NC0041483_LV-2019-0344_20191223

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RESEARCH & ANALyTICAl
LAbORATORIES, INC.
rrocess Consultations
December 04,2019 RECEIVED
DEC 2390e
Lon Snider DES
Regional Supervisor o
NC Division of Water Resources
Winston Salem Regional Office
450 West Hanes Mill Rd, Suite 300
Winston Salem NC,27105
Subject: Request for remission of Civil Penalty(LV-2019-0344)
Sunrise Mobile Home Park
Permit No: NC0041483
Dear Mr Snider,
Please find below our request for remission of the Civil Penalty (LV-2019-0344)issued to Sunrise MHP on November 21,
2019.The civil penalty was assessed for the following two fecal coliform violations in July of this year:
Exceedance of Fecal Coliform Daily Maximum limit on July 24,2019
Exceedance of Fecal Coliform Monthly Geometric Mean on July 30,2019
The wastewater treatment system at Sunrise MHP is an above-ground sandfilter system with UV sterilization of the final
effluent before discharge. The system has no transmittance or intensity indicator for the ultraviolet light assembly,and there
is no way to measure any type of downstream residual since it is an ultraviolet system. The only operational indicator of a
properly working system is a sight glass on the side of the UV assembly where we can see whether the bulb intensity is
bright,dim,or flickering. This sight glass is the only indicator of whether or not the UV system is operating.
During each weekly visit I clean the UV bulb using the internal brush attached to the main canister,and monthly I clean the
internal glass tube and bulb with a de-scaling solution to try to keep as maximum an intensity within the UV canister as
possible. With no way to physically measure intensity or a downstream residual,the only way to analytically gauge
performance is with the fecal coliform results from the twice a month monitoring.
After the initial exceedance of the fecal coliform monitoring,I immediately de-scale the in internal sheath and UV bulb,and
hose out any material that may have settled in the canister,which is what I did after the exceedance on July 24,2019. If
there is a second consecutive exceedance,I replace the UV bulb itself. This was performed immediately after notification
of the July 30,2019 exceedance. During both fecal exceedances the light on the canister sight glass was continuous and
looked strongly illuminated.
Since replacing the UV bulb after the second fecal exceedance,there have been no fecal coliform exceedances to date and
the system has maintained compliance with all required parameters.
P.0 Box 473• 106 Short Street• Kernersville, North Carolina 27284•336-996-2841 •Fax [phone]
www.randelabs.com

With this explanation I hope that the Division of Water Resources will see that both of these fecal coliform exceedances
were not the product of improper operation of the ultraviolet system,and were not something that we could have foreseen or
prepared for. Also,I hope the Division will see that appropriate corrective actions were taken immediately after notification
of each exceedance,and will take into account the fact that since July 2019 Sunrise MHP has been in full compliance.
Thank you for your consideration of our request for remission of the Sunrise MHP civil penalty. If you should have any
further questions or would like any additional information,please feel free to contact me at the numbers below.
Sincerely,
Glenn P IORC
Research&Analytical Laboratories,Inc.
(cell)336.408.7924
(office)336.996.2841
RECEIVED
DEC 2 3 2019
NCDEQID\NRII\'PDES

•
STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
COUNTY OF GUILFORD
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
Sunrise&Sons,LLC )
Sunrise Park )
PERMIT NO.NC0041483 ) CASE NO. LV-2019-034.4
Having been assessed civil penalties totaling$454.98 for violation(s)as set forth in the assessment document of the Division
of Water Resources dated November 21,2019.the undersigned.desiring to seek remission of the civil penalty,does hereby
Er
‘k'aive the right to an administrative hearing in the above-stated matter and does stipulate that the facts are as alleged in the
assessment document. The undersigned further understands that all evidence presented in support of remission of this civil
penalty must be submitted to the Director of the Division of Water Resources within thirty(30)days of receipt of the notice
of assessment- No new evidence in support of a remission request will be allowed after(30)days from the receipt of tux
notice of assessment.
This the I day of -oZCe-tnb t r , 20 VI
IGNATURE
ADDRESS
Kes
Ns\ne?bcru C. 11io5
1
TELEPHONE
33(� - 3oa- • 7S I1
RECEIVED
DEC 2$ ZAS
NDDEQIDWRINPDES
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4/Y.):'
ROY COOPER r�V,' ./ �
Gm rnor / f
NtiCNAE1.S.REGAN .l:..
ssaww y
LIMDA CULPEPPER NORTH CAROUNA
Oferctor Environments!(baby
Certified Mail# 7017 1450 0001 6450 1174
Return Receipt Requested
November 21,2019
Stephen R Davis,Owner
Sunrise& Sons, LLC
PO Box 2153
Asheboro, NC 27204-2153
SUBJECT: Notice of Violation and Assessment of Civil Penalty
for Violations of North Carolina General Statute(G.S.) I43-215.1(ax6)
and NPDES WW Permit No. NC0041483
Sunrise& Sons. LLC
Sunrise Park
Case No. LV-2019-0344
Guilford County
Dear Permittee:
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of$454.98(S350.00 civil penalty
+ 5104.98 enforcement costs)against Sunrise& Sons, LLC.
This assessment is based upon the following facts:a review has been conducted of the Discharge Monitoring Report
(DMR)submitted by Sunrise&Sons, LLC for the month of July 2019. This review has shown the subject facility to be
in violation of the discharge limitations and/or monitoring requirements found in NPDES WW Permit No. NC0041483.
The violations, which occurred in July 2019,are summarized in Attachment A to this letter.
Based upon the above facts. I conclude as a matter of law that Sunrise& Sons, LLC violated the terms,conditions or
requirements of NPDES WW Permit No. NC0041483 and G.S. 143-215.1(0(6)in the manner and extent shown in
Attachment A. In accordance with the maximums established by G.S. 143-215.6A(ax2),a civil penalty may be
assessed against any person who violates the terms, conditions or requirements of a permit required by G.S.
143-215.1(a).
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W.stonlLlom Roggnol Ofioo 1450 Woof Nonoo MI Rood,Soto 300 I Watftw$olom.►oofe Conlon 27105
33E-776- 0

