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HomeMy WebLinkAboutWQCS00057_NOI_NOV2020DV0509_Response_20201125o� THOtjgs 2� — �/U — li .� City of Thomasville Thomasville, North Carolina 27360 ti cnt4 ;YV 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 202002730 Dear Mr. Snider, N C Department of Environmental Quality Received NOV 3 0 2020 Winston-Salem Regional Office Utilities Department 2o2ooZ b,A 2oZa6`173g 25 November 2020 In response to the letter of Intent to Enforce of 19 November 2020 the City of Thomasville asks that the following be taken into consideration: Regarding incident # 202002730: Please find attached a table of the rainfall recorded in 15- minute increments recorded at the pump station that is equipped with rainfall monitoring equipment nearest to the Northside Pump Station. As reflected in the table 0.74 inches of rain fell in a 30-minute period about an hour before the spill began. The intensity and volume of rainfall overwhelmed the collection system leading into this pump station and the pump station's current pumping capacity. There are known issues with Inflow and Infiltration in the collection system leading to this pump station that are in process of being at least partially addressed through the Hanks Branch Rehabilitation Phases 1 and 2. Hanks Branch Rehabilitation Phase 1 has been partially complesgd. Contract 2 of Phase 1 as well as all of Phase 2 are scheduled for bid openings on December 16, 21QD so that we can move ahead with our existing plans to address the known sources of Inflow and Infiltration. A factor that aggravated this spill and will continue to have negative impacts until it can be remedied is that one of the two force mains that Northside Pump Station discharges through has ruptured, and thus cannot be used, so the effluent flow capacity of this pump station has been reduced. The section that ruptured was installed by NCDOT in 2002, not 1989 as initially reported. NCDOT additionally installed the force main approximately 20 feet deep and underneath a bridge and concrete buttress wall. A contractor hired to assess the damage and come up with a solution has managed to perform a video inspection of the point of failure. This inspection shows that the crown of the pipe is gone and a large granite stone has dropped into the line blocking it almost completely. No feasible means of addressing this issue have yet been formulated despite a great amount of effort. There were no known impacts to public health, fish kills, or recreational area closures as a result of this spill. The above statements are to share with you that the City of Thomasville is taking steps to address the issues that lead to this spill, but also finds itself bearing the weight of the result of NCDOT engineering incompetence. 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 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 Utilities Director City of Thomasville 336-475-4220 CC: Kelly Craver Golf Course PS Rainfall from 9/1/2020to 9/30/2020 Device Time Rainfall Amount (inches) 9/29/2020 16:15 0.02 9/29/2020 16:30 0.38 9/29/2020 16:45 0.36 0.74inches in 30 minutes 9/29/2020 17:00 0.04 9/29/2020 17:15 0.02 9/29/2020 17:30 0.01 9/29/2020 17:45 0 Spill Began 9/29/2020 18:00 0.01 9/29/2020 18:15 0 9/29/2020 18:30 0 9/29/2020 18:45 0 9/29/2020 19:00 0 9/29/2020 19:15 0.02 9/29/2020 19:30 0.04 9/29/2020 19:45 0.02 9/29/2020 20:00 0.03 9/29/2020 20:15 0.02 9/29/2020 20:30 0 9/29/2020 20:45 0.01 9/29/2020 21:00 0 9/29/2020 21:15 0 9/29/2020 21:30 0.01 9/29/2020 21:45 0 9/29/2020 22:00 0 9/29/2020 22:15 0 9/29/2020 22:30 0 9/29/2020 22:45 0 9/29/2020 23:00 0 9/29/2020 23:15 0 9/29/2020 23:30 0 9/29/2020 23:45 0 Total: 0.99 04 THOt�SG N�U' 202D .p Y - 050� r City of Thomasville Ci wY 161 � • '" 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 Le nse Incident Nu r 202002689 Dear Mr. Snider, NC Department of Environmental quality Received NOV 3 0 2020 Winston-Salem Utiftic as nt 25 November 2020 In response to the letter of Intent to Enforce of 19 November 2020 the City of Thomasville asks that the following be taken into consideration: Regarding incident # 202002689: Please find enclosed