WQ0003299_Notification of Intent (NOI) – GW Remediation_20240419

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CITY OF MONROE
3 PO BOX 69
MONROE NC 28111-0069
ATTN: BRIAN BORNE,CITY MANAGER
dwr/jh 4/19/24

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AI 'V: BRIAN BORNE,CITY MANAGER
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NCDEQ/WQROS
z- 610 E. CENTER AVENUE
SUITE 301
�'a >MOORESVILLE NC 28115
7
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2S-7899 hill'll'llli'liullli'i"liii1ll'ni1i'I"1+lill/l'ili'I'IdI'

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ROY COOPER li,
IELIZABETH -
S.BISER t* .0,
Secretary
RICHARD E.ROGERS,JR. NORTH CAROLINA
Director Environmental Quality
Certified Mail # 7022 0410 0000 7789 6760
Return Receipt Requested
April 19, 2024
Brian J Borne, City Manager
City of Monroe
PO Box 69
Monroe, NC 28111-0069
SUBJECT: NOTICE OF VIOLATION &INTENT TO ISSUE CIVIL PENALTY
Tracking No.: NOV-2024-DV-0219
Sanitary Sewer Overflows - March 2024
Collection System Permit No. WQCS00026
Monroe Collection System
Union County
Dear Mr. Borne:
A review has been conducted of the self-reported Sanitary Sewer Overflows (SSO's) 5-Day Report/s submitted by
City of Monroe. The Division's Mooresville Regional Office concludes that the City of Monroe violated Permit
Condition I (2) of Permit No. WQCS00026 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. 143-215.1.
The Mooresville Regional Office is providing the City of Monroe an opportunity to provide evidence and justification
as to why the City of Monroe 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 (Mins) Location Cause (Gals) (Gals) DWR Action
202400558 3/2/2024 540 1208 Rosa Drive, Grease, Roots 5,700 5,700 Notice of Violation
Monroe, NC, 28112 Intent to Enforce
202400712 3/27/2024 100 1914 Wolf Pond Rd, Inflow and 900 700 Notice of Violation
Monroe, NC, 28112 Infiltration, Severe
Natural Condition
E Nor h C.,olFu Department of Environmental Qo t DNhbn of Water Resources
NooresvNk Regional Ofhre'�610 Lac(Center Mem,r.Sour 301 I Moo,csr,lk.North Carolina/81M
�� TOJ ob Slboo

Total Vol
Total Surface
Incident Start Duration Vol Water
Number Date (Mins) Location Cause (Gals) (Gals) DWR Action
202400732 3/29/2024 112 217 I B Shive Drive, Pipe Failure(Break) 560 560 Notice of Violation
Monroe, NC, 28110
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 Joanna Harbison with the Water Quality Section in
the Mooresville Regional Office at 704-663-1699 or via email at [e-mail].
Sincerely,
DocuSignedd by::�
1.414640
F161FB69A2D84A3...
Andrew H. Pitner, P.G., 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
North Carolina Department or Enwonmentd QuitY Divwen d Water R<sawm
MoorlsvRk Regional 00ke 1,10 East Center Awn..Su.301 I MoorteNk North Crain 2816
700.1s3114,

....„0
, Laserfiche
City of
1l OrO monroenc.org • 704-282-4601 • PO Box 69,Monroe, NC 28111
Water Resources
A CEINEaNCDECVDWR
ApP-2 9 2024
April 25, 2024W ,
MOORESVILLE REGIONAL OFFICE
Mr. Andrew H. Pitner
Assistant Regional Supervisor
Water Quality Regional Operations Section
NCDEQ
Mooresville Regional Office
610 East Center Avenue, Suite 301
Mooresville,NC 28115
Subject: Response to Notice of Violation
Tracking#NOV-2024-DV-0219
Sanitary Sewer Overflow-March 2024
Collection System Permit No. WQCS00026
Monroe Collection System
Union County
Dear Mr. Pitner,
This letter is in response to the NC Department of Environmental Quality(NCDEQ)Notice of
Violation, the letter dated April 19th, 2024 and received by City of Monroe Water Resources on April
22nd, 2024.
NCDEQ identified the following Sanitary Sewer Overflow's (SSO) on March 2nd, 2024 incident
202400558 as ineffectively managing, and maintaining the collections system with intent to enforce.
March 27th, 2024 incident number 202400712 as ineffectively managing, and maintaining the
collections system. March 29th, 2024 incident number 202400732 as ineffectively managing, and
maintaining the collections system. In response the City of Monroe is providing the following evidence
that the SSO was unintentional, that the overflows were beyond the reasonable control of our operations,
and that compliance with our collections system permit remains our utmost responsibility.
Incident#202400558 on Rosa Drive on March 2, 2024 occurred on an off-street easement in the rear a
residential area where the lids in the area are to be water tight. The spill was called in by a homeowner
on Rosa Drive and Water Resources crews responded to the call immediately, it was noted that the SSO
was coming out around the pick holes in the cover. This specific line was cleaned and inspected in
January of 2017. As noted on the 5-day BIMS report there was debris in the manhole which included a
significant amount of rags, wipes, FOG (Fats, Oil, and Grease) and roots which had created a blockage
on the 18"DIP gravity sewer main. A City of Monroe Water Resources representative was stationed
onsite during the duration of the spill to monitor any changes until the spill was mitigated. Once the spill
was stopped the affected area was cleaned of all debris, the water way was raked, and the right of way
was limed as stated in the BIMS report. We also notified the City of Monroe Storm Water Division of
i

