WQCS00037_Waiver of Right_20190328

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NORTH CAROLINA
Post Office Box 207.Shelby,NC 28151-0207
March 8, 2019
RECEIVEDD ENRJDWR
PERCS Branch MAR 2 8 2019
Division of Water Resources
1617 Mail Service Center Wavii i.V:..ources
Raleigh, NC 27699-1617 Permitting Section
Re: Notice of Violation and Civil Penalty Assessment—Penalty Waiver Request
Case Number DV-2019-0550
Collection System Permit#WQCSO0037
City of Shelby, Cleveland County
Dear PERCS Branch:
Attached you will find Civil Penalty Waiver Request for Case Number DV-2019-0550. The justification for
this waiver is provided on the appropriate form. In short, the City believes we have responded
appropriately to halt the spill and have proceeded with line replacement. Construction is currently
ongoing and the City believes that the State has not given the City ample time to address the situation.
The City hereby requests waiver of the penalties and enforcement costs for this case.
Please contact me at anytime regarding any further information or questions you might have regarding
this issue. I can be reached at 704-669-6570 or [e-mail].
Sincerely,
tA.J [
David Hux
Director of Water Resources Director
cc: Rick Howell; City Manager
Certified Mail: 7018 0680 0001 0376 5132
www.cityofshelby.com

JUSTIFICATION FOR REMISSION REQUEST
Case Number: DV-2019-0050 County: Cleveland
Assessed Party: City of Shelby
Permit No.: WQCS00037 Amount Assessed: $628.35
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 Hearing, 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. § 143B-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).
X (a) one or more of the civil penalty assessment factors in N.C.G.S. 143B-282.1(b)were wrongfully applied to the
detriment of the petitioner(the assessment factors are listed in the civil penalty assessment document);
X (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:
As outlined in the City's response documentation,the City of Shelby was responsive and completed the repairs of this line in a timely fashion
to mitigate the spill.
Meanwhile at the time of this spill the City had already initiated the assistance of McGill Engineers to evaluate the line for possible upgrades.
The Engineer and the City had reviewed as-built drawings,technical specifications and involved an air release valve vendor to run a model of
the line to determine if air release valves were properly sized.
This comprehensive review determined that the section of line,that was only installed in 2009,was ductile pipe and was trapped corrosive air
because this area is the highest elevation and falls from this point downward to the VWVTP. Our engineer recommended change-out of 1300
feet of line from ductile iron to either DIP with epoxy coating or C900 and began developing a project scope and specifications. The City then
began working with McGill to develop a project scope and specifications. As noted in the documents the project was sent to contractors, bids
were opened on January 29, 2019 and the project is currently under construction.
The City contends that the City was not negligent in our responsibilities as an owner/operator and believes that the State's fine is not justified
based upon the City's response to temporarily repair the line and the City's efforts to ensure that the forcemain was properly repaired. The
City also does not believe that the State has given consideration of the City's efforts to comply with State Bid laws and time needed for the
procurement of construction materials. The City requests the remission of this Civil Penalty.

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
COUNTY OF CLEVELAND
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
) STIPULATION OF FACTS
City of Shelby )
Shelby Collection System )
)
PERMIT NO. WQCS00037 ) CASE NO. DV-2019-0050
Having been assessed civil penalties totaling$628.35 for violation(s)as set forth in the assessment document of the Division
of Water Resources dated February 28, 2019,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 20 /
/t Q C
SIGNATURE
ADDRESS
e'riv SJE-ity
Fj aD1-7
SlEf�� , t\k, fl/SI
TELEPHONE
70 4� z-(-F(/ 470

ATTACHMENT A
City of Shelby
CASE NUMBER: DV-2019-0050
PERMIT NO: WQCS00037 REGION: Mooresville
FACILITY: Shelby Collection System COUNTY: Cleveland
Other Violations
INCIDENT VIOLATION TOTAL VOLUME PENALTY
NUMBER DATE VIOLATION TYPE VIOLATION DESCRIPTION (GALLONS) AMOUNT
201803810 12/29/2018 CSO/SSO(Sewer Overflow) Discharge without valid permit 48,000 $500.00
201803811 12/30/2018 CSO/SSO(Sewer Overflow) Discharge without valid permit 4,150 $0.00

