NC0085928_Enforcement_20171025

Water Resources
ENV?gONMENTAL OUALUTY
March 07, 2018
John Gugliehnctti
Arnencan Truetzscher Inc
PO Box 669228
Charlotte, NC 28266-9228
Subject. Payment Ac ao rled ,ement
Civil Penalty Assessment.
Truetzschler reinediatron site
County Mecklenburg
Permit NC0085928
Case No. MV-2017-0019
Dear Mr Guglielmetti;
ROY COOPER
Cam°ter
hCHAEL Sa REGAN
Secret
1VDA CULPEPPER.
Interim Director
This letter is to acknowledge receipt of Check No. 136758 in the amount of $103.29 received from you dated
3/1/2018. This payment satisfies in full the civil assessment levied against the subject factfity and this case has been
closed. Payment of this penalty in no way precludes future action by this Division for additional violations of the
applicable statutes, regulations, or permits
If you have any yuestrrans, please call Wren Thedford 919-807-6397..
Sincerely,
Wren Thedford
Administrative Assistant
- 1111110 I.t,: n,apv.,.,,,ft,,, ersv..4e,,,

Water Resources
Environmental Quality
February 1, 2018
CERTIFIED MAIL 7t1!13 2260 0005 538Q Sri07
RETURN RECEIPT REQUESTED
Mr. John Guglielmetti
American Truetzschler, Inc.
PO Box 669228
Charlotte, NC 28266
Subject:
Dear Mr. Guglielmetti:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Interim Director
Request tin Remit Civil Penalties
Decision in Case Number: MV-201.7-0ti19
Truetzschler reinediation site
NPDES Permit NC0085928
Mecklenburg County
In accordance with North Carolina General. Statute 143-215.6A.(f), the Director of the North Carolina
Division of Water Resources (the Director) has reviewed your information submitted in. support of
your request to remit civil penalties in the subject case ($283.00 + $103,29 investigative costs)
totaling $386,29.
The Director has granted full remission in this case, exceptfor investigative costs (see attached
decision farm), Therefore, your outstanding balance totals $103.29. Two options are available to you
at this stage of the remission process:
1) You may pay this balance.
If you decide to pay the penalty, please make your check payable to the Department of Environmental
Quality (DEQ). Send the payment„ within thirty (30) calendar days of receiving this letter, to the
attention of:
Wren Thredford
Division of Water Resources
WQ Permitting Section - NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
OR
Stare of North Carolina E xa it�rnmenttar i uatit
tat Setvir Cent r Raleigh,, North Carolina 276 - i 617
919-707-9000

Mr, Guglielmetti
February 1, 2018
Page .2 of 2
2) You may request the Environmental Management Commission's (EMC's)
Committee on Civil Penalty Remissions (the Committee) to make the final
decision on your remission request considering your additional oral input, as
warranted,
If payment is not received ithin30ca1endas from you receiving this letter, your current request
for remission, with its supporting documents and the Director's attached recommendation, will be
delivered to the Committee on Civil Penalty Remissions for final agency decision.
If you or your representative would like to speak before the Committee, you must completeand return
the attached Requestfor Oral Presentation Form within thirty (30) calendar days of receiving this
letter. Send completed form(s) to:
Wren Thredford.
Division of Water Resources
WQ Permitting Section - NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
If you make such a request., the EMC Ch.ainrian will review the supporting documents and your
request for an oral presentation, if, in his/her judgment, the Chairman determines that there is
compelling reason to require a presentation, you will be notified as to when and where you should
appear. If your presentation is not required, the final decision will be based upon the written record.
Please be advised that the .ENIC's Committee on Civil Penalty Remissions will make its remission.
decision based on the original assessment amount, Therefore, the EMC may choose to uphold the
original penalty and offer no remission, they may agree with the DWR Director's remission
recommendation detailed above, or the penalty amount may be further remitted.
Thankyou for your cooperation in this matter. If you have any questions, please contact Derek
Denard at derek,denard(aIncdenr,gov or call 9.19-807-6307„
Sincerely,
Derek Denard, Environmental Specialist
Compliance &. Expedited Permitting Unit
Division of Water Resources, NCDEQ
Attachments: Director's Decision; Request for Oral Presentation form
cc: Enforcement File
NPDES Program Files
C7entrai Files
4."404144AATIV

