WQCS00179_DV-2024-0102 Civil Penalty Folder_20241008

ROY COOPER
Governor
MARY PENNY KELLEY
Secretary
RICHARD E. ROGERS, jll
Director
Certified Mail # 7017 0190 0000 2485 9180
Return Receipt Requested
Christopher Doherty, Director Public Utilities
Franklin County Public Utilities
1630 U S Hwy 1
Youngsville, NC 27596-9661
NORTH CAROLINA
Environmental Quality
October 8, 2024
SUBJECT: Notice of Violation and Assessment of Civil Penalty
for Violations of North Carolina General Statute (G.S.) 143-215. 1 (a)(6)
and Collection System Permit No. WQCS00179
Franklin County Public Utilities
Franklin County Collection System
Case No. DV-2024-0102
Franklin County
Dear Mr. Dohe:
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of $1,226.00 ($1,125.00 civil penalty
+ $101.00 enforcement costs) against Franklin County Public Utilities.
This assessment is based upon the following facts: a review has been conducted of the Sanitary Sewer Overflow (SSO)
5-Day Report submitted by Franklin County Public Utilities. This review has shown the subject facility to be in violation of
the requirements found in Collection System Permit No. WQCS00179 and G.S. 143-215.1(a)(1). The violation(s) that
occurred are summarized in Attachment A to this letter.
Based upon the above facts, I conclude as a matter of law that Franklin County Public Utilities violated the terms, conditions
or requirements of Collection System Permit No. WQCS00179 and G.S. 143-215.1(a)(]) in the manner and extent shown in
Attachment A. In accordance with the maximums established by G.S. 143-215.6A(a)(2), a civil penalty may be assessed
against any person who violates the terms, conditions or requirements of a permit required by G.S. 143-215.1(a).
NwiliCarohnaDeparim toftnriron ntalQuAlty Division ofWaierResaurces
Raklgh Regiona[Offke . 3600 Harreti Di ire Rakigh North Carolina 27609
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Based upon the above findings of fact and conclusions of law, and in accordance with authority provided by the
Secretary of the Department of Environmental Quality and the Director of the Division of Water Resources, I, Vanessa
Manuel, Assistant Regional Supervisor, Raleigh Regional Office hereby make the following civil penalty assessment against
Franklin County Public Utilities:
$1,125.00 For 1 of the 1 violations of Collection System Permit No. WQCS00179 and G.S. 143-215.1(a)(1) for
Sanitary Sewer Overflow(s) resulting in a discharge without a valid permit.
1 125.00 TOTAL CIVIL PENALTY
$101.00 Enforcement Costs
$1,226.00 TOTAL AMOUNT DUE
Pursuant to G.S. 143-215.6A(c), in determining the amount of the penalty i have taken into account the Findings of Fact and
Conclusions of Law and the factors set forth at G.S. 143B-282.1(b), which are:
(1) The degree and extent of harm to the natural resources of the State, to the public health, or to private property
resulting from the violation;
(2) The duration and gravity of the violation;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violation was committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs over which the Environmental
Management Commission has regulatory authority; and
(8) The cost to the State of the enforcement procedures.
Within thirty (30) days of receipt of this notice, you must do one of the following:
(1) Submit payment of the penalty, OR
(2) Submit a written request for remission, OR
(3) Submit a written request for an administrative hearing
Option 1: Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environmental Quality (do not include waiver
form). Payment of the penalty will not foreclose further enforcement action for any continuing or new violation(s).
Please submit payment to the attention of-
Attn: PERCS Branch
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617

Option 2: Submit a written request for remission or mitigation including a detailed justification for such
request:
Please be aware that a request for remission is limited to consideration of the five factors listed below as they may
relate to the reasonableness of the amount of the civil penalty assessed. Requesting remission is not the proper
procedure for contesting whether the violation(s) occurred or the accuracy of any of the factual statements contained in
the civil penalty assessment document. Because a remission request forecloses the option of an administrative hearing,
such a request must be accompanied by a waiver of your right to an administrative hearing and a stipulation and
agreement that no factual or legal issues are in dispute. Please prepare a detailed statement that establishes why you
believe the civil penalty should be remitted, and submit it to the Division of Water Resources at the address listed below.
In determining whether a remission request will be approved, the following factors shall be considered:
(1) whether one or more of the civil penalty assessment factors in NCGS 143B-282.1(b) was wrongfully
applied to the detriment of the petitioner;
(2) whether the violator promptly abated continuing environmental damage resulting from the violation;
(3) whether the violation was inadvertent or a result of an accident;
(4) whether the violator had been assessed civil penalties for any previous violations; or
(5) whether payment of the civil penalty will prevent payment for the remaining necessary remedial actions.
Please note that all evidence presented in support of your request for remission must be submitted in writing. The
Director of the Division of Water Resources will review your evidence and inform you of his decision in the matter of
your remission request. The response will provide details regarding the case status, directions for payment, and
provision for further appeal of the penalty to the Environmental Management Commission's Committee on Civil Penalty
Remissions (Committee). Please be advised that the Committee cannot consider information that was not part of the
original remission request considered by the Director. Therefore, it is very important that you prepare a complete and
thorough statement in support of your request for remission.
In order to re uest remission ou must com Mete and submit the enclosed "Request for Remission of Civil Penalties
_Waiver of Right to an Administrative Hearing, and Stipulation of Facts" form within thirty (30) dais of receipt of this
notice. The Division of Water Resources also requests that you complete and submit the enclosed "Justification for
Remission Request."
Both forms should be submitted to the following address:
Attn: PERCS Branch
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
AND
Vanessa Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
1628 Mail Service Center, Raleigh
Raleigh, NC 27699-1628

