NC0007552_Remission Request (LV-2023-0037)_20230306

John Hennessy
Supervisor
Wastewater Branch
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
March 01, 2023
.001
ittnn
NCDEQ/DWR/NPDES
Re: 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. NC0007552
Town of Edenton
Freemason WTP
Case No. LV-2023-0037
Dear Mr. Hennessy,
Please accept this letter and the included attachment(s) as a written request for remission for Case No. LV-
2023-0037. The Town of Edenton first received notice in August of 2022 regarding the exceeded limit for
Chlorides from the Beaver Hill WTP (NC0086291) Since this time the WTP ORC (Roy Alons) & Town
Manager (Corey Gooden) have worked towards developing a corrective action plan for the effluent chloride
exceedance but have exhausted all internal options. We have also reached out for guidance from the
Washington regional office since this time BUT do not see a logical option to meet the 230 mg/I limit within
our water system. We also shared this same sentiment with the NPDES division before the limit came in to
effect on the Towns permit for August 1st 2018 and continue receive no input or advice.
Since the 1" notice in August of 2022, the Town of Edenton sampled all water sources (on 11/09/2022) within
the water system ranging from each of the four (4) raw water well sites, both water treatment plants, and the
open water discharge points. These results are included in Attachment 1— Environment 1 Chloride sample
results, for a total of three (3) pages. Of the Town's four (4) well sites, two (2) were over the 230 mg/1 limit and
the remaining two (2) wells were at 60-72% of the limit. For the WTP site, one was over the limit and one was
70% of the limit. Lastly, when looking at the discharge points upstream and downstream, the open water bodies
are more that 550 to 750% of the limit. Often times the limit appears to be the lowest number in the group,
which creates quite a challenge for us.
Printed on Recycled Paper
P.O. BOX 300, Edenton N.C. 27932 - [phone]
[phone] - FAX

The Town of Edenton was recently awarded funding for two (2) additional well sites and an interconnect
between the two (2) raw water tanks at each plant location. The goal of the project is to improve the raw water
quality of the Town's well site and to use any raw well at either plant. The implementation of these new wells
would greatly increase the water chemistry and quality of our aging system. We know that until that time, we
will likely and often not meet the limit.
In the Interim, The Town of Edenton would like to request that we (1) be considered for a reduced or removed
penalty and, (2) be considered for a permit variance for this often -unreachable limit. We will also continue to
collect additional chloride samples for Filberts creek and Edenton bay. We have also requested for Oral
Presentation to the Environmental Management Commission for this abundance of unobtainable violations and
will continue to do so with each new NOV that is not remised.
Sin ly, -
Co an Goo
T Manager
Cc: Julie Grzyb, Deputy Director of DEQ Division of Water Resources
Robert Tankard, Assistant Supervisor, Division of Water Resources, DEQ
Sarah Toppen - Environmental Specialist II, Division of Water Resources, DEQ
Robbie Bullock - Environmental Specialist Il WWTP Consultant, Division of Water Resources, DEQ
David Meyers, Edenton PW Director
Roy Alons, Edenton WTP Supervisor

JUSTIFICATION FOR REMISSION RE UEST
Case Number:
LV-2023-0037
Assessed Party:
Town of Edenton
Permit No.:
NC0007552
County: Chowan
Amount Assessed: 8$ 22.50
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);
t (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:
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NC®EQ/D N R/N1 DES

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
COUNTY OF CHOWAN
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
Town of Edenton )
Freemason WTP )
PERMIT NO. NC0007552 ) CASE NO. LV-2023-0037
Having been assessed civil penalties totaling 8$ 22.50 for violation(s) as set forth in the assessment document of the Division
of Water Resources dated February 06.2023, 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
day of Alt 4
SIGNA URE
r
— tt� )RESS
TELEPH ONE
EZ 36t - S 30�
20 23

PERMIT: NC0007552
FACILITY: Freemason WTP
LIMIT VIOLATION(S)
SAMPLE LOCATION: Outfall 001 - Effluent
Violation Report
Date Month/Yr Parameter
9/14/2022 9-2022 Chloride (as Cl)
9/30/2022 9-2022 Chloride (as Cl)
ATTACHMENT A
Town of Edenton
CASE NUMBER: LV-2023-0037
REGION: Washington
COUNTY: Chowan
Unit of
Limit
Calculated % Over
Violation
Frequency Measure
Value
Value Limit
Type
Monthly mg/I
230
1,610 600.0
Daily
Maximum
Exceeded
Monthly mg/I
230
1,610 600.0
Monthly
Average
Exceeded
Penalty
Amount
$200.00
W---

EAmmufflM % hmpTOod
114 0AKMONT DRNE
GREENVILLE, N.C. 27858
TOWN OF EDENTON
MR. ANTHONY JORDAN
PUBLIC WORKS DEPARTMENT
P.O. BOX 300
EDENTON, NC 27932
"Mut4waeer TPI 10
PHONE [phone]
FAX [phone]
ID#: 58 Z
DATE COLLECTED: 11/09/22
DATE REPORTED : 11/16/22
REVIEWED BY:
Sample Sample Sample Sample Sample Analysis Method
PARAMETERS #1 #2 #3 #4 #5 Date Analyst Code
Chloride, mg/l 291 406 139 167 1730 11/14122 JDJ 4500CLB-11

'EH'A' mmum % kwundsd
114 OAKMONT ©(RIVL
GREENVILLE, N.C. 27858
TOWN 08 EDENTON
MR. ANTHONY JORDAN
PUBLIC WORKS DEPARTMENT
P.D. BOX 300
EDENTON, NC 27932
PARAMETERS
Sample
#6
Chloride, mg/1 1270
PHONE [phone]
FAX [phone]
ID#: 58 Z
DATE COLLECTED: 11/09/22
DATE REPORTED : 11/16/22
REVIEWED BY:
Sample Sample Analysis Method
#7 #8 Date Analyst Code
327 163 11/14/22 JDJ 4500CLB-11

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