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HomeMy WebLinkAboutNC0045471_Regional Office Historical File Pre 2018 (17)ROY COOPER coilymw MICHAEL S. REGAN sty.. LINDA CULPEPPER Dfrector Certified Mail #7016 1370 0000 2595 9539 Return Receipt Requested Gregory A Heaton Barium Springs Home for Children P© Box 1 Barium Springs, NC 28010 SUBJECT: NORTH CAROL NA Enrwromnonta!Qu City June 28, 2019 Notice of Violation and Assessment of Civil Penal' r for Violations ofNorth Carolina General Statute (G:S,) 143-215.1(06) and NPDES WW Permit No, NC0045471 Barium Springs Home for Children Barium Springs WWTP Case No. LV-2019-01.41. Iredell County Dear Mr. Heaton: This letter transmits a Notice of Violation and assessment of civil penalty in the amoun + $1 1.1.38 enforcement costs) against Barium Springs Horne for Children, 811.8 f$7 0.00 civil penalty This assessment is based upon the foliowing facts: a review has been conducted oftltie Discharge Monitoring Report (DMR) submitted by Barium Springs Horne for Children for the month of April 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 April 2019, are summarized in Attachment A to this letter„ Based upon the above facts, I. conclude as a matter of law that Barium Springs Home for Children violated the terns, 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. 143-21 5.6A(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), Bas 4ove ft dings 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, 1, W. Corey Basinger, Regional Supervisor, Mooresville Regional Office hereby make the following civil penalty assessment against Barium Springs Home for Children: $100.00 1_100.00 $250.00 $250.00 1 of 1 violations of G.S. 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-Bay (20 Deg. C) - Concentration 1 of 1 violations of G.S. I43-215.1(a)(6) and Permit No, NC0045471, by discharging waste water into the waters of the State in violation of the Permit Daily Maximum for Nitrogen, Ammonia Total (as N) - Concentration 1. of 1 violations of G.S. 14.3-2151 (a)(6) and Permit No. NC0045471, by discharging waste water into the waters of the State in violation of the Permit Monthly Average for BOD, 5-Dav (20 Deg. C) - Concentration 1 of 1 violations of G.S. 143-215.1(a)(6) and Permit No. NC0045471. by discharging waste water into the waters of the State in violation of the Permit Monthly Average for Nitrogen, Ammonia Total (as N) - Concentration $700.00 TOTAL CIVIL PENALTY $111.38 .Enforcernent Costs $811.38 TOTAL AMOUNT DUE Pursuant to G.S. 143-215,6A(c), in determining the amount of the penalty 1 have taken into accountthe 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 hum 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 ofthe 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 fo o ing: ( I) 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 ofthe 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 he 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 he considered: (I) whether one or more of the civil penalty assessment factors in NCGS 143B- 82.1(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 (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 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. In order to request remission, you must complete and submit the enclosed "Request for Remission of Civil Penalties, Waiver of Right to an Administrative Hearing, and Stipulation of Facts" form within thirty_(30) days of receipt of this no e. The Divisio -Water Reso rces also e uests that -ou com tete and submi he 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 adult; trative hearina with the Office of Administrative Hearino: 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 tile the petition with the Office of Administrative Hearings within thirty (30) days of receipt of tins notice. A petition is consi.deredfiled when it is received in the Office ofAdministrative 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 NCCS §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 andlor the details of the filing process. The mailing address and telephone and fax numbers for the Office of A.dministrative Hearings are as follows: 6714 Mail Service Center Raleigh. NC 27699 6714 Tel: (919) 431-3000 Fax (919) 431-3.100 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 the options above within thirty (30) days of receipt of this letter, as evidenced by an internal date/tinne 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. Office at (704) 663- 192 or via email at-wes.bel ou have, any questions. please con act Wes B11 with the Divi'ic n ot Water Resources staff cat th d % o esvill Regional rcdnr.ov. Sincerely, mil by or C A2DMA3 rey