WQCS00010_DV20210139_Response_20210927

Public 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-2021-0139
Incident Number 202101204
04/17/2021
Mr. Snider,
NORTH CAROLINA'S INTERNATIONAL CITY'
NC Department of 7
Environmental QUality
IReceived
OCT 01 2021
Winston-Salem
Regional Office
We are writing in response to your letter dated August 31 st, 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.
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,
Michael S. Parrish
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

ORC WWCS
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

Case Number: DV-2021-0139
JUSTIFICATION FOR REMISSION REQUEST
County: Guilford
Assessed Party: City of High Point
Permit No.: WQCS00010 Amount Assessed: $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 Nearing, 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. 14313-282. 1 (b) were wrongfully applied to the
detriment of the petitioner (the assessment factws are listed in the civil penally assessment document);
it (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 firture occurrences);
(c) the violation was inadvertent or a result of an accident (Le., explain why the violation was unavoidable or
something you could not prevent or prepare fou);
(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
horn payment ofthe civil penalty will prevent youfrom performing lire activities necessary to achieve
compliance).
EXPLANATION:

STATE OF NORTH CAROLINA
COUNTY OF GUILFORD
IN THE MATTER OF ASSESSMENT
OF CIVIL PENALTIES AGAINST
City of High Point
High Point Collection System
PERMIT NO. WQCS00010
DEPARTMENT OF ENVIRONMENTAL QUALITY
WAIVER OF RIGHT TO AN
ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
CASE NO. DV-2021-0139
Having been assessed civil penalties totaling $889.11 for violation(s) as set forth in the assessment document of the Division
of Water Resources dated August 27. 2021, the undersigned, desiring to seek remission of the civil penalty, does hereby
waive the right to an administrative hearing in the above -stated matter and does stipulate that the facts are as alleged in the
assessment document. The undersigned further understands that all evidence presented in support of remission of this civil
penalty must be submitted to the Director of the Division of Water Resources within thirty (30) days of receipt of the notice
of assessment. No new evidence in support of a remission request will be allowed after (30) days from the receipt of the
notice of assessment.
This the a$ A day of 5c7/DTGn qj�c� , 20 2.1
-Z.
SIGNATURE
ADDRESS
TELEPHONE
336- 883-32 /