WQCS00025_Remission Request (DV-2022-0045)_20220624

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Water Resources Division y OpRO`,"°R Tel: [phone] Ext. 258
146 N Church Street 45004‘4. �\ o.
PO Box 1106
Asheboro, NC 27204-1106 „cb'' Fax: [phone]
413ER 1�?
June 20, 2022 RECEIVED
JUN 2 4 2022
NCDEQ/D
WR/NPDES
PERCS Unit
Division of Water Resources
1617 Mail Service Center
Raleigh,NC 27699-1617
Re: Request for Remission of Civil Penalties for Case No. DV-2022-045
Dear PERCS Branch Reviewer:
The City of Asheboro respectfully requests remission of the above referenced civil penalty. We understand
that sanitary sewer overflows as a result of inflow and infiltration are not permitted and are violations of our
permit to operate our sanitary sewer system. However, we believe the weather conditions from Winter Storm
Frida that contributed to Incident Numbers 202200011, 202200035, 202200036, and 202200037were
extraordinary in nature and were unavoidable. The intensity of the rainfall for this weather event was not
normal. We received 2.4" of rain over a period of less than four hours. Flash floods were numerous
throughout the area impacting streets and causing many downed trees. In fact, the entire eastern US was
impacted with heavy rain and large amounts of snowfall.
The overall performance of the City of Asheboro sanitary sewer collection system is exemplary. The 2021
System Performance reveals that of the more than 1.4 billion gallons of wastewater treated at the City of
Asheboro WWTP, less than 0.05% was spilled at the plant or in the collection system. Laboratory personnel
sample after every SSO as soon as it is safe to do so. None of the laboratory results attached with this
correspondence reveal significant environmental impact.
The City of Asheboro is committed to protecting the environment and improving wastewater collection
service to customers. We are working from many angles to address issues that will improve the operation of
our collection system. We completed and Asset Inventory and Assessment study of the sewer collection
system in March of this year. The Capital Improvement Plan is currently being updated to address the issues
identified in this final report.
City staff has also been doing extensive flow monitoring in the Lift Station# 6 drainage basin to identify
sources of I & I. This flow study has already identified an outfall line that is scheduled to be repaired with
cured in place lining in the next few weeks. This monitoring along with smoke testing will continue
throughout the basin until all sources of I & I have been identified. We will move to the basin for Lift
Station #4 when this work is complete.
Home of the NC Zoological Park

Sanitary Sewer Overflow Request for Remission
Case No. DV-2022-0045
June 20, 2022
Page 2 of 2
The City of Asheboro requests that the Civil Penalty for this incident should be remitted based the extreme
conditions of this weather event, the negligible environmental impacts and the efforts being made to identify
sources of inflow and infiltration to prevent future events. Please take these efforts into consideration as you
deliberate this matter. The City of Asheboro takes pride in being good stewards of the environment and is
taking measures to ensure water quality in our community. Thank you for your consideration in this matter.
If you have any questions, please contact me at [phone] ext. 258.
Sincerely,
pietcp44 ,9/ _.#0verrvii/
Michael D. Rhoney, P.E.
Water Resources Director
cc: Lon T. Snider, Regional Supervisor
NCDEQ -Division of Water Resources
450 Hanes Mill Rd, Suite 300
Winston-Salem, North Carolina 27105
Enclosures
Home of the NC Zoological Park