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Shelbf
NORTH CAROLINA j
Post Office Box 207 Shelby, NC 28151-0207
r
February 13, 2019 _Art
Mr. Corey Basinger, Regional Supervisor
Division of Water Resources, Mooresville Regional Office
610 East Center Avenue, Suite 301
Mooresville, NC 28115
Re: Notice of Violation
Tracking#NOV-2019-DV-0085
Collection System Permit#WQCS00037
City of Shelby,Cleveland County
Dear Mr. Basinger:
The City of Shelby received the above referenced Notice of Violation regarding the sanitary sewer
overflows that occurred on December 29th and 30th at 1050 Sam Lattimore Road and a spill at 2304
Sherriff Allen Road on the westside sewer forcemain. The Westside system primarily serves two
schools, a neighborhood of 70 homes, small industrial park with low volume sewer dischargers and a
large industry that provides 500,000 gals/day. Both spills were discovered by the customers/public and
who then reported them to the City.
The spill at 1050 Sam Lattimore Road on December 29th was reported to the City at 3:00pm. Sewer
crews responded and were on the scene by 3:45pm and had the spill corrected by 5:00pm. The City was
able to cut the westside liftstation off and hold sewer in the gravity lines (15 inch and 24 inch) while the
valves on the parallel 10/12 inch forcemain were opened. There was available capacity in a 24 inch line
gravity line at the liftstation that was being installed for another industry that is slated to begin
operations in March.
The westside liftstation has two parallel sections of forcemain from the Crest Liftstation to the First
Broad WWTP. The original line installed was a 10 & 12 inch C900 PVC line that was installed around
1999. In 2009, a new 16 inch ductile line was installed from the Crest Liftstation to the Sam Lattimore
area where it tied back into the 12 inch C900 line. In 2018 the City installed another parallel section
from College (beyond spill location) and required the installation of Protecto 401 coated ductile iron
pipe.
Around the Sam Lattimore area is the highest point along the route to the WWTP and at this point a
portion of the lines are drained through gravity action to the WWTP even though the lines are
considered forcemains. When this happens, a large section of the unprotected DIP forcemain is being
exposed to corrosive hydrogen sulfide gas that is essentially trapped. Looking through the
specifications,the engineer specified higher pressure ductile iron pipe for the line from lift station to just
beyond 1050 Sam Lattimore Road at the College Road intersection; however they did not require a
www.cityofshelby.com

protective coating product such as Protecto 401. The last 1,300 feet before you get to College is the
area that is subjected to the corrosive conditions because of drainage. See the attached map, from
College Avenue to the treatment plant is constructed with coated and pvc lines.
The wall thickness of the line has been severely degraded by the hydrogen sulfide. Contract crews
replaced a section of line roughly 20 feet in length. Since this break, the City has utilized an engineer to
review the design and help determine a scope for replacement of the forcemain. It was critical to
determine how much of the line would need to be replaced. Our engineer provided a recommendation
of 1,300 feet of replacement of either C900 or epoxy coated ductile pipe. Bids were received on January
24, 2019 and construction is set to begin in the coming weeks with a contract completion time of March
15, 2019.
The spill at 2034 Sam Lattimore Road on December 30th was reported to the City at 10:27am on
December 30, 2018. Sewer crews responded and were on the scene by 11:15pm and had the spill
corrected by 12:10pm. This spill was on the 10" forcemain that was put into service during the break of
the 16" forcemain the previous night. With lower flows the City has been able to utilize only the 16"
forcemain. An air release valve isolation valve broke and was replaced by City crews. City replaced the
valve with a stainless steel isolation valve. The ARV was a newer unit. With the upcoming forcemain
replacement, the City will also replace isolation valves on all remaining air release valves including the
isolation valves.
Preventative Maintenance activitie
s are performed bythe Cityof Shelby. In review ofour records,
eco ds the
following information is provided:
Maintenance history — Line was installed in 2009. Air release valves are checked every 6
months. The air release valve had been replaced but the isolation valve had not. City replaced
the isolation valve at the time of the spill.
No other breaks have occurred on the forcemains.
Your letter lists ten areas of review in consideration for determining civil penalty amounts for a sanitary
sewer overflows. We have included the following brief responses for each item:
• Volume—1050 Sam Lattimore-48,000 gallons; 2034 Sam Lattimore-4,150 gallons
• Volume reaching surface waters— 1050 Sam Lattimore - 48,000 gallons; 2034 Sam Lattimore
- 500 gallons
• Duration and gravity—
1050 Sam Lattimore—2 hours
Because of this area flowing by gravity to the WWTP only a small portion of the pumped flow
was spilling
2034 Sam Lattimore—1 hour 43 minutes
• Impacts to public health-There were no identified impacts to public health.
• Fish kills- No fish kills were observed following this overflow.
• Recreational area closures- No recreational areas were closed due to this overflow.
www.cityofshelby.com