DWR SIGNATURE PAGE
SUMS1ARY OF REMISSION FACTORS FOR ASSESSING CIVIL PENALTIES
Case Number: MV-2017-0019 Region: Mooresville
Assessed Entity:
County: Mecklenburg
American Truetzschler, Inc. Permit No.: NC0085928
Assessment Factors
Whether one or more of the civil penalty assessment factors were wrongly applied to the detriment
of the petitioner:
NOT ASSERTED -- Not Applicable,
El (b) Whether the violator promptly abated continuing enviroumentai damage resulting from the
violation:
NOT ASSERTED Not Applicable.
(c)
ether the violation was inadvertent or a result of an accident:
The permittee asserts that the sampling did not occur for the month because of freezing temperatures that froze
and burst waterlines in their remediation system.
DWR Notes: The permittee did not respond to the NOV. The perrnittee fixed the piping by the end of the mont
The permittee has not missed sampling since this occurred.
Ei (d) Whether the violator had been assessed civil penalties for any previous violations:
NOT ASSERTED -- Not Applicable.
El (e) Whether payment of the civil penalty will prevent payment for the remaining necessary remedial
actions:
NOT ASSERTED — Not Applicable.
DECISION (Check One)
Request Denied El
Full Remission Retain Enforcement Cost?
Partial Remission EJ $

STATE OF NORTH CAROLINA
COUN-FY OF MECKLENBURG
IN THE M./VITER OF ASSESSMENT
OF CIVIL PENALTIES .AGAINST:
AMERICAN TRUETZSCHLER, INC,
ENVIRONMENTAL MANAGEMENT
COMMISSION
DWR Case Number MV-2017-00119
REQUEST FOR ORAL PRESENTATION
I hereby request to make an oral presentation before the Environmental Management Commission's Committee On Civil Penalty
Remissions in the matter of the case noted above. In making this request, I assert that I understand all of the following statements:
This request will be reviewed by the Chairnian of the Enviromnental Management Commission and may be either granted or
denied,
Making a presentation will require the presence of n yself andlor my representative during a Committee meeting held in. Raleigh,
North Carolina.
• My presentation will be. limited to discussioi of issues and information submitted in my original re!nission request, and because
no factual issues are in dispute, my presentation will be limited to five (5) minutes in length.
The North Carolina State Bar's Authorized Practice of Law Committee has .ruled that the appearance in a representative capacity at
quasi-judicial hearings or proceedings is limited to lawyers who are active members. of the bar. Proce-edings before the Committee on
Remissions are quasi-judicial, You should consider how you intend to present your case to the Committee in light .of the State Bar's
opinion and whether anyone will be speaking in a .representative capacity for you or a business or governmental entity. If you or your
representative would like to speak before the Committee, you must complete and return this form within thirty (30) days of receipt of
this lener.
Depending on your status as an individual, corporation, partnership or municipality, the State Bar's Opinion affects how you may
proceed with your oral presentation, See www.ncbar.com/ethics, Authorized Practice Advisory Opinion 2006-1 and 2007 Formal
Ethics Opinion 3.
If you are an individual or business owner and are granted an opportunity to make an oral presentation before the Committee,
then you do not need legal representation before the Committee; however, ifyou intend on havin.ganother individual speak
on your behalf regarding the factual situations, such as an expert, engineer or consultant, then you must .also be present at the
meeting in order to avoid violating the State Bar's Opmion on the unauthorized practice of law.
• If you are a co. municipality and are granted an opportunity to make an oral presentation before the
('ommittee, then your representative must consider the recent State Bar's Opinion and could be considered practicing law
without a license if he or she is not a licensed attorney. Presentation of facts by non -lawyers is permissible,
If you choose to request an oral presentation, please make sure that signatures on the previously submitted Remission Request form
and this Oral Presentation Request form are: 1) for individuals and business owners, your own signature and 2) for corporations,
partnerships and municipalities, signed by individuals who would not violate the State Bar's Opinion on the unauthorized practice of
law„
Also, be advised that the Committee on Civil Penalty Remissions may choose not to proceed .with hearing your case if the Committee
is informed that a potential violation of the statute concerning the authorized practice of Task! has occurred.
This the day of 20
SIGNATURE:
TITI„E (President, Owner, etc.)
ADDRESS
TELEPHONE (

