WQ0029945_Remission (Request)_20200113

January 13, 2020 ONWASA
Wastewater Branch
NCDEQ — Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
RE: Request for Remission of Civil Penalties
Permit No. WQ0029945 ��IDWR
Summerhouse Wastewater Reclamation WWTF RE�E�V�pIN�p'-
Onslow Water & Sewer Authority, Onslow County JaN 1 I 2020
DWR Staff: D�Schargk
e�}tt►n9 unit
This letter is sent to formally request remission of civil penalties associated with a
Notice of Violation (Case Number LV-2019-0341) issued by the Division of Water
Resources to the above -referenced facility for exceedance of permit limits during August
2019.
As noted in the enclosed correspondence with staff from the Wilmington Regional
Office, ONWASA has taken direct action to address the root cause of these violations
(cleaning frequency of the membranes in the MBR) and thus reduce the potential for a
recurrence. This included the expenditure of $4,250 to have an equipment
manufacturer's technician on -site to evaluate operating conditions and assist in the
cleaning effort, as well as $2,450 in crane rental costs necessary to remove and replace
the membrane panels for hand -cleaning.
Regarding the SCADA system revisions mentioned in the letter, ONWASA
Information Technology personnel have made the necessary programming changes and
we believe this issue is now corrected.
If you have any questions of need additional information regarding this request
please feel free to contact me directly at 910-937-7521 or [e-mail].
Sincerely,
David M. Mohr, P.E.
Engineering Director
Onslow Water & Sewer Authority
Enclosures
C: Mike Lutz, Summerhouse ORC
Jeffery L. Hudson, ONWASA CEO

DocuSign Envelope ID: 8D37B6BA-E173-4C71-9743-CA55300D3929
STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
COUNTY OF ONSLOW
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
Onslow Water and Sewer Authority )
Summerhouse Wastewater Reclamation WWTF )
PERMIT NO. WQ0029945 ) CASE NO. LV-2019-0341
Having been assessed civil penalties totaling $578.63 for violation(s) as set forth in the assessment document of the Division
of Water Resources dated December 18, 2019, 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 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 the
notice of assessment.
fx This the �3� day of J'9nJU'4/z1e , 20 ZO
SIGNATURE
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ADDRESS
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TELEPHONE
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REc.PuvED
NCDLQ/D'WR
17 AN 2020
Non -Discharge
Permitting Unit

.Docu&gn Envelope ID: 8D37B6BA-E173-4C71-9743-CA55300D3929
JUSTIFICATION FOR REMISSION REQUEST
Case Number: LV-2019-0341 County: Onslow
Assessed Party: Onslow Water and Sewer Authority
Permit No.: WQ0029945 Amount Assessed: $578.63
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 maybe 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);
X(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 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:
`.SE-e- ATTAGHie'O A1A-fZRP-T7V5- Apil>
RECEIVED
17 .'AN 2020
Non -Discharge
Permitting Unit

Case Number: LV-2019-0341
Assessed Party: Onslow Water and Sewer Authority
Permit Number: WQ0029945
County: Onslow
Amount Assessed: $578.63
EXPLANATION
The Onslow Water and Sewer Authority (ONWASA) hereby requests the remission
of civil penalties associated with the Notice of Violation received for August 2019 under
Permit No. WQ0029945 for the Summerhouse Wastewater Reclamation WWTF. While
not disputing the facts associated with this finding, we believe actions taken to identify
and address the causes for exceedance of the daily and monthly limits specified in the
permit, along with the costs already incurred by ONWASA to bring the facility back into
compliance, justify this request.
As noted in prior correspondence with Wilmington Regional Office personnel, we
believe both violations can be attributed to problems with membrane fouling and the
frequent in -place cleaning cycles (as often as every other week) associated with it.
ONWASA paid to have a factory technician come to this facility to review plant operations
and oversee the removal and hand -cleaning of the membrane panel assemblies. A crane
service was also hired to pull and replace the membrane panels. Total costs for this
effort, not including plant personnel and cleaning chemical cost, was $6,700. This work,
along with a modified cleaning procedure, has resulted in greatly improved membrane
performance and a reduction of in -place cleaning cycles to once every three months.
ONWASA Information Technology personnel also made a change to the plant's
SCADA programming to better address the transition to UV disinfection when a treatment
rain is brought on-line, and we have not seen a recurrence of either issue since all work
was completed.
Attached are the following supporting documents:
• Letter to Morella Sanchez -King, NCDEQ - DWR dated November 12, 2019.
• Invoice and purchase order to Evoqua Water Technologies (membrane
supplier).
• Invoice and purchase orders (2) to R&W Construction Company for crane
rental services.