WQCS00014_NOV-2021-DV-0064_20210215

ILV
Greenville
Utilities
February 15, 2021
Mr. Robert Tankard
Assistant Regional Supervisor
NCDEQ - Division of Water Resources
Water Quality Regional Operations Section
943 Washington Square Mall
Washington, NC 27889
252-948-3921
RE: NOTICE OF VIOLATION NOV-2021-DV-0064
Sanitary Sewer Overflow on November 12, 2020
Greenfield Boulevard and Haw Drive
Dear Mr. Tankard:
We are in receipt of the Notice of Violation, dated January 26, 2021, regarding the
Sanitary Sewer Overflow that occurred on our system on November 12, 2020 at the
location of Greenfield Boulevard and Haw Drive.
As indicated in GUC's initial report on this event, the overflow resulted from a system
surcharge due to extremely high rainfall associated with Tropical Storm Eta.
Tropical Storm Eta was a severe, rare, natural occurrence. A storm frequency analysis,
developed using the National Oceanic and Atmospheric Administration (NOAA) Atlas
14, Volume 2, Version 3, which is applicable to Greenville, N.C., indicates that Tropical
Storm Eta was a 25-year storm event.
Additionally, North Carolina Governor Roy Cooper has submitted a request to FEMA for
a major disaster declaration to help with recovery after flooding caused by the remnants
of Tropical Storm Eta.
The recorded rainfall in Pitt County was 7.0" for this event. Such excessive rainfall,
along with receiving excessive inflow from the Town of Bethel, created a condition
which was beyond the wastewater handling capabilities of GUC's system. Bethel's
typical average day wastewater discharge to GUC is approximately 263,000 gallons.
Recorded wastewater flow from the Bethel's wastewater system to GUC's system during
this event was approximately 1.4 million gallons. This was a fivefold increase in
PO Box 1847
Greenville, NC 27835
www.guc.com
Your Local
Advantage
Ai/O

Mr. Robert Tankard
February 15, 2021
Page 2 of 3
wastewater volume being discharged to GUC 's system in a single day. This was a
condition that no wastewater system is engineered to handle, nor is it realistic to expect
such volumes to adequately be properly conveyed in such a short period of time.
GUC's response to this event included arriving onsite prior to the overflow and taking
preemptive action in an attempt to prevent the overflow from occurring. Being unable to
prevent the overflow, GUC personnel responded immediately with mitigation and
cleanup efforts once the overflow had subsided. We also note that GUC personnel
assisted the Town of Bethel in mitigating the issues with their main pumping station that
were contributory to the inundation of both GUC's and Bethel's systems.
You may, or may not be, aware, of the current project being worked on among GUC,
Bethel and the DEQ.
The deteriorated condition of the Town of Bethel's wastewater system has been well
documented, as I'm sure your office is aware.
It is well known that Bethel has severe I/I problems on their system. During certain heavy
rainfall events this excessive I/I can overwhelm the GUC pipelines serving the Town of
Bethel, causing system overflows.
For the past 18 months, or more, GUC has been working diligently with the DEQ and
Bethel to arrange for the GUC takeover of both Bethel's water and wastewater systems.
As a part of this process, GUC conducted its own assessment of Bethel's systems and
developed a plan of action. This plan was submitted to, and approved by, the DEQ. In
addition, a preliminary engineering report was developed and approved by DEQ. The
preliminary engineering report calls for the construction of approximately $3.4 million of
improvements to Bethel's wastewater system. These improvements will serve to
eliminate the majority of I/I currently being experienced on Bethel's system. $3.0 million
of this funding is being provided by State SRF grants.
There has been extensive coordination among GUC, Bethel and the DEQ over the past 18
months on this project. DEQ is aware of the plan, schedule, and project status. The
current schedule is for GUC and Bethel to execute the agreement for Bethel to transfer its
water and wastewater assets to GUC in the March -April time frame. GUC has already
advertised for engineering proposals for the design on the infrastructure improvements in
Bethel. Construction of the improvements on Bethel's wastewater system should be
underway in late 2021 or early 2022.
The fact that GUC, along with its partners, is working on the Bethel project described
above does not lend itself to the NOV conclusion of GUC "failing to effectively
manage". On the contrary, pursuance of such a project lends itself to the conclusion that
GUC continues to maintain its reputation of professionally & effectively managing all its
enterprise systems.

Mr. Robert Tankard
February 15, 2021
Page 3 of 3
Considering the above information, we take issue with issuance of this NOV and with the
language in the NOV stating, "Violations include failing to effectively manage, maintain,
and operate the subject collection system".
The SSO which occurred on November 12, 2020, while unfortunate, was the result of a
force majeure event (25-year storm) creating natural conditions that were beyond the
capacity of the wastewater systems (GUC's and Bethel's) to handle.
Over the past two decades GUC has spent millions of dollars on its sanitary sewer
rehabilitation program. This program has resulted in GUC lining numerous miles of
pipeline and significantly reducing system I/I. GUC continues with that effort today,
having recently awarded an approximately $2.0 million contract for additional sewer
rehabilitation work. Programs such as these do not support a conclusion that GUC is
"failing to effectively manage its system".
GUC personnel are professional, competent, and diligent in their day to day efforts to
operate and maintain the GUC wastewater collection system in compliance with all the
requirements of the System -Wide Wastewater Collection System Permit. Based on the
above documentation, GUC is of the opinion that any enforcement action in connection
with this SSO is not warranted.
Lastly, if the Governor of North Carolina has concluded that the event that caused the
subject overflow was a major flooding disaster, one would hope that his regulatory
agencies would also recognize the storm's effects and expect SSO's, beyond the control
of the system's owners, to occur. Such events do not warrant the issuance of NOVs.
Should you have any questions or require any additional information regarding this
matter, please let us know.
Sincerely,
1
c� ' 2:4)
Randall D. Emory, P.E
Director of Water Resources
RDE/lab
c: Anthony C. Cannon, General Manager/CEO
Philip R. Dixon, GUC General Counsel
David W. Springer, P.E. — Assistant Director of Water Resources
J. Scott Farmer, P.E. — Water Resources Systems Engineer
Bryan P. Bland, Water/Sewer Systems Superintendent
M. Jason Manning — WWTP Superintendent
Ms. Sarah Toppen — NCDEQ WaRO