JUSTIFICATION FOR REMISSION REQUEST
Case Number: DV-2022-0045 County: Randolph
Assessed Party: City of Asheboro
Permit No.: WQCS00025 Amount Assessed: $3,382.71
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-282.1(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 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 RANDOLPH
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
) STIPULATION OF FACTS
City of Asheboro )
Asheboro Collection System )
)
PERMIT NO. WQCS00025 ) CASE NO. DV-2022-0045
Having been assessed civil penalties totaling$3,382.71 for violation(s)as set forth in the assessment document of the
Division of Water Resources dated May 20,2022,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.
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CITY OF ASHEBORO
WATER QUALITY RESPONSE REPORT
Type of Event I Spill Complaint Overflow Special j
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X
Date Notified: 1-3-22
Time Notified: 10:46 am
Person Notifying Laboratory: Louis Bivens
Laboratory Personnel Responding: Bernadine Wardlaw & Dina Tutterow
Location and Site Information
Manholes on Elm Street and Brewer Street were overflowing due to heavy rain event.
Laboratory Results:
Date Location Time Temp.C pH DO Conductivity NH3
Collected (mg/I) (umhos) (mg/I)
1-3-22 Salisbury Street 11:34 am 11 7.3 8.8 I 81.1 <0.15
(upstream)
1-3-22 Elm Street 11:28 am 11 6.9 10.8 101 1.96
(at-site)
1-3-22 Brewer Street 11:44 am 11 6.9 11.0 53.5 <0.15
(downstream)
1-3-22 Pritchard Street 11:49 am 12 6.6 10.7 73.0 0.38
(downstream 2)
Environmental /Human Impact:
Heavy Rain Event - No environmental impact sighted.
Remarks

CITY OF
ASHEBOpO
NORTH CAROLINA
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CITY OF ASHEBORO
WATER QUALITY RESPONSE REPORT
Type of Event Spill Complaint Overflow Special
X
Date Notified: 1-3-22
Time Notified: 5:36 am
Person Notifying Laboratory: Jeff Cagle
Laboratory Personnel Responding: Bernadine Wardlaw & Dina Tutterow
Location and Site Information
Lift Station #4 overflowed due to heavy rain event.
Laboratory Results:
Date Location Time Temp.C pH DO Conductivity NH3
Collected (mg/I) (umhos) (mg/I)
1-3-22 Lift Station #4 8:52 am 11 6.5 9.9 63.4 <0.15
(upstream)
1-3-22 Lift Station #4 8:50 am 10 6.1 9.9 72.0 <0.15
(at-site)
1-3-22 Lift Station #4 8:51 am 11 6.3 9.9 98.3 <0.15
(downstream)
Environmental /Human Impact:
Heavy Rain Event - No environmental impact sighted.
Remarks

CITY OF Zit
ASHEBOpD
NORTH CAROLINA
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CITY OF ASHEBORO
WATER QUALITY RESPONSE REPORT
Type of Event Spill Complaint Overflow Special
X
Date Notified: 1-3-22
Time Notified: 6:26 am
Person Notifying Laboratory: Jeff Cagle
Laboratory Personnel Responding: Bernadine Wardlaw & Dina Tutterow
Location and Site Information
Lift Station #6 overflowed due to heavy rain event.
Laboratory Results:
Date Location Time Temp.C pH DO Conductivity NH3
Collected (mg/I) (umhos) (mg/I)
1-3-22 Lift Station #6 9:43 am 9 7.1 10.1 72.9 <0.15
(upstream)
1-3-22 Lift Station #6 9:42 am 9 6.8 8.7 119 1.51
(at-site)
1-3-22 Lift Station #6 9:40 am 9 6.8 9.9 58.3 0.16
(downstream)
Environmental /Human Impact:
Heavy Rain Event - No environmental impact sighted.
Remarks

CITY OF
ASHEBOIO
NORTH CAROL MA
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CITY OF ASHEBORO
WATER QUALITY RESPONSE REPORT
Type of Event mill Complaint Overflow Special
X
Date Notified: 1-3-22
Time Notified: 5:36 am
Person Notifying Laboratory: Jeff Cagle
Laboratory Personnel Responding: Bernadine Wardlaw & Dina Tutterow
Location and Site Information
Lift Station #3 overflowed due to heavy rain event.
Laboratory Results:
Date Location Time Temp.C pH DO Conductivity NH3
Collected (mg/I) (umhos) (mg/I)
1-3-22 Lift Station #3 9:08 am 10 6.2 10.0 62.0 <0.15
(upstream)
1-3-22 Lift Station #3 9:12 am 9 6.9 9.9 38.7 <0.15
(at-site)
1-3-22 Lift Station #3 9:22 am 9 7.0 9.7 73.9 <0.15
(downstream)
Environmental /Human Impact:
Heavy Rain Event - No environmental impact sighted.
Remarks