WQCS00203_PC-2020-0003_20200213

I
February 3, 2020 RECEIVED
Wastewater Branch FEB 13 2020
Division of Water Resources
1617 Mail Service Center NCDEQ/DWR/NpDEs
Raleigh, NC 27699-1617
Subject: Remission Request
No. PC-2020-0003
Lake Waccamaw Collection System
Columbus County
Dear Wastewater Branch:
The Town of Lake Waccamaw is in receipt of the Notice of Violation and Assessment of Civil Penalty
dated January 22, 2020. The assessment is for failing to the meet the permit requirement to clean 10%
of the sewer system on an annual basis. The Town would like to offer the following comments regarding
the violation and civil penalty:
• During the time period involved, there was a significant amount of staffing change. The Town
Manager and finance officer positions were vacant. The Town had an interim manager for
several months, one staff member was transferred to the wastewater treatment plant to
prepare for the upcoming retirement of the operator-in-responsible-charge (ORC), and there
were ongoing vacancies in Public Works.
• The Collection System ORC had requested a sewer cleaning machine (jetter) be included in the
budget for several years. The request was always denied until a new manager was hired. The
jetter was purchased and the Town took delivery in July 2019. The cost of_the jetter was
approximately$32,400.00.
• Town staff started using the jetter to clean lines but staffing issues and training prevented the
cleaning of the full 10%.
• The Town has rehabilitated or replaced sewer lines during the past five years at a cost of
approximately 1,000,018 dollars.
• Except for hurricane events,the Town has had no reportable sanitary sewer overflows.
• The Town has not experienced any sewer main blockages in the last five years.
• The Town is now fully aware of the cleaning requirement and the cleaning will be achieved with
in-house resources or contracted out.
The Town sincerely regrets that we failed to clean the sewer lines as required in our operational report. .
But we are happy to note, that there was no failure of the collection system, nor sanitary sewer
overflows as a result of the noncompliance.
Sincerely,g�
,�drA,GUAR/
Gordan Hargrove,Town Manager
Town of Lake Waccamaw

DocuSign Envelope ID: B9ED6AEB-D061-44E9-9207-E73A2B51EC6E
ti
STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
COUNTY OF COLUMBUS
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
) STIPULATION OF FACTS
Town of Lake Waccamaw )
Lake Waccamaw Collection System )
)
PERMIT NO. WQCS00203 ) CASE NO. PC-2020-0003
Having been assessed civil penalties totaling$2,436.75 for violation(s)as set forth in the assessment document of the
Division of Water Resources dated January 22,2020,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. y�--
This the �� �� day of i-lArt P ,20
4P/C167-n C‘41fArtoi,cp
RECEIVED SIGNATURE
FEB 13 2020 ADDRESS
•
NCDEQ/DWR/NPDES a05 �'lervtrn�rt�4on 1Drive.
L-61 & iAlaccamaW , c- a8ySo
TELEPHONE
@10') - Cry 6 - 3900

DocuSign Envelope ID:B9ED6AEB-D061-44E9-9207-E73A2B51 EC6E •
JUSTIFICATION FOR REMISSION REQUEST
Case Number: PC-2020-0003 County: Columbus
Assessed Party: Town of Lake Waccamaw
Permit No.: WQCS00203 Amount Assessed: $2,436.75
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: