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NC0045471_Regional Office Historical File Pre 2018 (15)
Rai' COOPER Covcr MICHAEL S. REGAN Seers scar y LINDA CULPEPPER Oim aor Certified Mail #7016 170 0000 2595 8181 Return. ReceiptRequested Gregory A Heaton Barium Springs Home for Children PO Box, 1 Barium Springs, NC 28010 NORTH CAROLINA Enrtrananental Quality August 07, 20.19 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.. NC0045471 Barium Springs Home for Children WWTP Case No.1,V-2019-0185 lredell County Dear Mr. Heaton: This Letter trans its a Notice of Violation and assessment of civil penalty in the amount of 5 1.38 ($450,00 civil penalty + $1 1 1.38 enforcement costs) against Barium Springs Home for Children. This assessment is based upon the following facts: a review has been conducted of the Discharge Monitoring Report (DMR) submitted by Barium Springs Horne for Children for the month of May 2019. 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. NC0045471. The violations, which occurred in May 2019, are summarized in Attachment A to this letter. Based upon the above facts, 1 conclude as a matter of law that Barium Springs Home for Children violated the terms, conditions or requirements of NPDES WW Permit No. NC0045471 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(a)(2), 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). t4 r Citroth,e De¢53rtrrer,t of Eev°rDrmer,t& Que t,,° D vs 7n of water Resources vznue,Sole 301 p !'re, North r,. ra 28115 Based upon the above findings of fact and conclusions of law, arid 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 Barium Springs Home for Children: $200.00 2 of 2 violations of GS. 143-215.1(a)(6) and Permit No. NC0045471, by discharging waste water into the waters of the State in violation of the Permit Daily Maximum for :BOD., 5-Day (20 De2.C) - Concentration $250.00 1 of 1 violations of G.S. 143-215.4 (a)(6) and Permit No. NC0045471, by discharging waste water into the waters of the State in violation of the Perrnit Monthly Average for BOD, 5-Day (20 De. C) - Concentration $450,00 TOTAL CIVIL PENALTY $ 111„38 Enforcement Costs $_561.3 TOTAL AMOUNT DUE Pursuant to G. G.S. 143-215.6A(c), in determining the amount of the penalty 1 have taken into account he Findings of Fact and Conclusions of Law and the factors set forth at G.S. 143B-282,1(b), which are: (1) (2) (3) (4) (5) (6) (7) (8) 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; The duration and gravity of the violation; The effect on ground or surface water quantity or quality or on air quality; The cost of rectifying the damage; The amount of money saved by noncompliance; Whether the violation was committed willfully or intentionally; The prior record of the violator in complying or failing to comply with programs over which the Environmental Management Commission has regulatory authority; and 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 ofthe 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 2769.9-1617 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(bl 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; (I) whether the violator had been assessed civil penalties for any previousviolations; 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 must be submitted in writing, The Director of the Division of Water Resources 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. 'fherefore, it is very important that you prepare a complete and thorough statement in support of your request for remission. In order to request remission, you must complete and submit the enclosed "'Request for R„emission of Civil Penalties, Waiver of Right to an Administrative Hearing, and Stipulation of Facts" form within thiryC30) days of receiptof 'this notice, The Division of Water Resources .aiso requests that von 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 hearinglyith the Office f Admini. rings: 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 ((fa filing fee is required. by NCGS §150B-23,2) is received in the Office of Ad.ministrative 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 andlor the details of the filing process. 