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HomeMy WebLinkAboutAgenda - 01-18-1994-IX-A + 1 OR AN G E C 0 U N T Y BOARD OF COMMISSIONERS ACTION AGENDA ITEM ABSTRACT Meeting Date: January 18, 1994 Action Agenda item # _ly SUBJECT: Failure of Piney Mountain subdivision waste treatment system DEPARTMENT: County Manager PUBLIC HEARING: Yes _..A_No ATTACHMENT(S) : INFORMATION CONTACT: Letter to County Manager County Engineer Extension 2300 Proposed BOCC resolution Environmental Health report TELEPHONE NUMBERS: DEM letter Hillsborough - 732-8181 Colonial Engineering letter Durham - 688-7331 City of Durham letter Mebane - 227-2031 Piney Mountain miscellaneous Chapel Hill - 967-9251/968-4501 information packet PURPOSE: To present to the BOCC a petition from residents of Piney Mountain subdivision requesting the County's permission to construct and utilize a pump station and force main system connecting Piney Mountain's existing sewer collection system to the City of Durham's sewer collection system and to abandon Piney Mountain's existing on-site ground absorption waste treatment system which is malfunctioning and irreparable. BACKGROUND: Piney Mountain subdivision is a development of fifty-eight homesites on approximately 120 acres located within Chapel Hill Township and the Rural Buffer approximately one mile west of the Orange/Durham County line on the north side of Mount Sinai Road (SR 1718) . Currently, twenty-four of the homesites are undeveloped. Four of these remaining lots are still owned by the developer of Piney Mountain. Waste treatment for one homesite is provided by an individual on- site waste treatment unit which existed prior to the development. Waste treatment for all other existing homes in Piney Mountain is provided by a community waste treatment system consisting of two separate subsystems. Each subsystem includes individual septic and pump tanks at every home, a pressurized sewer collection system and a low pressure ground absorption waste disposal system. The treatment system be characterized as plagued by a multitude of instances of non-compliance with regulatory requirements, by design inadequacies, by installation of nitrification lines in unsuitable soils, by maintenance and operational problems and by frequent incidents where septic tank effluent is discharged on the surface of the ground. 2 Beginning in 1987, the Piney Mountain waste treatment system was permitted, constructed and operated by its owner, North State Utilities Inc. or its subsidiaries, which also owned and/or operated nine other similar systems located in Wake, Durham and Mecklenburg Counties. The Piney Mountain system was originally designed and permitted to serve all of the homesites within the subdivision. North State initially permitted and operated the Piney Mountain system and its other systems under the regulatory jurisdiction of the NC Division of Environmental Management (DEM) and the NC Utilities Commission. Regulatory authority over permitting and operational oversight for all ground absorption systems was transferred to the NC Division of Environmental Health (DEH) and local health departments in July, 1992. At that time, and in accordance with its new regulatory responsibilities associated with the Piney Mountain waste treatment system, the Environmental Health section of the Orange County Health Department opened communications with North State Utilities. The operating permit for the Piney Mountain treatment system was due to expire on January 31, 1993 and was to be renewed under the jurisdiction of the OC Health Department. As a part of the permit renewal process, the Environmental Health section began reviewing the Piney Mountain system's existing permit and permit requirements, design, remaining or unused treatment capacity, physical plant condition, operational practices, etc. During this process, the Environmental Health Section discovered that: a) the system was not constructed in accordance with either approved or as-built construction plans; b) did not contain sufficient nitrification line necessary to accommodate permitted waste flow; c) the number of existing bedrooms (and resulting regulatory waste flow loadings) per home averaged far in excess of the three bedrooms per home envisioned in system design and permitting; d) permitted total waste flow capacity was insufficient to serve all of the homesites intended to be served by the systems; e) sufficient nitrification field repair area was not available as required by current or original permit standards; and f) the system was receiving improper or inadequate monitoring and maintenance. All concerned parties were kept abreast of the Environmental Health section's findings. As a result of these findings, the Health Department declined to renew the system's operating permit or issue improvement permits for the septic and pump tank step systems for individual home sites. Environmental Health staff continued to work with North State to determine how the system's operating permit could be renewed. During this process, North State Utilities was directed to provide necessary information on the system, make specified repairs and modify its operational and maintenance practices. 3 In November 1992, while the Environmental Health section was involved in the early stages of the discovery process related to the regulatory and operational issues outlined above, Dennis Osborne, president of North State Utilities, resigned. His resignation deprived North State of its resident expert on the design and operation of ground absorption treatment systems. North State and its treatment system operating subsidiary continued in business under the direction of its vice-president. In early April 1993, North State's communications with several local health departments began indicating that the company was preparing to dissolve and abandon ownership and operation of all of its waste treatment systems. In July 1993, North State petitioned the NC Utilities Commission to be allowed to abandon all of its systems. This petition was never granted or denied but, in September 1993, Harrco Utilities was appointed by the Utilities Commission as the emergency operator for the Piney Mountain- treatment system. Prior to North State Utilities' July 1993 petition to abandon the Piney Mountain system, members of the Piney Mountain homeowners' association, including owners of homes and unimproved lots, had retained the services of an attorney and a professional engineer with ground absorption waste treatment expertise. Individual homeowners, the homeowners' attorney and engineer worked with staff from various County departments to determine how the treatment problems at Piney Mountain could be corrected. Once Harrco Utilities was appointed emergency system operation, its staff also became active in efforts to resolve problems. During the summer of 1993, an engineer working with the Piney Mountain homeowners began the process of evaluating various options for providing adequate waste treatment for both the existing homes and the undeveloped homesites within the subdivision. The engineer estimated that costs to correct the readily apparent design and construction flaws in the existing Piney Mountain system would be in the $50,000 to $100,000. Due to a significant possibility of undetected damage to the soils of the nitrification fields resulting from chronic overdosing and neglect, the engineer could not guarantee that recommended repairs would allow the system to function adequately for any length of time. The homeowners' attorney subsequently made a preliminary inquiry to the Durham City Engineer regarding the connection of the Piney Mountain sewer collection system to Durham's sewer system by means of a pumping station and force main. The City Engineer indicated that this was possible, but that OWASA would have to agree to this service extension in conformance with provisions of the existing service area agreement between Durham and OWASA. During discussions with County staff, the attorney and consulting engineer were informed that extension of municipal sewer service to any point within the Rural 4 Buffer area was expressly prohibited, except to address a public purpose or a health hazard, by the County' s Water and Sewer Policy. They were also informed that municipal service extensions were expressly discouraged by the Joint Planning Agreement involving the County, Chapel Hill and Carrboro. Subsequent efforts on the part of the homeowners, their attorney and engineer and Environmental Health staff to resolve the waste treatment problems focused on locating additional on-site areas which could be used for nitrification fields and repair areas. Environmental Health staff tested the soils at many sites within existing home sites, undeveloped lots and open areas in the subdivision, and they located several small areas containing suitable soil. However, the total additional area containing suitable soils was insufficient to provide the acreage for nitrification field expansion with repair area necessary to serve undeveloped lots. The new areas of suitable soils were also insufficient to provide the minimum repair area, even when added to existing repair area, required by regulation for the existing system. Upon completion of the unsuccessful effort to locate new nitrification fields and repair areas, the Piney Mountain homeowners and their consultants focused on investigating. the feasibility of replacing the existing system with other on-site waste treatment alternatives. They evaluated the possibility of utilizing non-discharging spray irrigation systems and a package waste treatment plant discharging to Piney Mountain Creek, a tributary of New Hope Creek. The consultants reported that spray irrigation was not feasible due to the large area required to provide buffers between spray fields and homesites, travel ways, wells, etc. The consultants also informed homeowners that DEM would be unwilling to issue a permit for discharge of treated wastes to Piney Mountain Creek. DEM confirmed (see attached DEM letter) that reported stream flow in Piney Mountain Creek does not meet DEM regulatory discharge requirements for minimum natural instream flow in receiving streams. The homeowners also had their consultants evaluate the suitability of the soils within the existing nitrification fields. Their soil scientist reported that seventy to eighty percent of the area in the existing nitrification fields was unsuitable for use as a nitrification field by virtue of one or a combination of unsuitable soils, insufficient soil depth or slope. His findings were essentially verified by a soils evaluation performed by County Environmental Health staff during the week of December 27, 1993. The Environmental Health staff reported (copy attached to abstract) that a maximum of thirty-five percent of the existing nitrification lines are installed in soils which could be classified as suitable for the installation. Additionally, the Environmental Health report noted concerns regarding the large size of the system that was installed in suitable soils. The report 5 also noted that staff had made no determination of overall system treatment capacity through evaluation of factors, other than soil suitability, which could produce additional limitations on system performance and treatment capacity. On the basis of the findings and rulings by various engineers, soil scientists, sanitarians, etc. , Piney Mountain homeowners have concluded that the existing waste treatment system is doomed to fail, probably in the near future and that it cannot be repaired or replaced by any available on-site waste treatment technology. County Environmental Health staff and the County Engineer concur with this assessment. Harrco Utilities is currently under order to make repairs to the existing system to bring that system into provisional compliance with Health regulations. Harrco, without benefit of the knowledge that most of the existing nitrification field is located in unsuitable soils, has proposed $200,000 in system repairs. The Piney Mountain homeowners have chosen to appeal to Orange County, other parties to the Joint Planning Agreement, OWASA and Durham to allow the connection of the Piney Mountain sewer collection system to nearest end of the City of Durham sewer collection system. That point is near the Kerley Road-Mount Sinai Road intersection, approximately 5000 feet east of the Piney Mountain entrance on Mount Sinai Road. RECOMMMMATION: Pursuant to the provisions, conditions and intent of the County Water and Sewer Policy, the Manager recommends that the Board of County Commissioners: 1) acknowledge the impending and irreversible failure of the Piney Mountain waste treatment with the serious potential for adverse public health and environmental .impacts; 2) acknowledge that waste treatment for the Piney Mountain subdivision cannot be provided by any available on-site waste treatment technology; 3) agree in principle to allow the extension of sewer service, dedicated solely to the approved homes and homesites within the Piney Mountain subdivision, from the City of Durham to Piney Mountain via a pump station and force main; 4) encourage the homeowners to direct their consultants to begin design and permitting of the pump station/force main system; 5) direct staff to work with the homeowners, the City of Durham, the Towns of Chapel Hill and Carrboro and OWASA to develop system design and operational codicils precluding any possibility that sewer service from this system would be available to any other users; and 6) direct staff to work with the homeowners, the City of Durham, the Towns of Chapel Hill and Carrboro and OWASA to develop a system ownership and operational proposals satisfactory to the Board. 