitation the day of the event. In the 4 hours
immediately preceding this event 0.13", 0.26", 0.67", and 0.11" of precipitation fell respectively. The
hydraulic saturation of the ground and resultant inflow and infiltration into sanitary sewer collection
system overwhelmed the downstream pump station. There were no known impacts to public health,
fish kills, or recreational area closures as a result of this spill.
Rehabilitation of the South Hamby Creek Outfall that leads into this station is listed in the city's
Capital Improvement Plan as adopted by Council. This project should help to reduce I&I and the
resultant spills at this pump station. The City of Thomasville has spent and will continue to spend
millions of dollars to protect the environment by identifying and correcting deficiencies in the collection
system.
The City of Thomasville asks that the extremely precipitation that both preceded and occurred
during this event 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, h Morgan Huffman
Y Public Services Director
City of Thomasville
336-475-4220
CC: Kelly Craver

Timber Creek
Rainfall from 1/1/2020to 1/26/2020
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
0.01
1/24/2020 5:00
0.11
1/24/2020 6:00
0.09
1/24/2020 7:00
0.09
1/24/2020 8:00
0.03
1/24/2020 9:00
0.01
1/24/2020 10:00
0.01
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
0.13
1/24/2020 18:00
0.26
1/24/2020 19:00
0.67
1/24/2020 20:00
0.11
1/24/2020 21:00
0.02
1/24/2020 22:00
0.07
1/24/2020 23:00
0.05
1/25/2020 0:00
0.01
Total:
1.67