'Fhe mailing address and telephoneand fax numbers for the Office of Administrative Hearings are as follows: 6714 Mad Service Center Raleigh, NC 27699 6714 Tel: (919) 431-3000 Fax: (919)431-3100 One (1) copy of tlie petition must also he 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 the 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 oldie penalty through a civil action. Please he advised that additional penalties. may he 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 (704) 235-2192 or via email at wes.belignedenr.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 (ta.serfiche) NPDES Compliance/Enforcement -Unit - Enforcement File (Laserfiche) JUSTIFICATION FOR REMISSION REQUEST Case Number: LV-2019-0185 Assessed Party: Barium Springs Home for Children Permit No.: NC00454171 County: Iredell Amount Assessed: $561..38 Please use this form when requesting remission of this civil penalty. You must also complete the "Request For Remission, river of Right to an Administrative Ho:1ring, 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.CCi.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 supportin.g 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. 1143B-282.1(b) were wrongfully applied to the detrimentof 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 Ititure occurrences): (c) the violation was inadvertent or a result of an accident explain why the violation was unavoidable or something you could not prevent or prepare for (d) the vo1ator had not been assessed civil penalties for any previous vioIations; (e) payment of the civil penalty will prevent payment for the remaining necessary: remedial actions explain how payment ,qf the civil penalty will prevent you rompertbrming the activities necessary to achieve compliance), EXPLANATION: STATE OF NORTH H CAROL! iA DEPARTMENT 0 EN8i'1R0 w F 1`..QUI, I ITY COUNTY 1T\ P IREDELL IN TI IF MATTER F . S FSS =IFN1T" OF CIVIL PENALTIES : G:1 1 T Bantu l rin s no e for Children 1'FRM11" 'O. N0O451 WAIVER OE RIG3T TO AN ADMINISTR.A FIVE BEARING ND STIPULATION FACTS T CASE NO. L.'4 - OI -I g beassessed civil penalties totaling $561,d8 for uir lation(s) as sthe assessment ent document of the Division g to seek remission of the civil penalty, does hereby waive the right to an administrative head t ire 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 ot`r eeiptof the notiee of assessment.. No new evidence in support of a remission request Will be allowed after(0) days from tlt receipt of the notice of asses.. ent. f Water Resources dated August 07, 7019, the undersigned, This thew day of I)DRFSS TFRFPIIONE TI ATTACHMENT Barium Springs Home for Children CASE NUMBER: Ltd-2 1 -01 S5 PERMIT: NC004S 7f FACILITY: Barium Springs Home for Chit ren TI LIMIT VIOLATIONS) S SAMPLE LOCATION; Outfall 1 -E uen REGION: oore COUNTY: Iredel,. Violation Report gait of Limit C #culated % Over Date MorithlYr Parameter Frequency Measure Value Valve Limit /712019 5-2019 DOD, 5-Day (20 Deg. 2 X month mg0'1 7.50 58.7 Daily CI - Concentration Maximum Exceeded Daily Maximum Exceeded Violation Type Doom 5/29/2019 5-2019 BOD, 5-Day (20 Deg. C) - Concentration 2 X month 2019 -2019 B D, 6-Day (20 Deg. 2 X month mg i C) - Concentration 7 50 11.7 136, Monthly Average Exceeded Penalty Amount. 100 00 1 0,00 Facility Barium Springs ww-rt, Report Period: May 2019 DNIR REVIEW RECORD Mooresville Regional Office Prior Assessments: Permit Number: NC0045471 Enforcement Factor: J 00 OtttalI # Outfall Description 001 effluentUT Duck Creek terbo Duck Creek Waterbody Iaasltication Monthly Average Limit Violations Sample Location: °Wall 001 - Effluent Violation Date 5/31/2019 BOD, 5-Day (20 Deg. C) - Concentration Parameter Unit of Limit Calculated % Over Frequency Measure Value Value Limit 2 X month mg/ l 5 11,80 136.0 Action Daily Limit Violations Sample Location: Outfall 001 Effluent Violation Unit of Limit Calculated % Over Date Parameter Frequency Measure Value Value Limit Action 5(7/2019 BOD, 5-Day (20 Deg. C) - Concentration 2 X month mg/I 7 50 11 90 58.7 P 5/29/2019 BOD, 5-Day (20 Deg. C) - Concentration 2 X month mgil 7,50 11 70 56 0 5/23/2019 Chlorine, Total Residual 2 X week ug/I 17 42. 