NC0035866_Remission Request_20180906

JUSTIFICATION FOR REMISSION REQUEST RECEIVED/DENR/DWR
SEP. 0 7 2018
Case Number: LV-2018-0190 County: Chatham Water Resources
Assessed Party: Chatham County Permitting Section
Permit No.: NC0035866 Amount Assessed: $137.78
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 preventfuture occurrences);
L/ (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:
sEe ,TTA cRet LETTEt.

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
COUNTY OF CHATHAM
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
) STIPULATION OF FACTS
Chatham County )
Bynum WWTP )
)
PERMIT NO.NC0035866 ) CASE NO. LV-2018-0190
Having been assessed civil penalties totaling$137.78 for violation(s) as set forth in the assessment document of the Division
of Water Resources dated August 07, 2018,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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SIGNAT ' . li
ADDRESS
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TELEPHONE
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CHATHAM COUNTY PUBLIC UTILITIES & WATER
UTILITIES—Public Works Division tzopM C�G*Y). Phone: [phone]
• Maintenance&Construction ""�"°"��'�p• Fax: [phone]
• Water Treatment Plant i' 'i toy
• Wastewater Treatment Plant i/ �iIA
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• Billing&Collections 1.A� 1"'j ��1� /i
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ry�41H CAROkw
POST OFFICE BOX 910
PITTSBORO,N.C.27312-0910
September 4, 2018
Wastewater Branch
Division of Water Resources,NCDEQ
1617 Mail Service Center, Raleigh,NC 27699-1617
Subject: Notice of Violation(NOV) and Assessment of Civil Penalty for
Violations of NC General Statute (G.S.) 143-215.1 (a)(6) and
NPDES WW Permit No.NC0035866
Bynum WWTP
Case No. LV-2018-0190
Chatham County
This letter is in response to the Notice of Violation(NOV) and Assessment of Civil Penalty for
Violations of NC General Statute(G.S.) 143-215.1 (a)(6) and NPDES WW Permit No.
NC0035866, Bynum WWTP, Case No. LV-2018-0190 dated August 7, 2018 that our office
received the week of August 13, 2018.
The Fecal Coliform was sampled on 1/09/2018 and was out of compliance (870#/100ML). The
Fecal Coliform samples before and after that date returned to levels less than 1.0#/100ML. This
incident the county experienced was in direct relation to a November 2017 sample that was out
of compliance on 11/21/2017 with a Fecal Coliform level of 1,600#/100ML (shown on
November 2017's Discharge Monitoring Report). A new bucket of chlorine tablets purchased
through Promag Enviro Systems (British Columbia, Canada) was opened and being used prior to
the two non-compliance sample dates. The county determined it could be a bad batch of the
chlorine tablets. The tablets were dissolving at a very slow rate. The county opened a new
bucket and stop using the bad batch of chlorine tablets. The Fecal Coliform sampling results
have been less than 1#/100ML since disposing of the bad batch of chlorine tablets. As a
precaution the county hired Clark's Septic Service to pump out the basins and the Aerobic
Digester and reseeded the plant with healthy microorganisms from the Town of Siler City's
WWTP. We also re-trained our sampling staff on proper sampling procedures to minimize the
risk of outside contamination during the acquisition of the effluent samples.

CHATHAM COUNTY PUBLIC UTILITIES & WATER
UTILITIES—Public Works Division d►P0? C9,„64),, Phone: [phone]
• Maintenance&Construction =j'"""�°"'s �'�p Fax: [phone]
• Water Treatment Plant (ti;�''�`�
• Wastewater Treatment Plant �' ;�"_ _ 05.
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• Billing&Collections ���, 1"' /i
We�H CARO'
POST OFFICE BOX 910
PITTSBORO,N C 27312-0910
Chatham County's mission and goal is to properly and successfully treat the wastewater that
enters our Bynum WWTP and to stay in compliance with the rules and regulations set forth by
NCDEQ. Through continual evaluation and improvement of our standard operating procedures
and best management practices the County will strive to consistently achieve this goal. Thank
you for your time.
Chatham County respectfully requests that any civil penalty be remitted due to the error in
manufacturing of the chlorine tablets.
Sincerel
I
p raA
Larry Bridges
Public Utilities Director

