WQCS00054_Enforcement_20170720

Water Resources
ENVittONMENT AL QUALM Y
August 16, 2017
Mr. Andrew Neff, PE
Union County Public Works
4600 Goldmine Rd.
Monroe, NC 28110
SUBJECT: Payment Acknowledgment
Civil Penalty Assessment
Union County Collection System
Union County
Permit No. WQCS00054
DV-2017-0043
Dear Mr. Neff,
ROY COOPER
MICHAEL S. REGAN
S. JAY ZIMMERMAN
yIVQROS:
This letter is to acknowledge receipt of check. No. 00467682 in the amount of $868.12 received
from you dated 8/1/2017. This payment satisfies in full the civil assessment levied against the
subject facility and this case has been closed. Payment of this penalty in no way precludes future
action by this Division for additional violations of the applicable statutes, regulations, or permits.
If you have any questions, please call. Steve Lewis at 919-807-6 308.
Sincerely,
S. Jay Zimmerman, P.G.
Director, Division of Water Resources
cc: Enforcement File DV-2017-0043
Corey'Basinger,Mooresville Regional Office Supervisor
Lon Snider, MRO
Central Files
State of North Carolina Environmenlai Quality I Water Resources
1617 Mail Service Center I Raleigh, North Carolina 27'699-1617
919 707 9000

Water Resources
SNVIStONMENTAL GUALOW
Certified Mail # 7015 1520 0002 6984
Return Receipt Requested
July 20, 2017
Cindy Coto
Union County
500 N Main St
Ste 918
Monroe, NC 28112
SUBJECT: Notice of Violation and Assessment of Civil Penalty
for 'Violations of North Carolina General Statute XIS.) 143-215, T )(6
and Collection System Permit No, WQCS00054
Union County
Union County Collection System
Case No, DV-2017-0043
Union County
Dear Ms. Coto:
This letter transmits a Notice of Violation and assessment of civil pena
$118.12 enforcement costs) against Union County.
ROY COOPER
Gownor
MICHAEL S. REGAN
S. JAY ZIMMERMAN
Om tot
a 2 750.00 civil penalty +
rhis assessment is based upon the following facts: a review has been conducted of the Sanitary Sewer Overflow (SSO)
5-Day, Report submitted by Union County. This review has shown the subject facility to be in violation of the requirements
found in Collection System Permit No. WQCS00054 and G.S. 143-21.5,1(a)( I.). The violation(s) that occurred are
summarized in Attachment A to this letter.
Based upon the above facts, 1 conclude as a matter of law that Union County violated the terms, conditions or requirements
of Collection System Permit. No, WQCS00054 and G.S, 143-215,1(a)(1) in the manner and extent shown in Attachment A.
In accordance with the maximums established by G.S. 143-215.6.A(a)(2) a civil penalty may be assessed against any
person who violates the terms, conditions or requirements of a permit required by. G.S. 143-215.1(a).
Based upon the above findings of fact and conclusions of law, and in accordance with authority provided by the Secretary
of the Department of Environmental Quality and the Director of the Division of Water Resources, I, W. Corey Basinger,
Regional Supervisor, Mooresville Regional Office hereby make the -following civil penalty assessment against Union County:
State of North Carolina Environmental Qualityl'Water Resources
610 East Center Avenue, Suite 301, Mooresville, NC 281 15
704-663-1699

$75I0„90 For 2 of the 3 violations of Collection System Permit No, WQCS00054 and G.S. 143-215.1(a)(1) for
Sanitary Sewer Overflow) resulting in a discharge without a valid permit,
$150,90 TOTAL CIVIL PENALTY
$1112 Enforcement Costs
$868.12 TOTAL AMOUNT DUE
Pursuant to G,S. 1.43-215.6.A(c), in determining the amount. of the penalty .1 have taken into account the Findings of Fact and
Conclusions of Law and the factors set forth at G.S. 143B-282.1(b), which are:
(i) The degree and extent of harm to the natural resources of the State, to the public health, Or to private property
resulting from the violation;
(2) The duration and gravity of the violation;
(3) The effect on ground or surface water quantity or quality or on air q
(4) 'lhe cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Vi,,,rhether the violation was committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs over which the Environmental
Management Commission has regulatory authority; and
(8) The cost. to the State of the enforcement procedures.
Within thirty (30) days of receipt of this notice, you must do one of the following:
(1) Submit payment of the penalty, OR
(2) Submit a written request for remission, OR
(3) Submit a written request. for an administrative hearing
Option 1.: Submit payment of the penalty:
Payment should he made directly to the order of the Department of Environmental Quality (do not include waiver
form) Payment of the penalty will not foreclose further enforcement action for any continuing or new violation(s
Please submit payment to the attention oF
Steven LekViS
PERCS Unit
Division of water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617