6 Piney Mountain Homeowners Association Mount Sinai Road, Orange County, N.C. January 13, 1994 Mr. John M. Link, Jr. Orange County Manager 200 S. Cameron Street Hillsborough, N.C. 27278 Re: Piney Mountain Homeowners Association Petition for Permission to Install Pressurized Sewer Line To Durham Municipal Sewer Dear Mr. Link: Petition to the Orange County Board of Commissioners Piney Mountain Homeowners Association hereby petitions the Orange County Commissioners for permission to install a pressurized sewer line from Piney Mountain to the City of Durham sewer line at Kerley and Mt. Sinai Roads in Durham County. Following approval, such a line will be constructed in accordance with specifications of the Orange Water and Sewer Authority (OWASA) and the City of Durham, and will be restricted to the existing 58 lots originally designated to use the existing and failing low pressure pipe community sewer system (LPP System). No new phases or additions to the subdivision or adjacent to the subdivision will be permitted to utilize the line. By letter dated December 22, 1993 (copy attached), Mr. Kenneth E. Wright, Durham City Engineer has confirmed the willingness of the City of Durham to permit such an installation and tie-in to the Durham City sewer line. Enclosed is a draft of a resolution approving the installation which we propose for consideration by the Orange County Board of Commissioners. No Exception to Current Policy Piney Mountain is not requesting an exception to existing policy. Rather, Piney Mountain falls squarely within existing policy, which provides that sewer may be extended into the Rural Buffer in cases of public health emergency, such as a failing septic system. Since Piney Mountain has a failing septic system, it qualifies under the existing policy. In addition, Piney Mountain has exhausted all other possible solutions to its sewer problem. M -2- 7 Unsuitable soils. You have already received copies of the soil testing report dated November 16, 1993 performed by Barrett Kays & Associates (Kays Soils Report). The Kays Soils Report indicates that 80%of the 10 acres of soils in the primary nitrification fields at Piney Mountain are unsuitable. You will shortly be receiving a report from Thomas Konsler, of the Orange County Health Department, confirming the Kays Soils Report and stating that only 1.5 of the 7 acres of designated repair area at Piney Mountain contain suitable soils. Piney Mountain has been unable to locate sufficient additional suitable land to purchase. LPP System Beyond Repair. You have also received copy of letter dated November 24, 1993 from Paul K. Thames, Orange County Engineer, to Kathryn R. Kalb, Operations Director with OWASA. The Thames letter indicates that even with suitable soils (Mr. Thames was not aware of the Kays Soils Report when Mr. Thames wrote his opinion), the LPP System at Piney Mountain is never likely to perform adequately, regardless of the funds spent. NPDES Treatment Plant Not Feasible. By letter dated December 8, 1993, Barrett Kays & Associates (Kays Stream Report - copy previously submitted) reported on the preliminary low flow stream analysis for Pine Mountain Creek in the Piney Mountain subdivision. The report concluded that the Pine Mountain stream was ' not suitable for an NPDES treatment plant. The Kays Stream Report was confirmed by letter dated January 5, 1994 from A. Preston Howard, Director of the Division of Environmental Management (DEM) of the N. C. Department of Environment, Health and Natural Resources (DEHNR) to the Piney Mountain Homeowners Association (copy attached). In addition, Mr. Vernon O. Harris, Jr., President of Colonial Engineering, Inc. has by letter dated December 29, 1993 (copy attached), confirmed that spray irrigation is not a suitable alternative for Piney Mountain, and concluded that municipal sewer hookup is the best alternative available to Piney Mountain from an environmental point of view. Approval of Piney Mountain Installation Will Not Set a Bad Precedent The best way to prevent future requests similar to that of Piney Mountain is to make certain that government regulators look closely at proposals for subdivision with private sewerage systems. In the case of Piney Mountain, regulators at DEM approved a system that did not meet existing state standards, and the Orange County Commission relied on the DEM approval in approving the construction of the subdivision. You have already received a sample complaint recently filed by owners of 30 lots in Piney Mountain against DEM. Responsibility for enforcement of existing guidelines for sewer systems changed, effective July 14,1993, from the DEM to the Division of Environmental Health (DEH) of DEHNR. DEH, in turn, has delegated to local Health Departments primary enforcement authority, and it was the Orange County Health Department which initially Piney Mountain 8 . -3- identified defects in the Piney Mountain LPP System in the spring and summer of 1993. With proper administration of State regulations, future sewer systems in the Rural Buffer can be designed, installed and maintained properly. It is certain that no purchaser of a lot at Piney Mountain can be blamed for the failure of our LPP System. The choice of unsuitable soils, the design, construction, maintenance and approval of the LPP System were the responsibility of others. The key to prevention of similar requests in the future, therefore, cannot lie in penalizing current owners. Approval As Soon As Possible Thank you for facilitating communication between Orange County Staff and Piney Mountain by arranging for meetings with your staff and by assigning Paul Thames to act as liaison to Piney Mountain from Orange County. Thank you also for placing the petition of Piney Mountain on the agenda of the January 18 meeting of the Orange County Commissioners. There is considerable urgency to Piney Mountain's petition. On December 1, 1993, the emergency operator of the Piney Mountain LPP System, Harrco Utility Corporation, submitted a request to make repairs totalling $207,610.57 (a copy of which you have previously received). Harrco has never tested the Piney Mountain soils, and at the time it recommended these repairs, Harrco did not have the results of the Kays Soils Report. Thus, Harrco has made no determination as to whether the Piney Mountain LPP System will operate adequately even after the these repairs are made. In fact, the Kays Soils Report indicates the LPP System will not operate properly for long. Piney Mountain has filed objection to Harrco's proposed assessment for capital improvements to the Piney Mountain LPP System (copy previously submitted to you), and a hearing has been set for February 24, 1994 on the assessment by the Utilities Commission. Obviously, the members of Piney Mountain are trying to avoid paying for extremely expensive repairs to an LPP System which will shortly have to be abandoned. In order to avoid making the futile repairs, and begin constructing an environmentally safe alternative system as soon as possible, we must be able to act quickly on the installation of the pressurized sewer line to Durham's municipal line. Piney Mountain has already made presentations to the OWASA Board (on December 10, 1993 - copy of statement previously submitted to you) and to the Chapel Hill Town Council. We are on the agenda of the Carrboro Board of Aldermen on January 18, at the same time we will be on the agenda of the Orange County Commissioners. We understand that there is to be a retreat attended by representatives from OWASA, Orange County, Chapel Hill and Carrboro on February 5, 1994, at which time Piney Mountain will be discussed. Piney Mountain w 9 -4- On behalf of all of the members of the Piney Mountain Homeowners Association, I thank you for your prompt assistance with this urgent petition. Sincerely yours, Alan Whitaker, President Piney Mountain Homeowners Association Attachments: 1) Letter from City of Durham 2) Draft Resolution 3) DEM letter 4) Colonial Engineering letter Piney Mountain 10 -5- Orange County Commission Resolution in regard to the installation of municipal sewer line to the Piney Mountain Subdivision WHEREAS, the Piney Mountain Subdivision ("Piney Mountain") is located on Mt. Sinai Road in Orange County, N.C. in the area designated as the "Rural Buffer" by the Joint Planning Agreement dated November 2, 1987 among Orange County, Chapel Hill and Carrboro ("1987 Joint Planning Agreement"); and WHEREAS, the 1987 Joint Planning Agreement and Joint Planning Land Use Plan among Orange County, Chapel Hill and Carrboro (adopted in October 1986 and amended on April 2, 1990 - "Joint Planning Use Plan") each provides that the Rural Buffer "will not require urban services (public utilities and other town services);" and WHEREAS, the Joint Planning Use Plan also acknowledges that the Orange Water and Sewer Authority ("OWASA"), as the provider of water and sewer in the Joint Planning Area, extends water and sewer in accordance with the adopted policies of the applicable local governments; and that the applicable policy of Orange County for the Rural Buffer is to extend water and sewer only to provide service to an essential ' public service, such as a school, or to remedy a public health emergency, such as a failing septic tank or failing package treatment plant; and WHEREAS, Piney Mountain has a failing community low pressure pipe sewerage disposal system ("LPP System"); and WHEREAS, Piney Mountain, after a complete investigation with the assistance of soil scientists and Orange County Engineers and Health Department staff, has established that the LPP System has been installed in unsuitable soils and that there is insufficient repair area either existing or available for purchase; that, even in suitable soils the LPP system has been so poorly designed, constructed and maintained that it is likely that it would never perform adequately, regardless of the funds spent; that other alternatives such as an NPDES discharge system (treatment plant) are not feasible; and that the only solution to providing sewer service to its 58 homesites is to install and maintain, at Piney Mountain's expense, in accordance with specifications of OWASA and the City of Durham, and in such a manner so as to deter additional connections, a pressurized sewer line from Piney Mountain to the City of Durham municipal line at the intersection of Kerley and Mt. Sinai Roads in Durham County ("Sewer Line"); and WHEREAS, Piney Mountain has secured the approval of Kenneth E. Wright, Durham City Engineer (subject to the usual conditions) to connect the Sewer Line with that of the City of Durham provided that Piney Mountain also secures the approval of OWASA; and Piney Mountain _6- 11 WHEREAS, Piney Mountain is in the process of securing the approval of OWASA and the towns of Chapel Hill and Carrboro to construct the Sewer Line as hereinbefore stated; and WHEREAS, time is of the essence since the LPP System is in urgent need of replacement; IT IS THEREFORE RESOLVED, that the Orange County Commission does hereby find that by virtue of Piney Mountain's failing LPP System, and with regard to the installation of the Sewer Line only, Piney Mountain does fall within existing exceptions to the general prohibition on the extension of sewer to the Rural Buffer, and the Commission does hereby approve the installation of the Sewer Line as requested in the petition from Piney Mountain, subject to such conditions as may be reasonable and necessary in accordance with the recommendations of the Orange County Manager and his staff, and the Orange County Manager is directed to take all necessary and appropriate actions to facilitate the installation of the Sewer Line as soon as possible. Piney Mountain , Nov County 54eaffi (�Depahtment 12 Daniel B. Reimer, MPH, Director ENVIRONMENTAL HEALTH DIVISION %Stl of PERSONAL HEALTH DIVISION P 0 Box 8181 • 306C Revere Road ��� DENTAL HEALTH DIVISION ANIMAL CONTROL DIVISION V�� �i P 0 Box 8181 • 300 W Tryon Street P 0 Box 8181 • 304 Revere Road Hillsborough.NC 27278 Hillsborough NC 27278 it L HILLSBOROUGH CHAPEL HILL ` MEBANE DURHAM 919-7328181 919-9679251 t.t' 919-2272032 919-688 7333 MEMORANDUM TO : Paul Thames FROM: Tom Konsler Ix RE : Soil/site evaluation of existing drainfield serving Piney Mountain Subdivision DATE : January 12 , 1994 In response to discussions in the meeting with representatives of Piney Mountain Subdivision on December 21 , 1993 , our staff soil scientist , Jerry Stimpson and I conducted assessments of the soils in the existing drainfield areas at Piney Mountain. The following is a summary of the results in the two phases of the subdivision. Phase I - Which currently has 13 connections plus 1 under construction: Out of 7 soil borings - All 7 borings could be classified Provisionally Suitable and ranged from 24 to 32 inch soil depth before encountering unsuitable horizons consisting of saprolite or in the case of two holes [ in the 12-16 subfields ] , massive clay . It should be noted that while these borings indicated a Provisionally Suitable classification, we would express concern over a large capacity system such as this installed in these marginal site conditions . We also recognize from earlier evaluations that the soil depth within Phase I can be quite variable. Phase II - Which has 20 connections: 5 borings in Field A - None were classified as Suitable or Provisionally Suitable . All borings were classified Unsuitable due to one or more of the following factors : -Topography/ landscape positions containing convergent valley slopes , gullies , and/or terraces . -Soils which are massive , exhibiting no structural peds , less than 24 inches from the ground surface . -Expansive clay mineralogy. SOUTHERN ORANGE OFFICE. Carr Mill Mall • Suite 225 • 100 N Greensboro Street • Carrboro.NC 27510 • 919.968.2022 13 2 -Shallow soil depths generally less than 24 inches to unsuitable horizons / saprolite or parent material . 