Water Resources
En virontnental Quality
November 30, 2017
Mr, John Guglielmetti
American Truetzschler, Inc.
PO Box 669228
Charlotte, NC 28266
Subject: Remission Request of Civil Penalty Assessment
Truetzschler remediation site
NPDES Permit NC00-70.289 S S 1 28
Case Number MV-201 7-00
Mecklenburg County 0 t)
Dear Mr. Guglielmetti:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretory
LINDA CIJLPEPPER
interim Director
This letter is to acknowledge your request for remission of the civil penalty levied against the
subject facility. Your request will be scheduled for review by the Director and you will be
notified of the result
If you have any questions about this matter, please contact me at [phone] or via e-mail at
derek.denard edenr.gov.
Sincerely,
Derek C. C. Denard, Environmental Specialist
Compliance & Expedited Permitting Unit
Division of Water Resources
cc: Enforcement File w/originals
NPDES Program Files
Central Files w/attachments
Mooresville Regional Office w/attachments
State of North Carolina Erv,ironmerital Quality
1611 Mail Set -ice Center 1Raleigh, North Carolina 27699-1611
919-707-9000

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1617 ,rvice Cen.
Raleigh 27699-1617
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12300 °ORES CHAPEL ROAD L P N: 9- 5 1 FAX 7 4-- 4525

STATE OF NORTH CAROLINA
COUNTY OF MECKLENBURG
IN THE MATTER OF ASSESSMENT
OF CIVIL PENALTIES AGAINST
American Truetzschier Inc
Truetzschler remediation site
PERMIT NO. NC0085928
DEPARTMENT OF ENVIRONMENTAL QUALITY
WAIVER OF RIGHT TO AN
ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
CASE NO. MV-2 17-0019
Having been assessed civil penalties totaling $386.29 for violation(s) as set forth in the assessment document of the Division
of Water Resources dated October 25, 2017, 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 (.1.--t day of
, 20 I.
ADDRESS
TELEPHONE
70

JIIFICA1ION FOR REMISSION REQUEST
Case Number: MV-2017-0019
Assessed Party: American Truetzschler Inc
Permit No.: NC0085928
County: Mecklenburg
Amount Assessed: S186.29
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 civi penalty assessment document);
(b) the violator promptly abated continuing environmental damage resulting from the violation expiain the
steps that you took to correct the violation andandpreventjliture occurrences);
(c) the violation was inadvertent or a result ofan 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 preent voufrorn perfi rming the activities )2ecessary to achieve
compliance).
E LANATION:

Water Resources
Environmental Quality
November 0, 2017
Mr. John Guglielmetti
American Truetzschler, Inc.
PO Box 669228
Charlotte, NC 28266
Subject: Remission Request of Civil Penalty Assessment
Truetzschler remediation site
NPDES Permit NC0070289
Case Number MV-2017-00189
Mecklenburg County
Dear Mr. Guglielmetti:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Interim Direcurr
This letter is to acknowledge your request for remission of the civil penalty levied against the
subject facility. Your request will be scheduled for review by the Director and you will be
notified of the result.
If you have any questions about this matter, please contact me at [phone] or via e-mail at
[e-mail].
Sincerely,
Derek C. Denard, Environmental Specialist
Compliance & Expedited Permitting Unit
Division of Water Resources
cc: Enforcement File w/originals
NPDES Program Files
Central Files w/attachments
Mooresville Re onal Office w/attachments
State of North Carolina I Environmental Quality
iit Service Center I Raleigh, North Carolina 27699-161 1
919-707-9000

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P. . BOX 66922 CHARLOTT N C 8266
North C
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Wafer Resources
1617 Mall Service ' nf
Raleigh NC 27 -1617
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STATE OF NORTH CAROLINA
COUNTY OF MECKLENBURG
IN THE MATTER OF ASSESSMENT
OF CIVIL PENALTIES AGAINST
American Truetzschler Inc
Truetzschler remediation site
PERMIT NO. NC0085928
DEPARTMENT OF ENVIRONMENTAL QUALITY
WAIVER OF RIGHT TO AN
ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
CASE NO. MV-2017-0019
Having been assessed civil penalties totaling $386.29 for violation(s) as set forth in the assessment document of the Division
of Water Resources dated October 25, 2017, 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 i.6-tti
day of
ADDRESS
P.c
, 20 L1
TELEPHONE
(9 if 31i • $3

