_20171020

Resources
rkital Quality
Certified Mail #701+ 12!0 0002 6880 3402
Return Receipt Requ
October 20, 2017
Mr. Yuri Selivanenco, Feed Mill Manager
Wayne Farms, LLC
332 East A Street
Newton, North Carolina 28658
SUBJECT: Notice of Violation and Assessment of Civil Penalty
for Violations of North Carolina General Statute (G.S.) 143-215.1(aX
Wayne Farms, LLC
Case No. DV-2017-Q072
Catawba County
Dear Mr. Selivanenco:
RGY COOPER
Governor
AEL S. REGAN
Secretory
S. JAY ZIMMERMAN
Director
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of $4,452.66 ($4000.00
civil penalty + $452.66 enforcement costs) against Wayne Farms, LLC.
This assessment is based upon the following facts: Apprc xirnately 2,000 gallons of wash water was discharged
into a stormwater drainage system and Town Creek from the pit and silo cleaning activities performed by the
Wayne Fa ins, LLC personnel at the R.enwood Mills facility on August 23 and 24, 2017. Wayne Farms,. LLC had.
not applied for or secured a permit to discharge the pit and silo cleaning wash water from the Division.
Based upon the above facts, I conclude as a matter of law that Wayne Farms, LLC violated G,S. 143-215.1(a)(1)
which states: "Activities for Which Permits Required —No Person shall do any of the following things or carry
out any of the following activities unless that person has received a permit from the Commission and has
complied with all conditions set forth in that permit.
(1) Make any outlet into the waters of the State"
Based upon the above findings of fact and conclusions of law, and in accordance with authority provided by
Secretary of the Department of Environmental Quality and the Director of the Division of Water Resources,
Corey Basinger, Regional Supervisor, Mooresville Regional Office hereby make the following civil penalty
assessment against Wayne Farms, LLC:
State aNarth Carolina !
4 cforeasille Regis nnL t:)
V*P
Saty w ret Resources j ',Nam Qs aint.i Regional Operations
Avenue, Suite 31 i) Moon ,lle Nor'th Carolina 28115
704-N 3-1699
e

$4,000.00 for the violation of G.S. 143-215.1(aX1), by making an outlet to waters of the State without a permit on
August 23 and 24, 2017.
$4,000OO TOTAL CIVIL PENALTY
Enforcement Costs
$452.66
$4,452.66 TOTAL AMOUNT DUE
Pursuant to G.S. 143-215.6A(c), in determining the amount of the penalty I have taken into account the Findings of Fact
and Conclusions of Law and the factors set forth at G.S, 143B-282,1(b), which are:
(1) The degree and extent of harm to the natural resources of the State, to the public health, or to private property
resulting from the violation;
(2) The duration and gravity of the violation;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violation was committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs over which the Environmental
Management Commission has regulatory authority; and
(8) The cost to the State of the enforcement procedures.
Within thirty (30) days of receipt of this notice, you must do one of the following.:
(1) Submit payment of the penalty, OR
(2) Submit a written request for remission, OR
(3) Submit a written request for an administrative hearing
Option is Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environmental Quality (do not include waiver
form). Payment of the penalty will not foreclose further enforcement action for any continuing or new violation(s).
Please submit payment to the attention of:
Wastewater Branch
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617