147.1 No Action, BPJ 5/29/2019 Chlorine, Total Residual 2 X week ugfl 17 31 82,4 No Action, BPJ Monitoring Frequency Violations Sample Location: Outfall 001 - Effluent Violation Date Parameter Unit of Frequency Measure Action 5/4/2019 Chlorine, Total Residual 2 X week ug/I No Action, BIMS Calculation Error 5/4/2019 Flow, in conduit or thru treatment plant Weekly mgd No Action, BIMS Calculation Error 5/4/2019 Oxygen, Dissolved (DO) Weekly mg/I No Action, BIMS Calculation Error 5/4/2019 Temperature, Water Deg,. Centigrade Weekly deg c No Action, BIMS Calculation Error Page 1 of 4 Other Violations/ ,ta Supervisor .etnar:s: Completed by: scant Regional Supervisor Sign -off: Regional Supervisor Sign -off: hate• Date: Page of 4 Prior 12-Month En P'ersmit Number, NC_O045471 e History Report Period: 11,1ay 2019 Limit Violation Sample Location: Outfall 001 - Effluent Violation Report Violation Date Period Parameter Type NOD NOV CPA 2/4/2019 2-2019 BCD. 5-Day (20 Deg. C) - Concentration Daily Maximum Exceeded NOV-2019-LV-0249 LV-2019-0098 2/2812.019 2-2019 BCD, 5-Day (20 Deg, C) - Concentration Monthly Average Exceeded NOV-2019-LV-0249 LV-2019-0098 2/2812.01'9 2-2019 Nitrogen. Ammonia Total (as N) - Concentration Monthly Average Exceeded NOV-2019-LV-0249 LV-2019-0098 4/2/2019 4-2019 BOD, 5-Day (20 Deg. C) - Concentration Daily Maximum Exceeded NOV-2019-LV-0390 LV-2019-0141 4/2/2019 4-2019 Nitrogen, Ammonia Total (as N) - Concentration Daily Maximum Exceeded NOV-2019-LV-0390 LV-2019-0141 4/30/2019 4-2019 BOD. 5-Day (20 Deg. C) - Concentration Monthly Average Exceeded NOV-2019-LV-0390 LW-2019-0141 4/30/2019 4-2019 Nitrogen, Ammonia Total (as N) - Concentration Monthly Average Exceeded NOV-2019-LV-0390 LV-2019-0141 6/20/2018 6-2018 Solids, Total Suspended - Concentration Daily Maximum Exceeded NOD-2018-LV-0110 7/11/2018 7-2018 Coliform. (Fecal MF. MF Broth, 44.5 C Daily Maximum Exceeded 8/7/2018 8-2018 BOD. 5-Day (20 Deg. C) - Concenlration Daily Maximum Exceeded NOV-2018-LV-0724 NOV-2018-LM-0074 LM-2018-0054 8/31/2018 8-2018 BCD, 5-Day (20 Deg_ C) - Concentrat'ion 9/6r2018 9-2018 BOD, 5-Day (20 Deg. C) Concentration Monthly Average Exceeded Daily Maximum Exceeded NOV-2018-LM-0074 LM-2018-0054 NOV-2018-LM-0087 9/30/2018 9-2018 BOD, 5-Day (20 Deg, C) - Monthly Average Concentration Exceeded NOV-2018-LM-0087 Monitorintt Violation Sample Location: Pintail 001 - Effluent Violation Report Date Period Parameter Violation Type NOD NOV CPA 814/2018 8-2.018 Oxygen, Dissolved (DO) Frequency Violation NOV-2018-LM-0074 LM-2018-0054 8/11/2018 8-2018 Oxygen, Dissolved (DO) Frequency Violation NOV-2018-LM-0074 LM-2018-0054 8118/2018 8-2018 Oxygen, Dissolved (DO) Frequency Violation NOV-2018-LM-0074 LM-2018-0054 Page 3 of 4 Monitoring Violation pie Location: Violation e Outte 0 E Report Period Parameter '2512018 8-2018 uent Oxygen, Dissolved (D 9-2018 Oxygen, Dissolved (DO) 9/8"2018 9-2018 Oxygen, Dissolved (DO) Violation Type quency Violation NCO NOV CPA N0V-2018-1)M-4074 L ®2018-0 54 Frequency Violation Frequency Violas on NOV-2918-LM-0087 NOV-2018-LM-0087 9/150018 9-2018 Oxygen, Dissoived (DO) Frequency Violation NOV-20184)M-0087 Ot er Violation Say ple ovation: Violation Report Period Parameter Violation Type NOD NOV CPA 102512. Violation detected during inspection N-2018-P 811 Violation detected NC Li-2518-P-0 during inspection Page 4o 4 July 23, 2019 W. Corey Basinger, Regional Supervisor Water Quality Regional Operations Section Mooresville Regional Office Division of Water Resources, NCDEQ Subject: NOTICE OF VIOLATION Tracking number: NOV-2019-LV-0390 Permit No. NC0045471 Barium Springs Home for Children Iredell County Mr, Basinger, Thank you for allowing Barium Springs Home for Children the opportunity to respond to the Notice of Violation dated June 11, 2019. Our response below is for the exceedance of BOD levels for the May 2019 sample period. Exceedances of BOD on May 7 and May 29 were due to inadequate filtration in the sand filter bed. Cracks in both distribution boxes lead to uneven distribution of water being applied to the sand filters. Flow was pooling at the head of the sand beds, which further prevented even. distribution of wastewater over the filter media. In an effort to amend this issue and to prevent future occurrences, Barium Springs maintenance staff sealed the distribution boxes and removed the sludge. The distribution piping was jetted ii order to remove accumulated sludge. The sand was leveled in order