NC0085812_SOC (acknowledgement)_20200323

Department of Public Works
Water/Wastewater Division
4600 Goldmine Road
Monroe, NC 28110
T. 704-289-1434
F. 704-289-7395
www.unioncountync.gov
March 13, 2020
W. Corey Basinger,
Regional Supervisor
NCDEQ
610 East Center Avenue, Suite 301
Mooresville, NC 28115
Dear Mr. Basinger,
F'ECEIVED/NCDENR/DWR
WQROS
MOORESVILLE REGIONAL OFFICE
Included with this letter are the Justification for Remission Request Forms, and the check for
$1478.48 to cover the enforcement administration costs for the Grassy Branch civil penalties per
your documentation. We understand that the civil penalties will be held in abeyance pending
completion of the upgrades to the Grassy Branch WRF, which will be included in the Special
Order By Consent. If you need anything further, please let me know at 704-296-4215.
Sincerely,
Akdrew
. Neff, PE
Water/Wastewater Division Director
Union County Public Works
Cc: Hyong Yi, Public Works Administrator
Roberto Schiller, Senior Environmental Specialist
Bart Farmer, WRF Superintendent

JUSTIFICATION FOR REMISSION REQUEST
Case Number; LV-2020-0101 County; Union
Assessed Party: Union County
Permit No.: NCO085812 Amount Assessed: $465.76
Please use this form when requesting remission of this civil penalty. You must also complete the "Request For Remission,
Waiver of Right to an Adininistrative Hearing, and Stipulation of Facts" form to request remission of this civil penalty.
You should attach any documents that you believe support your request and are necessary for the Director to consider in
evaluating your request for remission. ,Please be aware that a request for remission is limited to consideration of the five
factors listed below as they may relate to the reasonableness of the amount of the civil penalty assessed. Requesting
remission is not the proper procedure for contesting whether the violation(s) occurred or the accuracy of any of the factual
statements contained in the civil penalty assessment document. Pursuant to N.C.G.S. § 14313-282.1(c), remission of a civil
penalty may be granted only when one or more of the following five factors apply. Please check each factor that you
believe applies to your case and provide a detailed explanation, including copies of supporting documents, as to why the
factor applies (attach additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C.G.S. 14313-282.1(b) were wrongfully applied to the
detriment of the petitioner (the assessment factors are listed in the civil penalty assessment document).;
(b) the violator promptly abated continuing environmental damage resulting from the violation (i.e., explain the
steps that yoze took to correct the violation and prevent future occurrences);
(c) the violation was inadvertent or a result of an accident (i. e., explain ivliy the violation ivas unavoidable or
something you could not prevent or prepare for);
(d) the violator had not been assessed civil penalties for any previous violations;
x (e) payment of the civil penalty will prevent payment for the remaining necessary remedial actions (I. e., explain
hoi•v payment of the civil penalty will prevent you. from performing the activr.'ties necessat)i to achieve
compliance).
EXPLANATION:
Union County respectfully requests that the civil penalty be held in abeyance pending completion of
construction upgrades to the Grassy Branch WRF facility as part of the Special Order by Consent (SOC)
agreement between Union County and NCDEQ

JUSTIFICATION FOR REMISSION REQUEST
Case Number: LV-2020-0102 County: Union
Assessed Party: Union County
Permit No.: NCO085812 Amount Assessed: 1 015.76
Please use this form when requesting remission of this civil penalty. You must also complete the "Request For Remission,
Waiver of Right to an Administrative Hearing, and Stipulation of Facts" form to request remission of this civil penalty..
You should attach any documents that you believe support your request and are necessary for the Director to consider in
evaluating your request for remission. Please be aware that a request for remission is limited to consideration of the five
factors listed below as they may relate to the reasonableness of the amount of the civil penalty assessed. Requesting
remission is not the proper procedure for contesting whether the violation(s) occurred or the accuracy of any of the factual
statements contained in the civil penalty assessment document. Pursuant to N.C.G.S. § 14313-282.1(c), remission of a civil
penalty may be granted only when one or more of the following five factors apply. Please check each factor that you -
believe applies to your case and provide a detailed explanation, including copies of supporting documents, as to why the
factor applies (attach additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C.G.S. 143B-282.1(b) were wrongfully applied to the
detriment of the petitioner (the assessment factors are listed in the civil penalty assessment document);
(b) the violator promptly abated continuing environmental damage resulting from the violation (i,e., explain the
steps that you took to correct the violation and prevent fitture occurrences);
_ (c) the violation was inadvertent or a result of an accident (i.e., explain why the violation was unavoidable or
something you could not prevent or prepare for);
(d) the violator had not been assessed civil penalties for any previous violations;
x (e) payment of the civil penalty will prevent payment for the remaining necessary remedial actions (i.e., explain
how payment of the civil penalty will prevent you from performing the activities necessary to achieve
compliance).
EXPLANATION:
Union County respectfully requests that the civil penalty be held in abeyance pending completion of
construction upgrades to the Grassy Branch WRF facility as part of the Special Order by Consent
(SOC) agreement between Union County and NCDEQ