charts of the rainfall recorded in 15- minute increments at the two pump stations in the same sewershed as the Northside Pump Station that have rainfall monitoring equipment. Also enclosed are graphical charts showing both the daily rainfall totals in 15 minute intervals as well as the 24-hour daily totals visually. The intensity and volume of rainfall was high, depositing 1.62 inches in the initial 4-1/2 hours of rainfall. There are known issues with Inflow and Infiltration in the collection system leading to this pump station that are in process of being at least partially addressed through the Hanks Branch Rehabilitation Phases 1 and 2. Hanks Branch Rehabilitation Phase 1 has been partially completed. Contract 2 of Phase 1 as well as all of Phase 2 are scheduled for bid openings on December 16, 2020 so that we can move ahead with our existing plans to address the known sources of Inflow and Infiltration. A factor that aggravated this spill and will continue to have negative impacts until it can be remedied is that one of the two force mains that Northside Pump Station discharges through has ruptured, and thus cannot be used, so the effluent flow capacity of this pump station has been reduced. The section that ruptured was installed by NCDOT in 2002, not 1989 as initially reported. NCDOT additionally installed the force main approximately 20 feet deep and underneath a bridge and concrete buttress wall. A contractor hired to assess the damage and come up with a solution has managed to perform a video inspection of the point of failure. This inspection shows that the crown of the pipe is gone and a large granite stone has dropped into the line blocking it almost completely. No feasible means of addressing this issue have yet been formulated despite a great amount of effort. There were no known impacts to public health, fish kills, or recreational area closures as a result of this spill. The above statements are to share with you that the City of Thomasville is taking steps to address the issues that lead to this spill, but also finds itself bearing the weight of the result of NCDOT engineering incompetence. 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 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 Utilities Director City of Thomasville 336-475-4220 CC: Kelly Craver Golf Course PS Rainfall from 9/1/2020to 9/26/2020 Device Time Rainfall Amount (inches) 9/25/2020 0:45 0.02 9/25/2020 1:00 0 9/25/2020 1:15 0.01 9/25/2020 1:30 0 9/25/2020 1:45 0.01 9/25/2020 2:00 0 9/25/2020 2:15 0 9/25/2020 2:30 0 9/25/2020 2:45 0.01 9/25/2020 3:00 0.02 9/25/2020 3:15 0 9/25/2020 3:30 0 9/25/2020 3:45 0.01 9/25/2020 4:00 0.01 9/25/2020 4:15 0.05 9/25/2020 4:30 0.02 9/25/2020 4:45 0.01 9/25/2020 5:00 0.03 9/25/2020 5:15 0.09 9/25/2020 5:30 0.06 9/25/2020 5:45 0.1 9/25/2020 6:00 0.14 9/25/2020 6:15 0.1 9/25/2020 6:30 0.14 9/25/2020 6:45 0.17 9/25/2020 7:00 0.12 9/25/2020 7:15 0.1 9/25/20207:30 0.14 Spill Began 9/25/2020 7:45 0.08 9/25/2020 8:00 0.17 9/25/2020 8:15 0.05 9/25/2020 8:30 0.04 9/25/2020 8:45 0.01 9/25/2020 9:00 0 9/25/2020 9:15 0 9/25/2020 9:30 0 9/25/2020 9:45 0 9/25/2020 10:00 0 9/25/2020 10:15 0 9/25/2020 10:30 0 9/25/2020 10:45 0 1.62 9/25/2020 11:00 0 9/25/2020 11:15 0 9/25/2020 11:30 0.1 9/25/2020 11:45 0.03 9/25/2020 12:00 0 9/25/2020 12:15 0 9/25/2020 12:30 0 9/25/2020 12:45 0 9/25/2020 13:00 0 9/25/2020 13:15 0 9/25/2020 13:30 0 9/25/2020 13:45 0 9/25/2020 14:00 0 9/25/2020 14:15 0 9/25/2020 14:30 0 9/25/2020 14:45 0 9/25/2020 15:00 0.02 9/25/2020 15:15 0 9/25/2020 15:30 0 9/25/2020 15:45 0 9/25/2020 16:00 0 9/25/2020 16:15 0 Spill Ended 9/25/2020 16:30 0 9/25/2020 16:45 0 9/25/2020 17:00 0 9/25/2020 17:15 0 9/25/2020 17:30 0 9/25/2020 17:45 0 9/25/2020 18:00 0 9/25/2020 18:15 0 9/25/2020 18:30 0 9/25/2020 18:45 0 9/25/2020 19:00 0 9/25/2020 19:15 0 9/25/2020 19:30 0 9/25/2020 19:45 0 9/25/2020 20:00 0 9/25/2020 20:15 0 9/25/2020 20:30 0 9/25/2020 20:45 0.01 Total• 1.87 Ivey Creek PS Rainfall from 9/1/2020to 9/26/2020 Device Time Rainfall Amount (inches) 9/25/2020 2:00 0.03 9/25/2020 2:15 0 9/25/2020 2:30 0 9/25/2020 2:45 0.01 9/25/2020 3:00 0.02 9/25/2020 3:15 0 9/25/2020 3:30 0 9/25/2020 3:45 