Option 2: Submit a written request for remission or mitigation including a detailed justification for such
request:
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. Because a remission request forecloses the option of an administrative
hearing, such a request must be accompanied by a waiver of your right to an administrative hearing and a stipulation
and agreement that no factual or legal issues are in dispute. Please prepare a detailed statement that establishes why
you believe the civil penalty should be remitted, and submit it to the Division of Water Resources at the address
listed below. In determining whether a remission request will be approved, the following factors shall be
considered:
(1) whether one or more of the civil penalty assessment factors in NCGS 143B-282.1(b) was wrongfully
applied to the detriment of the petitioner,
(2) whether the violator promptly abated continuing environmental damage resulting from the violation;
(3) whether the violation was inadvertent or a result of an accident;
(4) whether the violator had been assessed civil penalties for any previous violations; or
(5) whether payment of the civil penalty will prevent payment for the remaining necessary remedial actions.
Please note that all evidence presented in support of your request for remission must be submitted in writing. The
Director of the Division of Water Resources will review your evidence and inform you of his decision in the
matter of your remission request. The response will provide details regarding the case status, directions for
payment, and provision for further appeal of the penalty to the Environmental Management Commission's
Committee on Civil Penalty Remissions (Committee). Please be advised that the Committee cannot consider
information that was not part of the original remission request considered by the Director. Therefore, it is very
important that you prepare a complete and thorough statement in support of your request for remission.
In order to request remission, you must complete and submit the enclosed "Request for Remission of Civil
Penalties Waiver of Ri lit to an Administrative Hearin and Sti ulation of Facts" forrn within thi 30 da
receipt of this notice. The Division of Water Resources also requests that you complete and submit the enclosed
"Justification for Remission Request."
Both forms should be submitted to the following address:
Wastewater Branch
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617

Option 3: File a petition for an administrative haring with the Office of Ad inistrative Hearings:
If you wish to contest any statement in the attached assessment document you must file a petition for an administrative
hearing. You may obtain the petition form from the Office of Administrative Hearings. You must file the petition with
the Office of Administrative Hearings within thirty (30) days of receipt of this notice. A petition is considered filed
when it is received in the Office of Administrative Hearings during normal office hours. The Office of Administrative
Hearings accepts filings Monday through Friday between the hours of 8:00 a.m. and 5:00 p.m., except for official state
holidays. The petition may be filed by facsimile (fax) or electronic mail by an attached file (with restrictions) - provided
the signed original, one (1) copy and a filing fee (if a filing fee is required by NCGS §150B-23.2) is received in the
Office of Administrative Hearings within seven (7) business days following the faxed or electronic transmission. You
should contact the Office ofAdministrative Hearings with all questions regarding the filing fee and/or the details of the
filing process.
The mailing address and telephone and fax numbers for the Office of Administrative Hearings are as follows:
One (1) copy of the petition
u
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, NC 27699-6714
Tel: [phone]
Fax: [phone]
also be served on DEQ as follows:
Mr. William F. Lane, General Counsel
Department of Environmental Quality
1601 Mail Service Center.
Raleigh, North Carolina 276994601
Please indicate the case number (as found on page one of this letter) on the petition.
Failure to exercise one of the options above within thirty (30) days of receipt of this letter, as evidenced by an internal
date/time received stamp (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 be assessed for violations
that occur after the review period of this assessment.
If you have any questions, please contact me at [phone] or via email at corey.basingergnedenr.gov.
ATTACHMENTS
Sincerely,
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
Cc: WQS Mooresville Regional Office - Enforcement File
NPDES Compliance/Enforcement Unit - Enforcement File
Jeff Carroll and Jeremy Bowfin, Wayne Farms, LLC (via email)
Dennis Tucker, Renwood Mills

JUSTIFICATION FOR REMISSION UEST
Case Number: DV-2017-0072
Assessed Party: Wayne Farms, LLC
Amount Assessed: $4,452.66
County: Catawba
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 explain the
steps that you took to correct the violation and prevent tree 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;
(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:

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
COUNTY OF CATA A
IN $t ITER OF ASSESSMENT
OF CIVIL PENALTIES AGAINST
WAYNE F
S, LLC
WAIVER OF RIG TO AN
AD 1STRATIVE REA G
STIPULATION OF FACTS
CASE NO. DV-2017-0072
Having been assessed civil penalties totaling 4 452.66 for violation(s) as set forth in the assessment document of the
Division of Water Resources dated October 20,1017, the undersigned, desiring to seek remission of the civil penalty,
does hereby waive the right to an administrative hearing in the above -stated matter and does stipulate that the facts are as
alleged in the assessment document. The undersigned further understands that all evidence presented in support of
remission of this Ci i! penalty must be submitted, to the Director of the Division of Water Resources within thirty (30)
days of receipt of the notice of assessment. No new evidence in support of a remission request will be allowed after (30)
days from the receipt of the notice of assessment.
This tbe day cif
ADDRESS
20
SIGNATURE
TELEPHONE

