WQCS00010_Remission Request (DV-2021-0137)_20211006

Public Services Department ;i
Water & Sewer Mains Division
s„„ HIGH ,Michael S. Parrish
ORC WWCS
NORTH CAROLINA'S INTERNATIONAL CITY-
September 27th, 2021
Attn: PERCS Branch
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699
RE: Notice of Violation and Assessment of Civil Penalty
Case No. DV-2021-0137
Incident Number 202100844
02/22/2021
Mr. Snider,
We are writing in response to your letter dated August 31st, 2021 Notice of Violation and Assessment
of Civil Penalty Case No.: DV-2021-0137 and would like to provide justification as to why a civil penalty
of any amount would impede our efforts to better the City of High Point collection system.
The above overflow was caused by grease in the line hindering the flow from exiting the invert. Once
the crews cleared the blockage the flow returned to normal. This line was cleaned to prevent any future
issues. The frequency of monitoring has been increased now that we are aware of this issue. There is a
a large private neighborhood / apartment complex that we believe caused the overflow. There hasn't
been an issue in this area in the past, Due to the pandemic, we have noticed more activity during the
day which has contributed to more grease to the Publicly Owned Treatment Works (POTW). We
handed out FOG doorhangers to educate the public in grease awareness and prevention. Since this
incident, we have not had any further issues in this area.
We respectfully request that a monetary fine not be imposed on the City of High Point so that we may
continue to better our collection system for the community of High Point.
If you have any questions or require further information, please feel free to call me at [phone].
Sincerely,
//( e ee S. Pavza
Michael S. Parrish
ORC WWCS
cc: Terry Houk- Public Services Director, Derrick Boone-Assistant Public Services Director, Joseph Holden-
W/S Mains Superintendent, Carrie Hyler-Pretreatment Supervisor, File
City of High Point, P.O. 230, 211 South Hamilton Street, High Point, NC 27261 USA
Office: 336-883-3691 Fax: [phone] TDD 336.883.8517

ATTACHMENT A
City of High Point
CASE NUMBER: DV-2021-0137
PERMIT NO: WQCS00010 REGION: Winston-Salem
FACILITY: High Point Collection System COUNTY: Guilford
Other Violations
INCIDENT VIOLATION TOTAL VOLUME PENALTY
NUMBER DATE VIOLATION TYPE VIOLATION DESCRIPTION (GALLONS) AMOUNT
202100706 2/19/2021 CSO/SSO(Sewer Overflow) Discharge without valid permit 3,600 $500.00
202100844 2/22/2021 CSO/SSO(Sewer Overflow) Discharge without valid permit 12,900 $1,250.00

JUSTIFICATION FOR REMISSION REQUEST
Case Number: DV-2021-0137 County: Guilford
Assessed Party: City of High Point
Permit No.: WQCS00010 Amount Assessed: $1,889.11
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.l(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 look 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:

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
City of High Point )
High Point Collection System )
)
PERMIT NO. WQCS00010 ) CASE NO. DV-2021-0137
Having been assessed civil penalties totaling$1,889.11 for violation(s)as set forth in the assessment document of the
Division of Water Resources dated August 27,2021,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.
This the /j` day of SG P7 SGk- ,20 Z
RECEIVED
I NAA TURE
0 6 2021
ADDRESS
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TELEPHONE
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