WQCS00037_NOV-2021-DV-0224 Response_20210507

Strickland, Bev
From: Hux, David <[e-mail]>
Sent: Friday, May 7, 2021 2:28 PM
To: Basinger, Corey; Meilinger, Michael J
Cc: Howell, Adam; Howell, Cameron; Greene, Brad; Wilkins, Karen; Hubbard, Chad
Subject: [External] Shelby SSO Responses - NOV 2021-DV-0224 SSO
Attachments: Linton Barnette Response Letter.pdf; Randolph Road Response Letter.pdf
Importance: High
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
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Please find the City of Shelby's responses to Notice of Violation #NOV-2021-DV-0224. A hard copy has been mailed via
certified mail. Please contact me if you have any questions.
David Hux
Director of Water Resources
City of Shelby
PO Box 207
Shelby, North Carolina 28151-0207
Phone [phone]
Shelby
NORTH CAROLIN /
•
1

Shelbv
NORTH CAROLINA
Post Office Box 207 . Shelby, NC 28151-0207
May 7, 2021
Mr. Corey Basinger, Regional Supervisor
Division of Water Resources, Mooresville Regional Office
610 East Center Avenue, Suite 301
Mooresville, NC 28115
Re: Notice of Violation
Tracking #NOV-2021-DV-0224
Sanitary Sewer Overflow —1600 Linton Barnette Drive — March 2021
Collection System Permit #WQCS00037
City of Shelby, Cleveland County
Dear Mr. Basinger:
The City of Shelby received the above referenced Notice of Violation regarding the sanitary sewer
overflow that occurred on March 26, 2021 at 1600 Linton Barnette Drive.
The location was inspected/checked by City personnel during a major flooding at 9:35 am, sewer crews
responded and were on the scene by 9:35 am and the problem was corrected at 2:30 pm. This spill
resulted in an overflow of 50,500 gallons, of which 50,500 gallons reached the First Broad River.
This spill event stemmed from a torrential rainfall event. The rain event dumped 3.5" + of precipitation
on portions of Shelby, resulting in localized flooding of ditches and streams. Based on rainfall data
collected the average monthly rainfall total for the month of March is 4.7 inches. March of 2021 totals
was 6.7 inches which has been the wettest since 2011. Over the course of the last 1 %2 years we have
seen more flooding events than the previous 8 plus years.
Four sewer outfalls come together in this area and combine to flow to the WWTP with at least two of
these lines being susceptible to flooding with low lying manholes within the floodplain. This and past
spills in this area have all been when the creeks/streams have come out of the banks resulting in
flooding. The tributaries within this area are collection points for flood/storm waters for much of the
southwest area of Shelby.
In 2015, the City implemented improvements in the area to correct some "damming" affects from the
collection lines coming together in this area. At this same time the City conducted improvements of the
First Broad Outfall going into the treatment plant to ensure that flow is not restricted.
Evaluations since then have included Tunnel Evaluations in 2013 to evaluate the condition of the City's
downstream sewer outfall tunnels to make sure that tunnels were structural sound and problems did
not exist causing flows to be restricted. Evaluations and cleanings have also been conducted since 2013
www.cityofshelby.com

