WQCS00054_Other Correspondence_20190417

Public Works
500 North Main Street
Suite # 600
Monroe, NC 28112
T. 704-296-4210
April 17, 2019
Mr. W. Corey Basinger
Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
610 East Center Ave., Suite 301
Mooresville, NC 28115
Subject: Notice of Violation
Tracking #: NOV-2019-DV-0194
Sanitary Sewer Overflow =March 2019
Collection System Permit — WQCS00054
Union County
Dear Mr. Basinger:
Union County has received the NOV referenced above for a collection system overflow.
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Explanations of the overflows were on the BIMS Overflow Reporting Forms submitted by Union
County Public Works (UCPW) to the NCDEQ. However, we have added a few additional facts
in the explanations below.
Incident_ Location
Response:
The SSO's listed in this section were due to I&I introduction during heavy rains and flash
flooding. The system associated with this area was inundated with floodwaters and increased
flows at CCWRF. The new CCWRF EQ system was being utilized to absorb the flow brought on
by the heavy rain. During peak hours the additional flow coupled with II in the system caused
hydraulic overload resulting in the SSO.
Union County Public Works has underwent a comprehensive Master Plan (Black & Veatch) and
improvements strategy in efforts to better identify areas of improvement within the Crooked
Creek basin. Efforts such as flow monitoring studies (CDM Smith/Hydrostructures and Frazier
Engineering) to identify areas of inflow and infiltration, capacity assessments of the CCWRF and
associated lift stations, lift station assessments to identify aging infrastructure, among others.
As a result of these studies, UCPW has developed a CIP plan to address certain areas of
concern.

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 removal/dewatering, 3MG EQ basin, and relocation of 1200' of 18" gravity sewer.
CDM Smith is the design engineer. MB Kahn is the general contractor.
I&I flow studies have been conducted by CDM Smith (Hydrostructures) and Frazier
Engineering. 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 2017 target 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 contract
was executed with AM Liner to complete the rehab work. Work has begun of the focused area is
due to be completed by the fall of 2019.
UCPW also has an aggressive Capital Improvement Program throughout the next 5 years. The
projects include:
Crooked Creek Interceptor Improvements Ph. 1 - $9,915,500.00
> Suburban Estates PS and FM - $1,000,000.00
Waxhaw Interceptor — 3,200,000.00
WW PS Improvements - $3,600,000.00
➢ Collection System SSES & Rehab — $2,080,000 (not including $85k annually in
Operations)
PS Upgrades - $300,000 annually
UCPW's current CIP projects are also ongoing with projects including:
Waxhaw Sewer Improvements - $295,000.00
Blythe Creek Sewer Improvements - $3,083,200.00
Forest Park PS Replacement & Interceptor Improvements - $2,540,000.00
9 Crooked Creek I&I Study & Remediation - $2,538,300.00
Suburban Estates PS replacement-$933,000.00
Union County Public Works continues to invest funds into SSES work, capital improvements,
maintenance and operations to improve the wastewater collection system. If further information
or details regarding the CCWRF Improvements, as well as, the CIP projects listed above are
required, please feel free to contact Greg Morgan, Superintendent/ORC, at 704-289-3288 or
myself at 704-296-4215.
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Thank you for your consideration on this issue.
Sincerely,
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Andrew Neff, PE
Water/Wastewater Division Director
CC: Aubrey Lofton, PE, Interim Executive Director
Josh Brooks, Assistant Oin8ctO[' \8/ate[yWGStSvvat8r{}p8[otionS

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MICHAEL S. REGAN
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LINDA CULPEPPER
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NORTH CAROLINA
Environmental Quality
CERTIFIED MAIL: 7017 2620 0000 6788 4989
RETURN RECEIPT REQUESTED
April 11, 2019
Monroe, NC 28112
Tracking No.: NOV-2019-DV-0194
Sanitary Sewer Overflows - March 2019
Collection System Permit No. WQCS00054
Union County Collection System
Union County
Dear Mr. Watson:
A review has been conducted of the self -reported Sanitary Sewer Overflows (SSO's) 5-Day Report/s submitted by
Union County. The Division's Mooresville Regional Office concludes that the Union County violated Permit Condition
1 (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 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.
143-215A.
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 (Mims) Location Cause (Gals) (Gals) DWR Action
201900499 3/3/2019 180 4015 Sardis Church Inflow and 2,100 2,100 Notice of Violation
Road Infiltration, Severe w/ Intent to Enforce
Natural Condition
No I r, CA 10 1 i=s Dep a nment 0 En V"I'an men--S: QU $ Iy I D�Y'I'or �f t"' $It f
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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 ($25,000,00) 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 me in the Mooresville Regional Office at 704-663-1699
or via email at [e-mail].
Sincerely,
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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
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