to ensure maximum utilization of the filters' surface area. In addition to these efforts, Envirolink has made use of their water/wastewater engineer in order to provide long-term solutions to the issues presented by recent BOD exceedances. Tt is always our goal to remain in complianc th regulations set forth by the Division of Resources. The errors that lad to this facilit3r s non-compliance have been clearly noted to avoid future non-compliance status. It is our request that our cooperation and action in these matters be taken into account by the ivision when enforcement ation is taken. Greg eaton Barium prin Home for Children CC: NC DEQ D Michael y rs, Envirolink DavidStrum, Envirolink rt e, Envirolink C Bias . an, Envirolink Madelyn ills, En irutink ROY C Gewernor MICHAEL . REGAN Croy LINDA CULPEPPER Ofrotiee Certified Mail #7016 1370 0000 2595 8174 Return Receipt Requested Gregory A Heaton Barium Springs Home for Children P© Box 1 Barium Springs, NC 28010 NO CAROU A €nrtionmentai Quality July 11, 2019 SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY Tracking Number: NOV-2019-LV-0475 Permit No. NC0045471 Barium Springs Home for Children WWTP Iredell County Dear Mr, Heaton: A review of the May 2019 Discharge Monitoring Report indicated below: Limit Exceedance Violatianfs); Sample Location Parameter DMR) fa he subject facility revealed the violation(s) Limit Reported Date Value Value. Type of Violation 001 Effluent BOD, 5-Day (20 Deg. C) _ 5/7/2019 7.5 11.9 Daily Maximum Exceeded Concentration (C0310) 001 Effluent Bop, 5-Day (20 Deg. C) - 5/29/2019 7.5 11,7 Daily Maximu Concentration (C0310) 001 Effluent Bap, 5-Day (20 Deg. C) - 5/31/2019 5 11.8 Monthly Average Exceeded Concentration (C0310) �a ry t t Asa tts ae .610 EVA OtAtIPt 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 (S25,000.00) 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. 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. A 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 violations. 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, DocuSigned by: A14CC681AF27425._ 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 (Laserfiche) NPDES Compliance/Enforcement Unit - Enforcement File (Laserfiche) 'OA 441,74;44, ' th Caro4 Drt1 Emt 46) Q4.otty Divrs,ort of Wt esouroes, h400rrasv,r4 RitioNsi Offioe- 610 Elm Cam Awthoe, Siote 301 Mooresoca*,. North Ca rokfro 28115 704-663-169a N OF WATER RESOURCES - CIVIL PENALTY' ASSESS M ENT Violator: Barium Springs 11 Facility Naane: Barium Springs Permit Number: NC0045471 County: Iredell Case Number: LV-2019-01.S5 r Children VTP ASSESSMENT FACTORS 1) The degree and extent (Ashanti to the property resulting from the violation; 2) The duration and gravity of the viol !., rit--.,m., State, to the public health, or to private ) The effect on ground or surface water quantity or quality or on a 4) The cost of rectifying the damage; tit 5) The amount of money saved by noneompli (11 her the violation was commi. 5/0-,r°c. LZ c ' 7) The Prior record of the violator in complying or failing to comply with programs over which the Envi ental Management Commission has regulatory authority; and '4'`01 -201 J-L V 04 2 2 --- Ammonia (MA V) _- February bruary° 2015 NO-2017-L V-0426 - p11 mini uuin violation -- February 2 0.17; NO201:7-L -0598 .._ BOD (1)AIV & MAI) - May 201 Case 4 L 1✓-20'1'w0321 IIOL) (DAN & :1f1 V), fecal C'(DA111) and pH ntim , NO'V-2017-L1°-0812 al Colt/uraa'a (1)111n j - August 2017; ; O V- 2018-L G' 03 `s'8 B „21) (D.AIV & MAP') and 11,nmonui (MA V) - January 2018; Case 4:° LV-2018-0184 - Ammonia (MA1k`1j __. February 2018; NOD- 2018-L V-0110 ---1 AS;S (DMV) - June 2018; SVOV-2018-LV-0724 - Fecal C'oliforin (D 1V) July 2018; AVOV-2018-LA1-00,24 BOD (DMV & MA Vt t (4) Dissolved 0xvgen ,nonilorin, 018-L11-0089 - ROD (DRfV & .1L91,') cant (3) Dissolved C vy en mnonit L V 20.1,9-0098 - BOD (DAD/ & MA V) nand Arnramnia (MA 1 I - Februa.aa LV-2019-0141 BOD (D41J & :IL-11'') and,Anununta IDA l 1') - April 2019, the tat of the ,et Enforcement Cost; 1 hour staff time..:: 1 hour supervisor time.. Administrative /CO staff cost.,....: Total enforcement cost 38.66 57,7 5.00 138 Regional S e visor V ter Quality Regional Operatiof rent Toor %ille i'I.e o nal +()ffir ivisio►a of s NCDEQ on