Option 3: File a petition for an administrative hearing with the Office of Administrative Hearings:
If you wish to contest any statement in the attached assessment document you must file a petition for an administrative
hearing. You may obtain the petition form from the Office of Administrative Hearings. You must file the petition with
the Office of Administrative Hearings within thirty (30) days of receipt of this notice. A petition is considered filed
when it is received in the Office of Administrative Hearings during normal office hours. The Office of Administrative
Hearings accepts filings Monday through Friday between the hours of 8:00 a.m. and 5:00 p.m., except for official state
holidays. The petition may be filed by facsimile (fax) or electronic mail by an attached file (with restrictions) - provided
the signed original, one (1) copy and a filing fee (if a filing fee is required by NCGS §15013-23.2) is received in the
Office of Administrative Hearings within seven (7) business days following the faxed or electronic transmission. You
should contact the Office of Administrative Hearings with all questions regarding the filing fee and/or the details of the
filing process.
The mailing address and telephone and fax numbers for the Office of Administrative Hearings are as follows:
6714 Mail Service Center
Raleigh, NC 27699 6714
Tel: [phone]
Fax: [phone]
One (1) copy of the petition must also be served on DEQ as follows:
Mr. William F. Lane, General Counsel
Department of Environmental Quality
1601 Mail Service Center
Raleigh, North Carolina 27699-1601
Please indicate the case number (as found on page one of this letter) on the petition.
Failure to exercise one of the options above within thirty (30) days of receipt of this letter, as evidenced by an internal
date/time received stamp (not a postmark), will result in this matter being referred to the Attorney General's Office for
collection of the penalty through a civil action. Please be advised that additional penalties may be assessed for violations
that occur after the review period of this assessment.
If you have any questions, please contact Kevin Fowler with the Division of Water Resources staff of the Raleigh Regional
Office at [phone] or via email at [e-mail].
Sincerely,
'X 61, eot'
Vanessa Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS
Cc: Laserfiche

JUSTIFICATION FOR REMISSION REQUEST
Case Number: DV-2024-0102 County: Franklin
Assessed Party: Franklin County Public Utilities
Permit No.: WQCS00179
Amount Assessed: $1,226.00
Please use this form when requesting remission of this civil penalty. You must also complete the "Request For Remission,
Waiver of Right to an Administrative Nearing, and Stipulation of Facts" form to request remission of this civil penalty.
You should attach any documents that you believe support your request and are necessary for the Director to consider in
evaluating your request for remission. Please be aware that a request for remission is limited to consideration of the five
factors listed below as they may relate to the reasonableness of the amount of the civil penalty assessed. Requesting
remission is not the proper procedure for contesting whether the violation(s) occurred or the accuracy of any of the factual
statements contained in the civil penalty assessment document. Pursuant to N.C.G.S. § 14313-282. 1 (c), remission of a civil
penalty may be granted only when one or more of the following five factors apply. Please check each factor that you
believe applies to your case and provide a detailed explanation, including copies of supporting documents, as to why the
factor applies (attach additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C.G.S. 14313-282. 1 (b) were wrongfully applied to the
detriment of the petitioner (the assessment factors are listed in the civil penalty assessment document);
(b) the violator promptly abated continuing environmental damage resulting from the violation (i.e., explain the
steps that you took to correct the violation and prevent future occurrences);
(c) the violation was inadvertent or a result of an accident (i.e., explain why the violation was unavoidable or
something you could not prevent or prepare for);
(d) the violator had not been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary remedial actions (i.e., explain
how payment of the civil penalty will prevent you from performing the activities necessary to achieve
compliance).
EXPLANATION:

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
COUNTY OF FRANKLIN
IN THE MATTER OF ASSESSMENT
)
WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST
)
ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
Franklin County Public Utilities
)
Franklin County Collection System
)
PERMIT NO. WQCS00179
}
CASE NO. DV-2024-0102
Having been assessed civil penalties totaling $1,226.00 for violation(s) as set forth in the assessment document of the
Division of Water Resources dated October 8, 2024, the undersigned, desiring to seek remission of the civil penalty, does
hereby waive the right to an administrative hearing in the above -stated matter and does stipulate that the facts are as
alleged in the assessment document. The undersigned further understands that all evidence presented in support of
remission of this civil penalty must be submitted to the Director of the Division of Water Resources within thirty (30) days
of receipt of the notice of assessment. No new evidence in support of a remission request will be allowed after (30) days
from the receipt of the notice of assessment.
This the
. ._. day of
ADDRESS
TELEPHONE
SIGNATURE
, 20--. -. -

ATTACHMENT A
Franklin County Public Utilities
CASE NUMBER: DV-2024-0102
PERMIT NO: WQCS00179
FACILITY: Franklin County Collection System
Other Violations
REGION: Raleigh
COUNTY: Franklin
INCIDENT VIOLATION TOTAL VOLUME
NUMBER DATE VIOLATION TYPE VIOLATION DESCRIPTION (GALLONS)
202400865 5/6/2024 CSOISSO(Sewer Overflow) Discharge without valid permit 9,000
PENALTY
AMOUNT

DIVISION OF WATER RESOURCES - CIVIL PENALTY ASSESSMENT
Violator: Franklin County Public Utilities
Facility Name: Franklin County Collection System
Permit Number: WQCS00179
County: Franklin
Case Number: DV-2024-0102
ASSESSMENT FACTORS
1) The degree and extent of harm to the natural resources of the State, to the public health, or to private
property resulting from the violation;
A total of 9,000 gallons of wastewater overflowed from the Franklin County Collection System due to pipe failure. 3,500
gallons of wastewater flowed to Brandy Creek, a class B;NSW in the Tar -Pamlico River Basin. Nutrients and pathogens to
surface waters.
2) The duration and gravity of the violation;
The SSO started on 05.06.2024 at 01:00 PM and ended the same day at 08:30 PM.
3) The effect on ground or surface water quantity or quality or on air quality;
The effect on surface water quality include nutrients and pathogens to surface waters.
4) The cost of rectifying the damage;
The cost of rectifying the damage was not provided.
5) The amount of money saved by noncompliance;
It is believed that no money was saved by noncompliance.
6) Whether the violation was committed willfully or intentionally;
It does not appear that the violation was committed willfully or intentionally.
7) The prior record of the violator in complying or failing to comply with programs over which the
Environmental Management Commission has regulatory authority;
There has been 1 enforcement case within the past 12 months.
8) The cost to the State of the enforcement procedures.
$101.00
Date Vanessa Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ

SCAM
Manuel, Vanessa
From: Chris Doherty <[e-mail]>
Sent: Monday, July 8, 2024 9.48 AM
To: Payton Proctor; Manuel, Vanessa
Subject: [External] RE: NOV-202-DV-0257
Attachments: 2024 07 08 NOV Response Letter NOV-2024-DV-0257.pdf
Follow Up Flag:
Flag Status:
Follow up
Flagged [,,J(QCSUC->I-f9
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Please find attached letter
THANKS
� �_r�ltklil�
* �OLltlty
Chris Doherty
Public Utilities Director
Phone, 919-556-6177
Email.
cdoherty@frankl incountvnc.aov
1630 US 1
Youngsville, NC 27596
www.franklincountync.nov
From: Payton Proctor <[e-mail]>
Sent: Monday, July 8, 2024 8:45 AM
To: Chris Doherty <[e-mail]>; Manuel, Vanessa <[e-mail]>
Subject: RE: NOV-202-DV-0257
Please find attached response letter for NOV-2024-DV-0257. Should you have any questions, please feel
free to contact me.
From: Chris Doherty<cdoherty@franklincountync..gov>
Sent: Tuesday, July 2, 2024 8:54 AM
To: Manuel, Vanessa <[e-mail]>
Cc: Payton Proctor<[e-mail]>
Subject: NOV-202-DV-0257
Importance: High
Vanessa
Good Morning
We are in receipt of the NOV dated 06-13-2024. 1 did not receive this NOV in my office until 06-27-2024. My Wastewater
Superintendent is on vacation and when he returns we will issue our response to this NOV. THANK YOU

r 1 Chris Doherty
nk] I f1 Public Utilities Director
•1�+��=.�7E1}} � Phone:[phone]
.. .. Email
cdoherty@frankl incountync.gov
1630 US 1
Youngsville, NC 27596
www.franklincountync.no

Fen lin
ount
Y
A Research Triangle Region (.ommunily
July 8, 2024
Vanessa Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Public Uti!AiE-s
1630 US #1 Hwy
Youngsville, NC 27596
Phone: [phone]
www.franklincountync-us
SUBJECT: RESPONSE TO NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY
Tracking Number: NOV-2024-DV-0257
Permit Number: WQCS00179
Franklin County Collection System
Franklin County
Dear Ms. Manuel,
Franklin County is in receipt of NOV-2024-DV-0257 dated June 13, 2024. Events that led to the SSO for which
this NOV reference was due to a pipe failure of the Industrial Park WWPS. The station is a duplex station and
was operating under normal conditions when a small section of force main beyond the pump station valves
failed. Franklin County staff along with an outside vendor began the work of replacing the section of pipe. Once
repairs were made, Franklin County staff began cleanup of the affected area.
We are confident that with the diligent work of Franklin County staff, vendors, and investments in
infrastructure this type of system failure and SSO can be prevented.
If you have any further questions, please contact our office at 919-556-6177.
Sincerely,
Christopher Doherty, Director of Public Utilities
Franklin County
1630 US Hwy 1
Youngsville, NC 27596
CC: File
"Equal Opportunity Employer"

�Fenklin
•••�ounty �,- C"6L�
A Researcb Triangle Region Community
July 8, 2024
Vanessa Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Public Utilities
1630 US #1 Hwy
Youngsville, NC 27596
Phone: [phone]
www.franklincountvnc.us
Received via email: 7/8/2024
SUBJECT: RESPONSE TO NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY
Tracking Number: NOV-2024-DV-0257
Permit Number: WQCS00179
Franklin County Collection System
Franklin County
Dear Ms. Manuel,
Franklin County is in receipt of NOV-2024-DV-0257 dated June 13, 2024. Events that led to the SSO for which
this NOV reference was due to a pipe failure of the Industrial Park WWPS. The station is a duplex station and
was operating under normal conditions when a small section of force main beyond the pump station valves
failed. Franklin County staff along with an outside vendor began the work of replacing the section of pipe. Once
repairs were made, Franklin County staff began cleanup of the affected area.
We are confident that with the diligent work of Franklin County staff, vendors, and investments in
infrastructure this type of system failure and SSO can be prevented.
If you have any further questions, please contact our office at 919-556-6177.
Sincerely,
Christopher Doherty, Director of Public Utilities
Franklin County
1630 US Hwy 1
Youngsville, NC 27596
CC: File
"Equal Opportunity Employer"

DocuSign Envelope ID: 4CD3D57F-Dl2C-4C79-8Dfi9-D59F22E9CCF9
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS. JR.
Director
Certified Mail # 7017 0190 0000 2237 3604
Return Receipt Requested
Christopher Doherty, Director Public Utilities
Franklin County Public Utilities
1630USHwy 1
Youngsville, NC 27596-9661
NORTH CAROLINA
Environmental Quality
June 13, 2024
SUBJECT: NOTICE OF VIOLATION & INTENT TO ISSUE CIVIL PENALTY
Tracking No.: NOV-2024-DV-0257
Sanitary Sewer Overflows - May 2024
Collection System Permit No. WQCS00179
Franklin County Collection System
Franklin County
Dear Mr. Doherty:
A review has been conducted of the self -reported Sanitary Sewer Overflows (SSO's) 5-Day Report/s submitted by
Franklin County Public Utilities. The Division's Raleigh Regional Office concludes that the Franklin County Public
Utilities violated Permit Condition I (2) of Permit No. WQCS00179 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 Raleigh Regional Office is providing the Franklin County Public Utilities an opportunity to provide evidence and
justification as to why the Franklin County Public Utilities should not be assessed a civil penalty for the violation(s)
that are summarized below:
Incident Start Duration
Number Date (Mina) Location Cause
202400865 5/6/2024 450 503 Park Ave, Pipe Failure (Break)
Youngsville, NC, 27596
Total Vol
Total
Surface
Vol
Water
(Gals)
(Gals) DWR Action
9,000
3,500 Notice of Violation -
Intent to Assess
North Camino Department o(1m* ernta1 Qpahty Dhi.Nn of Water Re mm
R*40 Rqo ..101fke 3800 Barren DHW RakWX North Carolna 27609
9f9.791.420D