JUSTIFICATION FOR REMISSION REOUEST
Case Number: NW-2017-0019
Assessed Party: American Truetzschler Inc
Permit No.: NC0085928
County: Mecklenburg
Amount Assessed: $386.29
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 enviroamental damage resulting from the violation (i.e., explain the
steps that you took to correct the violation andpreventfuture occurrences);
(c) the violation was inadvertent or a result ofan 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 paytnent 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:

Remissions Meeting February 1, 2018
Raleigh Regional Office
LV-2017-0300 Hawthorne Subdivision WWTP - $1,039.27 ($1,000.00 penalty + $39.27 enforcement)
Fayetteville Regional Office
No remissions to discuss
Wilmington Regional Office
No remissions to discuss
Asheville Regional Office
No remissions to discuss
Mooresville Regional Office
MV-2017-0019 American Truethzschler - $386.29 ($283.00 penalty+ $103.29 enforcement)
Washington Regional Office (Presenting first}
PC-2017-0046 Town of Hertford RLAP $4,067.92 ($4,000.00 penalty + $67.92 enforcement)
Winston-Salem Regional Office
No remissions to discuss

MICHAEL S. REGAN
seartary
S. JAY ZIMMERMAN
Dittetv
Certified Mail #7015 1520 000 6880 3419
Return Receipt Requested
October 2„ 2017
John Guglielmetti.
American Truetzschler Inc
PO Box 669228
Charlotte, NC 28266
SUBJECT: 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. NC0085928
American Truetzschler Inc
Truetzschler remediation site
Case No. MV-2017-0019
Mecklenburg County
Dear Mr. Guglielmefti:
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of $3t16.29 ($283.00 civil penalty +
$103,29 enforcement costs) against American Truetzschler Inc.
This assessment is based upon the following facts: a review has been conducted of the Discharge Monitoring Report
(DMR) submitted by American Truetzschler Inc for the month of January 2017. This review has shown the subject facility
to be in violation of the discharge limitations and/or monitoring requirements found in NPDES WW Permit No. NC0085928.
The violations, which occurred in January 2017, are summarized in Attachment A to this letter.
Based upon the above facts, I conclude as a matter of law that American Truetzschler Inc violated the terms, conditions or
requirements of NPDES WW Permit No. NC0085928 and G.S. 143-215.1(a)(6) in the manner and extent shown in
Attachment A. In accordance with the maximums established by G.S. 143-215.6A(aX2), a civil penalty may be assessed
against any person who violates the terms, conditions or requirements of a permit required by G.S. 143-215.1(a).
Based upon the above findings of fact and conclusions of law, and in accordance with authority provided by the Secretary
of the Department of Environmental Quality and the Director of the Division of Water Resources, I, W. Corey Basinger,
Regional Supervisor, Mooresville Regional Office hereby make the following civil penalty assessment against American
Truetzschler Inc:
State of North Carolina S Environmental Quality Water Resources
610 East Center Avenue, Suite 301, Mooresville, NC 28115
71)4-663-1,699

$43,00 for 1 of the 1 failures to properly monitor 1,1-DCE in violation of Permit No. NC0085928.
$43.00 for 1 of the 1 failures to properly monitor I,1-DCEY in violation of Permit No. NC0085928.
$68.00 for 1 of the 1 failures to properly monitor 1,2-DCE in violation of Permit No. NC0085928.
$43.00 for 1 of the 1 failures to properly monitor 111-TCE in violation of Penit No. NC0085928.
$43.00 for 1 of the 1 failures to properly monitor TCETHYLE in violation of Permit No. NC0085928.
43OO for 1 of the 1 failures to properly monitor TETCLETY in violation of Permit No. NC0085928.
$283.00 TOTAL CIVIL PENALTY
$ I 03.29 Enforcement Costs
$386.29 TOTAL AMOUNT DUE
Pursuant to G.S. 143-215.6A(c), in determining the amount of the penalty 1 have taken into account the Findings of Fact and
Conclusions of Law and the factors set forth at G.S. 143B-282.1(b), which are:
(1) The degree and extent of harm to the natural resources of the State, to the public health, or to private property
resulting from the violation;
(2) The duration and gravity of the violation;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violation was committed, willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs over which the Environmental
Management Commission has 'regulatory authority; and
(8) The cost to the State of the enforcement procedures.
Within thirty (30) days of receipt of this notice, you must do one of the following:
(1) Submit payment of the penalty, OR
(2) Submit a written request for remission, OR
(3) Submit a written request for an administrative hearing
Option 1: Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environmental Quality (do not include waiver
form). Payment of the penalty will not foreclose further enforcement action for any continuing or new violation(s).
Please submit payment to the attention of:
Wastewater Branch
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617