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If you wish to contest any statement in the Idtacfwd rise sorrier,t doc.onierd you MOM t a petition fur an adrnin►Mistive
hearing. You may nlnain the petition form from She Ifftcr,rt AdrniniMrative Heitiriga, You moot file the psthlom with
the(Alice of Administrative Nsaringx within thirty(10)days of receipt of this notice, A petition,is considered tiled
when it is received in the Office of Administrative hearings timing tonn al office hours, 'the(1ltiee of Administrative
I fearing%accepts filings Monday through hriday between the Nome ref ft;(NJ min,and i;00 p,m,,except for official Mahe
holidays, the peeetitkm may he filed by facsimile(tar,)or electronic mail Ir/an al(ac;hed tile(with flcsfric('unrts) 'provided
the ciyfled original.one(I)copy and a filmy,free(if a tiling tee Is required!r/fi('(,1S tr I:911.2),2)is feurivrd in the
Office of Administrative Ifearings within"J mn(7)business days hollowing the(tripod'n 4;1 ,tr(JtIlt fransmission. You
,hr,ul'1 r,',rlt-art ►M. Illfic.': ',I /,-1rni,riMildive 11'-,unio with all tluestkntaIrVi Jil,g lire f'llulz f.L1UJdli11 dr WI)if!the
Iihng l;►��r-.,
t tee rnnifin;i;Wilms;and telephone and fax numbers for the Office ofAdminforalive Hewing.;area tr/Ills?,'
014 Mail Service('rnfrr
Raleigh,N(' 276'r,1,714
'l el; (o/191)471.
Pax: (' t'J)431.3I($,
One(I)copy of the petition must also he served on fit;)as follows;
Mr, William 1',Lane,General oflint.g1
Department of Environmental(Duality
1601 Mail Service Center
Raleigh,North Carolina 27699-1601
Please indicate the case number(as found on page one of this letter)on the petition,
F ai lure to exercise one of the options above within thirty(30)days of receipt of this letter,as evidenced by an internal
date/time received ;tamp(not a postmark),will result in this matter being referred to the Attorney General's Office for
collection of the penalty through a civil action, Please be advised that additional penalties may he assessed for violation
that occur after the review period of this assessment,
If you have any yue%tiom:,please contact Jenny(,rarnak with the Division of Water Resources stall of the
Winston-Salem Regional(Alice at(33(,)776-OK R,In via email of jenny,gramnk(ueru,Aenr.gov,
to,rafrorallk
f o,r Lon l, Snider, Regional Supervisor
Water(Duality Regional Operation, 4leUi.,n REC
Winston-Salem Regional Office 2019
Division of Water Resources, NCt)1:Q DEC 2 3
ATTACHMENTS NCDEQIDWRINPDES
Cc: WQS Winston-Salem Regional Office-Enforcement I-tie
NPDI;S Compliance/Enforcement Unit •Enforcement ilk

r
ATTACHMENT A
Sunrise&Sons, LLC
CASE NUMBER: LV-2019-0344
PERMIT: NC0041483 REGION: Winston-Salem
FACILITY: Sunrise Park COUNTY: Guilford
LIMIT VIOLATION(S)
SAMPLE LOCATION: Outfall 001 -Effluent
Violation Report Unit of Limit Calculated %Over Violation Penalty
Date Monthlyr Parameter Frequency Measure Value Value Limit Type Amount
712412019 7-2019 Cohform,Fecal MF, 2 X month #/100m1 400 2,420 505.0 Daily $100.00
MFC Broth,44 5 C
Maximum ax um
Exceeded
7/31/2019 7-2019 Coliform, Fecal MF, 2 X month #/100m1 200 941 13 370 6 Monthly $250.00
MFC Broth,44 5 C Geometnc
Mean
Exceeded
RECEIVED
DEC 2 3 2019
NCDEQ/DWR/NPDES