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HomeMy WebLinkAboutWQCS00010_DV20210137_Response_20210927Public Services Department Water & Sewer Mains Division Michael S. Parrish ORC WWCS September 27th, 2021 Lon T Snider NCDENR Winston — Salem Regional Office 450 West Hanes Mill Road. Suite 300 Winston — Salem NC 27105 RE: Notice of Violation and Assessment of Civil Penalty Case No. DV-2021-0137 Incident Number 202100844 02/22/2021 Mr. Snider, NORTH CAROLLN:A'S INTERNATIONAL CITY" NC Department of Environmental Quality Received SEP 3 0 2021 Winston-Salem t Regional Office 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 (336) 883-3691. Sincerely, , -V 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: 336.822.7071 TDD 336.883.8517 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: 336.822.7071 TDD 336.883.8517 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. § 14313-282.1(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 (1he 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 fernn•e 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 penalo, irillprevent you from performing the activities necessmry 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 a 8 �" j` day of Sc P-72' � t— , 20ZI SIGNATURE ADDRESS (. a k3o k -23o o/c, TELEPHONE 33 6 ` �2l8