JUSTIFICATION FOR REMISSION REQUEST
Case Number: LV-2020-0100
Assessed Party: Union County
County: Union
Permit No.: NCO085812 Amount Assessed: $365.76
Please use this form when requesting remission of this civil penalty. You must also complete the "Request For Remission,
Waiver ofRight to an Administrative Hearing, and Stipulation of Facts" form to request remission of this civil penalty.
You should attach any documents that you believe support your request and are necessary for the Director to consider in
evaluating your request for remission. Please be aware that a request for remission is limited to consideration of the five
factors listed below as they may relate to the reasonableness of the amount of the civil penalty assessed. Requesting
remission is not the proper procedure for contesting whether the violation(s) occurred or the accuracy of any of the factual
statements contained in the civil penalty assessment document. Pursuant to N.C,G.S. § 143B-282,1(c), remission of a.civil
penalty may be granted only when one or more of the following five factors apply. Please check each factor that you
believe applies to your case and provide a detailed explanation, including copies of supporting documents, as to why the
factor applies (attach additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C.G.S. 143B-282.1(b) were wrongfully applied to the
detriment of the petitioner (the assessmentfactors are listed in the civil penalty assessment document);
(b) the violator promptly abated continuing environmental damage resulting from the violation (i.e., explain the
steps that you took to correct the violation and preventfitture occurrences);
(c) the violation was inadvertent or a result of an accident (i.e., explain ivhy the violation was unavoidable or
somethingyou could not prevent or prepare for);
(d) the violator had not been assessed civil penalties for any previous violations;
x (e) payment of the civil penalty will prevent payment for the remaining necessary remedial actions (i.e., explain
how payment of the civil penalty ivill prevent you from performing the activities necessary to achieve
compliance).
EXPLANATION:
Union County respectfully requests that the civil penalty be held in abeyance pending completion of
construction upgrades to the Grassy Branch WRF facility as part of the Special Order by Consent (SOC)
agreement between Union County and NCDEQ

JUSTIFICATION FOR REMISSION REQUEST
Case Number: LV-2019-0074
Assessed Party: Union County
County: Union
Permit No.: NCO085812 Amount Assessed: $565.76
Please use this form when requesting remission of this civil penalty. You must also complete the "Request For Remission,
Waiver of ftht to an Administrative Hearing, and Stipulation of Facts" form to request remission of this civil penalty.
You should attach any documents that you believe support your request and are necessary for the Director to consider in
evaluating your request for remission. Please be aware that a request for remission is limited to consideration of the five
factors listed below as they may relate to the reasonableness of the amount of the civil penalty assessed. Requesting
remission is not the proper procedure for contesting whether the violation(s) occurred or the accuracy of any of the factual
statements contained in the civil penalty assessment document. Pursuant to N.C.G.S. § 143B-282.1(c), remission of a civil
penalty may be granted only when one or more of the following five factors apply. Please check each factor that you
believe applies to your case and provide a detailed explanation, including copies of supporting documents, as to why the
factor applies (attach additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C.G.S. 143B-282.1(b) were wrongfully applied to the
detriment of the petitioner (the assessment factors are listed in the civil penalty assessment docannent);
_ (b) the violator promptly abated continuing environmental damage resulting from the violation (i.e., explain the
steps that you took to correct the violation and prevent future occurrences);
(c) the violation was inadvertent or a result of an accident (Le., explain why the violation ivas unavoidable or
something you could not prevent or prepare for);
(d) the violator had not been assessed civil penalties for any previous violations;
X. (e) payment of the civil penalty will prevent payment for the remaining necessary remedial actions (i.e., explain
how payment of the civil penaloJ will prevent you from performing the activities necessary to achieve
compliance),
EXPLANATION:
Union County respectfully requests that the civil penalty be held in abeyance pending completion of
construction upgrades to the Grassy Branch WRF facility as part of the Special Order by Consent (SOC)
agreement between Union County and NCDEQ