DocuSign Envelope ID. 4CD3D57F-D12C-4C79-8D69-D59F22E9CCF9
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 Kevin Fowler with the Water Quality Section in the
Raleigh Regional Office at 919-791-4261 or via email at [e-mail].
Cc: Laserfiche
Sincerely,
DocuSigned by:
Ua In t,SSa. f . kawd
6291BEBAB32144F
Vanessa Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
D_E > �a[h Carolina Npartmrnt al lnvW m IA Quality i Dmskm of Wier Rnaerces
Raleigh Reginrml Office 3t100 Barrett Orlrr : Raleigh, Yonh Cxnluu 21604
'719J9fd2W

Dlvlslon of Water Resources
PART I:
State of North Carolina
Department of Environment and Natural Resources
Division of Water Resources
Collection System Sanitary Sewer Overflow Reporting Form
Form CS-SSO
This form shall be submitted to the appropriate DWQ Regional Office within five business days of the first knowledge of the
sanitary sewer overflow (SSO).
Permit Number: WQCS00179 (WQCS# if active, otherwise use WQCSD#)
Facility: Franklin County Collection System Incident #. 202400865
Owner: Franklin County Public Utilities
City: Youngsville County: Franklin
Region: Raleigh
Source of SSO (check applicable): .7 Sanitary Sewer ❑ Pump Station / Lift Station
SPECIFIC location of the SSO (be consistent in description from past reports or documentation - i.e. Pump Station 6,
Manhole at Westall & Bragg Street, etc): 503 Park Ave, Youn sville, NC, 27596
Manhole #:
Latitude (Decimal Degrees):
Longitude (Decimal Degrees):
Incident Started Dt: 05/06/2024 Time: 1:00 pm Incident End Dt: 05/06/2024 Time: 08:30 pm
(mm-dd-yyyy) (hh:mm AM/PM) (mm-dd-yyyy) (hh:mm AMIPM)
Estimated Volume of the SSO: 9,000 gallons Estimated Duration (Round to nearest hour): 7:30 hours
Describe how the volume was determined: Gal/Min
Weather conditions during the SSO event:
Storms/Showers
Did SSO reach surface waters? [ Yes ❑ No ❑ Unknown Volume reaching surface waters (gals): 3500
Surface water name: Brandy Creek
Did the SSO result in a fish kill? ❑ Yes Q No ❑ Unknown If Yes, what is the estimated number of fish killed? 0
SPECIFIC cause(s) of the SSO:
W Pipe Failure (Break)
24 hour verbal notification (name of person contacted ): Curtis R Tyree
R DWR ❑ Emergency Mgmt Date (mm-dd-yyy): 05/07/2024 Time (hh:mm AMIPM): 10:15:00 am
If an SSO is ongoing, please notify the appropriate Regional Office on a daily basis until SSO can be stopped.
Per G.S. 143-215.1C(b), the responsible party of a discharge of 1,000 or more of untreated wastewater to surface waters
shall issue a press release within 24-hours of first knowledge to all print and electronic news media providing general
coverage in the county where the discharge occurred. When 15,000 gallons or more of untreated wastewater enters surface
waters, a public notice shall be published within 10 days and proof of publication shall be provided to the Division within 30
days. Refer to the reference statute for further detail.
The Director Division of Water Resources, may take enforcement action for SSOs that are required to be reported to
Division unless it is demonstrated that:
1) the discharge was cause by sever natural conditions and there were no feasible alternative to the discharge; of
2) the discharge was exceptional, unintentional, temporary and caused by factors beyond the reasonable control of the
Permittee and/or owner, and the discharge could not have been prevented by the exercise of reasonable control.
Part II must be completed to provide a justification claim for either of the above situations. This information will be the basis
WHETHER OR NOT PART ill IS COMPLETED A SIGNATURE IS REQUIRED AT THE END OF THIS FORM
CS-SSO Form Page

PART II:
ANSWER THE FOLLOWING QUESTIONS FOR EACH RELATED CAUSE CHECKED IN PART I OF THIS FORM AND
INCLUDE THE APPROPRIATE DOCUMENTATION AS REQUIRED OR DESIRED
COMPLETE ONLY THOSE SECTONS PERTAINING TO THE CAUSE OF THE SSO AS CHECKED IN PART 1
(In the check boxes below, NA = Not Applicable and NE = Not Evaluated)
A HARDCOPY OF THIS FORM SHOULD BE SUBMITTED TO THE APPROPRIATE DWR REGIONAL OFFICE UNLESS IS
Pipe Failure (Break)
Pipe size (inches)
6
What is the pipe material?
DIP
What is the approximate age of line/pipe? (years old)
30
Is this a gravity line? Yes W No FJ NA 0 NE
Is this a force main line?
Is the line a "High Priority" line?
Last inspection date and findings
If a force main then,
Was the break on the force main veritical?
Was the break on the force main horizantal?
Was the leak at the joint due to gasket failure?
Was the leafs at the joint due to split bell?
When was the last inspection or test of the nearest air -release valve to determine of
operable?
When was the last maintenace of the air release performed?
If gravity sewer then,
R Yes ❑ No ❑ NA NE
Fj Yes [ No W NA NE
[j Yes []No RNA ❑ NE
[ Yes No W NA ❑ NE
W Yes ❑ No ❑ NA ❑ NE
Yes [] No R NA r] NE
Does the line receive flow from a force main immediately upstream of the failed secti [] Yes ❑ No W NA NE
of pipe?
CS-SSO Form Page: 2