Option 2: Submit a written request for remission or mitigation including a detailed justification for such
request:
Please be aware that a request for remission is limited to consideration of the live factors listed below as they may
relate to the reasonableness of the amount of the civil penalty assessed. Requesting remission is not the proper
procedure for contesting whether the violation(s) occurred or the accuracy of any of the factual statements contained in
the civil penalty assessment document. Because a remission request forecloses the option of an administrative hearing,
such a request must be accompanied by a waiver of your right to an administrative hearing and a stipulation and
agreement that no factual or legal issues are in dispute. Please prepare a detailed statement that establishes why you
believe the civil penalty should be remitted, and submit it to the Division of Water Resources at the address listed below,
In determining whether a remission request will be approved, the following factors shall be considered:
(1) whether one or more of the civil penalty assessment factors in NCGS 143B-282..1(b) was wrongfully
applied to the detriment of the petitioner;
(2) whether the violator promptlyabated continuing environmental damage resulting from the violation;
(3) whether the violation was inadvertent or a result of an accident;
(4) whether the violator had been assessed civil penalties for any previous violations; or
(5) whether payment of the civil penalty will prevent payment for the remaining necessary remedial actions.
Please note that all evidence presented in support of your request for remission must he submitted in writing. Th.e
Director of the Division of Water Resources will review your evidence and inform you of his decision in the matter of
your remission request. TIFhe response .1,01 provide details regarding the case status, directions for payment, and
provision for further appeal of the penalty to the Environmental Management Commission's Committee on Civil Penalty
Remissions (Committee). Please be advised that the Committee cannot consider information that was not part of the
original remission request considered by the Director. Therefore, it is very important that you prepare a complete and
thorough statement in support of your request for remission,.
In order to request remission, you must complete and submit the enclosed "Request for Remission of Civil Penalties,
Waiver of Right to an Administrative Hearing, and Stipulation of Facts" form within thirty (30) days of receipt of this
notice, The Division of Water Resources also rewests that you complete and submit the enclosed "Justification for
Remission Request."
Both forms should be submitted to the folio • 'Mg address:
Steven Lewis
PERCS Unit
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617 -
AND
W, Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
610 East Center Avenue, Suite 301
Suite 301, -Mooresville, NC' 28115

Option 3: File a petiton for an administrative hearini with the Office of Ad inist
Hea
If you wish to contest any statement in the attached assessment document you must file a petition for an aclininistrative
hearing. You may obtain the petition form from the Office of .Administrative Hearings. You must file the petition with
the Office of Administrative Hearings within thirty (30) days of receipt of this notice. A petition is considered filed
when it is received in the Office of Admi.nistrative Hearings during normal office hours. The Office ofAdministrative
Hearings accepts filings Monday through Friday between the hours of 8:00 a.m. and 5:00 p.m., ex.cept, for official state
holidays. The petition may be filed by facsimile (fax) or electronic mail by an attached file (with restrictions) - provided.
the signed original, one (1) copy and a tiling fee (if a filing. fee is required by 'NCGS §150B-23.2) is received in the
Office of Administrative Hearings within seven (7) business days following. the faxed or electronic transmission. You
should contact the Office of Administrative Hearings with all questions regarding the filing 'fee andlor the details of the.
filing_process.
The mailing address and telephone and fax numbers for the Office of .Administrative Hearings are as follows:
6714 Mail Service Center
Raleigh, NC 27699 6714
Tel: [phone]
Fax: [phone]
One (1) copy of the petition must also he served on DEQ as follows:
Mr, William. F. Lane, General Counsel
Department of Environmental Quality
1601 Mail Service Center
Raleigh, North Carolina 27699-1601
Please indicate the case number (as found on page one of this letter) on the petition.
Failure to exercise one of the options above within thirty (30) days. of receipt of this letter, as evidenced by an internal
date/time received stamp (not a postmark), will result in this matter being referred to the Attorney General's Office, for
collection of the penalty through a civil action. Please be advised that additional penalties may be assessed for violations
that occur after the review period of this assessment.
If you have any questions, ,please contact Lon Snider with the Division of Water Resources staff of the Mooresville
Regional Office at [phone]. or via ernail at. lon.snidergnedenr.gov.
Sincerely,
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS
Cc: WQS Mooresville Regional Office Enforcement File
NPDES Compliance/Enforcement Unit - Enforcement File