JUSTIFICATION FOR REMISSION REQUEST
Case Number: DV-2020-0030 County: Union
Assessed Party: Union County
Permit No.: WQCS00054 Amount Assessed: $626.93
Please use this form when requesting remission of this civil penalty. You must also complete the "Request For Remission,
Waiver ofRight to an Adininistrative Hearing, and Stipulation of Facts" form to request remission of this civil penalty.
You should attach any documents that you believe support your request and are necessary for the Director to consider in
evaluating your request for remission. Please be aware that a request for remission is limited to consideration of the five
factors listed below as they may relate to the reasonableness of the amount of the civil penalty assessed. Requesting
remission is not the proper procedure for contesting whether the violation(s) occurred or the accuracy of any of the factual
statements contained in the civil penalty assessment document. Pursuant to N.C.G.S. § 143B-282.1(c), remission of a civil
penalty inay be granted only when one or more of the following five factors apply. Please check each factor that you
believe applies to your case and provide a detailed explanation, including copies of supporting documents, as to why the
factor applies (attach additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C.G.S. 14313-282.1(b) were wrongfully applied to the
detriment of the petitioner (the assessrnentfactors are listed in the civil penalty assessment document);
(b) the violator promptly abated continuing environmental damage resulting from the violation (i.e„ explain the
steps that you took to correct the violation and prevent fixture occurrences);
(c) the violation was inadvertent or a result of an accident (i.e., explain why the violation was unavoidable or
something you could nol prevent or prepare for);
(d) the violator had not been assessed civil penalties for any previous violations;
x (e) payment of the civil penalty will prevent payment for the remaining necessary remedial actions (i.e., explain
how payment of the civil penalty swill prevent you from per forming the activities necessar)r to achieve
compliance).
EXPLANATION:
Union County respectfully requests that the civil penalty be held in abeyance pending completion of .
construction upgrades to the Grassy Branch WRF facility as part of the Special Order by Consent (SOC)
agreement between Union County and NCDEQ

JUSTIFICATION FOR REMISSION REQUEST
Case Number: DV-2020-0032 County: Union
Assessed Party: Union County
Permit No.: WQC800054 Amount Assessed: $376.93
Please use this form when requesting remission of this civil penalty. You must also complete the "Request For Remission,
Waiver of Right to an Administrative Hearing, and Stipulation of Facts" form to request remission of this civil penalty.
You should attach any documents that you believe support your request and are necessary for the Director to consider in
evaluating your request for remission. Please be aware that a request for remission is limited to consideration of the five
factors listed below as they may relate to the reasonableness of the amount of the civil penalty assessed. Requesting
remission is not the proper procedure for contesting whether the violation(s) occurred or the accuracy of any of the factual
statements contained in the civil penalty assessment document. Pursuant to N.C.G.S. § 14313-282.1(c), remission of a civil
penalty may be granted only when one or more of the following five factors apply. Please check each factor that you
believe applies to your case and provide a detailed explanation, including copies of supporting documents, as to why the
factor applies (attach additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C.G.S. 143B-282.1(b) were wrongfully applied to the
detriment of the petitioner (the assessment factors are listed in the civil penalty assessment document);
(b) the violator promptly abated continuing environmental damage resulting from the violation (i.e., explain the
steps that you took to correct the violation and prevent future occurrences);
(c) the violation was inadvertent or a result of an accident (i.e., explain rvhy the violation was unavoidable or
something you could nol prevent or prepare for);
T (d) the violator had not been assessed civil penalties for any previous violations;
X (e) payment of the civil penalty will prevent payment for the remaining necessary remedial actions (i.e., explain
how payment of the civil penalty will prevent you from performing the activities necessary to achieve
compliance).
EXPLANATION:
Union County respectfully requests that the civil penalty be held in abeyance pending completion of
construction upgrades to the Grassy Branch WRF facility as part of the Special Order by Consent (SOC)
agreement between Union County and NCDEQ

