WQ0041163_NOV-2019-CV-0006 Response_20191008

Hugh Creed Associates, Inc. P.A.
Consulting Engineers & Land Surveyors
1306 W. WENDOVER AVENUE P.O. BOX 9623
GREENSBORO, N.C. 27408 GREENSBORO, N.C. 27429
TELE: [phone] OR [phone] FAX: [phone]
FIRM LICENSE #C-0551 E-MAIL: HCA(aHUGHCREEDASSOCIATES.COM
October 1, 2019
Description of Events
North Carolina Department of Environmental Quality
Division of Water Resources — Winston-Salem Regional Office
450 West Hanes Mill Road
Suite 300
Winston-Salem, NC 27105
Attn: Lon Snider, Regional Supervisor
Re: Steeplegate Village — Phase 1
City of Trinity
Permit No.: W00041163
Tracking NO. NOV-2019-CV-0006
Dear Mr. Snider,
This letter is to provide additional information regarding the sequence of events leading
to the Notice of Violation referenced by the Tracking No. above.
Around June 4th, 2019, Our client, Steeplegate Village, LLC, showed interest in
beginning work on the 38 Lots of Steeplegate Village Phase 1 for the Sewer Extension to
Hamby Creek WWTP. On that date plans were sent to John Cranford with the City of
Trinity Utilities for review, as well as a partially filled FTSA indicating Flow requested
and Length of Gravity Line to be added. Plans marked up and "approved" by the city of
Trinity were returned to our office on June 71h, 2019.
On June 19`h, 2019, Randy McNeill (Consulted Engineer for City of Trinity), sent us the
completed FTA, which was signed by myself and returned that same day via Email to
John Cranford, Mark Allred (City of Trinity Planner), Morgan Huffman (Thomasville
Utilities), and Randy McNeill. At that time, the FTSE had been sent to Ms. Huffman of
Thomasville by Mr. McNeill, for the necessary signature from Ms. Huffman, Utilities
Director.
On July 12`h, 2019, Mr. McNeill sent us the Completed FTSE, requesting a copy of the
permit package to himself and the city upon sending to DEQ.
On September 91h, 2019, we received notice from the Town of Trinity indicating their
inspections of the sewer and Certification of Completion was ready and asked us for the
Permit Information. At this point we searched our records and it had been determined the
completed package was never sent to the state or others by our office.

The Fast Track Sewer Extension application was then immediately sent on September 91'
2019, to the Division of Water Resources — Winston-Salem Regional Office, congruent to
previously stated understanding of events in the above referenced Notice of Violation.
Sincerely,
Hugh Creed Associates, Inc., P.A.
Norris Z. Clayton, P.E., P.L.S.
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October 1, 2019

NC Dcrzrtment of
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OCT 11 2019
Winston-Salem
Regional office
October 08, 2019
Mr. Lon Snider, Regional Supervisor
North Carolina Department of Environmental Quality
Division of Water Resources
Winston-Salem Regional Office
450 West Hanes Mill Rd
Suite 300
Winston-Salem, NC, 27105
Subject: NOTICE OF VIOLATION
Tracking No. NOV-2019-CV-006
Construction of Sewer Extension without a permit
Wastewater Collection System Extension
Steeplegate Village Phase 1
Randolph County
City of Trinity
Permit No.: WQ0041163
Authorization to Construct (ATC)
Dear Mr. Snider,
City of Trinity (City) regrets not stopping the developer from starting sewer construction
until we had the Authorization to Construct (ATC) in hand. The City was not aware that the ATC
permit was not obtained until the inspection process was nearly complete (September 9, 2019).
We immediately went to the NCDEQ website to monitor final approval of the project and found
no permit had been issued. We then contacted Hugh Creed Associates to determine the status of
the completed Flow Tracking Sewer Extension (FTSE) that was turned into Hugh Creed
Associates on July 12, 2019. During this conversation, it was verified that the FTSE was never
turned in and Hugh Creed Associates sent the FTSE to NCDEQ.
A letter from Hugh Creed Associates is attached to this letter to verify the timeline.
5978 NC Highway 62 • P.O. Box 50 • Trinity, NC 27370 • Phone [phone] • Fax [phone]

The City of Trinity will not release any permits for homes to be built on these new lots until
this situation is resolved. No wastewater has gone through the new sewer lines. The plug is still
located at the point where the new sewer line connects to the existing sewer lines.
The City of Trinity had an inexperienced Public Works Director that had not gone through a
major subdivision development from start -to -finish. The lack of experience led our Public Works
Director to believe the completed FTSE had been delivered to NCDEQ and that an ATC had
been granted. This employee resigned on September 4, 2019.
Now that staff is aware that a permit tracking website is available, we will also be checking
our project file and the website to make sure that the ATC has been received. We have changed
our procedures and added a redundant file that will be kept at the operational level.
We have created a checklist for developers to understand what is required of them for their
project. Trinity's staff and/or engineer will receive a copy of the same checklist for the project
as provided to the developer and will verify all steps are completed as required during the
process. This procedure will be followed on all major development projects with no exceptions
unless prior approval has been obtained from your office.
In the future, the City of Trinity will make sure that no sewer construction extensions will be
started until an ATC is in hand from NCDEQ.
We do apologize for any additional work and inconvenience this has caused your office.
Sincerely, `
Debbie Hinson, City Manager
City of Trinity
(1) attachment
5978 NC Highway 62 • P.O. Box 50 9 Trinity, NC 27370 • Phone [phone] • Fax [phone]