15 borings in Field III - 3 borings indicated soils meeting a classification of Provisionally Suitable for LPP systems . These borings were located in areas which leads to the estimation that approximately 2 , 510 linear feet of drainfield is located in Provisionally Suitable site/soil conditions . - 12 borings were classified as Unsuitable for the same reasons indicated above . SUMMARY Approximately 12 ,000/ 12, 240 linear feet or 982 of Phase I system was installed in soil and sites meeting a classification of Provisionally Suitable. Approximately 2 , 510/27 ,613 linear feet or less than 10 % of Phase II system was installed in soil and sites meeting a classification of Provisionally Suitable. With a total of 14 , 500 linear feet of system installed in Provisionally Suitable soil , the estimated capacity of the system in flow is approximately 7,250 Gallons Per Day. This is compared with: - the permitted regulatory flow of 12,240 Gallons Per Day based on DEM' s assumption of three bedroom homes, - and with the design flow rate of 15 ,360 Gallons Per Day based on the regulatory flow of 120 GPD per existing bedroom. Please keep in mind that these figures are only estimates based on the limited amount of evaluations done , but are indicative of the expected long term functionality of the system based on site and soil criteria. In this evaluation, we have not taken other factors into account such as installation techniques , proximity to embankments or monitoring wells , trench depths , system components and materials , design factors , or the present operating difficulties , all which affect system performance . Please let me know if you have any questions regarding this . 49 0 �+ L14 ONE Im WAR s HSE � cn 1 10 011, - 0 56 • 9 }.. CD - - - - - -_ - _ N O �• is on �._._. w .—• U k \ Z6 1 ir • O lam: 1 �� c ' � It it 1 ie I % 1 /0"— 9Z� Ln w r v r 0 w n n n N 16 S � 42 e� ---�--- --------------- --------- \; 43 - - w �• ��� '/.n•. !H �1.J\1 i IPA., - '. •' ,t t• , t i -- - � E VE L a 'o -{ r 44 S.a2 Of Ile -ER ' RVE _D - 19477 LF PIPE D 3E = 720 LF/HSE cl III :_:: : _.. , "". ��s:��-•��,:;� �' P�� 1 1 0 �• Klq� ,, 17 State of North Carolina Department of Environment, Health and Natural Resources r4i Division of Environmental Management James B. Hunt, Jr., Governor fi Jonathan B. Howes, Secretary ED E= A. Preston Howard, Jr., P.E., Director January 7, 1994 Mr.Alan K. Whitaker,President Piney Mountain Homeowners Associaton 4729 Tap Root Lane Durham,North Carolina 27705 Subject: Piney Mountain Subdivision Wastewater Disposal Alternatives Orange County Dear Mr.Whitaker The Division of Environmental Management has been asked to review and comment to you on the December 8, 1993 letter prepared by Barrett Kays&Associates concerning potential discharge alternatives for the subject facility. At the onset, I must say that if a A—I decision regarding the potential of a surface water discharge is necessary, an NPDES application prepared in accordance with the requirements of 15A NCAC 2H .0100 would have to submitted to our division for consideration. Since no application has been received, the opinion-we give here is advisory only and assumes the accuracy of the information in Barrett Kays & Associates' letter. With this caveat, we agree with the conclusion in Barrett Kays&Associates'letter that the division would not desire to issue a discharge permit for Piney Mountain Subdivision because it would be undesirable for reasons which follow. North Carolina General Statute 143-215.1 requires that a permit be obtained prior to any discharge to the surface waters of North Carolina. Furthermore, the statutes state that all permit decisions require that the practicable waste treatment and disposal alternative with the least adverse impact on the environment be utilized. The reason for this is that nondischarge alternatives such as recycling, subsurface disposal, spray irrigation and connection to regional waste treatment facilities, where feasible, are all more environmentally sound alternatives as compared to surface water discharges. Even in the name of the program authorized by the Clean Water Act,the National Pollutant Discharge Elimination System(NPDES),the intent of nondischarge preference is implied. Title 15A of the North Carolina Administrative Code 2H .0100 further elaborates on the requirements for an NPDES permit. One important aspect of an NPDES permit application is to provide a summary of waste treatment and disposal options and why the proposed system and point of discharge were selected. The rule further requires that the summary should have sufficient detail to assure that the most environmentally sound alternative was selected from the reasonably cost effective options. The division has prepared guidance for permit applicants to utilize in conducting technical and financial evaluation of potential disposal alternatives which clearly identifies nondischarge preferences superior to potential discharge alternatives. P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone 919-733-7015 FAX 919.733-2496 An Equal Opportunity Affirmative Action Employer 509'6 recycled!10%post-consumer paper January 7, 1994 18 Mr. Alan K. Whitaker Piney Mountain Subdivision Title 15A of the North Carolina Administrative Code 2B .0200 elaborates on the issue of potential discharges into low flow streams. In cases where the 7Q10 flow, the average flow for seven (7) consecutive days in a ten (10) year period as reported by the United State Geological Survey(USGS), is zero,approval for a new discharge is dependent upon the 30Q2, the average flow for thirty (30) consecutive days in a two (2) year period, as follows: 1. Where the 30Q2 flow is estimated to be greater than zero, effluent limitations for new discharges of oxygen consuming waste will be set at BODS =5 mg/l, NH3-N=2 mg/1 and DO=6 mg/l,unless it is determined that these limitations will not protect water quality standards. 2. If the 30Q2 and 7Q10 flows are both estimated to be zero,no new discharge of oxygen consuming waste will be allowed Due to the statistical variability of these estimates, any 30Q2 flow estimate 5 0.05 cfs is considered to be zero by the division. Therefore, based upon the information contained in the letter prepared by Barrett Kays & Associates, and that the estimated 30Q2 flow is below 0.05 cfs, we are in agreement with the conclusions drawn by the consultant. If you have any questions regarding this matter,please do not hesitate to contact Mr. Steve Tedder,Chief of the Water Quality Section or me at(919)733-7015. Since ly, A. Preston Howard, Jr., P.E. cc: Office of the Attorney General-Mr.Jim Gulick Mr.Steve Tedder Ms.Nancy Essex /� nn 19 aLtiaC/�&yineering, J�nc. V. 0 a'.•,P.6 P.0 12. 97005 919) 847-1499 P,.-,;J..i KoUgA, /7 if 27624 `7—(919) 847-1498 December 29, 1993 Mr. Morris Stanford Piney Mountain Home Owners Assoc. P. O. Box 15668 Durham, NC 27704 Re: Existing Wastewater Dilemma Piney Mountain Home Owners Assoc. (4316) Dear Mr. Stanford: Following up our conversation of December 22, 1993, we are herewith providing to you, for presentation to Orange County Agencies, a statement with regard to existing wastewater conditions and alternative possibilities. These situations are as personally observed during my visit to the Piney Mountain Subdivision on September 10, 1993. It should be noted that a very thorough review of the existing facilities and the proximity to other alternatives (i.e. hookup to Durham) was observed on that occasion. Alternatives that were evaluated and discussed were as follows: 1. Continue to operate the existing systems - as mentioned above, the existing system is already undersized in that more lineal feet of nitrification should have been installed and additional area is not available. The system, as installed, is doomed for failure as more houses, and lack of operational maintenance, occurs on the system. 2. Use exiting collection system and install treatment plant discharging to Piney Mountain Creek. The Regional office Staff of Eavironmeatal Management was checking on the ten year low flow for this condition. This would add a new point source discharge to the Basin. 3. Install spray irrigation - due to the proximity of existing homes and the tightness of the soils, sufficient area is not available to this community. Since it is a privately owned subdivision, it does not have condemnation rights and thus, cannot forcibly acquire other lands that may be in a reasonable proximity to this subdivision location. Furthermore, housing commitments to lands surrounding the subdivision would not allow for the existing nitrification area to be converted to above ground irrigation as sufficient buffers and protection Irom runoff would not be available. Some of the areas 20 where the LPP system is installed is steeply sloping areas which would expedite runoff into the streams under rainfall conditions With spray irrigation. LPP can be terraced in; spray irrigation cannot. 4. Hookup to the existing Durham sewers - the existing collection system would lend itself very well to continuing to operate by discharging into a central pump station (S) that could then pump into the Durham sewers. In fact, measuring the distance in the field, it is anticipated that 1.5 miles is the distance to the nearest Durham gravity manhole located at the intersection of Mt. Sinai and Kurley Roads. Two roadbores and one creek crossing would be necessary in order to install this line. From an environmental protection point of view and the Statefs direction of centralizing all minor. (even if potential) dischargers into a central, well-managed facility, this is the best alternative available to Piney Mountain Subdivision. We would be happy to discuss the situation in any detail as may be requested by any review agencies on behalf of the Piney Mountain Home Owners Association. The Association is to be commended for its positive, aggressive direction in seeking to protect their environment and to handle wastewater generated from their home in the best environmental method available. It is my opinion that time is of the essence to seeking a quick solution so that contamination of near b streams does not occur. Very ly o , Ve non O. ' Harris, of PE President VOH,Jr/ed stanf ord.pme 21 DURHAM DIVISIONS sa..t bole* ii0.4326 wets& se er E00OW4 $404326 use MOMWA" " City of Durham Department of Engineering 1 8 6 9 9)"T-0496 101 city Hd Phis olrt ft NC 27701 CITYOFMEDICINE December 22. 1993 Mr. Alan Whitaker. President Piney Mountain Homeowner's Association 4729 Taproot Lane Durham, N. C. 27705 Dear Mr. Whitaker: Over the last several months,I have had several conversations With Ms.Deborah Christie regarding the possibility of sewer service being provided by the City of Durham to the Piney Mountain subdivision. This discussion was in view of the fact that the current onske system serving the subdivision was not operating property. 1 had advised Ms. Christie that the Piney Mountain subdivision was located in a utility service area designated to OWASA by the City of Durham and that service by the City would be contingent upon a release from OWASA. As of this date. OWASA has not indicated a willingness to release the subdivision to service by the City of Durham, nor has R Indicated under what conditions, if any, it may be willing to do so. If, however, OWASA were to release the subdivision,subject to conditions found acceptable by the City,this is to advise that I would be willing to recommend to the City Council that the City of Durham provide sewer service to the Piney Mountain subdivision subject to the terms of an agreement. The terms to be Included in that agreement have not yet been fully determined. However, 4 would include a provision whereby the sewer collection system within the subdivision. a pump station, and farce main connecting the subdivision to the existing City sewer system would remain In the ownership of the Piney Mountain Homeowner's Association, and that sewer service would be limited to the existing lots within the Piney Mountain subdivision both developed and vacant. No new phases of the subdivision could be served by the sewer system nor could any other development outside the subdivision. The provisions of this letter are limited to an agreement between the City and the Piney Mountain Homeowner's Association. No commitment Is being made at this time for any similar arrangement with any other entity that might subsequently own and/or operate the sewer collection system serving the Piney Mountain subdivision. If you have any questions regarding this matter, please feel free to contact me. sincerely, Kenneth E. Wright, PE, RLS City Engineer KEW/icp c: Lee Murphy Don Greeley Deborah Christie AN EQUAL OPPORTUNITYIAPitRMATIYE ACTION EMPLOYER 22 Piney Mountain Homeowners Association Mount Sinai Road, Orange County, N.C. December 21, 1993 Mr. Calvin Horton Chapel Hill Town Manager 306 N. Columbia Street Chapel Hill, N.C. 27516 Re: Piney Mountain Request for Expedited Review by Chapel Hill Town Council Dear Mr. Horton: Petition to the Chapel Hill Town Council Thank you for meeting recently with Ms. Bes Baldwin, a member of the Piney Mountain Homeowners Association, concerning Piney Mountain's application to OWASA and the Orange County Commissioners for permission to install a pressurized sewer line from Piney Mountain to the City of Durham sewer line at Kerley and Mt. Sinai Road in Durham County. Such a line would be constructed in accordance with specifications of OWASA and the City of Durham, and would be restricted to existing lots in the Piney Mountain Subdivision. No new phases or additions to the subdivision or adjacent to the subdivision would be permitted to utilize the line. Mr. Ken Wright, Director of Engineering with the City of Durham is in the process of confirming by letter the willingness of the City of Durham to permit such a hookup to the Durham City sewer line, and I will forward to you a copy of his letter as soon as I receive it. In your meeting with Bes, you recommended that Piney Mountain submit a petition to you for presentation to the Chapel Hill Town Council at its January 10, 1994 meeting. Piney Mountain should then present in 3 minutes its request for a nonbinding resolution by the Council approving Piney Mountain's request to OWASA and Orange County. You anticipated that the Council would then refer the matter to staff. Following investigation and recommendations by staff, the matter would then come back to the Council for action at the January 25 or February 14, 1994 meetings, depending on how soon your staff could be ready to make a recommendation. Enclosed (Attachment 1) is a draft of a nonbinding resolution which we would propose for consideration by the Chapel Hill Town Council. We have drafted this resolution on the assumption that Chapel Hill will not approve or disapprove of Piney Mountain's request; instead, Chapel Hill will register its concurrence with whatever judgment is reached by OWASA and Orange County. Is this the correct approach? 