Case Number: DV-2017-0043
Assessed Party: Union County
'Permit No.: WQCS00.054
JUSTIFICATION FOR REMISSION REQUEST
County: tin ion
Amount Assessed: $868,12
Please use this form when requesting remission of this civil penalty. You ninst also complete the 'Request For Remission,
fflaiver of Right to an ,idministrative Hearing, and Stipulation of Facts" form to request remission of this civil penalty,
You should attach any documents that you believe support your request and are necessary for the Director to consider in
evaluating your request for remission. Please be aware that a request for remission is limited to consideration of the five
factors listed below as they may relate to the reasonableness of the amount of the civil penalty assessed, Requesting
remission is not the proper procedure for contesting whether the violation(s) occurred or the accuracy of any of the factual
statements contained in the civil penalty assessment: document. Pursuant to N.C.G.S. § 1438-282,1(e)„ remissionof a civil
penalty may be granted only when one or more of the following five factors apply. Please check each factor that you
believe applies to your case and provide a detailed explanation,including copies of supporting documents, as to why the
factor applies (attach additional pages as needed),
(a) one or more of the civil penalty assessment factors in N.C.G.S. 143B-282, i(h) were wrongfully applied to the
detriment of the petitioner (the assessment 'actors are listed in the civil penalty assessment document);
(h) the violator promptly- abated continuing environmental damage resulting from the violation explain .1 e
steps that ..you took to correct the violation and prevent fliture occurrences);
(c) the violation was inadvertent or a result of an accident (i.e., explain why the violation was unavoidable or
something you could not prevent or prepare
(d) the violator had not been assessed civil penalties for any previous dolatio
(e) payment of the civil penalty will prevent payment for the remaining necessary remedial actions (i.e„, explain
how paytnent of the civil penalty prevent you from per the activities necessary to aChieve
complianco.
EXPLANATION:

"fit OR"I1 I CAR R} IA
JN1 UNION
IA=II"'11 0.2 Sf l�ri i
PENALTIES F ...L`T`11 S .¢\ I N i
Linton County
1 nion County Collection.
i T' t . \ i tR tfti05
DR"I
F E 'li t) 11 II N 1 sL Q1 '
WAIVER IG " TO AN
`
ADMINISTRATIVE I IVV li AND
STIPULATION OF FACTS
I -I vFi been a - ,ed civil pert ies totaling e _2 for violation(
r Resources dated July 2022017, the undersigned, desiring to seek
administrative hearing in the above -stated nnatter and does stip
it document ri"1te undersigned further understands that all evidence presented in sttppo0 of remission of this cis€
penalty st he submitted lo the Director ofthe I i ision of Water Resources ithin thirty (It)) days of receipt of the notice
Ott assesstncn . No new es i lcnce in support rt of a remiss on request Ns ill be allowed after i 0 days from the receipt of the
notice al assessment:
day
M T RI
111 PI It ttN I
scsstnent document of tl
sion of the cic it penalty, does herd)),
ate that the facts are as alleged in the
SIGN _ f 1 Ri

PERMIT J+S004
ATTACHMENTA
Union o my
CASE NUMBER: DV-2017-0043
FACILITY: : Union County Collection System
h Viol
INCIDENT VIOLATION
NUMBER DATE VIOLATION TYPE
2017 645 4/24/2017 CSO/SSO(Sewer Overflow)
201700
VIOLATION DESCRIPTION
REGION: Mooresville
COUNTY:Union
Discharge without valid perm
4/24/2017 CSO/SSO(Sewer Overflow) Discharge without valid permit
TOTAL VOLU E PENALTY
(GALLONS) AMOUNT
201700642 4/24/2017 CSO/SSO(Sewer Overflow) Discharge without valid permit
825 5500,00
6,115
20,290
250 00
00