Option 2: Submit a written request for remission or mitigation including a detailed justification for such
request:
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. Because a remission request forecloses the option of an administrative hearing,
such a request must be accompanied by a waiver of your right to an administrative hearing and a stipulation and
agreement that no factual or legal issues are in dispute. Please prepare a detailed statement that establishes why you
believe the civil penalty should be remitted, and submit it to the Division of Water Resources at the address listed below.
In determining whether a remission request will be approved, the following factors shall be considered:
(1) whether one or more of the civil penalty assessment factors in NCGS 143B-282.1(b) was wrongfully
applied to the detriment of the petitioner;
(2) whether the violator promptly abated continuing environmental damage resulting from the violation.
(3) whether the violation was inadvertent or a result of an accident;
(4) whether the violator had been assessed civil penalties for any previous violations; or
(5) whether payment of the civil penalty will prevent payment for the remaining necessary remedial actions.
Please note that all evidence presented in support of your request for remission mustbe submitted in writing. The
Director of the Division of Water Resources will review your evidence and inform you of his decision in the matter of
your remission request. The response will provide details regarding the case status, directions for payment, and
provision for further appeal of the penalty to the Environmental Management Commission's Committee on Civil. Penalty
Remissions (Committee). Please be advised that the Committee cannot consider information that was not part of the
original remission request considered by the Director. Therefore, it is very important that you prepare a complete and
thorough statement in support of your request for remission.
order to re nest remission ou must corn late and submit the enclosed "Re oast for Remission of Civil Penalt
P " irtr ( daysof receipt of this
Waiver of Right to an Administrative Hearing, and Stipulation of Facts form within th" 3©}
notice. The Division of Water Resources also requests that you complete and submit the enclosed "Justification for
Remission Request."
Both forms should be submitted to the following address:
Wastewater Branch
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617

Option 3: File a petition for an administrative hearing with the Office of Administrative Hearings:
If you wish to contest any statement in the attached assessment document you must -file a petition for an administrative
hearing. You may obtain the petition form from the Office of Administrative Hearings. You must file the petition with
the Office of Administrative Hearings within thirty (30) days of receipt of this notice. A petition is considered filed
when it is received in the Office of Administrative Hearings during normal office hours, The Office of Administrative
Hearings accepts filings Monday through Friday between the hours of 8:00 a.m. and 5:00 p.m., except for official state
holidays. The petition may be filed by facsimile (fax) or electronic mail by an attached file (with restrictions) - provided
the signed original, one (1) copy and a filing fee (if a filing fee is required by NCGS §150B-23.2) is received in the
Office of Administrative Hearings within seven (7) business days following the faxed or electronic transmission. You
should contact the Office of Administrative Hearings with all questions regarding the filing fee andior the details of the
filing process.
The mailing address and telephone and fax numbers for the Office of Administrative Hearings are as follows:
6714 Mail Service Center
Raleigh, NC 27699 6.71,4
Tel: [phone]
Fax: [phone]
One (1) copy of the petition must also be served on DEQ as follows:
Mr. William F. Lane, General Counsel
Department of Environmental Quality
1601 Mail Service Center
Raleigh, North Carolina 27699-1601
Please indicate the case number (as found on page one of this letter) on the petition.
Failure to exercise one of die options above within thirty (30) days of receipt of this letter, as evidenced by an internal
date/time received stamp (not a postmark), will result in this matter being referred to the Attorney General's Office for
collection of the penalty through a civil action, Please be advised that additional penalties may be assessed for violations
that occur after the review period of this assessment.
If you have any questions, please contact Wes Bell with the Division of Water Resources staff of the Mooresville Regional
Office at [phone] or via email at wes.bellq-pncdenr,gov,
Sincerely,
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section.
Mooresville Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS
Cc: WQS Mooresville Regional Office - Enforcement File
NPDES Compliance/Enforcement Unit - Enforcement File