23 How Can Piney Mountain justify an Exception to Current Policy? You stated to Bes Baldwin that Piney Mountain would need to show how we justify an exception to the current policy which prohibits water and sewer in the Rural Buffer. As the attached nonbinding resolution shows, Piney Mountain is not requesting an exception to existing policy. Rather, Piney Mountain falls squarely within existing policy, which provides that sewer may be extended into the Rural Buffer in cases of public health emergency, such as a failing septic system. Since Piney Mountain has a failing septic system, it qualifies under the existing policy. In addition, Piney Mountain has exhausted all other possible solutions to its sewer problem. You have already received from Bes Baldwin copies of the soil testing report dated November 16, 1993 performed by Barrett Kays &Associates, and engineering opinion dated November 24, 1993 from Paul Thames, Orange County Engineer. The Kays report indicates that 80% of the soils in the primary nitrification fields at Piney Mountain are unsuitable. Tom Konsler, of the Orange County Health Department has determined that only 1.5 of the 7 acres of designated repair area at Piney Mountain contain suitable soils. We have been unable to locate sufficient additional suitable land to purchase. The Thames letter indicates that even with suitable soils (he was not aware of the Kays report when he wrote his opinion), the LPP System at Piney Mountain is likely never to perform adequately, regardless of the funds spent. The attached additional report dated December 8, 1993 from Barrett Kays & Associates (Attachment ?)indicates that the Pine Mountain stream is not suitable for an NPDES discharge system (treatment plant). Individual septics systems are possible for only a few homesites (7 of the 58), and individual septic systems are prohibited under the restrictive covenants for the subdivision. Will Granting Piney Mountain's Request Set a Bad Precedent? You also suggested to Bes that Piney Mountain should explain what will prevent future requests similar to that of Piney Mountain. The best way to prevent future requests like the present one is to make certain that government regulators look closely at proposals for subdivisions with a private sewerage system. In the case of Piney Mountain, regulators at the Division of Environmental Management(DEM)approved a system that did not meet existing state standards, and the Orange County Commission relied on the DEM approval in approving the construction of the subdivision. Attachment 3 is a sample of the complaint recently filed by owners of 30 lots in Piney Mountain against DEM. Responsibility for enforcement of exisiting guidelines for sewer systems changed, effective June 1992, from the DEM to the Division of Environmental Health (DEH) of the State Department of the Environment, Health and Natural Resources. DEH, in turn, has delegated to local Health Departments primary enforcement authority, and it was the Orange County Health Department which initially identified defects in the Piney Mountain LPP System in the spring and summer of 1993. With proper administration of State regulations, future sewer systems in the Rural Buffer can be designed, installed and maintained property. Norton 24 3 - It is certain that no purchaser of a lot at Piney Mountain can be blamed for the failure of our LPP System. The choice of unsuitable soils, the design, construction and maintenance of the LPP System were the responsibility of others. The key to prevention of similar requests in the future, therefore, cannot lie in penalizing current owners. Staff Investigation As Soon As Possible I am also writing to inquire whether it might be possible to accelerate the process by having your staff begin its investigation in advance of the January 10 meeting, so that Council members might have your recommendation and take possible action at the January 10 or 25 meetings. Such an investigation by your staff can be facilitated by their contact with the OWASA and Orange County staffs who have already begun extensive investigation of our LPP System and alternatives. To explain further: the Piney Mountain LPP System is failing. On December 1, 1993, the emergency operator of the LPP System, Harrco Utility Corporation, submitted a request to make repairs totalling$207,610.57(Attachment 4). Harrco has never tested the Piney Mountain soils, and at the time it recommended these repairs, Ham did not have the results of the Kays Report. Thus, Harrco has made no determination as to whether the LPP System will operate adequately even after these repairs are made. In fact, the Kays report indicates the LPP System will not operate properly for long. Attachment S is a copy of the objection to Harrco's proposed assessment for capital improvements to the curmt LPP System, which Piney Mountain Homeowners Association filed with the Utilities Commission. Obviously, the members of Piney Mountain are trying to avoid paying for extremely expensive repairs to a system which will shortly have to be abandoned. In order to avoid making the futile repairs, we must be able to act quickly on the installation of the pressurized sewer line to Durham's municipal line. We have already made a presentation (on December 10, 1993) to the OWASA Board. Attachment 6 is a copy of the statement we offend. OWASA Staff was instructed at that meeting to investigate finrther into the matter, and to determine the best method of communication with the governmental bodies which appoint members to OWASA (Chapel Hill, Carrboro, and Orange County). The next meetings of the OWASA Board are January 13 and 27, 1994. The Orange County Commissioners meet on January 3 and 18, the Carrboro Aldermen meet on January 4 and 11, and the Chapel Hill Town Council meets on January 10 and 25. If Piney Mountain could secure the approval/concurrrence of these governmental bodies on one of these dates, then OWASA could perhaps take definitive action on January 13 or 27. horton 25 - 4 - On behalf of all of the members of the Piney Mountain Homeowners Association, I thank you for your patient understanding of our request. If not for the urgence of the situation, we would not ask you for accelerated assistance. I will be telephoning you in the next few days to speak further with you about our request. Bes has already provided you with a contact sheet with the names and addresses of various members of our Association. Please feel free to contact any of those listed. Thank you for your assistance in placing the matter of Piney Mountains request to OWASA and Orange County on the agenda for the January 10 meeting, and for beginning staff investigation as soon as you can. Sincerely yours, Alan Whitaker, President Piney Mountain Homeowners Association Attachments: 1) Draft of a nonbinding resolution 2) Report dated December 8, 1993 from Barrett Kays & Associates 3) Complaint against DEM 4) Request to Utilities Commission from Harrco dated December 1, 1993 S) Objection of Piney Mountain to Harsco's Request to Utilities Commission 6) Statement to OWASA dated December 10, 1993 c w/att: Ralph Carpinos, Esquire Chapel Hill Town Attorney Ms. Sonna Loewenthal Ms. Flo Miller The Honorable Kenneth Broun Mayor of Chapel Hill Ms. Julianne Andresen, Chair OWASA Board of Directors Robert Epting, Esquire Attorney to OWASA Norton 26 - S - Mr. Everett Billingsley Executive Director of OWASA Ms. Kathryn Kalb General Manager of Operations of OWASA Orange County Manager Geoffrey E. Gledhill, Esq. Attorney to Orange County Mr. Marvin E. Collins Orange County Director of Planning Mr. Robert W. Morgan, Carrboro Town Manager Mr. Roy Williford, Carrboro Director of Planning horton 27 Piney Mountain Homeowners Association Mount Sinai Road, Orange County, N.C. December 22, 1993 Mr. Robert W. Morgan Cantioro Town Manager 301 W. Main Street Canboro, N.C. 27510 Re: Piney Mountain Request for Expedited Review by Carrboro Board of Aldermen Dear Mr. Morgan: Petition to the Carrboro Board of Aldermen Thank you for meeting recently .with Ms. Bes Baldwin, a member of the Piney Mountain Homeowners Association, concerning Piney Mountain's application to OWASA and the Orange County Commissioners for permission to install a pressurized sewer line from Piney Mountain to the City of Durham sewer line at Kerley and Mt. Sinai Road in Durham County. Such a line would be constructed in accordance with specifications of OWASA and the City of Durham, and would be restricted to existing lots in the Piney Mountain Subdivision. No new phases or additions to the subdivision or adjacent to the subdivision would be permitted to utilize the line. Mr. Ken Wright, Director of Engineering with the City of Durham is in the process of confirming by letter the willingness of the City of Durham to permit such a hookup to the Durham City sewer line, and I will forward to you a copy of his letter as soon as I receive it. Enclosed (attachment 1) is a draft of a nonbinding resolution which we would propose for consideration by the Carrboro Board of Aldermen at its January 11 meeting. We have drafted this resolution on the assumption that Canfboro will not approve or disapprove of Piney Mountain's request; instead, Carrboro will register its concurrence with whatever judgment is reached by OWASA and Orange County. Is this the correct approach? How Can Piney Mountain justify an Exception to Current Policy? As the attached nonbinding resolution shows, Piney Mountain is not requesting an exception to existing policy. Rather, Piney Mountain falls squarely within existing policy, which provides that sewer may be extended into the Rural Buffer in cases of public health emergency, such as a failing septic system. Since Piney Mountain has a failing septic system, it qualifies under the existing policy. In addition, Piney Mountain has exhausted all other possible solutions to its sewer problem. You have already received from Bes Baldwin copies of the soil testing report dated November 16, 1993 performed by Barrett Kays &Associates, and engineering opinion dated November 24, 28 1993 from Paul Thames, Orange County Engineer. The Kays report indicates that 80% of the soils in the primary nitrification fields at Piney Mountain are unsuitable. Tom Konsler, of the Orange County Health Department has determined that only 1.5 of the 7 acres of designated repair area at Piney Mountain contain suitable soils. We have been unable to locate sufficient additional suitable land to purchase. The Thames letter indicates that even with suitable soils (he was not aware of the Kays report when he wrote his opinion), the LPP System at Piney Mountain is likely never to perform adequately, regardless of the funds spent. The attached additional report dated December 8, 1993 from Barrett Days & Associates (Attachment 2)indicates that the Pine Mountain stream is not suitable for an NPDES discharge system (treatment plant). Individual septies systems are possible for only a few homesites (7 of the 58), and individual septic systems are prohibited under the restrictive covenants for the subdivision. Will Granting Piney Mountain's Request Set a Bad Precedent? The best way to prevent future requests like the present one is to make certain that government regulators look closely at proposals for subdivisions with a private sewerage system. In the case of Piney Mountain, regulators at the Division of Environmental Management (DEM) approved a system that did not meet existing state standards, and the Orange County Commission relied on the DEM approval in approving the construction of the subdivision. Attachment 3 is a sample of the complaint recently filed by owners of 30 lots in Piney Mountain against DEM. Responsibility