WQCS00329_NOV-2023-DV-0242_20230620

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BRENDA BROWN
MAYOR
RANDY LANSING
TOWN MANAGER
June 20, 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-0242, Permit No. WQCS00329
Town of Nashville Collection System, Nash County
Dear Mr. Vinson,
TOWN COUNCIL
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KATE C. BURNS
LYNNE HOBBS
LARRY D.TAYLOR
This letter is in response to your letter (received on June 12, 2023) concerning the Notice of Violation —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 39.3 miles of 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 do 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]

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Incident Number 202300763: 801 South Creek Drive:
An SSO occurred near 801 South Creek Drive on May 1, 2023. The initial report was made to the NCDEQ at 2:47 PM, on
May 1, 2023. The visually estimated spill rate was 5 gallons per minute for approximately 1,320 minutes, with a reported
total of 3,960 gallons being discharged. Weather conditions were cool, with lingering showers after a major rain event.
The SSO discharged to a nearby open stormwater ditch which flows to an unnamed pond. 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 inflow and infiltration due to severe natural conditions as the area received over 2
inches of rain. The point of the SSO was a low-lying manhole located on the bank of the stormwater ditch. This
section of the system flows to our South Creek Lift Station and when inundated with inflow and infiltration forces
pumps to their maximum efforts and at times the pumps are barely able to keep up.
• Remediation action:
The discharge was relieved after the lift station wet -well pumps caught up. After the relief, the local manholes were
inspected, the area was remediated, washed with fresh water and the system appeared to be operating as intended.
All actions taken to prevent re -occurrence:
This section of sewer main was then visually inspected after the discharge was relieved on May 2, 2023.
Through the winter of 2019 we made a significant effort in smoke testing our system to assist in combating inflow
and infiltration. We identified and repaired 112 points of inflow.
We have recently contracted with a firm to assist the Town with an alternate way of metering the flow of
wastewater at our flume and nearby interconnection. We are hoping to determine whether our system is inundating
their collection system or if their collection system is reaching capacity first and causing ours to backup.
All portions of the collection system that flow to the South Creek lift station have been cleaned and inspected with a
camera crew in early 2021.
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 flyer posted to its website to help educate residents about the
negative effects of FOG.
httl)s://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
Cc: Randy Lansing, Town Manager
Lou Bennett, Town Clerk
Post Office Box 987 . Nashville, North Carolina 27856. Telephone: [phone] . Fax: [phone]