Water Resources
IENVERONM'ENTAL QCIA6tT1'
September 21, 2017
CERTIFIED MAIL #: 7015 1520 0002 6880 3136
RETURN RECEIPT REQUESTED:
Mr. Dennis Tucker, Plant Manager
Renwood Mills
Post Office Box 350
Newton, North Carolina 28658
CERTIFIED MAIL #: 7015 1520 0002 6880 3143
RETURN RECEIPT REQ1 EST'ED:.
Mr. Yuri Selivanenco, Feed Mill Manager
Wayne Farms, LLC
332 East A Street
Newton, North Carolina 28658
Dear Messrs, Tucker and Selivane
PAT MCCRORY
DONALD R."''VA DE1( VAART
S...JAY ZIMMERMAN
ilrecfor
Subject: Notice of Violation/Notice of
Recommendation for Enforcement
Violation of G.S. 143-215.1(a)
Unpertnitted Discharges of Wastewater
Renwood Mills
Tracking #; NOV-2017-.DV-0239
Catawba County.
Chapter 143, Article 21 of the North Carolina General Statutes (G.S.) authorizes and directs the
Environmental Management Commission of the Department of Environmental Quality to protect and
preserve the water resources of the State, The Division of Water Resources (DWR) has the delegated
authority to enforce adopted water pollution control rules and regulations.
On August 24, 2017, Wayne Farms, LLC reported to this Office that less than 1,000 gallons of
wash water was discharged into an adjacent stormwater drainage system and Town Creek from the pit
cleaning activities at the Renwood Mills facility (located in Newton/Catawba County) earlier on August
24, 2017. In addition, Wayne Farms, LLC submitted a follow-up written report dated September 7, 2017,
detailing the discharge of less than a 1,000 gallons of silo rinse water into the same stormwater drainage
system and waterbody (Town Creek) that had occurred at the Renwood Mills facility on August 23, 2017.
The on -site investigation performed by DWR staff on August 29,2017 revealed the discharges of air
compressor condensate into the Renwood Mill's stormwater drainage system. Renwood Mills and Wayne
Farms, LLC had not applied for or secured a permit to discharge any of the wastewaters from the Division.
State of North. Carolina; l rrvit° nraental Quality; water Resort s
Mooresville Regional Offic [ 610 East Center Avenue, Suite 301
704 663 1699
r Quality Regional Operation,
uaville„ l oTklt Cart liaa 28115

is Tucker
Yuri Selivanenco
September 21, 2017
Page Two
Please be advised that G.S. 143-215.6A provides for a civil penalty assessment of not more than
twenty-five thousand dollars ($25,000.00), or twenty-five thousand dollars ($25,000.00) per day when the
violation is of a continuing nature, against any person who is required but fails to apply for or to secure a
permit required by G.S. 143-215.1(a). Penalties may also be assessed for any damage to the surface waters
of the State that may result from the unpermitted discharge.
This letter is also to advise both of you that this Office is considering the initiation of an
enforcement action for the unpermitted discharges of wastewater into Town Creek. It is requested that both
of you respond in writing within ten (10) working days of receipt of this Notice. The response(s) should
include how the flow volumes were determined through the submittal of water usage readings, calculations,
etc. and all activities to prevent the recurrence of these wastewater discharges. Although this Office has
received the follow-up written reports (dated September 11 and 18, 2017) from Wayne Farms, LLC
detailing the August 23 and 24, 2017 discharge events and all corresponding remedial activities, any
additional information including all activities to address the air compressor condensate discharges, should
be included with the response(s).
Should you have any questions concerning this Notice, please do not hesitate to contact me at
[phone], or via email atLbasinerncenr.ov.
Sincerely,
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
cc: Catawba County Health Department
Jeff Carroll, Wayne Farms, LLC (via email)
Jeremy Bowfin, Wayne Farms, LLC (via email)
NPDES Compliance/Enforcement Unit
WB

