WQCS00329_NOV-2023-DV-0364 Response to Notice_20231023

BRENDA BROWN
MAYOR THE 0RIGINRL
RANDY LANSING
TOWN MANAGER \A8HVIL
1. E S T. 1 7 0 0
Ms. Vanessa Manuel, Assistant 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-0364, Permit No. WQCS00329
Town of Nashville Collection System, Nash County
Dear Ms. Manuel,
TOWN COUNCIL
LOUISE W. HINTON
LARRY D. TAYLOR
KATE C. BURNS
LYNNE HOBBS
This letter is in response to your letter dated October 10, 2023 (received on October 17, 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 doing its best to comply with all the terms of
our sewer collection permit.
The following is the information you requested, by incident.
Incident Number 202301389: 803 South Creek Dr
An SSO occurred near 803 South Creek Drive on September 23, 2023. The initial report was made to the
NCDEQ at approximately 8:00 AM, on September 24, 2023. The visually estimated spill rate was 1 gallon
per minute for approximately 870 minutes, with a reported total of 870 gallons being discharged.
Weather conditions were warm, 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:
499 Barnes Street P.O. Box 987 Nashville, NC 27856

■ Causes of noncompliance:
The SSO has been attributed to inflow and infiltration due to severe natural conditions as the area
received nearly 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 visually inspected after the discharge was relieved.
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 alternative 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.
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
lee.brtr [e-mail].
Sincerely,
Lee Brown
Director of Public Works
Cc: Randy Lansing, Town Manager
Lou Bennett, Town Clerk
499 Barnes Street P.O. Box 987 Nashville, NC 27856