for enforcement of exisiting guidelines for sewer systems changed, effective June 1992, from the DEM to the Division of Environmental Health (DEH) of the State Department of the Environment, Health and Natural Resources. DEH, in turn, has delegated to local Health Departments primary enforcement authority, and it was the Orange County Health Department which initially identified defects in the Piney Mountain LPP System in the spring and summer of 1993. With proper administration of State regulations, future sewer systems in the Rural Buffer can be designed, installed and maintained properly. It is certain that no purchaser of a lot at Piney Mountain can be blamed for the failure of our LPP System. The choice of unsuitable soils, the design, construction and maintenance of the LPP System were the responsibility of others. The key to prevention of similar requests in the future, therefore, cannot lie in penalizing current owners. Staff Investigation As Soon As Possible I am also writing to inquire whether it might be possible to accelerate the process by having your staff begin its investigation so that Aldermen might have your recommendation and take possible action at the January 11 meeting of the Aldermen. Such an investigation by your staff can be facilitated by their contact with the OWASA and Orange County staffs who have already begun extensive investigation of our LPP System and alternatives. Morgan 29 - 3 - To explain further. the Piney Mountain LPP System is failing. On December 1, 1993, the emergency operator of the LPP System, Harrco Utility Corporation, submitted a request to make repairs totalling$207,614.57(Attachment 4). Ha=has never tested the Piney Mountain soils, and at the time it recommended these repairs, Harrco did not have the results of the Kays Report. Thus, Harrco has made no determination as to whether the LPP System will operate adequately even after these repairs are made. In fact, the Kays report indicates the LPP System will not operate properly for long. Attachment 5 is a copy of the objection to Harrco's proposed assessment for capital improvements to the current LPP System, which Piney Mountain Homeowners Association filed with the Utilities Commission. Obviously, the members of Piney Mountain are trying to avoid paying for extremely expensive repairs to a system which will shortly have to be abandoned. In order to avoid making the futile repairs, we must be able to act quickly on the installation of the pressurized sewer line to Durham's municipal line. We have already made a presentation (on December 10, 1993) to the OWASA Board. Attachment b is a copy of the statement we offered. OWASA Staff was instructed at that meeting to investigate further into the matter, and to determine the best method of communication with the governmental bodies which appoint members to OWASA (Chapel Hill, Carrboro, and Orange County). The next meetings of the OWASA Board are January 13 and 27, 1994. The Orange County Commissioners meet on January 3 and 1$, the Canfboro Aldermen meet on January 11, and the Chapel Hill Town Council meets on January 10 and 25. If Piney Mountain could secure the approvallconcurrrence of these governmental bodies on one of these dates, then OWASA could perhaps take definitive action on January 13 or 27. On behalf of all of the members of the Piney Mountain Homeowners Association, I thank you for your patient understanding of our request. If not for the urgence of the situation, we would not ask you for accelerated assistance. I will be telephoning you in the next few days to speak further with you about our request. Bes has already provided you with a contact sheet with the names and addresses of various members of our Association. Please feel free to contact any of those listed. Thank you for your assistance in placing the matter of the nonbinding resolution concerning Piney Mountain's request to OWASA and Orange County on the agenda for the January 11 meeting of the Carrboro Board of Aldermen, and for beginning staff investigation as soon as you can. morgan 30 - 4 - Sincerely yours, CK�A 6A Alan Whitaker, President Piney Mountain Homeowners Association Attachments: 1) Draft of a nonbinding resolution 2) Report dated December 8, 1993 from Barrett Kays & Associates 3) Complaint against DEM 4) Request to Utilities Commission from Harrco dated December 1, 1993 5) Objection of Piney Mountain to Harrco's Request to Utilities Commission 6) Statement to OWASA dated December 10, 1993 c w/att: Mr. Roy Williford Carrboro Director of Planning Mr. Calvin Horton Chapel Hill Town Manager Ralph Carpinos, Esquire Chapel Hill Town Attorney Ms. Sonna Loewenthal Ms. Flo Miller The Honorable Kenneth Broun Mayor of Chapel Hill Ms. Julianne Andresen, Chair OWASA Board of Directors Robert Epting, Esquire Attorney to OWASA Mr. Everett Billingsley Executive Director of OWASA Ms. Kathryn Kalb General Manager of Operations of OWASA morgan 31 - $ - Mr. John M. Link, Jr. Orange County Manager Geoffrey E. Gledhill, Esq. Attorney to Orange County Mr. Marvin E. Collins Orange County Director of Planning morgan 32 Chapel Hill Town Council Nonbinding Resolution in regard to the installation of municipal sewer line to the Piney Mountain Subdivision I WHEREAS the Piney Mountain Subdivision("Piney Mountain") is located on Mt. Sinai Road in Orange County, N.C. in the area designated as the "Rural Buffer" by the Joint Planning Agreement dated November 2, 1987 among Orange County, Chapel Hill and Carrboro ("1987 Joint Planning Agreement"); and WHEREAS, the 1987 Joint Planning Agreement and the Joint Planning Land Use Plan among Orange County, Chapel Hill and Carrboro (adopted in October 1986 and amended in April 2, 1990 • "Joint Planning Use Plan") each provides that the Rural Buffer "will not require urban services (public utilities and other town services);* and WHEREAS, the Joint Planning Use Plan also acknowledges that the Orange Water and Sewer Authority ("OWASA"), as the provider of water and sewer in the Joint Planning Area, extends water and sewer in accordance with the adopted policies of the applicable local governments; and that the applicable policy of Orange County for the Rural Buffer is to extend water and sewer only to provide service to an essential public service, such as a school, or to remedy a public health emergency, such as a failing septic tank or failing package treatment plant; and WHEREAS, Piney Mountain has a failing community low pressure pipe sewerage disposal system ("LPP System"); and WHEREAS, Piney Mountain, after a complete investigation with the assistance of soil scientists and Change County Engineers and Health Department staff, has established that the LPP System has been installed in unsuitable soils and that there is insufficient repair area either existing or available for purchase; that, even in suitable soils, the LPP System has been so poorly designed, constructed and maintained that it is likely that it would never perform adequately, regardless of the funds spent; that other alternatives such as an NPDES discharge system (treatment plant) are not feasible; and that the only solution to providing sewer service to its 58 homesites is to install and maintain, at Piney Mountain's expense, a pressurized sewer line from Piney Mountain to the City of Durham municipal line at the intersection of Kerley and Mt. Sinai Roads (*Sewer Line*); and WHEREAS, Piney Mountain has secured the approval of the City of Durham to connect the Sewer Line with that of the City of Durham provided that Piney Mountain also secures the approval of OWASA; and P:chaphill 33 - 2 - WHEREAS, Piney Mountain is in the process of securing the approval of OWASA and the Orange County Commissioners to construct the Sewer Line in accordance with OWASA specifications and such a manner that will deter additional connections; and WHEREAS, the gaff and Board members of OWASA have indicated to Piney Mountain that the towns of Chapel .Hill and Carrboro have a strong interest in the Rural Buffer, and especially extensions of municipal water and sewer lines into the Rural Buffer; and WHEREAS, Piney Mountain is also in the process of securing from the Town of Carrboro, a nonbinding resolution similar to this resolution; WHEREAS, time is of the essence since the LPP System is in urgent need of replacement; IT IS THEREFORE RESOLVED, that the Chapel Dill Town Council does hereby find that by virtue of Piney Mountain's failing UP System, and with regard to the installation of the Sewer Line only, Piney Mountain does appear to fall within the already established exceptions to the general prohibition on the extension of sewer to the Rural Buffer, and Chapel Hill hereby does register its concurrence in the decision of OWASA and the Orange County Commissioners, whatever it may be and based on their more complete investigation of the facts and alternatives, with regard to the approval of the installation and maintenance of the Sewer Line to Piney Mountain. Pxhaphill 34 Carrboro Board of Aldermen Nonbinding Resolution in regard to the installation of municipal sewer line to the Piney Mountain Subdivision WHEREAS the Piney Mountain Subdivision ('Piney Mountain') is located on Mt. Sinai Road in Orange County, N.C. in the area designated as the "Rural Buffer" by the Joint Planning Agreement dated November 2, 1987 among Orange County, Chapel Hill and Carrboro ("1987 Joint Planning Amt'); and WHEREAS, the 1987 Joint Planning Agreement and the Joint Planning Land Use Plan among Orange County, Chapel Hill and Carrboro (adopted in October 1986 and amended in April 2, 1990 - "Joint Planning Use Plan") each provides that the Rural Buffer "will not require urban services (public utilities and other town services);" and WHEREAS, the Joint Planning Use Plan also acknowledges that the Orange Water and Sewer Authority ("OWASA"), as the provider of water and sewer in the Joint Planning Area, extends water and sewer in accordance with the adopted policies of the applicable local governments; and that the applicable policy of Orange County for the Rural Buffer is to extend water and sewer only to provide service to an essential public service, such as a school, or to- remedy a public health emergency, such as a failing septic tank or failing package treatment plant; and WHEREAS, Piney Mountain has a failing community low pressure pipe sewerage disposal system ('LPP System'); and WHEREAS, Piney Mountain, after a complete investigation with the assistance of soil scientists and Orange County Engineers and Health Department staff, has established that the LPP System has been installed in unsuitable soils and that there is insufficient repair area either existing or available for purchase; that, even in suitable soils, the LPP System has been so poorly designed, constructed and maintained that it is likely that it would never perform adequately, regardless of funds spent; that other alternatives such as an NPDES discharge system (treatment plant) are not feasible; and that the only solution to providing sewer service to its 58 homesites is to install and maintain, at Piney Mountain's expense, a pressurized sewer line from Piney Mountain to the City of Durham municipal line at the intersection of Kerley and Mt. Sinai Roads ("Sewer Line'); and WHEREAS, Piney Mountain has secured the approval of the City of Durham to connect the Sewer Line with that of the City of Durham provided that Piney Mountain also secures the approval of OWASA; and Pxarrboro 35 - 2 - WHEREAS, Piney Mountain is in the process of securing the approval of OWASA and the Orange County Commissioners to construct the Sewer Line in accordance with OWASA specifications and such a manner that will deter additional connections; and WHEREAS, the staff and Board members of OWASA have indicated to Piney Mountain that the towns of Chapel MR and Carrboro have a strong interest in the Rural Buffer, and especially extensions of municipal water and sewer lines into the Rural Buffer; and WHEREAS, Piney Mountain is also in the process of securing from the Town of Chapel Hill, a nonbinding resolution similar to this resolution; WHEREAS, time is of the essence since the LPP System is in urgent need of replacement; IT IS THEREFORE RESOLVED, that the Carrboro Board of Aldermen does hereby find that by virtue of Piney Mountain's failing UP System, and with regard to the installation of the Sewer Line only, Piney Mountain does appear to fall within the already established exceptions to the general prohibition on the extension of sewer to the Rural Buffer, and the Carrboro Board of Aldermen hereby does register its concurrence in the decision of OWASA and the Orange County Commissioners, whatever it may be and based on their more complete investigation of the facts and alternatives, with regard to the approval of the installation and maintenance of the Sewer Line to Piney Mountain. i Pxarrboro 36 RECFIVB NDY Barrett Kays & Associates Civil Engineering/Environmental En gi neeri n g/Envi ron mental LN&AtOWOW, ENT November 16, 1993 Ms. Deborah C. Christie c/o Law Department Liggett Group, Inc. 300 North Duke Street Durham, NC 27702 BSA Project *9310002 Dear Ms. Christie: This letter constitutes our report of our soil evaluations of the Piney Mountain low pressure system site. On November 8 and 9, 1993 1 conducted a field evaluation of the soils on the low pressure system site. Ten soil borings were located across the site, as shown on the attached maps. The borings were located across the toposequence to provide a good idea about the basic soil changes across the site. Attached are copies of the soil profile