Mr. Wes Bell
Senior Environmental Specialist
Water Resources
Water Quality Regional Operations Section
Mooresville Regional Office, NCDEQ
61.0 East Center Avenue, Suite 310
Mooresville, NC 28115
Dear Mr. Bell:
RE:
September 7, 2017
Addendum to Spill Report dated August 31, 2017
Wayne Farms, EEC (leasing facility from Renwood Mills)
324 East A Street
Newton, NC 28658
Certificate of Coverage NCG060158 (Renwood Mills)
Catawba County
This letter is the written report to amend the subject spill report dated August 31.„ 2017. The following
additional information is supplied as spill documentation as requested by Wes Bell (NC DEQ):
Discovery Date and time:
Discharge Date and time:
Type of release:
Quantity released:
Discharge Duration:
8-29-2017 (9:30 AM) Photographs taken by staff of the City of
Newton indicating what appeared to be a discharge from a pipe
in a secondary containment area were presented to Jeremy
Bowfin and Wes Bell (NC DEQ) during an inspected on August
29, 2017 at the facility. The City of Newton presented the
photographs.
8-23-2017 Morning shift
Wash water from cleaning an 'impervious area beneath grain
silos
Estimated at < 1,000 gallons flush water
Approximately 3 112 hours (intermittent discharge)

Location/Source description:
Cause of incident:
On the morning of.Aug 23, an operato
discharge exited a secondary containrne
entered a storrn.water system.
Discovery description:
))ischat°ged from Wayne Farrns secondary containment structure
into the City of Newton Storm water system, Unnamed Tributary
to Town Creek
ed underneath the silos on the south side of the property. The
ucture through a discharge pipe that had been uncapped and
Wayne Farms' site management was unaware this activity occurred until a photograph was presented
during an inspection by the NC DEQ on August 29.. The City of Newton staff presented the photograph
of the pipe to Wes Bell (NC DEQ) and Jeremy Bowfin during the inspection of August 29. A brief
discussion with Wes Bell concerning this discovery was had a't that time,
Notification to DEQ:
On September 5`h, a voicemail from °fr. Wes Bell was le# ftr Jeremy Bowling requesting additional
information on any releases that may have occurred as a result of the silo rinsing activities. A call was
made back to Mr. Bell on September 5, 2017 at 4:30pm by Jeremy Bowfin, Wayne Farms and Beth
Morton, Morton Environmental Consulting, Inc. to further discuss Mr, Bell's request for additional
information,
Actions taken to stop, remove, and mitigate impacts:
Wayne Farrns initiated cleanup of any discharges from the single point of storm water outfall discharge,
which occurred on the dates of August 23rd and 24th with actions described in their spill report letter dated.
August 31, 2017. Carolina Environmental and STAT Environmental services performed remediation of
areas :from which there were odor complaints received from the City of Newton on August 26, 2017..
Initial cleanup cost to Wayne Farrns was $4797.50,
Wayne Farms personnel have taken corrective action to tram personnel in the proper procedures for
cleaning, including the proper methods for liquid collection and disposal from silo area cleaning
activities. Wayne Farms is in the process of drafting written procedures for this cleaning and
maintenance activity. These Standard Operating Procedures will be forwarded to Renwood Mills so that
th,e facility can modify its Stormwater Pollution Prevention Plan to insure compliance and to avoid further
incidents.