1STIFICATION FOR REMISSION REQUEST
Case Number: DV-2020-0033 County: Union
Assessed Party: Union County
Permit No.: WQCS00054 Amount Assessed: 626,93
Please use this form when requesting remission of this civil penalty. You must also complete the "Request For Remission,
Waiver of Right to an Administrative Hearing, and .Stipulation of Facts" form to request remission of this civil penalty.
You should attach any documents that you believe support your request and are necessary for the Director to consider in
evaluating your request for remission. Please be aware that a request for remission is limited to consideration of the five
factors listed below as they may relate to the reasonableness of the amount of the civil penalty assessed. Requesting
remission is not the proper procedure for contesting whether the violation(s) occurred or the accuracy of any of the factual
statements contained in the civil penalty assessment document. Pursuant to N.C.G,S. § 14313-282.1(c), remission of a civil
penalty may be granted only when one or more of the following five factors apply. Please check each factor that you
believe applies to your case and provide a detailed explanation, including copies of supporting documents, as to why the
factor applies (attach additional pages as needed).
T (a) one or more of the civil penalty assessment factors in N.C.G.S. 143B-282.1(b) were wrongfully applied to the
detriment of the petitioner (the assessment factors w-e listed in the civil penalty assessment document);
(b) the violator promptly abated continuing environmental damage resulting from the violation (Le., explain the
steps that you look to correct the violation and prevent future occurrences);
T (c) the violation was inadvertent or a result of an accident (Le., explain why the violation was unavoidable or
something you could not prevent or prepare for);
(d) the violator had not been assessed civil penalties for any previous violations;
x (e) payment of the civil penalty will prevent payment for the remaining necessary remedial actions (i.e„ explain
hoiw payment of the civil penalty rill prevent you fi'orn performing the activities necessary to achieve
compliance).
EXPLANATION:
Union County respectfully requests that the civil penalty be held in abeyance pending completion of construction
upgrades to the Grassy Branch WRF facility as part of the Special Order by Consent (SOC) agreement between
Union County and NCDEQ

JUSTIFICATION FOR REMISSION REQUEST
Case Number: DV-2020-0034 County: Union
Assessed Party: Union County
Permit No.: WQCS00054 Amount Assessed: $376.93
Please use this form when requesting remission of this civil penalty. You must also complete the "Request For Remission,
Waiver of Right to an Administrative Hearing, and Stipulation of Facts" form to request remission of this civil penalty.
You should attach any documents that you believe support your request and are necessary for the Director to consider in
evaluating your request for remission. Please be aware that a request for remission is limited to consideration of the five
factors listed below as they may relate to the reasonableness of the amount of the civil penalty assessed. Requesting
remission is not the proper procedure for contesting whether the violation(s) occurred or the accuracy of any of the factual
statements contained in the civil penalty assessment document. Pursuant to N.C.G.S. § 14313-282.1(c), remission of a civil
penalty may be granted only when one or more of the following five factors apply. Please check each factor that you .
believe applies to your case and provide a detailed explanation, including copies of supporting documents, as to why the
factor applies (attach additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C.G.S. 14313-282.1(b) were wrongfully applied to the
detriment of the petitioner (the assessment factors are listed in the civil penalty assessment document);
(b) the violator promptly abated continuing environmental damage resulting from the violation (i.e., explain the
steps that you took to correct the violation and prevent fixture occurrences);
(c) the violation was inadvertent or a result of an accident (i.e., explain why the violation was unavoidable or
something you could not prevent or prepare for);
(d) the violator had not been assessed civil penalties for any previous violations;
x (e) payment of the civil penalty will prevent payment for the remaining necessary remedial actions (i.e., explain
horn payment of the civil penalt}) hill prevent you ftom performing the activities necessary to achieve
compliance),
EXPLANATION:
Union County respectfully requests that the civil penalty be held in abeyance pending completion of
construction upgrades to the Grassy Branch WRF facility as part of the Special Order by Consent (SOC)
agreement between Union County and NCDEQ

