WQCSD0733_NOV-2021-DV-0203 Response_20210513

ighlands
nvironmental
olutions, Inc.
8410-D Falls of Neuse Road: Raleigh. NC
May 13, 2021
Mr. Scott Vinson
North Carolina Department of Environmental Quality
Division of Water Resources
3800 Barrett Drive
Raleigh, North Carolina 27609
Subject: Response to Notice of Violation
City Hall Properties — 500, 506, and 508 Jones Ferry Road; Chapel Hill, North Carolina
HES Project #
Dear Mr. Vinson:
On behalf of our client, Highlands Environmental Solutions, Inc. (HES) hereby submits this correspondence in
response to the Notice of Violation (NOV) dated April 28, 2021 to City Hall Properties, LLC. This NOV was issued
in regards to an unpermitted sanitary sewage discharge at the property.
The cause of the release was an accumulation of grease in the underground sewer pipe prior to discharge to the
Town of Carrboro sewer main. This resulted in the back-up of sewage, eventually discharging from a sewer clean
out on the West side of the strip mall building on the structure. The release was discovered on April 1, 2021, and
impacted the ground surface behind the strip mall building and a wooded area immediately adjacent to the West.
Mr. Joe Beaman (of HES) inspected the property on April 1, 2021. Sewage solids were only observed on the
subject property. Sewage liquids were observed to be pooled in the aforementioned wooded area. A small
drainage ditch was observed on the West side of the wooded area, and surface water flow was observed in this
ditch due to recent precipitation. Evidence of untreated sewage to this ditch was not observed during the site
inspection.
The grease blockage was cleared on April 1, 2021, and the sewer clean out was repaired. Untreated sewage
solids were recovered and transported off -site for proper disposal. The excavated area was treated with
pulverized lime and seeded to prevent erosion. During remediation activities, pooled water formerly observed in
the wooded area had infiltration into the ground surface. This area was also treated with pulverized lime. A Form
S-SSO was prepared and submitted to the North Carolina Department of Environmental Quality (NCDEQ).
A Mexican restaurant is located in the subject strip mall. This is suspected to the source of the grease that
caused the blockage in the underground sewer pipe. To prevent future releases. The property owner (City Hall
Properties, LLC) has met with restaurant management and cautioned the management regarding the improper
discharge of grease to the sanitary sewer system. Additionally, the property owner will conduct annual
inspections of the sewer piping to ensure blockages or discharge of excess grease and/or oil are not occurring.
City Hall Properties, LLC respectfully requests that the NCDEQ not issue fines for this incident. The NOV
incorrectly identifies the cause of the release to be a pipe break. The cause of the release was a grease blockage
in the pipe, no a pipe break. This was confirmed with Town of Carrboro personnel during the site inspection on
April 1, 2021. Upon being notified of the release, City Hall Properties, LLC immediately initiated response and
remediation activities. The release was stopped and corrected on the date of discovery. Site remediation
activities were completed within one week of discovery of the release. The release did not result in detrimental

Mr. Scott Vinson
Response to Notice of Violation
May 13, 2021
Page 2
impacts to surface water quality, fish kills, or closure of recreational areas. The volume of the release was
estimated at 500 gallons. Although the duration of the release is not exactly known, conversations with the
management of the Circle K store (located in the strip mall) suggests the duration of the release was two days.
The subject release not intentional, and there is no history of previous non-compliance. For these factors, we
conclude the issuance of a fine is not justifiable, and we respectfully request fines not be issued.
We appreciate your review of this correspondence and consideration of our request. If there are any questions
regarding this correspondence, or the project in general, please contact me at 919-414-7081.
Sincerely,
Highlands Environmental Solutions, Inc.
Jo-e/ 13 e-crlw
Joe Beaman, P.G., RSM
Principal Geologist
cc: Mr. Mike Pleasant — City Hall Properties, LLC
File