Wayne Farms feels that this addendum to the August 31 Spill report completely addresses the corrective
actions specified by Wes Bell for the cleaning activity release from the facility's single outtall, Should
any further concerns or clarification be required for this report, please contact Beth Morton, Morton
Environmental Consulting, Inc, (336)9984'757 or me at [phone],
tricerely,
Jeremy Bowlin
Environmental. Manager
Cc: Jeff Carroll
Bellwood Mills

Mr.
Senior Envi.n
Water Resources
Water Quality Regis
Mooresville Region
WAYN E FARM1
Specia
1 Operations Section
Office, NCDEQ
610 East Center Avenue, Suite 310
Mooresville, NC 28115
Dear Mr. fleII:
Spill Report fo
Wayne Farms,
3'24 East A Street
Newton, NC 286.58
Certificate of Coverage NCG06015 8
Catawba County
This letter is the ww'rit
2017 at the Newton,. NC Wayna:
mated at 324 East A S
August 31, 2C117
24-17)
facility frc
Renwood Mills)
document the reported release incident which occurred on August 24,
:s Feed Mill. Wayne 'Farms, LLC leases part of the Renwood Mills
purposes of animal feed manufacturing activities. The
ng information is supplied as documentation:
Reported Discharge„ 1)
Discovery Date and tin
'Type of release:
Quantity released:
Discharge Duration:
Location/Source description:
and time:
Morning of 8-24- 1 7
Notification by City on 8-24-1.7 at approximately 1' :3€ PM
Suspected Rinse water from pit cleaning activiti
Unknown; Estimated at less than 1,000 gallons.
Unknown; Intermittent discharge — Estimated at
Suspected Rinse Water from Wayne Farms receiving pit
s

Cause of Incident/Discovery Description:
On August 24, 2017, Mr. Alex Fulbright, with the City of Newton came to the Wayne Farms Feed Mill at
approximately 1.2:30pm to inform site management. of a suspected unauthorized discharge from the
Wayne Farrns facility into the City of Newton Municipal Stormwater System. Upon investigation, the
discharge in have originated from eleaning/rinsing activities at a below ground receiving pit Which
captures animal feed ingredients during rail offloa.ding...At the time of Mr. Fit Origin's visit, no discharge
was occurring from the Wayne Farms site Steps were immediately taken to investigate the reported
discharge and determine its impacts.
Notification to DEQ:
After steps were taken to determine the extent of the incident, Jeremy Bowfin of Wayne Farms and
consultant, Beth Morton of Morton Environmental, called Mr. Wes Bell with the NCDEQ to report the
incident (call logged on August 24 at 4:52 pm). Mr, Bell stated that, subsequent to this conversation,
should anysignificant enviromnental impacts be discovered from the release to the City's storm water
system or receiving waters, that Wayne farms should move forward with the appropriate actions to
remediate any :suspected contamination from the affected areas.
Actions Taken to Mitigate Impacts:
The initial assessment from site management indicated that no significant impacts were realized
downstream from the discharge point. Personnel took photographs of the reported discharge, receiving
city storm drain system, and unnamed tributary. No significant impacts to the receiving waters were
discovered at this time.
Late in the evening, Jeff Carroll, Wayne Farms Corporate Environmental Compliance & Engineering
Manager, called. Mr. Fulbright's Office and the Newton Wastewater Treatment Plant and left messages to
inquire if any impacts were realized at the waste treatment plant or within the municipal storm system.
Mr, Carroll did not receive aiyreturn calls.
August 25, 2017
Jeff Carroll spoke ,with .1N/ r. Fulbright the morning of the 25'1' At this point in time, Mr, Fulbright
indicated that, to his knowledge, no significant impacts had been observed or realized. Jeff Carroll and
Beth Morton followed up with a call to Mr, Wes Bell Nvith NCDEQ after lunch and informed Mr, Bell
that the initial investigation indicated that any suspected release impacts were minimal, but that the
Wayne Farms investigation was ongoing and that Wayne Farms was waiting on .final: word from Mr.
Fulbright that no impacts had been realized to their systems, Wayne Farms indicated to Mr. Bell that any
necessary remedial action ‘vould be taken if any impacts were suspected.
At approximately 4pm. Mr. Fulbright reported to Mr. Carroll that an odor complaint had been received
and thal. some contamination downstream was suspected. Mr. Fulbright .indicated that some remediation