If yes, what measures are taken to control the hydrogen sulfide production?
When was the line last inspected or videoed?
If line collapsed, what is the condition of the line up and down stream of the failure?
What type of repair was made?
Is the repair temporary or permanent?
If temporary, when is the permanent repair planned?
Have there been other failures of this line in the past five years? ❑ Yes W No ❑ NA ❑ NE
If so, then describe
System Visitation
ORC [7i Yes
Backup W1 Yes
Name:
Luther P Proctor
Cert#
1009195
Date visited:
05/06/2024
Time visited:
01:00 PM
How was the SSO remediated (i.e. Stopped and cleaned up)?
Mobilized equipment and began digging to find issue. Made repairs to line and valve as needed.
CS-SSO Form Page: 3

As a representative for the responsible party, I certify that the information contained in this report is true and accurate to the
best of my knowledge.
Person submitting claim: Luther Payton Proctor
Signature
Telephone Number:
Date: 05/08/24 07:18 am
Title:
Any addition information desired to be submitted should be sent to the appropriate Division Regional Office within five days of i
knowledge of the SSO with reference to the incident number (the incident number is only generated when electronic entry of th
form is completed, if used).
CS-SSO Form Page: 4

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STATE OF NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
SYSTEM -WIDE COLLECTION SYSTEM PERMIT
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as
amended, and other applicable Laws, Rules, and Regulations, permission is hereby granted to the
Franklin County Public Utilities
WQCS00179
FOR THE
operation and maintenance of a wastewater collection system consisting of, at the time of permit issuance,
approximately 34.04 miles of gravity sewer, approximately 31.81 miles of force main, 27 duplex pump
stations, and all associated piping, valves, and appurtenances required to make a complete and operational
wastewater collection system to serve Franklin County Public Utilities, pursuant to the application received
November 7, 2017, and in conformity with the documents referenced therein and other supporting data
subsequently filed and approved by the Department of Environmental Quality and considered a part of this
permit.
This permit shall be effective from June 1, 2018 until May 31, 2026, and shall be subject to the following
specified conditions and limitations:
Page 1 of 7

L PERFORMANCE STANDARDS
1. The sewage and wastewater collected by this system shall be treated in the properly permitted
Wastewater Treatment Facility identified in the permit application and documented in the Division's
database. [15A NCAC. 02T .0108 (b)]
2. The wastewater collection system shall be effectively managed, maintained and operated at all times
to prevent discharge to land or surface waters, and to prevent any contravention of groundwater
standards or surface water standards. In the event that the wastewater collection system fails to
perform satisfactorily, including the creation of nuisance conditions, the Permittee shall take immediate
actions as per the Response Action Plan (Condition II(9)), as well as any actions that may be required by
the Division of Water Resources (Division), such as the construction of additional or replacement sewer
lines and/or equipment. [15A NCAC 02T .0108 (b)]
3. The Permittee shall establish by ordinance, inter -local agreement or contract its legal authority to
require new sewers be properly constructed; to ensure proper inspection and testing of sewer mains
and service laterals; to address flows from satellite systems and to take enforcement action as required
by Condition 1(4). [G.S.143-215.9B; G.S. 143-215.1(f)(1)]
4. The Permittee shall develop and implement an educational fats, oils and grease program that shall
include at least semiannual distribution of educational material targeted at both residential and non-
residential users. The Permittee shall also develop and implement an enforceable fats, oils and grease
program for non-residential users under which the Permittee can take enforcement against users who
have not properly installed, operated and maintained grease traps or grease interceptors as directed
or otherwise violated the terms of the enforcement program pertaining to fats, oils and grease.
[15A NCAC 02T .0108 (b)]
S. The Permittee shall adopt and implement a Capital Improvement Plan (CIP) to designate funding for
reinvestment into the wastewater collection system infrastructure. The CIP should address the short-
term needs and long-term "master plan" concepts. The CIP should typically cover a three to five year
period and include a goal statement, description of the project area, description of the existing facilities,
known deficiencies (over a reasonable period) and forecasted future needs. Cost analysis is integral to
the CIP. [G.S. 143-215.9B]
6. Overflow piping from manholes and pump stations, excluding piping to approved equalization
structures, known or discovered after permit issuance shall be immediately removed or permanently
= capped. Plugged or valved emergency pumping connections are allowable for portable pumping or _
rerouting without intentionally bypassing the wastewater treatment facility.
[15A NCAC 02T .0108 (b)]
7. The Permittee shall maintain a contingency plan for pump failure at each pump station. If one of the
pumps in a pump station containing multiple pumps fails, the process of repairing or replacing the pump
shall be initiated immediately and the new parts or pump shall be installed as soon as possible. The
permittee shall provide justification for delay in initiating the process for repair or replacement at the
Division's request. If the pump in a simplex pump station serving more than a single building or pump
stations not capable of pumping at a rate of 2.5 times the average daily flow rate with the largest pump
out of service fails, it shall be replaced immediately. [1SA NCAC 02T .0305 (h) (1)]
Page 2 of 7