description of each boring. The site and soil characteristics for each boring were compared with the N.C. Division of Environmental Management Administrative Code 15 NCAC 2H.0300 - Septic Tank Systems, July 1, 1988 and the N.C. Division of Environmental Health Administrative Code 15A NCAC 18A.1900, April 1, 1993. The site and soil evaluations indicated that eight of the ten borings are unsuitable for shallow trenches and therefore a low pressure system under the DEM standards. The same eight borings are also unsuitable for low pressure system under the DEH regulations. I have collected six subsoil samples for clay mineralogy analysis. I have not sent the samples into the laboratory. Please be advised that the soils are also unsuitable due to other factors, therefore the analysis would provide clarification but should not change my overall classification. Please advise me within the next week if you would like me to submit the samples, otherwise I will discard them. 304 East Jones Street / Raleigh, North Carolina 27601 Telephone: 919-828-1903 Fax: 919-828-nIA; 37 Letter to Deb Christie Page 2 November 16, 1993 You requested that we determine the maximum number of homes which could be connected to the primary fields through the existing low pressure septic system without premature failure of the soils. Due to the significant amount of unsuitable soils present, the total number of homes which can be connected is, in fact, probably less than the number presently connected. Although it is difficult to determine the exact amount of provisionally suitable soils based upon the ten borings, it appears that approximately 12,000 lineal feet of low pressure trench are located in provisionally suitable soils. This would generally allow for up to 50 bedrooms or 12.5 homes, assuming 4 bedrooms per residence. While the State may continue to allow the existing homes to be served, the soil suitability means that addition of new homes, expansion in the number of bedrooms of existing homes, and the rebuilding of any homes that might be destroyed for example by fire is not likely to be approved. Due to the severe soil limitations on the property, I recommend that you seriously consider other wastewater alternatives to serve the subdivision. I am sorry to report these problems to you, but I know you want to have an accurate assessment of the situation. Please contact me if you have any questions. Sincerely, B SSOCIATES, P.A. S Ph.D. ;ys' �a�rrr s, Ph.D. cientist BLK085:cr Enclosures 38 LOW PRESSURE GROUND ABSORPTION SYSTEM SITE and SOIL CRITERIA Standard Criteria Classification Um DE.8 Slope Suitable <15% <10% Provisional 15-30% Unsuitable >30% >10% Texture Suitable Sandy, Loamy Sandy, Coarse, Loamy Provisional Clayey 1:1 Fine Loamy, Clayey 1:1 Unsuitable Clayey 2:1 Clayey 2:1 Structure Suitable Crumb, Granular Crumb. Granular Provisional Blocky Blocky Unsuitable Platy, Massive Platy, Prismatic, Massive Clay Mineralogy Suitable -------- Sandy, Coarse, Loamy Unsuitable ------ Clayey 2:1 Drainage Suitable 24 inches 24 inches Unsuitable <24 inches <24 inches Depth Suitable 24 inches 24 inches Unsuitable <24 inches <24 inches Restrictive Horizon Suitable 24 inches 24 inches Unsuitable <24 inches <24 inches Percolation Suitable <30 min/in. ------------- Provisional 30-60 min in. ----------- Unsuitable >60 minrn. ----------- PINEYM:9311002:TaEle 1:1 39 PINEY MOUNTAIN SUBDIVISION SOIL EVALUATION SUMMARY DEM STANDARDS FOR SHALLOW TRENCHES Soil Borings Criteri 1 2 4 5 7 $ 2 1Q Slope PS PS S S S S S S S S Texture PS PS PS PS PS PS PS US US US Structure US US PS PS US US US US US US Drainage US US PS S US US US US US US Depth US US PS PS US US US US US US Restrictive Horizon US US PS PS US US US US US US Overall Classification US US PS PS US US US US US US S = Suitable PS = Provisionally Suitable US = Unsuitable PINEYM:9011002:T&bW ZI 40 t PINEY MOUNTAIN SUBDIVISION SOIL EVALUATION SUMMARY DEH LPS STANDARDS Soil Borings Crited 1 2 4 5 7 Slope PS PS PS PS S S PS S S S Texture PS PS PS PS PS PS US US US US Structure US US PS PS US US US US US US Clay Mineralogy S US S S S S US US US US Drainage US US PS S US US US US US US Depth US US PS PS US US US US US US Restrictive Horizon US US PS PS US US US US US US Overall Classification US US PS PS US US US US US US S = Suitable PS = Provisionally Suitable US = Unsuitable PINEYM.9311002:Table 3:1 �• oo / 41 / 4 _ so 1S • 1 or • 0 56 ./ e� ♦�j� � �� � - � � • �• � • �,., �� �'� ��� `�� � 1 � ♦ �� �� � . �•. -- 1\� �_ ��� �� f ����`` _ �` • ��� - � ..► �_-� . `.` �.�� • �� r'' ��� , ���"=__ -c_= i�_,� . 43 TA E ' E ELOr mill oo T7 E .00, i i - - 19477 LF PIPE ; ! ! ; �• - 720 LF/HSE .....� . ,fill, t j s it qo IACKEL vlo. C O t I t ' ..... . •-.r i• -- V 1,00 0 ORANGE.- 47 N '13 A DRIVEWAY :� 44 Barrett Kays & Associates Civil Engineering/Environmental Engineering/Environmental Assessment December 8, 1993 Ms. Deborah Christie c/o Piney Mountain Home Owners Association 5310 Taproot Lane Durham, NC 27705 RE: Preliminary Low Flow Stream Analysis Pine Mountain Creek Orange County, NC BKA Project #9311003 Dear Ms. Christie: On your request Barrett Kays &Associates, P.A. has conducted a preliminary low flow stream analysis for Pine Mountain Creek in Orange County, NC. Pine Mountain Creek, adjacent to the Piney Mountain Subdivision, has a drainage area of 3.5 square miles. We utilized the United States Geological Survey methodologies for estimation of low flows. These are the methodologies used by North Carolina Division of Environmental Management (DEM) for waste load allocations for wastewater discharge permits to surface waters. DEM requests flow calculations from USGS. Ms. Nancy W. Lasater, P.E. of our office worked with Mr. Robert Mason, P.E. of USGS in determining the low flow values. Using the regional equation methodology the 7Q10 is 0.00 cfs and the 30Q2 is 0.02 cfs. The 7Q10 is an estimated stream flow that would typically occur once every 10 years for at least 7-consecutive days. The 30Q2 is an estimated stream flow that would typically occur once every 2 years for at least 30 consecutive days. The USGS has previously completed a final flow analysis downstream at SR 1718 and their records showed a 7Q10 of 0.00 cfs. It was reported to DEM as no or zero flow under the criteria with DEM. DEM's regulations prohibit a discharge of treated wastewater into a surface stream where the 7Q10 flow is zero. However, the regulations allow a discharge if the 30Q2 flow is greater than zero and where the waste load allocation modelling can demonstrate that the discharge will not impair the water quality below the standards for the stream. 304 East Jones Street / Raleigh, North Carolina 27601 Telephone: 919-828-1903 Fax: 919-828-0365 • 45 Letter to Deb Christie Page 2 December 8, 1993 The average daily wastewater discharge for Piney Mountain Subdivision would be 2.5 times the 0.02 cfs 30Q2 flow. This means that the wastewater discharge would frequently be the majority of the stream flow for extended periods of time. The peak daily wastewater discharge would be over 6 times the 0.02 cfs 30Q2 flow. In addition, the 30Q2 flow is very close to zero. The difference between 0.02 and 0.00 cfs may be greater than the standard error in the flow estimation methodology. Given these facts, it is my opinion than DEM would not desire to issue a discharge permit for Pine Mountain Creek. It is my opinion that DEM would want the Piney Mountain Subdivision sewer system connected into a municipal wastewater collection system. I trust that this information may be helpful to you in evaluating your options. Please contact me if you have any questions or need further elaboration. Sincerely, BARRETT KAYS &ASSOCIATES, P.A. eoll Ili• Nancy W. Lasater, P.E. Project E Barnet . Kays, Ph.D. President BLK103tNWL001:cr iv kiK i n k AJCULLN A LN D USZTR.IAL COMMISSION 4 I.C. FILE NO. T- ' N.C. PRISONER NO.- RALEIGH (I[applicable CLAIM FOR DAMAGES UNDER TORT CLAIMS ACT, G.S. 143-291 et. seq. STATE OF NORTH CAROLINA AFFIDAVIT COUNTY OF ORANGE Lawrence J. Noe , being duly sworn, deposes and says: (rnn Nr a ch;..a 1. That his/her name is Lawrence J. Noe, 2. That he/she lives at 5209 Piney Hollow. Durham, NC 27705. and that his/her mailing address is Lame as above. 3. That he/she hereby files a claim against State of North Carolina Deo�e,nt of Environment Health & Natural Resources, Division of Environ_MSa1 Management (3ww Ag.ry er CMW 9-4 d 5b"W and that its mailing address is 512 N. Salisbury St.. Raleigh. NC for damages resulting from the negligence of See Exhibit A (PM Hr e(8wrigw w Apo bwdw* 4. That he/she has been damaged in the amount of S See Exhibit A by reason of the negligent conduct of the employee agent named above. 5. That the injury or accident giving rise to this claim occurred at .Pi= Mountain subdivision_ Otange Coun on 19,_„_, at M. t That the injury or property damage occurred in the following manner: (Giw&W&MMM 1 Wre N ri.lirr et Rrirw� +e.) The Claimant is an owner of lot 30 and has a home oetha_t lot served bX the community^sewer system in the Piney Mountain subdivision The Claimant has been damag2d by the actions of DEM in the manner described in Exhibit A. (Claimant owns the lot iointil with his wife. Susan Y. Noe.) 7. That the damages claimed above consist of the Claimant's cots in reoirin!an%r rlplacing the sewerage system an expenses of investigating how to mitigate this damage. IN TESTIMONY WHEREOF, the said Lawrence 1. Noe has hereunto set his hand and seal, (N. of chw" this day of '"nOWAY1,601 . 19_U i worn to before me :�--�-- 1. J Subscribed and �... this day of 1 JzmW 36 er Newry tiw+ My Commission Expires FILE FOUR COMPLETE COPIES Wli INDUSTRIAL COMMISSION (Lr admaw of+wee-.n.r.rMd--2 ago" Set MWW re et rom rw to"board rw 47 ATTACHMENT TO AFFIDAVIT 1. The claimant is one of several property owners of lots in the Piney Mountain subdivision located in Orange County. The subdivision has a low pressure pipe (LPP) sewerage system owned and formerly operated by North State Utilities, Inc. ("North State") . The subdivision's restrictive covenants prohibit individual septic tanks and there is no publicly-owned sewerage service available. 2. As of 1987 and until July 14, 1992, the Division of Environmental Management � (DEM) of the N.C. Department of Environment, Health and Natural Resources (or its predecessor) had statutory responsibility for regulating and permitting the construction of privately-owned community sewerage systems such as the one built in the Piney Mountain subdivision and for overseeing the operation of such systems. Because of this responsibility, DEM had a duty to insure that such systems were designed, constructed and operated in compliance with applicable state laws and regulations and sound engineering practices. 3. on December 23, 1987, DEN issued a permit to North State pursuant to the regulations in 15 NCAC Chapter 2H of the North Carolina administrative code authorizing the construction of an LPP sewerage system in the Piney Mountain subdivision to provide sewer service to 59 lots in the Piney Mountain subdivision. On November 300 1990, DEN issued another permit for the Piney Mountain system that voided the 1987 permit and again authorized the construction of an LPP system for 59 lots in the subdivision. On August 30, 1991, DEM issued a third permit, voiding the 1990 permit and authorizing the construction of an LPP system for 58 lots in the subdivision (the 59th lot is served by its own septic tank, which was in place before the subdivision was developed and the restrictive covenants were imposed) . 4. After the time DEN issued the permits described above and pursuant to those permits, North State constructed the LPP community sewerage system at the Piney Mountain subdivision and received permission from DEN to commence operation of the system. To date, 55 of the lots in the subdivision have been sold. There are 34 houses hooked up to the sewerage system. There are 24 unimproved lots, four of which belong to the developer. 5. In 1992, jurisdiction for the permitting of privately-owned community sewerage systems, such as the one in place at the Piney Mountain subdivision, changed by statute from DEN to the Division of Environmental Health ("DEH") within the Department of Environment, Health and Natural Resources. DEH authorized the Orange County Department of Health to administer on its behalf the permitting of systems in Orange County. 6. on January 31, 1993, the DEN Permit for the Piney Mountain sewerage system expired. In the process of considering North M1\01U17-M0=U#\It-*" 1 48 State's application for renewal of the permit, the Orange County Department of Health determined that the system does not meet the state requirements for a permit, despite the fact it was permitted by DEN previously. Among other things, the Orange County officials determined that the system does not have sufficient capacity to serve all of the homes in the subdivision and does not have sufficient "repair area", or land to be used as nitrification fields if the existing fields fail. This means that the system can only serve the 34 homes that are already built at the subdivision, and none of the remaining 24 lots in the subdivision. Orange County also determined that the existing system did not meet all applicable regulations and required that certain improvements be made. on the basis of these findings, Orange County issued only a limited permit for the system, authorizing it to serve only the 34 existing homes in the subdivision, and also required that certain improvements be made to the existing system or even this limited permit would be revoked. 