WQCS00010_Remission Request (DV-2021-0138)_20211006

Public Services Department ' -
0
Water & Sewer Mains Division
: Ate,
Michael S. Parrish
ORC WWCS
NORTH CAROLINA'S INTERNATIONAL CITY-
RECEIVED
September 27th, 2021
062021
Attn: PERCS Branch
Division of Water Resources NOD
1617 Mail Service Center
Raleigh, North Carolina 27699
RE: Notice of Violation and Assessment of Civil Penalty
Case No. DV-2021-0138
Incident Number 202101067
03/22/2021
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-2021-0138 that took place at 304 South Scientistic Street 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.
A Crew was onsite of the spill at the above-mentioned address within fifteen minutes of receiving the
call. During that time crews worked to unstop the sewer main using a sewer cleaning truck. It was
determined that the blockage consisted of grease. Once the spill was contained all solids were
removed and lime was spread over the area. The creek was flushed with clean water and monitored for
adverse effects. This line was cleaned and flushed with degreaser afterwards.
This section of main was placed on the Preventive Maintenance (PM) list to be cleaned every other
month. We will continue to monitor this section of line and the sub-basin to ensure the fats, oil, and
grease are properly being addressed.
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,
%7(e Dee S. Pa u t4
Michael S. Parrish
ORC WWCS
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

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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

JUSTIFICATION FOR REMISSION REQUEST
Case Number: DV-2021-0138 County: Guilford
Assessed Party: City of 1-ligh Point
Permit No.: WQCS000I0 Amount Assessed: $889.1 I
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. § I43B-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. I43B-282.1(b)were wrongfully applied to the
detriment of the petitioner(die 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 conk/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'tire civil penalty will prevent you from performing the activities necessary to achieve
corrrpliance).
EXPLANATION:
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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. WQCS000I0 ) CASE NO. DV-2021-0138
Having been assessed civil penalties totaling$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 aq6) 7/4 day of 5. 6 ,20 z I
RE
CENNED SIGNATURE
1 r-c 0 6 2021 ADDRESS
NCDEQID
WRINPDES P. a . 8 - 2SO
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TELEPHONE

ATTACHMENT A
City of High Point
CASE NUMBER: DV-2021-0138
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
202101051 3/17/2021 CSO/SSO(Sewer Overflow) Discharge without valid permit 275 $0 00
202101067 3/22/2021 CSO/SSO(Sewer Overflow) Discharge without valid permit 3,230 $750 00