8. Each pump station shall be clearly and conspicuously posted with a pump station identifier and an
emergency contact telephone number at which an individual who can initiate or perform emergency
service for the wastewater collection system 24 hours per day, seven days per week can be contacted.
This emergency contact telephone number shall be coupled with instructions that the emergency
contact should be called if the visual alarm illuminates, if the audible alarm sounds, or if an emergency
is apparent. 115A NCAC 02T .0305 (h) (2)]
9. Pump station sites, equipment and components shall have restricted access.
[15A NCAC 02T .0305 (h) (4)]
10. Pump stations that do not employ an automatic polling feature (i.e. routine contact with pump stations
from a central location to check operational status of the communication system) shall have both
audible and visual high water alarms. The alarms shall be weather-proof and placed in a clear and
conspicuous location. Permits issued for the construction of pump stations that included high water
alarms in the description must maintain the alarms even if simple telemetry (i.e. notification of an alarm
condition initiated by the pump station control feature) is installed.
[15A NCAC. 02T .0305 (h) (1)]
11. For all newly constructed, modified and rehabilitated pump stations, all equipment and components
shall be sealed within a corrosion -resistant coating or encasement to the extent practicable and
equivalent to the minimum design criteria unless the permittee can demonstrate it Is not practicable
or another form of corrosion resistance is employed. [15A NCAC 02T .0108 (b)]
OPERATION AND MAINTENANCE REQUIREMENTS
1. Upon classification of the collection system by the Water Pollution Control System Operators
Certification Commission (WPCSOCC), the Permittee shall designate and employ a certified operator to
be in responsible charge (ORC) and one or more certified operator(s) to be back-up ORC(s) of the
facilities in accordance with 15A NCAC 815 .0201. The ORC shall visit the system within 24 hours of
knowledge of a bypass, spill, or overflow of wastewater from the system, unless visited by the Back -Up
ORC, and shall comply with all other conditions of 15A NCAC 813 .0204.
[15A NCAC 08G .0200 et.seq.]
2. The Permittee shall develop and adhere to a schedule for reviewing all inspection, maintenance,
operational and complaint logs. if the review process results in the identification of any recurring
problem in the wastewater co-lection system that cannot be resso vved in a short time period, the
Permittee shall establish a plan for addressing the problem(s). [15A NCAC 02T_,0108 (b)1
3. The Permittee shall develop and adhere to a schedule for testing emergency and standby equipment.
[15A NCAC 02T .0108 (b)]
4. The Permittee shall develop and implement a routine pump station inspection and maintenance
program which shall include the following maintenance activities:
a. Cleaning and removing debris from the pump station structure, outside perimeter, and wet
well;
b. Inspecting and exercising all valves;
c. Inspecting and lubricating pumps and other mechanical equipment; and
d. Verifying the proper operation of the alarms, telemetry system and auxiliary equipment.
115A NCAC 02T .0108 (b)]
Page 3 of 7

5. For each pump station without pump reliability (i.e. simplex pump stations serving more than a single
building or pump stations not capable of pumping at a rate of 2.5 times the average dailyflow rate with
the largest pump out of service), at least one fully operational spare pump capable of pumping peak
flow shall be maintained on hand. [15A NCAC 02T .0305 (h) (1) (A)]
6. The Permittee shall maintain on hand at least two percent of the number of pumps installed, but no
less than two pumps, that discharge to a pressure sewer and serve a single building, unless the
Permittee has the ability to purchase and install a replacement pump within 24 hours of first knowledge
of the simplex pump failure or within the storage capacity provided in a sewer line extension permit.
[15A NCAC 02T .0108 (b)]
7. Rights -of -way and/or easements shall be properly maintained to allow accessibility to the wastewater
collection system unless the Permittee can demonstrate the ability to gain temporary access in an
emergency situation where existing land -use conditions do not allow the establishment and
maintenance of permanent access. In this case, the Permittee shall continue to observe the lines
visually, utilize remote inspection methods (e.g. CCTV) and use the opportunity of drier conditions to
perform further inspections and necessary maintenance. [15A NCAC 02T .0108 (b)]
8. The Permittee shall assess cleaning needs, and develop and implement a program for appropriately
cleaning, whether by hydraulic or mechanical methods, the wastewater collection system. At least 10
percent of the gravity wastewater collection system, selected at the discretion of the ORC, shall be
cleaned each year. Preventative cleaning is not required for sewer lines less than five years old unless
inspection otherwise reveals the need for cleaning or cleaning is required by a sewer line extension
permit. [15A NCAC 02T .0108 (b)]
9. The Permittee shall maintain a Response Action Plan that addresses the following minimum items:
a. Contact phone numbers for 24-hour response, including weekends and holidays;
b. Response time;
c. Equipment list and spare parts inventory;
d. Access to cleaning equipment;
e. Access to construction crews, contractors and/or engineers;
f. Source(s) of emergency funds;
g. Site restoration and clean up materials; and
h. Post-SSO assessment.
[15A NCAC 02T .0108 (b)]
i0. The Permittee, or their authorized representative, sha11 conduct an on -site evaluation for all SSOs as
soon as possible, but if feasible no more than two hours after first knowledge of the SSO. The Permittee
shall document in its 5-day report why it was unable to initially respond to any SSO location within two
hours. [15A NCAC 02T.0108 (b)]
11. In the event of an SSO or blockage within the wastewater collection system, the Permittee shall restore
the system operation, remove visible solids and paper, restore any ground area and restore the
surroundings. [15A NCAC 02T .0108 (b)]
III. RECORDS
1. Records shall be maintained to document compliance with Conditions 1(4),11(2) - Il(4), II(7) - II(8), IV(3)
and V(1) -V(4). Records shall be kept on file for a minimum of three years. [i5A NCAC 02T .0108 (b)]
Page 4 of 7