needed to be conducted in that area, Mr. Carroll then instructed Mr. Bobby Stanley with Carolina
Environmental to go to the site and assist With the impact assessment and recommended remediation.
Later that evening Mr. Stanley, along with site management, assessed the area and determined that while
there was no immediate threat to people or the environment, additional work, would insure no further
impact. A plan was formalized for work to be done on the following day.
August 26, 2017
Wayne Farms hired Carolina Environmental and STAT Environmental Services to perform work at any
suspected area of impact, On the morning of the 26th, Wayne Farms' contractors removed any suspected
spilled materials, including the area where the odor complaint originated. Elpon completion of the work,
site management„ along with Mr. Stanley, believed that the efforts were satisfactory and would meet, the
expectations of both IVIr. Fulbright and Mr, Bell,
Wayne .Farms personnel has taken. action to train personnel in the proper procedures for pit cleanout,
including the proper methods for liquid disposal. Wayne Farms is drafting written procedures to follow
for this maintenance activity, 'These SOPs will he forwarded to Renwood Mills to insure compliance and
avoid further incidents,
While communications with NCDEQ are ongoing, at this time, Wayne Farms feels that it has completed
the corrective actions necessary as specified .on August 24 be Mr. Wes ,Bell to address the reported release
incident of August 24, 2017, Should any further information or clarification be required for this report,
please contact Beth !Vlorton, Morton Environmental Consulting. Inc. [phone] or inc at (336)386-
5867.
Jeremy Bowlin
Environmental Manager
Cc: Jeff Carroll
Renwood Mills

October 10, 2017
O, B IX 5 NEWTON, NORTH C RO INA 28658 - a
FAX [phone]
Mr W. Corey Basinger
Water Quality Regional Operations Section
Division of Water Resources, NDEQ
Mooresville Regional Office
610 East Center Avenue, Suite 301
Mooresville, NC 28115
Subject: Notice of Violation
Unpermrtted Discharge of Wastewater
Renwood Mills-
Tracking ##NOW-2017-DV-0289
Catawba County
Dear tvir. Basinger,
This letter is a written response for the Notice of Violation dated Seoterr her 21, 2017
This is to advise that the oil discharge from the air compressor Ploys/down was remediated on September
9th with the Installation of two (2) Ecotron 600 Oil/Water separators on our two air compressor systems,
Piping that was discharging from the air compressor blowdowns to the outside was removed and wall
penetrations were filled with mortar. Water component from the separator has been piped to the
sanitary sewer system:
Should you have any questions, please contact me at 828. 64,1611 ext, 225
Dennis Tucker
Director of Operations
Renwood Nulls

DIVISION OF WATER RESOURCES - CIVIL PENALTY ASSESSMENT
(Background Inforrnation for Consideration of the Assessment Factors)
Violator: Wayne Farms, LLC
County: Catawba.
Case Number: DV-2017-0072
ASSESSMENT FACTORS
1) The degree and extent of harm to the natural resources of t
property resulting from the violation;
rho Ca-4
2) The duration and gray'
r..
61
of the violation;
,r...2.�
e, to the public health, or to private
3) The effect on ground or surface water quantity or quality or on air quality;
7�� Ctri
.0 -,. r- a"� �q r,4 4146� t ..
4) The cost of rectifying the damage;
5) The amount of money saved by noncompliance;
i
, per.,.; y{eJ -;" - �t.a C - '
6) Whether the violation was committed willfully or intentionally;
rr<s),_ �`t-- " —fit-,* .04.244,.. ..�.. a..�
7) The prior record of the violator in complying or failing to comply with programs over which the
Environmental Management Commission has regulatory authority; and
No prior record in previous five years.
8) The cost to the State of the enforcers ent procedures.
$452.66

W. Coreyrinr, Rinna
t r Quality Regional One
%ill' Regional Office
Di on of Water Resources, \CDEQ