JUSTIFICATION FOR REMISSION REQUEST
Case Number: DV-2020-0035 County: Union
Assessed Party: Union County
Permit No.: WQCS00054 Amount Assessed: $501,93
Please use this form when requesting remission of this civil penalty. You must also complete the "Request For Remission,
Waiver of Right to an Administrative Hearing, and Stipulation of Facts" form to request remission of this civil penalty.
You should attach any documents that you believe support your request and are necessary for the Director to consider in
evaluating your request for remission. Please be aware that a request for remission is limited to consideration of the five
factors listed below as they may relate to the reasonableness of the amount of the civil penalty assessed. Requesting
remission is not the proper procedure for contesting whether the violation(s) occurred or the accuracy of any of the factual
statements contained in the civil penalty assessment document. Pursuant to N.C,G,S. § 14313-282. 1 (c), remission of a civil
penalty may be granted only when one or more of the following five factors apply. Please check each factor that you
believe applies to your case and provide a detailed explanation, including copies of supporting documents, as to why the
factor applies (attach additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C.G.S. 14313-282.1(b) were wrongfully applied to the
detriment of the petitioner (the assessment factors are listed in the civil penalty assessment document);
(b) the violator promptly abated continuing environmental damage resulting from the violation (i.e., explain the
steps that you took to correct the violation and prevent fitture occurrences);
(c) the violation was inadvertent or a result of an accident (Le., explain why the violation was unavoidable or
something you could not prevent or prepare for);
(d) the violator had not been assessed civil penalties for any previous violations;
X. (e) payment of the civil penalty will prevent payment for the remaining necessary remedial actions (i.e„ explain
horn payment of the civil penalty will prevent you from per;forniing the activities necessary to achieve
compliance).
EXPLANATION:
Union County respectfully requests that the civil penalty be held in abeyance pending completion of
construction upgrades to the Grassy Branch WRF facility as part of the Special Order by Consent (SOC)
agreement between Union County and NCDEQ

JUSTIFICATION FOR REMISSION REQUEST
Case Number: DV-2020-0036 County: Union
Assessed Party: Union County
Permit No.: WQCS00054 Amount Assessed: $376.93
Please use this form when requesting remission of this civil penalty, You must also complete the "Request For Remission,
Waiver of Right to an Administrative Hearing, and Stipulation of Facts" form to request remission of this civil penalty.
You should attach any documents that you believe support your request and are necessary for the Director to consider in
evaluating your request for remission. Please be aware that a request for remission is limited to consideration of the five
factors listed below as they may relate to the reasonableness of the amount of the civil penalty assessed. Requesting
remission is not the proper procedure for contesting whether the violation(s) occurred or the accuracy of any of the factual
statements contained in the civil penalty assessment document. Pursuant to N.C.G.S. § 143B-282.1(c), remission of a'civil
penalty may be granted only when one or more of the following five factors apply. Please check each factor that you
believe applies to your case and provide a detailed explanation, including copies of supporting documents, as to why the
factor applies (attach additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C..G.S. 143B-282. I (b) were wrongfully applied to the
detriment of the petitioner (the assessment factors are listed in the civil penalty assessment document);
(b) the violator promptly abated continuing environmental damage resulting from the violation (i.e., explain the
steps that you took to correct the violation and prevent future occurrences);
(c) the violation was inadvertent or a result of an accident (i.e., explain ivhy the violation was unavoidable or .
something you could not prevent or prepare foi);
(d) the violator had not been assessed civil penalties for any previous violations;
x (e) payment of the civil penalty will prevent payment for the remaining necessary remedial actions (i.e., explain
hoii, payment of the civil penalty tivill prevent you fi oun peifornuing the activities necessary to achieve
compliance).
EXPLANATION:
Union County respectfully requests that the civil penalty be held in abeyance pending completion of
construction upgrades to the Grassy Branch WRF facility as part of the Special Order by Consent (SOC)
agreement between Union County and NCDEQ