SSO Eva .tuation Routing S
p
hNQV
PERMIUEE:
Lon
Andre
�w�
Co

Public Works
4600 Goldmine Rd
Monroe NC, 28110
T. 704-289-1434
www.unioncountync.gov
842
May 31, 2017
Mr. W. Corey Basinger
Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
610 East Center Ave,, Suite 301
Mooresville, NC 28115
Dear Mr, Basinger:
Union County has received the NOV referenced below for collection system overflows,
Notice of Violation & Intent to Issue Civil Penalty
Tracking #: NOV-2017-DV-0110
Sanitary Sewer Overflows — April 2017
Collection System Permit — WQCS00054
Union County
Explanations for the overflows were on the BUS Overflow Reporting Forms submitted by
Union County Public Works (UCPVV) to the NCDEQ. However, we have added a few additions
facts in the explanations below

lnciden
201700642 4;24`2017
20l700644 fr24.12017
20 1700645 424!20 1 7
Wea (`reek t:tuttitl
300.5 Asherol C)r,
eh Outtall
iOn wcrc due
this area
erclnrc. 1
c\ti tiler, I'Ie, tse s tic a
Efforts of Prevention
Illy Public works has underwent a coo prehensive N1 tie
211C
tell lift Stations„ lilt statio
re.., among others.
• CCWRF is undergoing a significant plant upgrade which
includes new headworks, a 3MG EQ basin, and process
improvement. Total cost is $7.775M includes building a new
10.3 MGD influent PS, new headworks containing new bar
screens, compactor, and grit remov'all'dewatering, 3MG EQ
basin, and relocation of 1200' of 18" gravity sewer.
CDMSmith is the design engineer. MB Kahn is the general
contractor. See attached project details.
I&I flow studies have conducted by CDMSmith
(Hydrostructures) and Frazier Eng. These studies have
narrowed the basin into concentrated sub -basins to target
I&I reduction, The intended approach is a find -fix method to
utilize funding efficiently and consistently. The first initial
2017target area is southwest of CCWRF in the Indian Trail
area south of Hwy 74, west to the Union/Mecklenburg
county line.
• Scope of Work has been developed, funding has been
secured of approx. $2M, and Frazier Engineering has been
selected to conduct a SSES of the identified zones,
beginning in June 2017, The SSES will consist of smoke
testing, MH inspections, CCTV inspection (if necessary), etc.
Once complete, the schedule of repairs will be presented in
a bid package to secure a utility contractor to repair the
infrastructure appropriately.
SSU Details
SS() s listeat in this tie tionwore dui. to [Set intro cavv
r Associated with rOIS arca wtos int�trdateal
l od oi rs a.rad it c:re�ase:d t1to4 s at Ilia (1 assyF ttr'ancIl WR1', therefore
forcing ttic. reieas of tstewater. r ig tse sec th attrsclrc-d piclrrres,
it
'arks has cveork relentlessly to isle€ (it ° ICcations al
1. Efforts include:
Extensive manhole rehab of all identified manholes with
defects in the Grassy Branch trunk collection system in

2014-2015. Rehab contractor was Prism |nc.with
CDMSmhhasthe design engineer
~ Continued outfa| in»pectionn, indudinO inma||ing Al dishes
inall manholes within the Grassy Branch trunk sewer
system
~ Smoke testing ofarea residential areas and conducting
associated repairs
° Flow monitoring tYFrazier EngineerinSpring 2O16
n Identified the associated pub|icschool campus as
the main contributor
w Smoke testing associated public school campus
o Issuing Sower Use Ordinance violation to Union
CovntyPublic Schools for drains and excessive
groundwater and surface water entry points (see
attachments)
o Continued cooperation between UCPG staff and
UCPVVstaff toidentify and napan|&|entry points,
o Scheduled repairs byUCP3will begin July 1.2V17
once funding has been secured and contractor
acquired. UCPVV Will follow LIP immediately with
post -smoke testing, anticipating numemun
iterations mfrepairs and post smoke tests until all
entry points have been eliminated,
UCPVVhas an aggressive Capital Improvement Program throughout the next years. The
projects include-,
�p Crooked Creek Basin Improvements $24.259.822M
�~ Crooked Creek Interceptor Improvements Ph. 1 -$9.915.5ODOQ
�+ Suburban Estates PS and FM $1.800,000,00
� VVaxhavv Interceptor —3.2QO.00D.00
VV\8/PGImprovements $3.000.000.00
� Collection System 8SE8&Rehab —$2'OOO.00Q(not including $85kannua|Iyin
Operations)
PS Upgrades -$3OO'OOOannually
UCPVV's currentC|P projects are also ongoing with projectsinduding�
VVaxhawSewer Improvements '$295.OUQOU
� Blythe Creek Sewer Improvements -$3.003.2DOOO
:o~ Forest Park PS Rep|acarnent& Interceptor Improvements ' B2.540.000,00
�+ Crooked Creek |&| Study &RemodiatiOn $2.538.300.00
Union County Public Works continues to invest funds into SSES work. capital