of the sewer lines from this overflow location to the First Broad WWTP. In 2019 the outfall south of this
area was completely cleaned from College Road to the WWTP. In 2018/19 the City completed a $6.6
million upgrade to the City's Influent/Preliminary Treatment at the First Broad WWTP, which included
and increased main lift pumping capacity from 16.0 MGD to 24.5 MGD.
Since 2009, the City has been very active in areas above this spill location to reduce inflow and
infiltration through several collection system improvement projects:
Improvement and Preventative Maintenance Projects — Above and Below the Spill location
• Royster Avenue Sewer Rehabilitation 2009 —1,340 ft
• Putnam/Wilmouth/Dodd 2013 —1,520 ft
• Outfall Upgrades 2015 — 863 feet replaced. WWTP Main Outfall and Linton Barnette
• Uptown Sewer Improvements Phase 1 2018 — 620 ft
• West Shelby Sewer Rehabilitation 2016 — 3,400 ft
• Arey Trade 2016 — 500 ft
• Sumter Street 2016 — 430 ft
• Trade/Dale 2016 — 570 ft
• Leander Street 2017 —170 ft
• Campbell/Trade 2017 — 500 ft
• Arey and Trade Sewer Replacement 2017 — 504 Feet Replaced
• Dale, Trade & Morgan Replacement 2017 — 529 Feet Replaced
• Mark Drive 2018 — 585 ft
• Broad Street Sewer Repairs 2018 —1,400 ft
• Numerous point repairs
With these projects we have removed gutter drains from the collection system (Uptown Area) and
reduced I&I from broken sewer lines and bad sewer taps. These improvements have resulted in the
replacement of nearly 13,000 feet of sewer lines. Along with this rehabilitation, the City has conducted
the following preventative maintenance activities:
Preventative Maintenance Projects
• Surveying of Manhole Rims & Inverts — 2021 (Ongoing)
o Comparing manhole rim elevation to flood plains in the area.
o Review of sewer line slope.
• Acoustic Testing of Major Outfalls in this area — Recent testing 2021
• Manhole Inspections in this area — Most recent in 2021
• Sewer Line Inspections by Camera — Various areas Annually throughout the collection system
• Flow Monitoring Evaluations — 2009 & 2015
▪ Preventative Maintenance activities - Rodding and Jetting of First Broad Outfall (Various)
• External Contractor Cleaning of First Broad Outfall 2019 — Highway 150 to WWTP
• Sanitary Sewer Inventory and Assessment Project (Grant) 2018-2019
o Included Cleaning and Sewer Video of critical sections in West Shelby and Uptown area
Maintenance history — Outfall lines have been cleaned and evaluated via camera (video) from
the overflow point south to the First Broad WWTP. The overall condition of these outfalls is
good. City has also provided cleaning and evaluation above the overflow point. In 2019 several
critical sections above the overflow point were evaluated in the Sanitary Sewer Inventory and
www.cityofsh nl h_y.co rn

Assessment Grant Project. Many of these areas will be added to the Capital Improvement
Program and prioritized.
Your letter lists ten areas of review in consideration for determining civil penalty amounts for a sanitary
sewer overflow. We have included the following brief responses for each item:
• Volume — 50,500 gallons
• Volume reaching surface waters — 50,500 gallons
• Duration and gravity — 255 minutes
• Impacts to public health - There were no identified impacts to public health.
• Fish kills - No fish kills were observed following this overflow.
• Recreational area closures - No recreational areas were closed due to this overflow.
• History of spills — There have been four (4) reportable spills at this location.
February 22, 2019 February 6, 2020 November 12, 2020 March 26, 2021
• Cost of rectifying damage —
No environmental damage was identified requiring remediation. City staff performed
cleanup and lime application.
• Intentional spill —
These overflows were not intentional and were a result of heavy rainfall within a short
period of time resulting in flash flooding of roads, ditches and creeks. Over three and a half
inches of rain fell in parts of Shelby in a short amount of time with soils that were saturated.
• Money saved by non-compliance —
No money was saved by this non-compliance.
The City has significantly improved our SSO history, however our efforts have not totally corrected
issues in this area resulting from severe flooding of streets and creeks. The City of Shelby is reviewing
the possibility of placing manhole inserts or sealed manhole lids in low lying areas to help combat the
inflow issues in this area. Surveying of two of the main outfalls above this area is scheduled to begin to
determine rim and invert elevations of the manholes. City will compare/evaluate these elevations and
flood zone elevations.
As a longer -term option, the City is also conducting a future service evaluation of the western sections
of the sewer system within this area of Polkville/Randolph Roads. Part of this evaluation would provide
service alternatives and costs that would more than likely include combining multiple Iiftstations into
one new liftstation south of Randolph Road. The flows from these areas currently flow through the
Linton Barnette Area. The City will consider redirecting/pumping the flows from this area to the
Westside Sewer Outfall that flows to the Westside Crest Liftstation and is pumped directly to the First
Broad WWTP. This option will reduce flows from the First Broad Outfalls. The City will consider these
recommendations and add this project to the City's prioritized Capital Improvement Program in a year
that has yet to be determined.
w w w.cityo fs h e l by.carn

We recognize the requirements of our wastewater collection system permit and the importance to the
environment and public health in the prevention of sanitary sewer overflows. The City of Shelby has
experienced a downward trend of sanitary sewer overflows in our system and the City has shown a good
faith effort to make significant improvements to the City's sewer collection system and Wastewater
Treatment Plant. The City estimates that we have spent nearly $35 million in upgrades to the WWTP
and another $12-15 million in improvements to the City's collection system in the last 10 years. While
this location is important, we ask NDEQ to consider that we are attempting to make necessary repairs
across a 200+ mile collection system. The City is proud of the improvements that we continue to make
and requests that NCDEQ recognize the efforts that have been made and requests that the issuance or a
civil penalty assessment for the subject spill be withheld.
Please contact me at anytime regarding any further information or questions you might have regarding
this issue. I can be reached at 704-669-6570 or [e-mail].
incerely, lit thott)t
David Hux
Director of Water Resources
cc: Rick Howell; City Manager
Adam Howell; Collection System Crew Supervisor/ORC
Brad Greene; Plant Operations Superintendent
Certified Mail: 7013 2250 0001 6246 9752
www.cityofshelby.com