P.O.Box 308
POKE R9,, 1000 Jackson Street
♦d
Roanoke Rapids,NC 27870
CR r.11 Roanoke Rapids Sanitary District [phone]
9 v
Fax: [phone]
�f�9Ry D1S/�4, www.rrsd.org
September 5,2018
RECEIVED/DENR/DWR
Ms. Teresa Rodriguez SER 0 7 2018
NC DENR,Division of Water Quality,NPDES Unit Water
1617 Mail Service Center . 0Sources
Raleigh,North Carolina, 27699-1617 Perm�tt�ng Section
RE: Permittee Comments on Draft NPDES Permit Number NC0024201
Roanoke River Waste Treatment Plant(WWTP)
Dear Ms.Rodriguez,
The Roanoke Rapids Sanitary District(RRSD)received the draft National Pollutant Discharge
Elimination System(NPDES)permit for its referenced treatment unit on August 17, 2018. Per the cover
letter from the Division of Environmental Quality(DEQ)Division of Water Resources (DWR)NPDES
Unit,we have 30 days from receipt of the draft permit to submit comments to DWR. We respectfully
request that the following changes be made to our permit:
1. We noticed several inconsistencies in our Fact Sheet that require correction,as follows:
a. On page 1,the Fact Sheet incorrectly states that we have two significant
industrial users(SIUs)and one non-categorical user.We have one SIU and two
categorical industrial users(CIUs).
b. In Section 3 Table 1 and Section 12 Table 3,the Fact Sheet references a
dissolved oxygen(DO) limit of 5 mg/L. Our permit does not require a permit
limit for DO. We are required to monitor for DO.
c. In section 5 Compliance Summary the NOV's are not distinguished between
weekly and monthly.
d. On page 5 of 8 and page 8 of 8 in Section 12 Table 3,the proposed effluent
chronic toxicity requirement is specified at 90 percent effluent. Our toxicity
requirement is at 1.1 percent effluent.
2. A typo in our permit cover letter applicant address delayed its postal delivery.The correct
address is P.O.Box 308,Roanoke Rapids,NC,27870. The Fact Sheet correctly specifies
the applicant and facility addresses.
3. Since our NPDES renewal application was submitted in September 2016,we have
determined that our downstream sampling location is not a safe location for our staff at
low flows. We request that the sampling location be moved to 1090 Rockfish Lane in
Weldon,NC in lieu of the current Weldon sampling location at 419 River Road. Our
proposed sampling location remains downstream of our outfall and also the US 158/301
bridge crossing the Roanoke River.

4. In Section A. (3)of the permit,DEQ has specified that the effluent priority pollutant
scans be conducted in 2019,2020, and 2021.Due to the uncertainty associated with the
timing of this next 5-year permit cycle,we have already conducted a pollutant scan in
2018.We request that DEQ modify the timing of the effluent pollutant scans to 2018,
2020,and 2021.
We very much appreciate the time and effort of the NPDES Unit to consider our requests for
modification of our Draft Permit and Fact Sheet. Please do not hesitate to call myself(252-537-9137)or
Mary Sadler with Hazen and Sawyer(919-755-8560) if you have any questions.
Sincerely,
Roanoke Rapids Sanitary District
1 ::,)a.o..3,
R. Danieley Brow .E.
Chief Executive Officer
cc: Steven Ellis, ORC RRSD Wastewater Treatment Plant
Isabelle Wilcoxin,Laboratory Manager Wastewater Treatment Plant
Gregg Camp, Wastewater Treatment Plant
Mary Sadler,PE,Hazen and Sawyer