collection syssystem, Additional information is available for further details regarding the CCIARF
improvements as well as the CIP projects listed above If you have any questions, please feel
free to contact Josh Brooks. Superintendent/ ORC, at '71 4- 8 - 74 or myself at T 4- 96 4 1 ,
Thank you or your consideration on this issue:
Sincerely:
Andrew Neff, PE
Water/Wastewater Division Director
cc Edward t osicki, PE utive Director
Josh Brooka, Superintendent

UNION Ct .N
Facilities Department
iLit:'scut
201 Venus Street
Monroe, NC 28112
Phone 704298,3160 Fax 704„296.3163
Ntcurns,k.1.2,nc,us
6 January 2017
To:
Andrew Neff, PE
Union County Public Works
Water and Wastewater Division Director
From: Donald S. Hughes, AIA
Director
Re: Piedmont HS Sewer
Andrew G. Houlihan, Ed.D. — Superintendent
Board of Education
Melissa Merrell Chairrna.n
Gary Sides - Vice Chalrma.n
Leslie Boyd
Kathy Heintel
Christina Helms
Matt Helms
Joseph Morreale
Dennis Rape
Candice Sturdiyant
I apologize for not keeping you informed as we moved forward with the required corrective measures for the
Piedmont HS sewer system.
Since instructed by your office to make repairs we have attempted several times to obtain bids for contractors to
do the work. We were also challenged with not having appropriate funds as our capital dollars have been
earmarked to be job specific by the commissioners.
Recently we were able to resolve the funding issue and were able to secure a viable bid from a contractor. Our
intent was to complete the work over the holiday break; however, due to inclement weather the contractor was
only able to complete about 75%. The contractor had intended on completing the work this coming weekend but
again with the impending inclement weather they will not be working this weekend. They have assured us that the
project will be completed by January lrh.
You will be informed upon completion of the project.
Ed Goscicki, PE, Executive Director, UCPW
Josh Brooks, Field Superintendent
Dr, Jonathan Tyson, Principal, Piedmont HS
Danny McManus, Assistant Director of Facilities
Growing Possibilities.

UNION COUNTY
DEPARTMENT OF PUBLIC WORKS
500 North Main. Street, Suite 600, Monroe, NC 23112
Phone; (704)296410 • Fax: [phone]
February 27, 2017
Dr. Jonathan Tyson
Union County Public Schools, Piedmont High School
3006 Sikes Mill Rd
Monroe, NC 28110
Subject: Notice of Violation Union County Sewer Use Ordinance
Dr. Tyson:
Both UCPW and UCPS maintenance staff conducted additional smoke testing of the Piedmont
High (PDHS) campus on February 4, 2017. Due to ongoing student activities, approximately 2/3 of
the campus was tested. Within that area, the smoke testing revealed numerous locations needing
repair. UCPW has compiled information regarding the locations of those areas and UCPS
Maintenance personnel were on site to visually confirm these areas,
A second additional smoke test was scheduled with UCPS maintenance staff on February 18, 2017.
However, the test was not able to be conducted at the time due to athletic activities in the specific
testing area and UCPS maintenance staff was not in attendance. UCPS personnel will need to
coordinate with UCPW staff to re -schedule the final post smoke test for the remaining areas
within the PDHS campus.
We continue to experience very high flows at our Grassy Branch Wastewater Treatment Facility
along with high infiltration and inflow (I&I) from your facility. This creates a regulatory issue for
us. We exceeded the regulated flow rate for this facility in January.
Once all the smoke testing is completed, we will forward the report to you. This report will verify
areas requiring attention, confirm what was noted in the field by UCPS and UCPW personnel and
will require corrective action.
Thank you for your continuing cooperation and diligence regarding this issue.
Sincerely,
Andrew Neff, P.E.
Water and Wastewater Division Director
cc: Edward Goscicki, P.E., Executive Director, Union County Public Works
Josh Brooks, Utility Field Services Superintendent
Danny McManus, Assistant Director of Facilities