• History of spills—
1050 Sam Lattimore - One additional spill occurred on October 11, 2018. City began
evaluating the situation immediately with an engineer.
2034 Sam Lattimore—This was the first spill at this location.
• Cost of rectifying damage—
No environmental damage was identified requiring remediation. City staff utilized a
contractor assist with the repairs to the forcemain and utilized City staff for cleanup and
lime application.
• Intentional spill—
These overflows were not intentional and were a result of material specification and
corrosion. City will place line with corrosion resistant line.
Isolation valve was replaced with stainless steel valve and the other isolation valves will be
upgraded as well.
• Money saved by non-compliance—
No money was saved by this non-compliance. This line was installed in 2019 and the City
did not have any indication of corrosion in the line. The City will replace the upper section
of the line from the high point to the transition to epoxy coated pipe. A forcemain crossover
will also be included for a total price of around $190,000. Work is scheduled to begin when
materials arrive.
We recognize the requirements of our wastewater collection system permit and the importance to the
environment and public health in the preventing sanitary sewer overflows. The City of Shelby had no
idea this line was on the verge of failure from corrosion, particularly since this line was placed into
service in 2009. The older forcemain was forced into service to help reduce the overflow potential with
the forcemain break on the 16 inch line. The air release valve was new but the City did not know that
the isolation valve had corroded. The City replaced the valve and will be replacing the other isolation
valves on the 10 inch force main in the coming weeks. The City has quickly developed a replacement
plan for the plan for this section of line and the contractor has begun to order materials and anticipates
completion by March 15th
In response to the City's actions to correct the problems both short and long term and considering the
fact that these areas have not been reoccurring problems for a significant amount of time, the City
requests that NCDEQ withhold the issuance or a civil penalty assessment for the subject spills.
Please contact me at anytime regarding any further information or questions you might have regarding
this issue. I can be reached at 704-669-6570 or [e-mail].
Sincerely,
11-6)6
Jv
David Hux
Water Resources Director
cc: Rick Howell; City Manager
Brad Greene; Plant Operations Superintendent
Mark Swink; Field Operations Superintendent
Adam Howell; Collection System Crew Supervisor
Certified Mail: 7018 0680 0001 0376 5101
www.cityofshelby.com

fi1 Y�
ROY COOPER 1. 4
Governor � � i �
: -.\110‘t 10,(4DVZ
MICHAEL S.REGAN '•,w
Secretary k
LINDA CULP
EPPER NORTH CAROLINA
EnvironmentalQuality (`� �
Dir�rtnr
CERTIFIED MAIL: 7016 1370 0000 2591 1629
RETURN RECEIPT REQUESTED
February 01, 2019 g4i0
Rick Howell, City Manager
Cityof Shelby
Y
PO Box 207
Shelby, NC 28151-0207
SUBJECT: NOTICE OF VIOLATION &INTENT TO ISSUE CIVIL PENALTY
Tracking No.: NOV-2019-DV-0085
Sanitary Sewer Overflows - December 2018
Collection System Permit No. WQCS00037
Shelby Collection System
Cleveland County
Dear Mr. Howell:
A review has been conducted of the self-reported Sanitary Sewer Overflows (SSO's) 5-Day Report/s submitted by
City of Shelby. The Division's Mooresville Regional Office concludes that the City of Shelby violated Permit
Condition I (2) of Permit No. WQCS00037 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 Shelby an opportunity to provide evidence and justification
as to why the City of Shelby 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
201803680 12/17/2018 39 1121 S. Morgan St. Grease 195 100 No Action
201803714 12/20/2018 27 1302 Kings Rod Debris in line 135 135 No Action
201803810 12/29/2018 120 1050 Sam Lattimore Rd. Pipe Failure (Break) 48,000 48,000 Notice of Violation
w/Intent to Enforce
North p Gro!na Department of Env.ronrnenta,Qua,ty I D;vs.on of Water Resources woo. a Reg ona Off,oe 1610 East Center Avenue,Sute 301 I Mooresv re.North Caro•ne 28115
_.......\ /'.° 704-63-1699

Total Vol
Total Surface
Incident Start Duration Vol Water
Number Date (Mins) Location Cause (Gals) (Gals) DWR Action
201803811 12/30/2018 103 2304 Sheriff Allen Rd. Other 4,150 500 Notice of Violation
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 W. Corey Basinger with the Water Quality Section
in the Mooresville Regional Office at 704-663-1699 or via email at [e-mail].
Sincerely,
,--- -DocuSigned by:
•
Al 4CCB81 AF27425...
W. Corey Basinger, 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 C®ro -.3 Department of Env ronmentel Qua ly I Dyson of Water Resources
��" Moores- a Regona'0ff:oe 6101 Eav Cs ter Avenue,Sale 301 Mooresv e,North Gem no 28116
•h---••� V 704-663-1699

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