7. Because the Piney Mountain sewerage system has only a limited permit, the property owners who have not yet built homes on their lots cannot obtain a building permit to build a home on their lots. They will not be allowed to build until the Piney Mountain sewerage system is expanded to accommodate more users or another provision is made for sewage disposal. North State has said it has insufficient land in the subdivision to expand the system. In fact, North State has abandoned the system and gone out of business. The North Carolina Utilities Commission has named an emergency operator to operate the system until a new owner for the system can be found. The emergency operator has also stated that the system cannot be expanded to accommodate any homes yet to be built in the subdivision without adding land to the system. The Piney Mountain property owners are informed and believe that only some of the unimproved lots have soil of a good enough quality to permit the installation of a septic tank and owners of such lots cannot do this under the current restrictive covenants. The other owners of unimproved lots have lots with soils that will not accommodate septic tanks and there is no other alternative available to them for sewerage service. S. Because of inadequacies in the existing system, the current homeowners who are using the system will have to pay for repairs to the system required by Orange County. Furthermore, the current homeowners are informed and believe that some of the soil in the existing nitrification fields is not suitable for this use under the applicable state standards, and that as a result the fields may fail to adequately absorb the wastewater discharged by the system sooner than they would have if they had met the state requirements for this use. 9. The claimant and other property owners who are filing claims against DEN are informed and believe that the Piney Mountain sewerage system did not meet all applicable state laws and w1\0113174 \00822iS\12-1643 2 49 regulations at the time it was originally permitted and thus did not in fact qualify for the permits DEN issued. They also are informed and believe that some of the deficiencies in the existing system result from the fact that the system was not built in accordance with the plans and specifications submitted to DEM, and that the system has not been monitored as required by the applicable state regulations and the DEN permit. They also are informed and believe that if the system had not all state requirements when DEN permitted the system, and if ttie system had been built in accordance with the plans and specifications submitted and monitored as required by state law, it would be adequate today to serve 58 lots in the subdivision. 10. At the time DEN issued the permits described above and at all relevant times subsequent, DEN knew the Piney Mountain sewerage system was to serve a subdivision with 58 lots needing the service and that purchasers of the lots would rely on DEN to require that the system was built with adequate capacity and quality to serve the lots. DEN also knew that the purchasers would rely on DEM to insure that the system was built in accordance with the plans and specifications approved by it and was adequately monitored after operation began. 11. At the time claimant and the other property owners in the subdivision bought their lots, they were informed by the developer of the subdivision or his agent that North State had constructed or was constructing a community sewerage system to serve the Piney Mountain subdivision. They also knew that the State of North Carolina required that North State obtain a permit to construct and operate such a system. Claimant relied on the fact that the system had been approved by DEM or would have to be approved by DEK in determining that the lot claimant planned to purchase would have adequate sewer service and thus would be suitable for use as the site of a residence. r 12. Claimant is informed and believes that DE through the actions of its employees listed in paragraph 1 , ra. , was negligent in permitting the North State system for construction and operation in the following respects: a. DEN permitted the system to serve 58 lots in the subdivision even though the plans for the system were based on a projected capacity lower than that required by DEN's own applicable regulations and insufficiently low given the size of homes planned for the subdivision and the quality of the soil in the subdivision. DEN continued to permit the system for 58 lots even when homes were built in the subdivision of a size much larger than the average size projected by North State, even though it was probable that the system would not have enough capacity to serve all the homes planned in the subdivision. wtsZoiui�-0oz\oosztuti�i-�a 3 50 b. DEN continued to permit Phase I of the system to serve 24 lots in the subdivision even after an engineer for North State reported information to DEM showing that the pipe actually laid in the Phase I nitrification fields was not as much as originally planned, and thus Phase I of the system could not serve this many lots. DEN also permitted Phase II of the system first to serve 35 lots and subsequently 34 lots, even though North State never submitted detailed plans showing how it intended to construct a system with this capacity; North State did not file a proper certification by an engineer showing that North State had installed the total linear feet of pipe required by its permit and depicted in its original plans and specifications. A visual inspection of the system would have disclosed that North State had not installed the total number of linear feet required by the permit. C. DEM permitted the system even though North State had not provided the amount of repair area required by the DEN regulations for a system serving 58 lots, and even though much of the area designated for repair area was not suitable either because of the quality of the soil or the location of the proposed repair area. d. DEN permitted the system on the basis of insufficient information about the quality of the soil for the nitrification fields and repair area from the soil scientist retained by North State. DEN was further negligent in the names in which it conducted its own investigation to determine whether the soil was suitable, and in concluding that the soil was suitable when in fact much of the soil was not suitable for this use. e. DEM allowed North State to operate the system when it did not have a certification from an engineer who had observed the construction indicating that the system had been constructed as set forth in the original or amended plans and the system had not been constructed as set forth in the plans. As discussed above, the system did not have the planned amount of linear feet of pipe. Also, the system lacked other components required by the permit and included in the plans. f. DEN authorized the system to go into operation even though the system did not have adequate monitoring devices to determine whether the system was operating properly, and did not have all monitoring wells required by the state, and some monitoring wells were not located in compliance with DEN regulations. wu\011317-OM\MMU\11-1e93 4 • 51 q. DEN allowed North State to continue operation of the system even after it failed to receive the required monitoring reports from North State and when a visual inspection would have determined that North State was not monitoring the system properly and as required by the permit. 13. Based on information and belief, the individuals who are responsible for the negligent acts alleged are some or all of the following persons who had a role in the approval and oversight of the Piney Mountain sewage system; Arthur Nouberry, Babette McKemie, Donald Safrit, Timothy L. Donally, William A. Kreutzberger, Rick Biers, R. Paul Wilms, Robert D. Harding, Lindsay L. Mize, George T. Everett, Carolyn McCaskell, Jeff Lautier, Edmond John Maguire, C. Brian Wootton, J. William Reid, Bob Cheek, Jay Zimmerman, Michael D. Cleary, and James R. Parker. 14. As a direct and proximate result of DEM's negligence, the value of the lots owned by property owners who have not yet built homes has decreased from the value they would have had without DEM's negligence. The claimant will present evidence at the hearing on this claim as to the amount of depreciation in the value of claimant's property caused by the negligence of DEN. 15. As a direct and proximate result of DEN's negligence, the property owners who have homes using the sewerage system must pay for the repairs to the system required by orange County as a condition of the existing limited permit. The emergency operator has estimated this cost will be a total of approximately $50,000. These property owners shall also have to bear the expense of replacing the system and seek from DEM the cost to them of securing a substitute system, which costs shall exceed five thousand dollars for each lot. 16. Also as a result of DEN's negligence, claimant has shared in the expense incurred by the Piney Mountain Homeowner's Association to investigate possible ways to expand the capacity of the sewage system and other steps necessary to provide an adequate system for the entire subdivision. These expenses exceed $ for each property owner, and continue to grow at this time. R&11\011317-002\00=1$\11-16.43 5 52 HARRCO UTILITY CORPORATION December 1 , 1993 "�!-�y Robert H. Bennink, Jr., General Counsel 199; North Carolina Utilities Conaission P.O. Box 29510 CLEPK Raleigh, NC 27626-0510 L7F S Cp 4'MIS3��y RE: Docket No. W-848, Sub . -16 Capital Improvements Requiring Assessment Piney Mmzxtx3n Subdivision Dear Mr. Bennlnk. In order to comply with ordering paragraph number nine of the "Reccw*nde3 Order Appointing Emergency Operator and Approving Interim Rate", issued September 1, 1993 by the commission in the above referenced docket, Harrco Utility Corporation (HUC) has contracted with Mr. James R. Butler, a professional engineer with the firm of Bass, Nixon and Kennedy, Inc. Mr. Butlers' duties are to aid HUC in determining the improvements necessary to bring the existing North State Systems into an acceptable working order. Mr. Butler has worked closely with HUC personnel and local health officials in making site visits and inspections in order to assess the condition of the North State Systems. Attached to this letter, is a copy of his findings and recommendations relating to the North State System serving the Piney Mountain Subdivision. At the request of HUC, Mr. Tom Konsler of the Orange County Health Department conducted an inspection of the system serving the Piney Mountain Subdivision. Attached to this letter, is a copy of his findings dated October 29, 1993. After review of threw two reports and compilation of operating data by our staff since September 1, 19930, Harrco Utility Corporation formally re=wands the following repairs and impravenants be performed as a minimum in order to bring this system into an acceptable working order that can be maintained and operated with reasonable effort and safety to the operating personnel. 8601 Barefoot Industrial Road Raleigh, NC 27613 • (919) 782.3440 53 Page 2 RE: Docket No. W-848, Sub 15 & 16 Capital Ltrprovemants Requiring Assessment Piney Mountain Subdivisixaat 1 ) Provide all weather access to Phase I dosing tanks and maintenance access to field areas. Remove brush and debris left on site by North State Utilities. Materials: ABC Stone (4" thick) 3.9 TN @ 10.50 404.50 Dump Fees(Clearing debris) 150.00 Equipment & Labor: Tractor w Blade 3 hrs @ 30.00 40.00 Skilled Tabor 5 hrs @ 15.00 75.00 Bobcat ? 5 hrs @ 35.00 175.00 Dump Tnick 5 hrs @ 30.00 150.00 I rM 1 TOTAL: $1049.50 2) Repipe existing pumps in Phase I dosing tanks to allow for prrMr maintenance access, provide appa:opriate isolation valves for each pub, provide proper disconr:arct for pumps and floats adjacent to dosing tank, replace existing float switches, install non-cxu%=ive float bracket, replace existing controls with new M sated duplex control panel having suitable control logic to provide for reliable automatic and manual operation of control valves and valve-specific an-uciaticn of improper operation of any given valve. New control panel will include event and time aazsnulators for each control zone. Replace inoperable telephone dialer. Materials 20070.00 Equipment & Lebar 584.00 Electric 2420.00 MM 02 TOM",, $23074.00 3) Raise buried access covers to additional "Phase V dosing tank to around surface. Raise Buried Covers: (2' dia. riser wlccr=ete lids) via l�s 910.00 Equipment & Labor 1104.00 Imo! 03 TOTAL: INI4.00 54 M Page 3 RE: Docket No. W-848, Sub 15 & 16 Capital Improvements Requiring Assessment Piney Mountain Subdivision 4) Replace all existing irrigation type solenoid valves at Phase I drain field with suitable "contaminant resistant" (effluent rated) valves, including the provision of in4epesx3snI ball valve for isolation and gate valve for flow control and flow sensing device. Valve assembly shall be installed in suitable enclosures such that normal foot traffic and mowing equipment may pass over them without injury to either enclosure or equipment, while providing sufficient room to repair and adjust the valves. 17 valve assemblies @ 530.00 ea. Materials 4420.00 Equipment & Labor 4590.00 ti r= 04 TOTAL: $ 9010.00 5) Locate and adjust to elevation acceptable to local authority all "turn-up" pipes at act of laterals in Hum I drainfield and provide physical protection for those "turn-ups". 