WQCS00054_NOV-2019-DV-0257 Response_20190628

Department of Public Works
500 North Main Street
Suite #600
n Monroe, NC 28112
T. 704.296.4217
www.unioncountync.gov
June 28, 2019
Mr. W. Corey Basinger
Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
610 East Center Ave., Suite 301
Mooresville, NC 28115
Subject: Notice of Violation & Intent to Issue Civil Penalty
Tracking #: NOV-2019-DV-0257
Sanitary Sewer Overflows — May 2019
Collection System Permit — WQCS00054
Union County
Dear Mr. Basinger:
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Union County has received the NOV referenced above for collection system overflows.
Explanations of the overflows were on the BIMS Overflow Reporting Forms submitted by Union
County Public Works (UCPW) to the NCDEQ. However, we have added a few additional facts
in the explanations below.
Incident # Date
201900955
Response:
5/18/2019
Location
2103 Lytton Lane (Brookhaven Pump Station)
The SSO listed in this section was due to a force main break of the pipeline. This break occurred
on our wastewater easement that runs parallel to our gravity. Once we discovered the break, we
began apump/haul of the station and mobilized a team that worked thru the night to make the
repair. There were no signs leading up to the break that would indicate a failure was to occur.
The pipe had a longitudinal crack and the entire joint of pipe was replaced. Once repair was
made, the area affected was cleaned and restoration occurred.

Incident # Date Location
201900966 5/23/2019 706 White Oak Drive (Forest Park Pump Station)
Response:
The SSO listed in this section was due to a force main break of the pipeline. This break occurred
on our wastewater easement at 706 White Oak Drive. Once we discovered the break, we began a
pump/haul of the station and mobilized a team that made the repair within a few hours. There
were no signs leading up to the break that would indicate a failure was to occur. The pipe had a
longitudinal crack and the entire joint of pipe was replaced. Once repair was made, the area
affected was cleaned and restoration occurred. This pump station is currently under construction
as an entire replacement including new wet -well, electrical panels, new ARV's, and generator
set.
Incident # Date Location
201900977 5/28/2019 2844 Gray Fox Road (Ilelmsville Pump Station)
Response:
The SSO listed in this section was due to a force main break of the pipeline. This break occurred
beside the driveway to the pump station near a power pole. Once we discovered the break, we
began a pump/haul of the station and mobilized a team that made the repair within a few hours.
There were no signs leading up to the break that would indicate a failure was to occur. The pipe
was split from a power pole guide wire anchor installed when the new pole was set. Once repair
was made, the area affected was cleaned and restoration occurred.
UCPW also has an aggressive Capital Improvement Program throughout the next 5 years. The
projects include:
Crooked Creek Basin Improvements - $24,259,922.00
Crooked Creek Interceptor Improvements Ph. 1 - $9,915,500.00
Suburban Estates PS and FM - $1,000,000.00
Waxhaw Interceptor — 3,200,000.00
WW PS Improvements - $3,600,000.00
➢ Collection System SSES & Rehab — $2,080,000 (not including $85k amlually in
Operations)
PS Upgrades - $300,000 annually

Mercury Minimization Plan
We request that the requirement for a Mercury Minimization Plan (MMP) be removed from our permit.
The effluent mercury data from our four Priority Pollutant Scans demonstrates an average discharge
concentration of 0.77 ng/L and a maximum discharge concentration of 1.1 ng/L. Our effluent data is less
than the Water Quality Based and Technology Based Effluent Limits. Additionally, we will be required to
develop a plan to address the Dental Amalgam Rule, which should address any issues associated with
mercury.
If you have any questions regarding any of the NPDES permit renewal application materials, please
contact me at [phone] or [e-mail].
Sincerely,
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Andrew Neff, PE
Water and Wastewater Division Director
Attachments
Cc: Hyong Yi, Public Works Administrator
Bart Farmer, Union County Public Works, Water Reclamation Facilities Superintendent
Jonathan Jordan, Union County Public Works, Supervisor Twelve Mile Creek WRF
Mary Sadler, PE, Hazen and Sawyer
Jim Struve, PE, Hazen and Sawyer