WQCSD0059_NOV-2019-DV-0146 Response_20190325

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CITY OF SALUDA
NORTH CAROLINA
Monday, March 25, 2019
G. Landon Davidson, P.G., Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ
2090 U.S. 70 Highway
Swannanoa NC, 28778
RE: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY. TRACKING NO.: NOV-2019-DV-
0146
Dear G. Landon Davidson, P.G.,
The City of Saluda experienced two sanitary spillovers (SSO) as mentioned in the referenced
Notice of Violation. The SSO’s were a result of gravel and road base clogging a manhole located
on Pearson Falls Road. Other manholes were found to have significant amounts of the same
material. The other manholes were not overflowing. The one manhole located on Pearson Falls
road had significant amounts of the material. City staff jetted the mot problematic manhole and
then the other manholes to open their flow during the SSO incident. City staff coordinated with
the city of Hendersonville to bring a large vacuum truck to completely open and clear the
manhole and lines both downstream and upstream of the debris. These are not the first SSO of
this nature in this same manhole. The city has actively inspected and checked manholes along
Pearson Falls Road, the railroad tracks, and US 176 in order to clear debris and prevent SSO
incidents.
City staff have reviewed the evidence acquired from the inspections and during the SSO
incidents. The source of the debris was traced from manhole to manhole and along sewer lines.
This evidence leads me to believe the road base and gravel are entering the sewer system and
manholes from a terra cota sewer line upstream of the manholes. The suspected line is located
underneath US 176, Main Street Saluda, a state highway.
The following information provides a brief history of work which I believe impact the line which
I believe is compromised.
MAYOR
Fred Baisden
CITY MANAGER
Jonathan Cannon
COMMISSIONERS
Mark Oxtoby
Paul C. Marion
Stan Walker
Leon Morgan
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Approximately 5 years ago, a property owner adjoining US 176 performed excavation
operations. Those operations damaged a stone box culvert servicing a NCDOT street. The
culvert quickly became blocked and then clogged. NCDOT was contacted and after 4 years of
bantering with the property owner, the property owner installed a drop inlet and piping to
establish a new outlet for the stone box culvert. Shortly after this rebuild, the city began seeing
gravel and road base in its lines and at the waste water treatment plant. This material began to
increase in volume as the heavy rains continued to pummel the city in 2018. The result was the
SSO’s which have been reported to NCDEQ. The city of Saluda suspecting this area under US
176 as being a problem, have placed cameras in this section of line. The camera shows
significant deficiencies at the joints of the line in this location. I suspect these joints are th
points of inflow of both gravel, road base, and water during storm events. NCDOT has been
contacted. I have met with Lonnie Watkins from the Mills River office, Ben Williams from Polk
County Maintenance, and Mark Shown with Raleigh Hydrology. NCDOT is in no hurry to address
the stone box culvert which I believe has now failed and is compromising the city of Saluda
sewer line. The city of Saluda has an engineering opinion of probable cost of approximately
$150,000 to replace the compromised line from manhole to manhole. The problem with this
work is that replacement of the line requires the city to coordinate with NCDOT. The stone box
culvert crosses over the top of the sewer line and would necessarily need to be dealt with as
part of the project.
The city could perform a partial repair of the sewer line up to the stone box culvert, but this still
leaves joints which could be compromised once again by the failure of the culvert. It also, could
result in the discovery of significant problems under US 176. These problems could be more
than the city is prepared or able to deal with.
The City of Saluda asks NCDEQ to look at the above considerations. I understand the concern of
NCDEQ that the city take active measures to repair issues and preempt issues which cause SSO
incidents. Notice of Violations encourage cities to take action and when cities do not take
action then civil penalties mitigate damage and penalize negligence. The City of Saluda is
working hard to eliminate issues whenever possible. This particular issue has become one
which the city does not control all of the components which contribute to the cause of the
incident. The city is also hampered by cost of the repair as well as unknown conditions which
could elevate the cost dramatically. The city is not negligent, but instead taking action in this
matter. Civil penalties would have a negative impact on the cities ability to pay for needed
repairs. More importantly, civil penalties would not be effective in motivating the city to
remedy the violation since the city is already anxious to remedy the issue, but is limited in its
ability to act.
Therefore, I ask, on behalf of the city that NCDEQ not issue a civil penalty? Instead, I have a
meeting scheduled on April 2 with Mikal Wilmer. We will visit the site of the SSO and the
compromised sewer line. We can then discuss a course of action the city can follow to remedy
this problem.
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Please do not hesitate to contact me if you have any questions or comments.
Sincerely,
Jonathan Cannon
City Manager
Office: [phone]
Fax: [phone]
Email: [e-mail]
Website: www.cityofsaludanc.com
Address:
6 E. Main St.
PO Box 248
Saluda NC, 28773