UNION COUNTY
DEPARTMENT OF MLIC WORKS
500North Main Street, Suite 600, M"nro*NC2SI2
March I2,2017
Dr. Jonathan Tyson
Union County Public Schools
Piedmont High School
3006Sikes Mill Rd
Monroe, N[Z8l1O
Subject: Notice o(Violation Union County Sewer Use Ordinance
Dear Dr. Tyson:
We have previously communicated with you regarding high wastewater flows atthe Grassy
Branch Wastewater Treatment P|ark(~Grassy8ranchVVVVTP")causedbylnflowfromroofdrains
and other deficiencies directly entering into the wastewater collection system in violation of the
Union County Sewer Use Ordinance, ascodified inArticle 34ofthe Union County Code, We
providedomrin|tia||e1tertoyouonSmptember23`:.2OI6neqmirin8ag0dayneapwnseastoyour
actions torepair these deficiencies. You provided aresponse onJanuary 60indicating a
contractor would complete the repairs byJanuary l7'h. Upon completion ofthose repairs we
again inspected the system using smoke testing and discovered defects not previously observed
needing repair, You were notified that immediate correction of the remaining defects was
required. However, we received a response indicating you were pursuing funds for next fiscal year
for the additional work needed.
While we understand you must identify proper funds for these repairs, we stress there is an
urgent need toget the repairs completed. |nJanuary, the Grassy Branch VVVVTPexperienced
flows exceeding 145% of plant capacity due to rain events and the violation at Piedmont High
School. The flow amounts have been reported tothe State ofNorth Carolina, Suchexcaeclsnceo
nfplant capacity at Grassy Branch WWTP may result in fines to Union County Public Works by the
North Carolina Department nfEnvironmental Quality.
The continued connection of roof drains and other deficiencies is a violation of Union County Code
Section 34'IO7(b)1l. The violation nfthis Union County Code section could subject UCPStothe
administrative remedies, civil penalties, and other available remedies set forth in Division 7 of
Article III ofChapter 34ofthe Union County Code. Should Union County Public Works receive a
penalty from the State for capacity exceedancesatGrassy Branch VVW/TP' or should this violation
unnecessarily persist, itmay benecessary toimpose acivil penalty, administrative remedy, or
other available remedy on UCP6due tothe violation. Therefore, your prompt attention to
correcting the deficiencies iswarranted and appreciated.
Our staff will continue towork with U[PSstaff toidentify and correct any remaining deficiencies.
Our Point of Contact in this matter is Josh Brooks. He may be reached at telephone mumber(7U4)

UNION iU TY PUBLIC
We appreciate the cooperation UCPS staff extended to Union County Public Works in conducting
these smoke tests and look forward to working with you toward a prompt resolution of this
matter.
Sincerely:.
Water and Wastewater Division Direct()
cc; Dr. Andrew Houlihan, Superintendent
Joe Delaney, Consultant to the instructional Technology and Operatiaris Departments
DannyMcManus„ Director of Facilities
Edward Goscicki, Executive Director, Union County Public Works
Josh Brooks, Utility Field Services Superintendent

UNION COUNTY
DEPARTMENT OF PUBLIC WORKS
500 North Main Street, Suite 600, Monroe,. NC 26112,
Phone:[phone] i Fax: [phone]
January 3`d, 2017
Union County Public Schools
Piedmont High School
Dr. Jonathan Tyson
3006 Sikes Mill Rd
Monroe, NC 28110
Subject: Notice of Violation Union County Sewer Use Ordinance
Dr, Tyson:
Ed Goscicki, Union County Executive Director of Public Works, sent you a communication on
September 23`d outlining concerns with direct connection of some of the schools drainage systems
into the wastewater collection system. This direct connection is causing significant problems with
excessive wet weather flows inundating the Grassy Branch Wastewater Treatment Facility serving
your area.
As stated in our earlier communication these direct storm water entry points violate the Union
County Sewer Use Ordinance (UCSUO).
A 90-day time period was afforded to allow sufficient time to develop your plan to co
violation and remedy the problem, including schedule and specific actions.
Since we have not heard from, your prompt response is appreciated.
Sincerely:
Andrew Neff, P.E.
Water and Wastewater Division Director
14(
cc: Edward Goscicki, P.E., Executive Director, Union County Public Works
Josh Brooks, Utility Field Services Superintendent
Don Hughes, Director of Facilities
his