0 9/25/2020 4:00 0.01 9/25/2020 4:15 0 9/25/2020 4:30 0.07 9/25/2020 4:45 0 9/25/2020 5:00 0.04 9/25/2020 5:15 0.09 9/25/2020 5:30 0.06 9/25/2020 5:45 0.07 9/25/2020 6:00 0.13 9/25/2020 6:15 0.07 9/25/2020 6:30 0.11 9/25/2020 6:45 0.18 9/25/2020 7:00 0.15 9/25/2020 7:15 0.11 9/25/2020 7:30 0.09 Spill Began 9/25/2020 7:45 0.1 9/25/2020 8:00 0.18 9/25/2020 8:15 0.09 9/25/2020 8:30 0.06 9/25/2020 8:45 0.02 9/25/2020 9:00 0 9/25/2020 9:15 0 9/25/2020 9:30 0 9/25/2020 9:45 0 9/25/2020 10:00 0 9/25/2020 10:15 0 9/25/2020 10:30 0 9/25/2020 10:45 0 9/25/2020 11:00 0 9/25/2020 11:15 0 9/25/2020 11:30 0.03 9/25/2020 11:45 0.13 9/25/2020 12:00 0.01 1.62 9/25/2020 12:15 0 9/25/2020 12:30 0 9/25/2020 12:45 0 9/25/2020 13:00 0 9/25/2020 13:15 0 9/25/2020 13:30 0 9/25/2020 13:45 0 9/25/2020 14:00 0 9/25/2020 14:15 0 9/25/2020 14:30 0 9/25/2020 14:45 0 9/25/2020 15:00 0.01 9/25/2020 15:15 0 9/25/2020 15:30 0 9/25/202015:45 0 9/25/2020 16:00 0 9/25/2020 16:15 0.01 Spill Ended 9/25/2020 16:30 0 9/25/2020 16:45 0 9/25/202017:00 0 9/25/2020 17:15 0 9/25/2020 17:30 0 9/25/2020 17:45 0 9/25/2020 18:00 0 9/25/2020 18:15 0 9/25/2020 18:30 0 9/25/2020 18:45 0 9/25/2020 19:00 0 9/25/2020 19:15 0 9/25/202019:30 0 9/25/2020 19:45 0 9/25/2020 20:00 0 9/25/2020 20:15 0 9/25/2020 20:30 0 9/25/2020 20:45 0 9/25/2020 21:00 0.01 -Total:1.89. © MSN I Outlook Office, Skype. 8: X °a Mission Communication f e 0 123mccom/123mc/main201 t,asp • ' apes ; UMSMobdk • tNi C... ®Mappng the novN,.. tj M(tsm mj" Thomasville NC, City of • Reports • c-Tent Status Data Rainfall —.b f _-t. ] ] R--•"a Rump If. 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REGAN Secretary S, DANIEL SMITH DINE ar NORTH CAROLINA aWMWW"r'W QUa&y CERTIFIED MAIL: 7018 1130 0000 1612 9592 RETURN RECEIPT REQUESTED November 19, 2020 Kelly Craver City of Thomasville PO Box 368 Thomasville, NC 27361-0368 SUBJECT: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY Tracking No.: NOV-2020-DV-0509 Sanitary Sewer Overflows - September 2020 Collection System Permit No. WQCS00057 Thomasville Collection System Davidson County Dear Permittee: A review has been conducted of the self -reported Sanitary Sewer Overflows (SSO's) 5-Day Reports submitted by City of Thomasville. The Division's Winston-Salem Regional Office concludes that the City of Thomasville violated Permit Condition I (2) of Permit No. WQCS00057 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 Winston-Salem Regional Office is providing the City of Thomasville an opportunity to provide evidence and justification as to why the City of Thomasville should not be assessed a civil penalty for the violation(s) that are summarized below: Total Vol Total Surface Incident Start Duration Vol Water Number Date (Mira) location Cause (Gab) (Gals) DWR Action 202002624 9/17/2020 35 104 Williams Street Pipe Failure (Break) 3,500 0 Notice of Violation 202002625 9/17/2020 630 Northside Pump Station Inflow and 6,300 6,000 Notice of Violation Infiltration, Pipe Failure (Break) Nona Caron Dwortmaat of Enviranmmtal QuNty I Dmwn of Www Rasaoroas WomonSalem Rago"I m 1 430 Wag Honer Mill Roae, Suitt 300 I WmM&Aelem, NoM Cem€m 27105 ..n 336 776-9800 Incident Number Start Date Duration (Mins) Location Cause Total Vol (Gals) Total Vol Surface Water (Gals) DWR Action 202002689 9/25/2020 530 1002 West Cooksey Inflow and 21,200 21,000 Notice of Intent North Side Pump Infiltration, Pipe Station Failure (Break), Severe Natural Condition 202002730 9/29/2020 420 1002 West Cooksey Rd Inflow and 31,200 31,000 Notice of Intent Infiltration, Pipe Failure (Break), Severe Natural Condition 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 Ron Boone with the Water Quality Section in the Winston-Salem Regional Office at 336-776-9800 or via email at ron.boone(obncdenr.gov. cc: Laserfiche Sincerely, CDocu!1 pnad Ey: Loti T `ai..iu, teeeaeezzecaerw_ Lon T. Snider, Regional Supervisor Water Quality Regional Operations Section Winston-Salem Regional Office Division of Water Resources, NCDEQ Roma Caruhns Department of Enwwrn"tsi Qualay I D,wvon of Watt, 11* o rms Wwston6a*m RagamI Offm 1 450.WM Na na Mit Road, sate 300 1 wmstonSaiem, Nonh C, rot m 27105 336-776-9600