ROY COOPER
Governor
DIONNE DELLI-GATTI
Suntory
S. DANIEL SMITH
Director
Certified Mail # 7019 1120 0000 8362 1021
Return Receipt Reauested
Rick Howell, City Manager
City of Shelby
PO Box 207
Shelby, NC 28151-0207
NORTH CAROLINA
Environmental Quality
April 22, 2021
SUBJECT: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Tracking No.: NOV-2021-DV-0224
Sanitary Sewer Overflows - March 2021
Collection System Permit No. WQCS00037
Shelby Collection System
Cleveland County
Dear Mr. Howell:
A review has been conducted of the self -reported Sanitary Sewer Overflows (SSO's) 5-Day Report/s submitted by
City of Shelby. The Division's Mooresville Regional Office concludes that the City of Shelby violated Permit
Condition I (2) of Permit No. WQCS00037 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 Mooresville Regional Office is providing the City of Shelby an opportunity to provide evidence and justification
as to why the City of Shelby 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
202101098 3/26/2021 140 703 Hanover Drive Inflow and Infiltration 1,400 1,400 Notice of Violation
202101099 3/26/2021 255 1600 Linton Barnette Inflow and
Drive
Infiltration, Severe
Natural Condition
50,500 50,500 Notice of Violation
Intent to Enforce
202101100 3/25/2021 600 1902 Randolph Rd Severe Natural 2,400 2,400 Notice of Violation
(Randolph LS) Condition Intent to Enforce
Nrclh Caroline Depsr 'men' of Enrlronmenlal Quail* I Olvhbn d Wmer aewurces
Moor,,944 Regional Office 1610 Ean Curler Arenue.5uhe 301 I MoanNlle. North Carolina 28115
704 Mtl l6'W

Totic'e a Via i[ _ Rio i q Intent to Enforce (NOV/NOI) is being issued for the noted violation. Pursuant
t : 143-215.6A, a civil of not more than twenty-five thousand dollars ($25,000.00) may be assessed
a.g i 2 t any person who viol s r fails to act in accordance with the terms, conditions, or requirements of any
peoSit issued pursuant to G- 3-215.1.
This,Qffice requests that you respond to this Notice, in writing, within 10 business days of its
receipt. In yourTesponse; 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 Michael Meilinger or me with the Water Quality Section
in the Mooresville Regional Office at 704-663-1699 or via email at michael.meilingerCcincdenr.gov or
cor_ey.basiflgeTO)ncden3 c)v.
Sincerely,
DocuSigned by:
Al 4CC681AF27425.._
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
North Caro4ne Deperlaenl of CnNranamul Quelhy 1 olenkn of W4IN Reeaacea
Me9mMle Repbrul Duke 1210 Earl [enter Aw99#.. Sale 301 1 Moo.. ., North C.r0Ana 28115
704 6631699

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NORTH A OLINA
Post Office Box 207 Shelby, NC 28151-0207
May 7, 2021
Mr. Corey Basinger, Regional Supervisor
Division of Water Resources, Mooresville Regional Office
610 East Center Avenue, Suite 301
Mooresville, NC 28115
Re: Notice of Violation
Tracking #NOV-2021-DV-0224
Sanitary Sewer Overflow —1902 Randolph Road — March 2021
Collection System Permit #WQCS00037
City of Shelby, Cleveland County
Dear Mr. Basinger:
The City of Shelby received the above referenced Notice of Violation regarding the sanitary sewer
overflow that occurred on March 25, 2021 at 1902 Randolph Road.
The spill was reported by City of Shelby personnel at 6:48 pm on March 25, 2021, sewer crews
responded and were on the scene by 7:00 pm on March 25, 2021 and the problem was corrected at 6:30
am on March 26, 2021. This spill resulted in an overflow of 2,400 gallons, of which 2,400 gallons
reached Brushy Creek.
This spill event stemmed from a torrential rainfall event. The rain event dumped 3.5" + of precipitation
on portions of Shelby, resulting in localized flooding of ditches and streams. Based on rainfall data
collected the average monthly rainfall total for the month of March is 4.7 inches. March of 2021 totals
was 6.7 inches which has been the wettest since 2011.
The system in this area (gravity/Iiftstation) was installed and operated by the Doran Mill until the City of
Shelby took over the lines and station in 1999. When the system was installed, the Mill had their own
treatment system and private discharge. In that era, mills would also connect some non -sewer drainage
to the sewer system. This portion of that system is made up of around 7,162 feet of line and 35
manholes and the Randolph Road Liftstation. There are 23 customers that contribute to this portion of
the sewer system. The largest contributors are the two old mills in the area. One of the mills is
approximately 300,000 square feet (Mostly 2-story) and the other is approximately 155,000 square feet.
The other contributors are eighteen (18) homes, two (2) businesses, and one (1) Church.
www.ci tyofsbelby,com