UN COUNTY P
201 Venus Street
Munroe, NC 28112
Phone [phone]C Fax 7i74.296,3163
WWW.ucps,k12..nc„us
26 January 2017
To: Andrew Neff, PE
Union County Public Works
Water and Wastewater Division Director
From: Donald S. Hughes, AIA
Director
Re: Piedmont HS Sewer
Andrew G. Houlihan, Ed.D. — Superintendent
Board of Education
Melissa Merrell - Chairman
Gary Sides - Vice Chairman
Leslie Boyd
Facii€tie Department Kathy H€tntel
Christina Helms
Matt Helms
Jaseph Morreale
Dennis Rape
Candice Sturdivant
I have been informed that the repair work needed for the Piedmont HS sewer system has been completed as of
last week. We have informed your staff that we would like UCPW to coordinate with us to do a smoke test at the
school to assure all those involved that the work has been completed satisfactorily to UCPW. As soon as your
staff has contacted Maurice Brown, Maintenance Manager for PdHS, we will schedule and complete the testing.
You will be informed upon completion of the projects
C: Ed Goscicki, PE, Executive Director, UCPW
Josh Brooks, Field Superintendent
Dr, Jonathan Tyson, Principal, Piedmont HS
Danny McManus, Assistant Director of Facilities
Maurice Brown, UCPS Maintenance Manager
Growing Possibilities.

UNION COUNTY
DEPARTMENT OF PUBLIC WORKS
500 North Main Street, Suite 600, Monroe, NC 2811.2
Phone; (7€ 4)296-42W • Fax: [phone]
February 27, 2017
Dr. Jonathan Tyson
Union County Public Schools,, Piedmont. High School
3006 Sikes Mill Rd
Monroe, NC 28110
Subject: Notice of Violation Union County Sewer Use Ordinance
Dr. Tyson:
Both UCPW and UCPS maintenance staff conducted additional smoke testing of the Piedmont
High (PDHS) campus on February 4, 2017. Due to ongoing student activities, approximately 2/3 of
the campus was tested. Within that area, the smoke testing revealed numerous locations needing
repair. UCPW has compiled information regarding the locations of those areas and UCPS
Maintenance personnel were on site to visually confirm these areas.
A second additional smoke test was scheduled with UCPS maintenance staff on February 18, 2017.
However, the test was not able to be conducted at the time due to athletic activities in the specific
testing area and UCPS maintenance staff was not in attendance, UCPS personnel will need to
coordinate with UCPW staff to re -schedule the final post smoke test for the remaining areas
within the PDHS campus.
We continue to experience very high flows at our Grassy Branch Wastewater Treatment Facility
along with high infiltration and inflow (l&I) from your facility. This creates a regulatory issue for
us., We exceeded the regulated flow rate for this facility in January.
Once all the smoke testing is completed, we will forward the report to you. This report will verify
areas requiring attention, confirm what was noted in the field by UCPS and UCPW personnel and
will require corrective action,
Thank you for your continuing cooperation and diligence regarding, this issue.
Sincerely,
Andrew Neff, P.E.
Water and Wastewater Division Director
cc: Edward Goscicki, P,E., Executive Director, Union County Public Works
Josh Brooks, Utility Field Services Superintendent
Danny McManus, Assistant Director of Facilities

