NC0073571_Remission Request (LV-2021-0275)_20211203

November 29,2021
Lon T. Snider,Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources,NCDEQ
Subject: Notice of Violation and Assessment of Civil Penalty
for Violations of North Carolina General Statute(G.S.) 143-215.1(a)(6)
and NPDES WW Permit No.NC0073571 RECEIVED
Mervyn R King
Countryside Manor WWTP DEC, 0-a 2021
Case. No LV-2021-0275
Guilford County NCDEQIDWRINPDtS
Mr. Snider,
Thank you for allowing Countryside Manor the opportunity to respond to the following Notice of Violation and
Assessment of Civil Penalty. This response pertains to the (1)TSS daily maximum exceedance and(1)ammonia
nitrogen monthly average exceedance events that occurred during the April 2021 monitoring period.
During the April 2021 period,the Ammonia Nitrogen monthly average reached a monthly average of 13.85 mg/L,
exceeding the permitted monthly average limit value of 5.4 mg/L. None of the(4)individual Ammonia Nitrogen
samples taken during this period exceeded the daily maximum,however,the calculated total average was enough
to exceed the limit value as indicated in the permit.A trending increase in pH levels during this period had
impacted adequate ammonia nitrogen removal.The facility has historically applied soda ash to control pH,
therefore upon identification of this issue,the application of soda ash has since been adjusted, and additional pH
monitoring has been conducted as a process control measure.
In addition,the plant experienced a TSS daily max exceedance event on 4/21. At this time,a faster than average
accumulation of solids resulted in the above exceedance event,requiring that the operator make arrangements to
expedite sludge hauling.Operators responded by coordinating sludge removal, and the plant was pumped down
on 4/23. However,this time-lapse prior to the arrival of the pump truck enabled solids to temporarily leave the
effluent. The plant is currently on a routine sludge hauling schedule,taking place once every 2-4 weeks as needed.
Compliance was restored once the sludge hauling was completed,and no further non-compliance events occurred
for the remainder of the month.Outside of the above exceedance event,the rest of the TSS results for the April
2021 period were compliant.
It is always the goal of Countryside Manor to remain in compliance with regulations set forth by the Division of
Water Resources. It is our request that our cooperation and action in these matters be taken into account by the
Division when proceeding with enforcement.
Sincerely,
Todd Nunn
Countryside Manor
CC:
Josh Powers,Envirolink
Todd Robinson,Envirolink
Ronald Wall,Envirolink

JUSTIFICATION FOR REMISSION REQUEST
Case Number: LV-2021-0275 County: Guilford
Assessed Party: Mervyn R King
Permit No.: NC0073571 Amount Assessed: $419.11
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 yoir 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);
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);
X (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:
During the April 2021 period, the Ammonia Nitrogen monthly average reached a monthly average of 13.85 mg/
L, exceeding the permitted monthly average limit value of 5.4 mg/L. None of the (4) individual Ammonia Nitrog
en samples taken during this period exceeded the daily maximum, however, the calculated total average was
enough to exceed the limit value as indicated in the permit. A trending increase in pH levels during this period
had impacted adequate ammonia nitrogen removal. The facility has historically applied soda ash to control pH,
therefore upon identification of this issue, the application of soda ash has since been adjusted, and additional
pH monitoring has been conducted as a process control measure.
In addition, the plant experienced a TSS daily max exceedance event on 4/21. At this time, a faster than
average accumulation of solids resulted in the above exceedance event, requiring that the operator make
arrangements to expedite sludge hauling. Operators responded by coordinating sludge removal, and the plant
was pumped down on 4/23. However, this time-lapse prior to the arrival of the pump truck enabled solids to
temporarily leave the effluent. The plant is currently on a routine sludge hauling schedule, taking place once
every 2-4 weeks as needed. Compliance was restored once the sludge hauling was completed, and no further
non-compliance events occurred for the remainder of the month. Outside of the above exceedance event, the
rest of the TSS results for the April 2021 period were compliant.

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 � STIPULATIONTOF FACTIVE S�G��CEIVED
Mervyn R King ) 0+ 2021
Countryside Manor WWTP ) r
PERMIT NO.NC0073571 ) CASE NO. LV-2021-0275 NCDEQIDWRINPDtS
Having been assessed civil penalties totaling$419.1 I for violation(s)as set forth in the assessment document of the Division
of Water Resources dated October 14,2021,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 Z e' day of N ovcmb,'( ,20Z1
SIGNATURE
ADDRESS
-7-1 O O US t1tc�\t,wo►\/ 152
S-bv•c,s daft NC 27 3 S1
TELEPHONE
33la - 3-63Ot

ATTACHMENT A
Mervyn R King
CASE NUMBER: LV-2021-0275
PERMIT: NC0073571 REGION: Winston-Salem
FACILITY: Countryside Manor WWTP COUNTY: Guilford
LIMIT VIOLATION(S)
SAMPLE LOCATION: Outfall 001 -Effluent
Violation Report Unit of Limit Calculated %Over Violation Penalty
Date Month/Yr Parameter Frequency Measure Value Value Limit Type Amount
4/30/2021 4-2021 Nitrogen, Ammonia Weekly mg/I 5 40 13 85 156.5 Monthly $300.00
Total (as N) - Average
Concentration Exceeded
4/21/2021 4-2021 Solids, Total Weekly mg/I 45 66 46.7 Daily $0.00
Suspended- Maximum
Concentration Exceeded