After the City took the system over in 1999, the City had issues with overflows after the demolition of
several old mill homes. Spills occurred in 2004 & 2005 and the City responded by removing a large
portion of the gravity system. This corrected the station overflows.
In 2013 the City upgraded the Randolph Road Lift Station pumps and electrical. The lift station is rated
to pump at a rate of 130 to 140 gallons per minute.
Over the course of the last couple of years the City has seen increase of I&I into the City and has
investigated the sources of this additional water. A few point repairs were made in the area; however,
most of the water has been traced to the old Mill that is currently only being used for warehousing.
The City conducted smoke testing around the mill and determined that the Mill's owners had connected
storm drains to the sanitary sewer system. The City has met with the owners on a couple of occasions
to discuss our findings and has also coordinated efforts to inspect the inside during a smoke testing
event.
In response the owner has removed the gutter discharges from the sewer; however the problem is not
completely resolved. The City and owners are still working together with the property owner to resolve
I&I contributions.
The City has conducted the following preventative maintenance activities to help combat the I&I coming
into this station:
Preventative Maintenance/Corrective Action Projects
• Randolph Road Sewer Capacity Study - 2000
• Abandoned unused sewer lines at the Mills — Early 2000's
• Randolph Road Lift Station Upgrade — 2013
o Upgrade of the existing pumps in the station.
• Upstream I&I Manhole Repairs — 2020
o Repaired a hole in an invert that was causing I&I.
o Removed and plugged old service tap that was causing I&I.
• Smoke Testing of sanitary sewer system — 2020
• Repair of sewer lines from smoke test results — 2020
o Replaced a portion of 8" sewer line due to hole in the pipe.
• Westside Sewer Evaluation — 2021 (Ongoing)
o Evaluation to see if a single lift station can replace three lift stations in this area. This
includes the Randolph Road Lift Station.
• Upstream Manhole Inspections - Routine
• Removal of Stormwater connections at the Mills (Property Owner)
o Continuing to work with the mills to find other sources of I&I.
Maintenance history — The City has performs periodic cleaning and evaluation upstream and
downstream of the overflow point. The overall condition of these lines is good. The liftstation was
upgraded in 2013 and is inspected weekly. Both pumps are in good condition and operational.
Your letter lists ten areas of review in consideration for determining civil penalty amounts for a sanitary
sewer overflow. We have included the following brief responses for each item:
vww.Lity❑isIisl hy.cum