178 "turn-ups" @ $9.50 ea. Materials 890.00 Equipment & Labor 801 .00 05 WJML: $1691.00 6) Provide and install such additional soil material as may be necessary to smooth surface contour of Phase I field areas so that surface water pondin9 and trench settling are eliminated. Seeding and mulching of all disturbed areas. Removal of Pine Stray Omw 1.73 AC @ 2000.00 3460.00 Furnish & Install Topsoil Fill 300 CY @ 22.50 6750.00 Seeding & Mulching 2.16 AC @ 1650.00 3564.00 T'®! 06 1 ZK.- $13774.00 55 Page 4 RE: Docket No. W-848, Sub 15 & 16 Capital Improvements Requiring Assessment Piney Mountain Subrlivision 8) Provide boundary survey of existing nitrification fields and repair area. Boundary Survey 8095 IF @ .50 4047.50 rM #7 TOTRL: $4047.50 8) Check and pump acctmulated residuals from individual septic and pump tanks (STEPS}. Repipe effluent pump to provide maintenance and repair from ground surface. Provide approved for pump, controls and alarm adjacent to pump chamber. Install proper access risers and covers to septic and pump tanks as required by local health department. Provide separate electrical circuit for pump alarm. Materials 6841 .89 Equipment & Labor 7738.50 STEP Pumping (33 @ 145.00/ea) 4785.00 T= 08 VOOL: $19365.39 9) Provide all weather access to Phase Z1 dosing tank and maintersaruu a access to field areas. Remove bah and debris left on site by North State Utilities. Materials: ABC Stone (4" thick) 70 TN @ 10.50 735.00 Dump Fears (cleating debris) 450.00 15" Ate' 40 IF @ 8.60 344.00 Egu�_IAbour: Fra�tt�—I --- - 16 hrs @ 70.00 1120.00 Skilled Lsbu:ar 16 hrs @ 15.00 240.00 Bobcat LoadW 6 hrs @ 35.00 210.00 Dump, Truk 16 hrs 8 30.00 480.00 Backhos 4 hrs @ 45.00 180.00 I= 09 Togua $3759.00 56 w Page 5 RE: Docket No. W-848, Sub 15 & 16 Capital Improvements Requiring Assessment Piney rlomtain S ibdivisicn 10) Replace existing pumps in Phase II dosing tank and pipe new pumps to allow for proper maintenance access, provide appropriate isolation valves for each pump, provide proper disconnect for pumps and floats adjacent to dosing tank, replace float switches, install non-corrosive float bracket, replace existing controls with new UL rated duplex control panel having suitable control logic to provide for reliable automatic and manual operation of control valves and valve-specific annunciation of improper operation of any given valve. New control panel will include event and time accumulators for each control zone. Replace inoperable telephone dialer. Materials 43372.00 Equipment & Labor 2336.00 Electrical 3630.00 IMN #10 TOTRL: $49338.00 11) Replace all existing irrigation type solenoid valves at Phase II drainfield with suitable w'COntBmLinanit resistant" (effluent rated) valves, including the provision of irrdepe t ball valve for isolation and gate valve for flow control and flow sensing device. Valve assemble shall be installed in suitable enclosures such that normal foot traffic and mowing equipment may pass over them without injury to either enclosure or equipment, while providing sufficient roam to repair and adjust the valves. 51 valve assemblies 0 530.00 ea. Materials 13260.00 Equipment & Labor 13770.00 T= #II S0=0. $ 27030.00 57 Page 6 RE: Docket No. W-848, Sub 15 & 16 Capital Improvements Requiring Assessment Piney Mountain Subdivision 12) Locate and adjust to elevation acceptable to local authority all "turn-up" pipes at ends of laterals in Phase II drainfield and provide Physical protection for these "turn-ups". 517 "turn-ups" @ 9.50 ea. Materials 2585.00 Equipment & Labor 2326.50 rM 012 TOTAL: $ 4911.50 13) Provide and install such additional soil material as may be necessary to smooth surface countour of Phase II field areas so that surface water pondinq and trench settling are eliminated. Seeding and mulching of all disturbed areas. Furnish & Install Topsoil Fill 600 CY @ 22.50 13500.00 Seeding & Mulching 3.92 AC @ 1650.00 6468.00 Imo! 013 202RL: $ 19968.00 The above figures totalling $179031.89 represent the estimated outside oast to be incurred by HUC in making the listed repairs and improvemnnts. In addition, HUC anticipates an cost of ap WoX mately $9705.00 to include submittal of plans and specifications necessary to aaquire the ree;WxW repair permit from the Wake County Department of Health. A fee of ten percent of the total cost for than repairs will be needed by HUC in order to cover overhead menses incurred by HUC in supervising and coordinating these repairs and impcov nts. A reconciliation of the total cost is as follows: Cost for Items 01 thru $13: $179031.89 Engineering Few: 9705.00 HUC Supervision & Caooa dilation: 18873.68 TOM: $207610.S7 t 58 Page 7 RE: Docket No. W-848, Sub 15 & 16 Capital Im;ux ements Requiring Assessment Piney Mountain - tAivisicn As emergency operator for the Piney Mountain Sewer Sytem, Harr= Utility Corporation request the imposition of an assessment under G.S. 62-118(C)in the amount of $207,610.57. For your convenience and use in determining the brieaak&d of this assessment, we have attached a current customer list to this letter reflecting the following numbers. Total System Capacity 57 Hanes 'Dotal Connections Served to Date 33 Homes *Appplicaticn and patent has been received ft= Mr. Clay Thameat to , , , , ,I lot 08. No fees have been acalleoAed far repairs or is>11, oeeg-to to eodating in Sysrts. The above repairs and impsoven ants include only those items recommended or required by Mr. Butler or Mr. Tom Nonsler in their respective reports. Items listed in either report and not detailed above have been determined to be normal. mwa iteme and are being performed by HUC under the existing rate structure in place. The repairs and improvewts oovered by this report will bring the existing Piney Mountain System into an acceptable working order. The Orange County Health Department has currently suspended all -I actions over 34 until suitable "repair areal# can be located to serve this system. The existing system, once .repaired, should be capable of serving the total 57 lots, although "repair area" is not present. The suspension by the a x]e County Health Department of future connections has caused difficulties to lot owners w1w purchased lots unknowing of these problems. HW has been requested by several of these lot owners to explore alternatives available foot future ooca%ectians. Please advise HOC of its duties or obligations as emergency operat= to serve future a maotians. Please advise of additional information or assistance re[*zired of our office. Respeo--t tted, President HAMW cn=+IT'r aaRPaRA�xoN LWH/msh Cagy: (w/enclosures) Mr. Robin Cauthen i 59 STATE OF NORTH CAROLINA UTILITIES COMMISSION RALEIGH Docket No. w-848, Sub 15 Docket No. W-848, Sub 16 BEFORE THE NORTH CAROLINA UTILITIES COMMISSION In the Matter of Piney Mountain Homeowners ) Association, Inc. , ) Complainant ) OBJECTION OF PINEY MOUNTAIN HOMEOWNERS ASSOCIATION TO V. ) PROPOSED ASSESSMENT FOR CAPITAL IMPROVEMENTS North State Utilities, Inc. , ) Respondent ) The Piney Mountain Homeowners Association ("Homeowners Association") objects to the request by Harrco Utility Corporation ("Harrco") filed on December 1, 1993, for an assessment to users of the system in the Piney Mountain sewerage system to pay for certain- capital improvements and repairs and asks the Commission to postpone consideration of this request. In support of this motion, the Homeowners Association shows the Commission as follows: 1. Harrco has requested an assessment totaling $207, 610. 57, which would result in an assessment of over $6,000 to each current user of the system (assuming only current users would be subject to the assessment. ) This amount is substantial and would impose a considerable financial burden on each user. 2 . The Homeowners Association has information indicating that even if this substantial sum is spent to improve and repair the sewerage system, it still will not be adequate to serve the subdivision for the life of the homes in the subdivision. The Homeowners Association has a letter from Paul K. Thames, the Engineer for Orange County, stating his opinion that because of the poor design and construction of the system, "there is no way to assure that this waste treatment system will ever perform adequately, regardless of the funds expended on improving operational practices or mechanical flaws inherent in the system. " A copy of this letter is attached as Exhibit A. The Homeowners Association also has a report from Barrett Kays & Associates, a private engineering firm hired by the Homeowners Association to test the soils in the existing nitrification fields, stating that much of the soil presently used by the system for nitrification fields does not meet the state standards for such use and that the Rai l\011317-002\(x1Dr6 Z\ 12.2:•73 15 1 -s;i .5 Li 60 residents should consider other wastewater alternatives to serve the subdivision. A copy of this report is attached as Exhibit B. 3 . Because of the information cited above, the Homeowners Association desires to have the subdivision served by the Durham municipal sewer system, so that the homeowners will not have to rely on the North State Utilities, Inc. system. The City of Durham has indicated it is willing to serve the subdivision. However, because of previous agreements made for planning purposes, Durham will not extend its service into Orange County to serve Piney Mountain without permission from the Orange water and Sewer Authority ("Owasa"} and OWASA requires approval from Orange County, the town of Chapel Hill and the town of Carrboro. 4 . The Homeowners Association is in the process of petitioning all related governmental entities for approval of the Durham extension to Piney Mountain. If these petitions are granted, the North State system (or much of it) will not be needed and thus it would be a waste of money to make substantial repairs to the system at this time. The Homeowners Association is moving as fast as possible to- have its petitions heard; however, it is informed that it will take at least a month and possibly two to gain the approvals needed to allow the subdivision to hook up to Durham. 5. Because of the facts cited above, the Homeowners Association objects to any assessments for capital improvements or repairs at this time. The Homeowners Association asks the Commission not to consider any such assessments (except to the extent required to meet an emergency situation) while the Homeowners Association pursues its effort to obtain approval for municipal service to the subdivision and, if approval is obtained, not make any assessments other than for emergency repairs before the subdivision can hook up to the Durham system. This the day of December, 1993. POYNER & SPRUILL By: Nancy Bentson Essex Attorneys for the Piney Mountain Homeowners Association 3600 Glenwood Ave. Post Office Box 10096 Raleigh, North Carolina 27605-0096 Telephone: (919) 783-6400 i2U1\011317-00''\0083602\ 12-22.93 12 ,_ :1.3 15 1 ZY19 19;5.31i17S POWER&SPRC ILL t 61 CERTIFICATE OF SERVICE This is to certify that the undersigned has this day served the attached Objection of Piney Mountain Homeowners Association to Proposed Assessment for Capital Improvements on all parties to this cause by United States Mail, first class, postage prepaid, addressed as follows: Robert B. Cauthen, Jr. Staff Attorney, Public Staff North Carolina Utilities Commission Post Office Box 29520 Raleigh, NC 27625-0520 James F. Jordan 2840 Plaza Place Suite 105 Raleigh, NC 27612 for North State Utilities Karen E. Long Assistant Attorney General NC Department of Justice Post Office Box 629 Raleigh, NC 27602 for Attorney General's Office Martha K. Walston McMillan Kimzey & Smith Post Office Box 150 Raleigh, NC 27602 for Carpenter Pond Development Corporation Harrco Utility commission 8601 Barefoot Industrial Rd. Raleigh, NC 27613 Tri--County Waste Water Management 712 S. Hayne St. Monroe, NC 28112 This the day of December, 1993 Nancy Bentson Essex Ra11\011317-002\0054b02\ 12-22-93 r 52 ti PINEY MOUNTAIN HOMEOWNERS' ASSOCIATION To the Baud of the Orange Water and Saver Authority The vast majority of the members of the Piney Mountain Homeowners' Association chose to live in Piney Mountain because of its unique features within the rapidly developing Triangle area. As part of the rural buffer in Orange County, Piney Mountain offers a woodland serenity that is unsurpassed in its natural beauty and character. All of us are proud of and want to maintain Piney Mountain's natural heritage. We share the concerns of OWASA and the pertinent governing bodies to preserve the planned character of the rural buffer. Through no fault of our own, due to failure of our community sewage disposal system, we find ourselves having taken an arduous and circuitous path that has led us to doorstep of OWASA. As our problem is discussed by you this evening, and in the coming weeks, we confirm for the OWASA Board our commitment to protect the rural buffer environment not only for ourselves and for our children, but also for the benefit of those who live in neighboring areas and who visit the area to partake of its beauty. Our request to OWASA to connect with the Durham County sewer line comes as a last resort. Our petition is intended not to change the nature of the rural buffer but rather to assure its preservation. The failure of our community sewage disposal system poses economic and environmental health concerns. It behooves OWASA to consider seriously our unfortunate plight. A favorable response to our request at this time will help secure the future of the rural buffer for those who live in and around it, for generations to come. For the December 9, 1993 OWASA Board meeting. PP�7