WQCS00010_Remission Request (DV-2021-0139)_20211006

Public Services Department
r.:a
Water & Sewer Mains Division , 11-7.1,-5,
Michael S. Parrish s ��
ORC WWCS - d
NORTH CAROLINA'S INTERNATIONAL CITY-
September 27th, 2021
Attn: PERCS Branch
RECEIVED
Division of Water Resources (1CT 6 2021
1617 Mail Service Center
Raleigh, North Carolina 27699 NCDEQC/T R/2NPDES
RE: Notice of Violation and Assessment of Civil Penalty
Case No. DV-2021-0139
Incident Number 202101204
04/17/2021
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-2021-0139 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.
I have reviewed the five-day report and would like to submit the following information for clarification for
the extended time of spill. After talking to the crew that responded to the spill, they advised me that
while trying to clear the obstruction there were some issues with locating the manhole due to it being in
a secluded area. Once the manhole was reached, crews flushed. removed, and recovered some
grease. After further investigation it was discovered that there are several apartment complexes near
the blockage. Educational material was handed out as part of our FOG program to ensure they are
properly disposing of fats, oil, and grease.
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,
1/ d aee S. Pavzid
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

2
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-2021-0139
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
202101204 4/17/2021 CSO/SSO(Sewer Overflow) Discharge without valid permit 4,680 $750.00
202101236 4/26/2021 CSO/SSO(Sewer Overflow) Discharge without valid permit 8,680 $0.00

JUSTIFICATION FOR REMISSION REQUEST
•
Case Number: DV-2021-0139 County: Guilford
Assessed Party: City of High Point
Permit No.: WQCS00010 Amount Assessed: $889.1 I
Please nse 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 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 penaltywillprevent payment for the remainin necessaryremedial actions u e, explain
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how payment of the civil penalty will prevent you from om per forming 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-2021-0139
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 a 8 �4 day of 6-G PE"ni i&k_,20 . /
�GNATURE
RECEIVED
ADDRESS
P, O , mar- 236
NCDEQIDWRINPDES iqk pa(tiT' ,UC 272�
TELEPHONE
336- - &3 -32J4