JUSTIFICATION FOR
1SSIQi'
ST
Case Number: MV-2017-0019
Assessed Party: American Truetzschler Inc
Permit No.: NC0085928
County: Mecklenburg
Amount Assessed: $386.29
Please use this form when requesting remission of this civil penalty. You must also complete the ".Request For Remission,
Waiver of Right t© 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);
(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
how payment of the civil penalty
compliance).
EXPLANATION:
l prevent payment for the remaining necessary remedial actions (i.e., explain
l prevent you from performing the activities necessary to achieve

STATE OF NORTH CAROLINA DEPARTNIENT OF ENVIRON NTAL QUALITY
COUNTY OF MECKLENBURG
IN THE MATTER OF ASSESSMENT
OF CDTIL, PENALTIES AGAINST
American Truetzs filer Inc
Truetzschler re rn iatitii
PERMIT N. NC0085928
ER OF RIGHTTO AN
IS TWEICE
STIPULATION F FACTS
CASE NO. - 01 -001
Having been assessed civil penalties totaling $386.29 for violation(s) as set forth in the assessassessment document of the Division
of Water Resources dated October 25, 2017, 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 er 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 thir` 0 days of receipt of the notice
of assessment. No new evidence in support of a remission request will he allowed after (0 days from the receipt of the
n tire of sessment.
This the day of
.DI SS
0
TELEPHONE

PERMIT: NC0085928
FACILITY: Tmetzschler remediation SI"
ATTACH
American Try
CASE NU V- 7 1l
REGION: r vllle
Ot1N : Mecklenburg
MONITOR NG VIOLATIONS)
SAMPLE LOCATION: Outten 001 - Eftluent
Violeti n Report
Month/Yr Parameter
17 1-2017
-dichloroothane
Frequency
Unit of t
Measure
d Over
Limit
rnthl
ugll
Violation
Type
Frequency
Violation
Penalty
Amount
12017 1- 017 t-dictlbcreethylene
onthly
ug/I
017 1- 017 ,1-Trichler thane Monthly ugA
7 1-2 '17 1-dichlor thane
Monthly ugt1
Frequency
Violation
Frequency
Violation
17 1-017 Tetrachloroethlene
Monthly ugtl
017 1-017 Trichtor thyl
Monthly udl
Frequency
Violation
Frequency
Violation
Frequency
Violation
.01

DM R REVIEW RECORD
M ooresville Regional Office
Facility Name: Truetzschler remediation site Permit Number: NC0085928
Report Period: January 2©17
Prior Assessments'. Enforcement Factor:
Monitoring Frequency Viol
Sample Location: Outfall 001 - Effluent
Violation
Date
Parameter
Unit of
Frequency Measure
Action
1/31/2017 1,1 dichloraethane
1/31/2017 1,1- d ichloroethyiene
1/31/2017 1„1,1-Trichioroethane
Monthly ugll
Monthly ug/I
Monthly ug/l
1131/2017 1,2-diehhloroethane
2017 Tetrachloroethylene
Monthly ug/t
Monthly ug/9
1/31/2017 Trichtoroethylene
Monthly ug/t
Page 1 of 3

C ?yetby-
A d/ant Regional
u(+% #gn f
R &ip&v
Sign -off
Date ...

Per mtt a 1b : NC0085928
Other VicRation
Sample Loh ion:
Violation Report
Date Period Parar
e
2- ont
h riftar° t H i ory
Violation
"type
NOD
P t P N oci. 2017
NOVCPA
7(8' 016 PerNOV- 017-P 33059
hon
7t8/0 16
Permit conditions
violator
NOV-2 ti 17-R -0059
PaE
or