• Volume — 2,400 gallons
• Volume reaching surface waters — 2,400 gallons
• Duration and gravity — 600 minutes
• Impacts to public health - There were no identified impacts to public health.
• Fish kills - No fish kills were observed following this overflow.
• Recreational area closures - No recreational areas were closed due to this overflow.
• History of spills — There have been six (6) spills at this location since 2004.
June 16, 2004
August 19, 2010
September 7, 2004
February 6, 2020
October 7, 2005
March 25, 2021
• Cost of rectifying damage —
No environmental damage was identified requiring remediation. City staff performed
cleanup and lime application.
• Intentional spill —
These overflows were not intentional and were a result of heavy rainfall and l&I within a
short period of time resulting in flash flooding of roads, ditches, and creeks. Over three and
a half inches of rain fell in parts of Shelby in a short amount of time.
• Money saved by non-compliance —
No money was saved by this non-compliance.
As noted above, the City will continue work with the mill owner and make strides to reduce the I&I
contribution from the mill. The City has local septic haulers that can and have assisted the City during
periods of higher flow. The City will also evaluate increasing the pump capacity if the mill cannot resolve
this additional flow discharge.
As a longer -term option, the City is also conducting a future service evaluation of the western sections
of the sewer system within this area of Polkville/Randolph Roads. Part of this evaluation would provide
service alternatives and costs that would more than likely include combining multiple liftstations into
one new liftstation south of Randolph Road. It is the City's intention to add this project to the City's
prioritized Capital Improvement Program.
We recognize the requirements of our wastewater collection system permit and the importance to the
environment and public health in the prevention of sanitary sewer overflows. The City of Shelby has
experienced a downward trend of sanitary sewer overflows in our system and the City has shown a good
faith effort to make significant improvements to the City's sewer collection system and Wastewater
Treatment Plant. The City estimates that we have spent nearly $35 million in upgrades to the WWTP
and another $12-15 million in improvements to the City's collection system in the last 10 years. While
this location is important, we ask NCDEQ to consider that we are attempting to make necessary repairs
across a 200+ mile collection system. The City is proud of the improvements that we continue to make
and requests that NCDEQ recognize the efforts that have been made and requests that the issuance or a
civil penalty assessment for the subject spill be withheld.
www.cityoCsheIby.com

Please contact me at anytime regarding any further information or questions you might have regarding
this issue. I can be reached at 704-669-6570 or [e-mail].
Sincerelr,( 14/
-)thi(
David Hux
Director of Water Resources
cc: Rick Howell; City Manager
Adam Howell; Collection System Crew Supervisor/ORC
Brad Greene; Plant Operations Superintendent
Certified Mail: 7013 2250 0001 6246 9752
www.cityofshelby.com

ROY COOPER
Coo n,or
DIONNE DELLI-GATTI
Secretary
S. DANIEL SMITH
Director
Certified Mail # 7019 1120 0000 8362 1021
Return Receipt Requested
Rick Howell, City Manager
City of Shelby
PO Box 207
Shelby, NC 28151-0207
NORTH CAROLINA
Environmental Quality
April 22, 2021
SUBJECT: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Tracking No.: NOV-2021-DV-0224
Sanitary Sewer Overflows - March 2021
Collection System Permit No. WQCS00037
Shelby Collection System
Cleveland County
Dear Mr. Howell:
A review has been conducted of the self -reported Sanitary Sewer Overflows (SSO's) 5-Day Report/s submitted by
City of Shelby. The Division's Mooresville Regional Office concludes that the City of Shelby violated Permit
Condition I (2) of Permit No. WQCS00037 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 Mooresville Regional Office is providing the City of Shelby an opportunity to provide evidence and justification
as to why the City of Shelby 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
202101098 3/26/2021 140 703 Hanover Drive Inflow and Infiltration
202101099 3/26/2021 255 1600 Linton Barnette Inflow and
Drive
Infiltration, Severe
Natural Condition
1,400 1,400 Notice of Violation
50,500 50,500 Notice of Violation
Intent to Enforce
202101100 3/25/2021 600 1902 Randolph Rd Severe Natural 2,400 2,400 Notice of Violation
(Randolph LS) Condition Intent to Enforce
9J Nonhcarotlne Depwlmml ornM1I Cen l Avenue 1 alel': of Weteraeswces
J//B Nno, ll4 RrglaeNdllce 1610EeN Cemer Menoe.5lAe 7011 Mn4lk, North Ca roll. 2B115
704667169n

•
6 5 .
otice of- Oa 1.1,p9 Intent to Enforce (NOV/NOI) is being issued for the noted violation. Pursuant
f 143-215.6A, a civil of not more than twenty-five thousand dollars ($25,000.00) may be assessed
ag i�st any person who viol s r fails to act in accordance with the terms, conditions, or requirements of any
�
pe(rhit issued pursuant to G• 3-215.1.
Thiis,RfOce requests that you respond to this Notice, in writing, within 10 business days of its
receipt. In yourT sponse; 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 Michael Meilinger or me with the Water Quality Section
in the Mooresville Regional Office at 704-663-1699 or via email at [e-mail] or
[e-mail].
Sincerely,
f—DocuSigned by:
`— A14CC681 AF27425...
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
No.h Carolina Depxlmenl of EnNrunmenlal Qaaby 1 Division of Wolof Rmources
MoornMle ReybnJ Office 1610 Earl timer Avenue. SWe 301 1 Moorerv4E. Narlh Carolina MI5
10e 6631699

CITY OF SHELBY ® SEWER OVERFLOWS
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