UNION COUNTY
DEPARTMENT OF PUBLIC WORKS
500 North Main Street, Suite rt0J, Monroe, NC 28112
Phone: {:70.41296- 10 +
September 23, 2016
Union County Public Schools
Piedmont High School
Dr. Jonathan Tyson
3006 Sikes Mill Rd
Monroe, NC 28110
(a-1232
Subject: Notice of Violation Union County Sewer Use Ordinance
Dr. Tyson:
Due to recent concerns regarding high wastewater flows at the Grassy Branch Wastewater
Treatment Plant, UCPW conducted investigations to determine if there were any points in the
associated wastewater collection system of storm water entry, Utilizing smoke testing, a proven
method of identifying points of storm water entry, numerous locations throughout the Piedmont
High School campus was determined as locations of illicit storm water entry. These direct storm
water entry points violate the Union County Sewer Use Ordinance (UCSUO) as defined below.
UCSUO, Section 2.1(b), (12) states:
(b) Specific Prohibitions, No user shall contribute or cause to be contributed into the POTW
(Publicly Owned Treatment Works)..,
(12) Storm water, surface water, ground water, artesian well water, roof runoff, subsurface
drainage, swimming pool drainage, condensate, deionized water, noncontact cooling water and
unpolluted industrial wastewater..,
These areas of deficiency must be corrected immediately to eliminate any further stress on the
wastewater collection system and treatment plant. Please respond within 90 days with your plan
to correct this violation and remedy the problem, including schedule and specific actions.
We appreciate the cooperation UCPS staff extended to Union County Public Works in conducting
these smoke tests. UCPS staff was very helpful and diligent in assisting in various aspects of the
tests and we look forward to continued combined efforts in the future,
Sincerely:
Edward Goscicki. P.E.
Executive Director, Union County Public Works

iCilliVcCVUNTSCPUBLICCWORK.S:
cc: Andrew Deft P:E„ Water and Wastewater Division Director
Josh Brooks, Utility Field Services Superintendent
Don Hughes, Director of Facilities
2 of2 9'21/2016

varces
NTAL QUALITY
CERTIFIED IMAI7015 1520 0002 6984 9683
RETURN RECEIPT REQUESTED
May 25, 2017
Cindy Coto
Union County
500 N Main St
Ste 918
Monroe, NC 288112.
SUBJECT: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Tracking No,: NOV-2017-DV-0110
Sanitary Sewer Overflows - April 2017
Collection System Permit No. WQCS00054
Union County Collection System
Union County
Dear Ms.. Coto:
ROY COOPER
MICHAEL S. REGAN
Secrrtary
S. JAY ZIMMERMAN
D6rctor
A review has been conducted of the self -reported Sanitary Sewer Overflows (SSO's) 5-Day Reports submitted by
Union County. The Division's Mooresville Regional Office concludes that the Union County violated Permit Condition
I (2) of Permit No. WQCS00054 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 S5O 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 Mooresville Regional Office is providing the Union County an opportunity to provide evidence and justification
as to why the Union County 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 (Mins) Location Cause (Gals) (Gals) DWR Action
201700642 4/24/2017 1,780 Crooked Creek outfall Inflow and
Infiltration, Severe
Natural Condition
201700644 4/24/2017 735 3005 Ashcroft Dr Inflow and
Infiltration, Severe
Natural Condition
20,290 20,290 Notice of Intent
6,115 6,115 Notice of Intent
State of North Garo1ina j Environmental Quality Q Water Resources
610 East. Center Avenue, Suite 301„ Mooresville, NC 28 i 15
704-663-1699

Incident Start Duration
Number Date (Mins) Location
Cause
Total Vol
Total Surface
Vol Water
(Gals) (Gals) DWR Action
201700645 4/24/2017 85 Grassy Branch Outfall Inflow and 825 825 Notice of Violation
Infiltration, 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 (525,000.00) 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 Lon Snider with the Water Quality Section in the
Mooresville Regional Office at 704-663-1699 or via email at lon.snider©ncdenr.gov.
(-A W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
Cc: Mooresville Regional Office - WQS File
Central Files, Water Quality Section
State of North Carolina 1 Environmental Quality Water Resources.
61.0 East Center Avenue, Suite 301, Mooresville, NC 28,115
704-663-1699

Violator:
Case #:
ASSESSMENT FACTORS GS.
1. Harm:
NCDEQ - Division of Water Resources
Water Quality Regional Office Operations Section - Mooresville
Sanitary Sewer Overflow Penalty Matrix
SSO Date:
Incident #:
43B-282.1(b
2. Duration and Gravity of the Violation
Effect on Water Quantity or Quality:
4. Cost of Rectifying Damage:
Amount saved by Noncompliance:
6. Violation was committed willfully or
intentionally:
7. Prior record of failing to comply with
Sanitary Sewer Overflows:
Enforcement Costs:
PENALTY AMOUNT:
Comments: 4 c, -40'
Assessor:
Date:
. Corz,61-1
Xa