Wa
AL
Certified Mail #7015 1520 0002 6880 3365
Return Recpipt,Requested
September 25, 2017
John Guglielmetti
American Truetzschler Inc
PO Box 669228
Charlotte, NC 28266
SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY
Tracking Number: NOV-2017-MV-0175
Permit No. NC0085928
Truetzschler remediation site
Mecklenburg County
Dear Mr. Guglielmetti:
ROY CO
t1i.0f1M11
Cr
MICHAEL S. REGAN
Secretary
S. JAY ZIMMERMAN
iNritctur
A review of the January 2017 Discharge Monitoring Report (DMR) for the subject facility revealed the violation(s)
indicated below:
Monttoring V
Sample
Location Parameter
Monitoring
Date Frequency Type of Violation
001 Effluent 1,1,1-Trichloroethane (34506) 1/31/2017 Monthly Frequency Violation
001 Effluent 1,1-dichloroethane (34496) 1/31/2017 Monthly Frequency Violation
001 Effluent 1,1-dichloroethylene (34501) 1/31/2017 Monthly Frequency Violation
Effluent ,2-dichbroethane (32103) 1/31/2017 Monthly Frequency Violation
001 Effluent Tetrachioroethylene (34475) 1/31/2017 Monthly Frequency Violation
001 Effluent Trichloroethylene (39180)
1/31/2017 Monthly
Frequency Violation
A Notice of Violation/Intent to Issue Civil Penalty is being issued for the noted violation of North Carolina General
Statute (G.S.) 143-215.1 and the facility's NPDES WW Permit. Pursuant to G.S. 143-215.6A, a civil penalty of
not more than twenty-five thousand dollars ($25,000MO) may be assessed against any person who violates or
fails to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S.
143-215.1.
State of North Carolina I Environmental Quality I Water Resources
610 East Center Avenue, Suite 301, Mooresville, NC 28115
704-663-1699

If you wish to provide additional information regarding the noted violation, request technical assistance, or
discuss overall compliance please respond in writing within ten (10) business days after receipt of this Notice,
review of your response will be considered along with any information provided on the submitted Monitoring
Report(s). You will then be notified of any civil penalties that may be assessed regarding the violators. If no
response is received in this Office within the 10-day period, a civil penalty assessment may be
prepared.
Remedial actions should have already been taken to correct this problem and prevent further occurrences in the
future. The Division of Water Resources may pursue enforcement action for this and any additional violations of
State law. If the violations are of a continuing nature, not related to operation and/or maintenance problems,
and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by
Consent.
Reminder: Pursuant to Permit Condition 6 in Section E, the Permittee is required to verbally notify the Regional
Office as soon as possible, not to exceed 24 hours, from first knowledge of any non-compliance at
the facility including limit violations, bypasses of, or failure of a treatment unit. A written report may
be required within 5 days if directed by Division staff. Prior notice should be given for anticipated or
potential problems due to planned maintenance activities, taking units off-line, etc.
If you have any questions concerning this matter or to apply for an SOC, please contact Wes Bell of the
Mooresville Regional Office at 704-663-1699.
Sincerely,
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
Cc: WQS Mooresville Regional Office - Enforcement File
NPDES Compliance/Enforcement Unit - Enforcement File
State of North Carolina 1 Environmental Qualityl Water Resources
610 Fasi Center Avenue, Suite 301, Mooresville, NC 28115
704-663-1699

IVISION OF WATER RESOIJRCS - CIVIL PENALTY ASSESSMENT
Violator: American Truetzschler Inc
Facility Name: Truetzschler remediation site
Permit Number: NC008;5928
County: Mecklenburg
Case Number: MV-2017-0019
ASSESSMENT FACTORS
1) The degree and extent of harm to the natural resources of the State, to the public health, or to private
property resulting from the violation;
"i41-1.70
nu_
c.d.,- ...4(-
2) The duration and gravity of the violation;
ef/-44-e-& MO
3) The effect on ground or surface water quantity or quality or on air nail ;
42 15 24 4.4
41 it
4) The cost of rectifying the damage;
5) The amount of money saved by noncompliance;
Ste_ et-tA-41f15, ieAr
6) Whether the violation was committed willfully or intentionally;
L.. a CA-00 f
,
7) The prior record of the violator in complying or failing to comply with programs over which the
Environmental Management Commission has regulatory authority; and
NOV-2012-MV-0067
NOV-2013-TX-0006 —
NOV-2013-TX-0041 —
NOV-2014-LR-0040 —
NOV-2015-LV-0608 —
NOV-2017-PC-0099
— Failure to monitor the six volatile organic parameters — May 2012;
Chronic Toxicity Failure — November 2012;
Chronic Toxicity Failure — April 2013;
Late DMR Reporting — June 2014;
1,2-dichloroethane daily maximum limit violation — February 2015;
Failure to register/submit eDMR (July 2016 monitoring report).
8) The cost to the State of the enforcement procedures.
Enforcement Cost:
1 hour staff time. .$ 34.51
1 hour supervisor time .$ 53.78
Administrative staff cost .. 15.0Q
Total Enforcement Cost $ 103.29

Corey lager, Regional Su
Water Quality Regional Operatics
Mooresville Regional Office
Division of Water Resources, N D ►