Mr. Andrew H. Pitner
April 25, 2024
Page 2
the spill as indicated in the BIM's report. Later CCTV footage by an outside contractor found what
appeared to be a fabric bag in the line, the line has since been cleaned.
Incident#202400712 on Wolfe Pond Rd March 27, 2024 was a result of severe natural causes as a result
of creeks and streams being inundated with several inches of rain. The City of Monroe saw nearly 5
inches of rain in the days and weeks prior to the SSO. With already saturated soils and nowhere for the
water to shed, the collections system was inundated. We had an additional inch of rain on the day of the
SSO. This particular line was last inspected December of 2016. We have smoke tested 51,349 feet of the
basin, we have pipe burst 1,109 feet VCP lines in the area with HDPE pipes, and CCTV work has been
completed in the immediate area. We have a contract in place to smoke test an additional 100,256 feet of
tributary basins that feed into this larger basin to also help us with I&I in the area.
Upon visual inspection inside of the manholes in the area, the incident was identified as an I&I issue as a
result of multiple creeks and small tributaries being up over manholes in the area. During this time,we
had a contract crew in from Info-sense doing manhole and mainline assessment looking for blockages in
the area using acoustic technologies. As stated in the BIMS report we are also using Smart Cover
technology. Staff was onsite the duration of the spill to monitor conditions as they changed. Staff
notified the City of Monroe Storm Water Division of the spill as well. The area was cleaned of any
debris and the area was limed.
Incident#202400732 at 217 I.B. Shive Dr. March 29, 2024 was a result of a pipe failure. The pipe
failure was due to the gravity sewer main being an aerial crossing over Bear Skin Creek,the aerial was
struck by debris that was traveling down the creek due to heavy rains that the City of Monroe had seen
in the days leading up to line being broken. The break occurred in the middle of the pipe structure. This
particular line was last CCTV'd in October of 2019, and a visual inspection of the line was completed
on January 25, 2024 after a previous rain event with no defects noted at that time. City staff was onsite
within minutes of being notified of the spill. In order to make the repair in the creek during the high
flow conditions a raft was deployed by Monroe Fire Department in order to safely get staff to the break.
Once the raft was in the water staff were able to install a repair clamp on the pipe to stop the leak. City
staff are currently working to get a contractor in to replace the crossing.
The City of Monroe Water Resources Staff are currently working throughout the City of Monroe on
smoke testing, and putting out a public outreach on our social media page with the help of the City of
Monroe Public Information Officer with a plan to help reduce/stop spills due to FOG. The Maintenance
Superintendent as well as the Pre-Treatment Coordinator have discussed outreach to residential
customers as the vast majority of the area around Incident#202400558 is primarily residential with
debris coming from homes. Crews will CCTV the area in the coming months as part of a basin project
after smoke testing is completed.
Water Resources is also working with other departments within the City of Monroe, as well as NCDOT
to locate any areas that trees or debris are obstructing any parts of creeks or tributaries. This will help to
allow the flow of water in the areas to move unobstructed, and allow it to shed faster. Our hope is that
through these communications and partnerships with such departments we can help to prevent SSO's

Mr. Andrew H. Pitner
April 25, 2024
Page 3
due to I&I as a result of water being backed up in these areas over manholes, or a debris striking lines
and causing damage.
We feel that the SSO's in question were not within reasonable control of the permittee; the SSO's could
not have been prevented by the exercise of reasonable control, such as proper management or preventive
maintenance. The permittee followed all City of Monroe Sanitary Sewer Overflow Response Plan
(SSOP)procedures.
The City of Monroe meets and exceeds the 10% cleaning goal each year with various methods including
pipe bursting, CIPP,basin cleaning, CCTV and cleaning, inspection of all priority lines after excessive
rain events. The City of Monroe has staff available 24 hours a day 7 days per week with anticipated
response time of less the 45 minutes to any given call. These measures help us to reduce the impact and
duration of sanitary sewer spills. In addition, contracts are utilized with construction companies for
emergency situations.
The City of Monroe respectively requests that no civil penalties be applied to any of the above SSO's
that occurred during the month of March 2024, due to the above factors being satisfied and evidence
showing that the overflow was not expected to occur and the lines have been inspected and maintained
as required by the permit.
If you have any questions or require further information, please contact me at phone number 704-282-
4610 or via email at [e-mail]
Sincerely,
Chuck Derrick
Water Resources Maintenance Superintendent/ORC
Water Resources Department
City of Monroe
Attachment: DEQ NOV letter
Area Map of SSO

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