WQ0041587_NOV-2020-CV-0004_20200504

Engineering Services Department
Terry Kuneff, P.E., CFM
April 28, 2020
Terry Houk
Public Services Director
High Point, North Carolina27260
RE: Meadow Valley Subdivision, Phase 5
Proposed Sanitary Sewer
Dear Terry:
I am writing this letter to explain and document the Engineering Services Department's role in the
construction of the proposed sanitary sewer at Meadow Valley Subdivision, Phase 5. The final proposed
subdivision plans including proposed sanitary sewer were reviewed and approved by the City of High Point
Technical Review Committee (TRC) on October 11, 2019. Ed Brunton, Engineering Services Department
construction inspector, first noticed sanitary sewer pipe delivered to the site on October 9, 2019. The
contractor began installing the gravity sanitary sewer on St. John Street and Brayden Drive once TRC
approved the subdivision plans. Ed Brunton tested and passed the portion of the gravity system that was
installed on December 11, 2019. Construction slowed down during the winter and picked back up in the
spring. The contractor installed the rest of the gravity sanitary sewer on Braydon Drive and one section of
pipe that would connect to the proposed lift station once it was constructed. Ed Brunton tested and passed this
part of the gravity sanitary sewer system on Apt -it 9, 2020. The proposed lift station and force main have not
been constructed. None of the gravity sani&ry sewer systems that have been constructed and tested have been
connected to any permitted sewer outfalls. Also, the City of High Point has not accepted the sanitary sewer
system for maintenance.
The Engineering Services Department has since changed our Standard Operating Procedure to require a copy
of the Authorization to Construct (ATC) to be provided to our construction inspector prior to conducting any
inspections or testing.
If you have any questions or concerns, please contact me at [phone].
Sincerely,
Terry A. Kuneff, P.E.,
Interim Engineering Services Director
City of High Point, P.O. Box 230, 211 South Hamilton Street, High Point, NC 27261 USA
Fax:[phone] Phone:[phone] TDD:336,883.8517

Public Services Department
Date: April 30, 2020
To: Lon T. Snider
Winston Salem Regional Office
Division of Water Resources — NCDEQ
From: Terry L. Houk, Public Services Director
Re: Notice of Violation and Intent to Assess Civil Penalty
Tracking No. NOV-2-2-CV-0004
Construction/Expansion of Sewer Extension without a permit
Wastewater Collection System Extension
Meadow Valley Phase 5 (Public), High Point, NC
Guilford County
Dear Mr. Snider,
NORTH CAROLINNS INTERNATIONAL CITr'
I" �, DePartment Q'r
Environmental Quality
Received
6�111Y 0 4 2ca
Winston-Salem
Regional OfNce
As requested by your letter dated April 9, 2020, 1 am providing additional information regarding the
noted violation and an explanation as to why the Division should not assess a Civil Penalty in the matter.
Please see explanation below:
The City acknowledges receiving a letter on November 1, 2019 stating the Division of Water Resource's
Winston Salem Regional Office was unable to accept the Meadow Valley Subdivision, Phase 5
application package due to three failures. (see attachment letter). The design engineer, Vince C.
Townsend (Green Mountain Engineering, PLLC), also received a copy of the letter sent November 1,
2019 and was aware ATC was not approved. The City was working with Davis -Martin and Powell to
address these issues and submit information requested so the application could be processed.
The City submitted a permit modification on April 14, 2020 for Waterview Pump Station (existing Permit
No: WQ0024300) to NCDEQ— Division of Water Resources to the attention of Justin Henderson to rerate
the station from a duplex to at triplex and increase the pumping capacity from 1300 GPM to 1550 GPM.
The increase in pumping capacity would rerate the station to 2.232 MGD. (See attached pdf. transmittal
cover letter from Ben Palmer-DMP)
Also, on April 24, 2020 a permit modification (Permit No. WQ0037661) was submitted to NCDEQ
Division of Water Resources attention Jenny Graznak as per NCDEQ request. (See attached pdf. of
transmittal cover letter from Andy Larrick - DMP)
The City of High Point acknowledges that Meadow Valley Subdivision, Phase 5 does not have an
Authorization to Construct the sewer system, and the contractor should not have installed the lines.
However, apparently the contactor proceeded to install the sewer line as designed without the proper
authorization. The City of High Point Engineering Services Department performed inspections and
testing of the gravity sanitary sewer system. The system was installed correctly and to City of High
City of High Point, P.O. Box 230, 211 South Hamilton Street, High Point, NC 27261 USA
Fax:[phone] Phone:[phone] TDD:336.883.8517

Public Services Department
Point's requirements, however, the system has not been accepted by the City for maintenance and
operations. The gravity sanitary sewer system is not connected to any permitted sewer outfalls. The
gravity system is proposed to connect to the recently permitted lift station and force main once it is
constructed. The City of High Point Engineering Services Department has since modified their
operational protocols not to conduct inspections or testing unless they see the ATC from the Contractor
(See documentation from Terry Kuneff, City of High Point Interim Engineering Services Department
Director).
The City of High Point accepts the Notice of Violation, but requests that NCDEQ waive the civil penalties
for the City since the contractor is ultimately responsible to verify an Authorization to Construct for
sewer or water systems before beginning installation. Also, the Meadow Valley Subdivision, Phase 5
sanitary sewer system is not connected to any permitted sewer outfalls.
Please feel free to contact me for any additional information. The City welcomes the opportunity to
meet with NCDEQ staff to further discuss and resolve the items addressed In the Notice of Violation.
Sincerely,
Terry L. HB
Pubic Services Director
City of High Point
CC: Randy McCaslin, Deputy City Manager
Derrick Boone, Assistant Director of Public Services
Terry Kuneff, P.E., Interim Engineering Services Director
File
City of High Point, P.O. Box 230, 211 South Hamilton Street, High Point, NC 27261 USA
Fax:[phone] Phone:[phone] TDD:336.883.8517