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2. The Permittee shall maintain adequate records pertaining to SSOs, and SSO or wastewater collection
system complaints for a minimum of three years. These records shall include, but are not limited to,
the following information:
a. Date of 550 or complaint;
b. Volume of wastewater released as a result of the SSO and/or nature of complaint;
C. Location of the SSO and/or complaint;
d. Estimated duration of the SSO;
e. Individual from the Division who was informed about the SSO and/or complaint, when
applicable;
f. Final destination of the SSO;
g. Corrective actions;
h. Known environmental/human health impacts resulting from the SSO; and
i. How the SSO was discovered.
[15A NCAC 02T .0108 (b)]
The Permittee shall maintain an up-to-date, accurate, comprehensive map of its wastewater collection
system that also notes the locations where other wastewater collection systems become tributary. If
a comprehensive map of the collection system has not been established, a rough sketch shall be drawn.
The Permittee shall map approximately 10 percent of its existing collection system each year for the
next ten years beginning at the original permit issuance date, or until complete, whichever is sooner.
The comprehensive map shall include, but is not limited to: pipe size, pipe material, pipe location, flow
direction, approximate pipe age, and each pump station identification, location and capacity. [15A
NCAC 02T .0108 (b))
The Permittee shall maintain records of all of the modifications and extensions to the collection system
permitted herein. The Permittee shall maintain a copy of the construction record drawings and
specifications for modifications/extensions to the wastewater collection system for the life of the
modification/extension. Information concerning the extension shall be incorporated into the map of
the wastewater collection system within one year of the completion of construction. The system
description contained within this permit shall be updated to include this modification/extension
information upon permit renewal. [15A NCAC 02T.0108 (b)]
IV. MONITORING AND REPORTING REQUIREMENTS
1. In the event of an 55 -the Division may require monitoring that is necessary to ensure surface water
and groundwater protection and -an acceptable sampling and reporting schedule shall be implemented.
[15A NCAC 02T .0108 (c)] -"
2. The Permittee shall verbally report to a Division of Water Resources staff member at the Raleigh
Regional Office, at telephone number [phone] as soon as possible, but in no case more than 24
hours following first knowledge of the occurrence of the following circumstances within the collection
system which is underthe Permittee's ownership or maintained and operated bythe Permittee through
a perpetual legal agreement:
a. Any SSO and/or spillover 1,000 gallons to the ground; or
b. Any SSO and/or spill, regardless of volume, that reaches surface water.
Voice mail messages or faxed information shall not be considered as the initial verbal report. SSOs (and
other types of spills) occurring outside normal business hours may also be reported to the Division of
Emergency Management at telephone number [phone] or [phone].
Page 5 of 7

Persons reporting any of the above occurrences shall file a spill report by completing Part I of Form CS-
SSO (or the most current Division approved form), within five business days following first knowledge
of the occurrence. This report shall outline the actions taken or proposed to ensure that the problem
does not recur. [G.S.143-215.iC(ai)]
3. The Permittee shall meet the annual reporting and notification requirements provided in North Carolina
General Statute §143-215.1C.
V. INSPECTIONS
1. The Permittee or the Permittee's designee shall inspect the wastewater collection system regularly to
reduce the risk of malfunctions and deterioration, operator errors, and other issues that may cause or
lead to the release of wastes to the environment, threaten human health or create nuisance conditions.
The Permittee shall keep an inspection log or summary including, at a minimum, the date and time of
inspection, observations made, and any maintenance, repairs, or corrective actions taken by the
Permittee. [15A NCAC 02T .0108 (b)]
2. Pump stations that are not connected to a telemetry system (i.e., remote alarm system) shall be
inspected by the permittee or its representative everyday (i.e., 365 days per year). Pump stations that
are connected to telemetry shall be inspected at least once per week. [15A NCAC 02T .0108 (b)]
3. A general observation by the permittee or its representative of the entire wastewater collection system
shall be conducted at least once per year. [15A NCAC 02T .0108 (b)]
4. Inspections of all high priority lines (i.e. aerial line, sub -waterway crossing, line contacting surface
waters, siphon, line positioned parallel to stream banks that are subject to eroding in such a manner
that may threaten the sewer line, or line designated as high -priority in a permit) shall be performed at
least once per every six-month period of time. A list of high -priority lines is presented as Attachment A
and is hereby incorporated into this permit condition. New high priority limes installed or identified
after permit issuance are incorporated by reference and subject to this permit condition until permit
renewal where they shall be referenced in writing in Attachment A. [15A NCAC 02T .0108 (b)]
VI. GENERA! CONDITIONS
1. This permit is not transferable. In the event that the Permittee desires to transfer ownership of the
wastewater collection system or there is a name change of the Permittee, aTbrmal permit modification
request shall be submitted to the Division. The request shall be accompanied by documentation from
the parties involved, and other supporting materials as may be appropriate. Such request will be
considered on its merits and may or may not be approved. [15A NCAC 02T .0104; G.S. 143-215.1(d)(3)]
2. Failure to abide by the conditions and limitations contained in this permit may subject the Permittee to
an enforcement action by the Division in accordance with North Carolina General Statute §143-215.6A
through §143-215.6C, and a sewer moratorium may be established. [15A NCAC 02T .0104]
3. The issuance of this permit does not exempt the Permittee from complying with any and all statutes,
rules, regulations, or ordinances that may be imposed by other government agencies (i.e., local, state,
and federal) having jurisdiction. [G.S. 143-215.1(b)]
4. The issuance of this permit does not prohibit the Division from reopening and modifying the permit,
revoking and reissuing the permit or terminating the permit as allowed by the laws, rules, and
regulations or as needed to address changes in federal regulations with respect to the wastewater
collection system, in accordance with required procedures. [G.S. 143-215.1(b)(4)]
Page 6 of 7

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5. The Permittee shall pay the annual fee within thirty (30) days after being billed by the Division. Failure
to pay the fee accordingly may cause the Division to initiate action to revoke this permit.
115A NCAC 02T .0110 (4)]
6. The Permittee shall file an application for renewal of this permit at least six months prior to the
expiration of this permit. Upon receipt of the request, the Director will review the adequacy of the
wastewater collection system described therein, and if warranted, will extend the permit for a period
of time and under such conditions and limitations, as the Director may deem appropriate. [15A NCAC
02T .0109]
7. The Permittee shall notify the Division's Pretreatment, Emergency Response and Collection Systems
Unit in writing at 1617 Mail Service Center, Raleigh, North Carolina 27699 of any changes to the name
and/or address of the responsible party (i.e. mayor, city/town manager) of the wastewater collection
system. [15A NCAC 02T .0106 (c)]
8. Any duly authorized officer, employee, or representative of the Division may, upon presentation of
credentials, enter and inspect any property, premises or place on or related to the collection system at
any reasonable time for the purpose of determining compliance with this permit, may inspect or copy
any records that must be maintained under the terms and conditions of this permit, and may obtain
samples of wastewater, groundwater, surface water, soil, or plant tissue.
[15A NCAC 02T .0110 (3)]
9. The Permittee or their authorized representative shall have available a copy of this permit to present
upon request by any duly authorized officer, employee, or representative of the Division.
[15A NCAC 02T .0104]
Permit issued this the 21" of November, 2017
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
for Linda Culpepper
Interim Director, Division of Water Resources
By Authority of the Environmental Management Commission
by Deborah Gore, Pretreatment, Emergency Response, Collection System Unit Supervisor
Division of Water Resources, NCDEQ
Page 7 of 7