JUSTIFICATION FOR REMISSION REQUEST
Case Number: DV-2020-0037 County: Union
Assessed Party: Union County
Permit No.: WQCS00054 Amount Assessed: $626.93
Please use this form when requesting remission of this civil penalty. You must also complete the "Request For Reinission,
Waiver of Right to an Administrative Hearing, and Stipulation of Facts" form to request remission of this civil penalty.
You should attach any documents that you believe support your request and are necessary for the Director to consider in
evaluating your request for remission. Please ,be aware that a request for remission is limited to consideration of the five
factors listed below as they may relate to the reasonableness of the amount of the civil penalty assessed. Requesting
remission is not the proper procedure for contesting whether the violation(s) occurred or the accuracy of any of the factual
statements contained in the civil penalty assessment document. Pursuant to N.C.G.S. § 143B-282. I (c), remission of a civil
penalty may be granted only when one or more of the following five factors apply. Please check each factor that you
believe applies to your case and provide a detailed explanation, including copies of supporting documents, as to why the
factor applies (attach additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C.G.S. 143B-282.1(b) were wrongfully applied to the
detriment of the petitioner (the assessment factors are listed in the civil penally assessment document);
(b) the violator promptly abated continuing envirorunental damage resulting from the violation (i.e., explain the
steps that you look to correct the violation and prevent fixture occurrences);
(c) the violation was inadvertent or a result of an accident (i.e., explain why the violation was unavoidable or
something you could not prevent or prepare for);
(d) the violator had not been assessed civil penalties for any previous violations;
X (e) payment of the civil penalty will prevent payment for the remaining necessary remedial actions (i.e., explain
how payment of the civil penaty, tiidll preventyou from petforming the activities necessary to achieve
compliance).
EXPLANATION:
Union County respectfully requests that the civil penalty be held in abeyance pending completion of
construction upgrades to the Grassy Branch WRF facility as part of the Special Order by Consent (SOC)
agreement between Union County and NCDEQ

JUSTIFICATION FOR REMISSION REQUEST
Case Number: DV-2020-0038 County: Union
Assessed Party: Union County
Permit No.: WQCS00054 Amount Assessed: $1,376.93
Please use this form when requesting remission of this civil penalty. You must also complete the "Request For• Remission,
Waiver of Right to an Administrative Hearing, and Stipulation of Facts" form to request remission of this civil penalty.'
You should attach any documents that you believe support your request and are necessary for the Director to consider in
evaluating your request for remission. Please be aware that a request for remission is limited to consideration of the five
factors listed below as they may relate to the reasonableness of the amount of the civil penalty assessed. Requesting
remission is not the proper procedure for contesting whether the violation(s) occurred or the accuracy of any of the factual
statements contained in the civil penalty assessment document. Pursuant to N.C.G.S: § 143B-282.1(c), remission of a civil
penalty may be granted only when one or more of the following five factors apply. Please check each factor that you
believe applies to your case and provide a detailed explanation, including copies of supporting documents, as to why the
factor applies (attach additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C.G.S. 143B-282.1(b) were wrongfully applied to the
detriment of the petitioner (the assessment. factors are listed in the civil penalty assessment document);
(b) the violator promptly abated continuing environmental damage resulting from the violation (i.e., explain the
steps that you took to correct the violation and prevent future occurrences);
(c) the violation was inadvertent or a result of an accident (i.e„ explain rvhy the violation was unavoidable or
something you could not prevent or prepare for);
(d) the violator had not been assessed civil penalties for any previous violations;
x (e) payment of the civil penalty will prevent payment for the remaining necessary remedial actions (i.e., explain
hory payment of the civil penalty will prevent you f rorn performing the activities necessary to achieve
compliance).
EXPLANATION:
Union County respectfully requests that the civil penalty be held in abeyance pending completion of
construction upgrades to the Grassy Branch WRF facility as part of the Special Order by Consent (SOC)
agreement between Union County and NCDEQ