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Attachment A for Condition V(3)
Franklin County Public Utilities Sewage Lift Stations
NAME
LOCATION
ALARM TYPE
PUMP
EMERGENCY
CAPACITY GPM
RELIABILITY
POWER SOURCE
AMERICAN
43 AMERICAN
TELEMETRY/VISUAL/
YES
PERMANENT
210
LEGION LS
LEGION RD
AUDIBLE
GENERATOR
FRANKLINTON
PINE ST LS
18 PINE ST
TELEMETRY/VISUAL/
YES
PERMANENT
200
FRANKLINTON
AUDIBLE
GENERATOR
KOREASTLS
1KOREAST
TELEMETRYIVISUAL/
YES
PERMANENT
90
FRANKLINTON
AUDIBLE
GENERATOR
PARK LS
100 PARK AVE
TELEMETRY/VISUAL/
YES
PERMANENT
180
FRANKLINTON
AUDIBLE
GENERATOR
OAK RIDGE LS
156 OAK RIDGE
TELEMETRY/VISUAL/
YES
PERMANENT
255
RD
AUDIBLE
GENERATOR
FRANKLINTON
US SA LS
641 S MAIN ST
TELEMETRY/VISUAL/
YES
PERMANENT
90
FRANKLINTON
AUDIBLE
GENERATOR
FRANKLINTON LS
442 S CHAVIS ST
SCADA/VISUALJ
YES
PERMANENT
750
FRANKLINTON
AUDIBLE
GENERATOR
YOUNGSVILLE LS
SW RR ST
SCADA/VISUALJ
YES
PERMANENT
180
YOUNGSVILLE
AUDIBLE
GENERATOR
NOVO IS
33 PERRY
SCADA/VISUAL/
YES
PERMANENT
1257
CHAPEL RD
AUDIBLE
GENERATOR
FRANKLINTON
INDUSTRIAL
501 PARK AVE
SCADA/VISUAL/
YES
PERMANENT
710
PARK LS
YOUNGSVILLE
AUDIBLE
GENERATOR
OLDE LIBERTY 1
LONG VIEW DR
SCADA/VISUAL/
YES
PERMANENT
IOD0
LS
FRANKUNTON
AUDIBLE
GENERATOR
OLDE LIBERTY 2
POCOMOKE RD
SCADA/VISUAL/
YES
PERMANENT
8D0
LS
FRANKLINTON
AUDIBLE
GENERATOR
HOLDEN FARMS
75 SHILOH LN
SCADA/VISUAL/
YES
PERMANENT
ISO
1 LS
YOUNGSVILLE
AUDIBLE
GENERATOR
HOLDEN FARMS
ALCOCK LN
SCADA/ViSUAL/
YES
PERMANENT
110
2 LS
YOUNGSVILLE
AUDIBLE
GENERATOR
FARMINGTON
29'CARRINGTON
SCADANISUAL/
YES
PERMANENT
85
OAKS LS
AVE
AUDIBLE
GENERATOR
YOUNGSVILLE
ROYAL SCHOOL
308 FLAT ROCK
SCADA/VISUAL/
YES
PERMANENT
340
LS
CH RD
AUDIBLE
GENERATOR
YOUNGSVILLE
STEPHENS
PADDY LN
SCADA/VISUAL/
YES
PERMANENT
138
GLENN LS
YOUNGSVILLE NC
AUDIBLE
GENERATOR
HUNTER PLACE
515 HOLDEN RD
SCADA/VISUAL/
YES
PERMANENT
945
LS
YOUNGSVILLE
AUDIBLE
GENERATOR
WINSTON RIDGE
30 MORNING
SCADA/VISUAL/
YES
PERMANENT
255
LS
GLORY DR
AUDIBLE
GENERATOR
YOUNGSVILLE
POSTSOFTWARE
FLEX WAY
SCADA/VISUAL/
YES
PERMANENT
150
LS
YOUNGSVILLE
AUDIBLE
GENERATOR
COTTAGE CT LS
111 COTTAGE CT
SCADA/VISUAL/
YES
PERMANENT
20
AUDIBLE
GENERATOR
EAST
703 TARBORO RD
SCADA/VISUAL/
YES
PERMANENT
220
YOUNGSVILLE LS
YOUNGSVILLE
AUDIBLE
GENERATOR
SOUTH NASSAU
230SOLFTH
SCADA/VISUAL/
YES
PERMANENT
20
LS
NASSAU ST
AUDIBLE
GENERATOR
YOUNGSVILLE
THOMPSON
131 THOMPSON
SCADA/VISUAL/
YES
PERMANENT
20
CIRCLE LS
CIRCLE
AUDIBLE
GENERATOR
YOUNGSVILLE
ANDERSON
357 NORTH
SCADA/VISUAL/
YES
PERMANENT
20
PARK LS
NASSAU ST
AUDIBLE
GENERATOR
BONTERRA LS
124 BONTERRA
SCADA/VISUAL/
YES
PERMANENT
20
DR YOUNGSVILLE
AUDIBLE
GENERATOR
Page 1

Attachment A for Condition V(3)
K FLEX LS 100 NOMACO DR SCADA/VISUAL/ YES PERMANENT 80
YOUNGSVILLE AUDIBLE I I GENERATOR
Page 2

Franklin county Public Utilities High Priority Sewer Lines "Attachment A for Condition V 4 "