Basinger, Regional Supervisor Water Quality Regional Operations Section Moor sville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS c; WADS Mooresvill Raga) Off e - Enforcement File (l asertiche) PDRS ompfance/ f nfn Enforcement File (Laserfi he) JUSTIFICATION FOR REMISSION REQUEST Case Number: LV-201.9-01.41 Assessed Party: Barium Springs Home for Children Permit Na.: NC0045471 County: Iredell Amount Assessed: $81 1,38 Please use this form when requesting remission of this civil penalty. You roust also complete the "Request For Re ion, k aiver° of Right to an Administrative Hearing, and Stipulation cal 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.r„ explain the steps that you took to correct the violn and prevent fixture occurrences); (c) the violation was inadvertent or a result of an accident something you could not prevent or prepare fiar); explain ru,hy the violation was unavoidable or (d) the violator had not been assessed civil penalties .for any previous violations;. (e) payment ofthe civil penaltywill prevent payment for the remaining necessary remedial actions (i.e., explain how payment of the civil penalty sui11 prevent youfi orn performing the activities necessary to achieve compliance)„ EXPLANATION: STATE OF NORTH CAR 11NA DEPART I ,NT OF ENVIIII N1 lENTAL QUA ITY COUNTY OF IREI)EL.L. IN THE MATTER OF ASSESSMENT F CIVIL PENALTIES AGAINST Springs Horne for Children PERMIT N. N1004547 WAIVER OF RIGHT TO AN ADMINISTRATIVE TIE HEARING AND STIPULATION OF FACTS CASE NO. 19-0141 Having been assessed civil penalt`se totaling $811,38 for violation(sl as set forth in the assessment document of the Division of Water Resources dated June 28, 2019 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 ell penalty must be submitted to the Director of the Division of Water Resources within thirty (0) days of receipt of the notice of assessment. No new evidence in support ofa remission request will be allowed alter (30) days from the receipt of the notice of assessment. This the day of ADDRESS ION TURI ONE ATTACHMENT A Bariurn Springs Home for Children CASE NUMBER: LV 2C 1 - 141 PERMIT: NC0045471 FACILITY: Barium Springs Harme forChildren L1 IT VIOATIONS) S SAMPLE LOCATION: Oa ll 001 - Effluent Violation Report Date Monthr Parameter Frequency Measure Value Value 4/2/2019 4-2019 BOO, 5-Day (20 Deg. 2 X month C) - Concentration REGION: Mooresville COUNTlf: bedsit Unit of Limt Calculated ' over Violation Penalty Type Amount 00.00 mgil 7,50 33.5 345.7 Daily Maximum Exceeded 4P3012019 4-2019 SOU, 5-Day (20 Deg, 2 month mgil - Concentration 18,6 2'72,0 Monthly Average Exceeded 4/2/2019 4-2019 Nitrogen, Ammonia Total as N) - Concentration 2 Xrr7onth 4 9J2t119 4-2019 Nitrogen, Ammon' 2 X month rngil Total (a N) Concentration 250.00 10 17.47 74,7 Daily Maximum Exceeded 9.91 395,5 Monthly Average Exceeded 00 2500 June 20, 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-4390 Permit No, NC0045471 Barium Springs WWTP Iredell County WOROS MOO'RE'SVILLE rit,CtONA Mr. Basinger, Thank you for providing Barium Springs Wastewater Treatment Plant an opportunity to reply to the Notice of Violation issued 11 June 2019 by the Division of Water Resources. This letter is our response to the exceedances of effluent BOD and NH3-N for the month of April, 2019. These parameters exceeded the permitted daily maximum on 2 April 2019 which, in turn, raised the monthly average for both parameters above their respective monthly average limits. In the days leading up to the sampling event that occurred on April 2, significant leaks in the concrete distribution box caused unevenly distributed wastewater to be dispersed onto the head of the sand filters. This led to ponding at the head of the sand filters, ultimately causing BOD and NH3-N to both exceed permitted limits. The distribution pipes could not properly disburse wastewater through the sand bed as designed. The water, left concentrated in one area, was unable to utilize all of the available sand needed for filtration. Since the discovery of the above -mentioned leaks, Barium Springs maintenance staff have repaired the leaks in the distribution box to ensure that wastewater entering the filters maintains an even distribution and is filtered according to the design of the filters. In addition, the distribution lines have been jetted and flushed to remove any accumulated solids that have built up. It is our beliefhat our wastewater treatment au ility is being run in a responsible m . f er, and the drag it doing so in a niter according to rules and regulations set f* by the Depi* ent of Enviro • ental Quality, It is our request that the Division of Wattr Resources take into consideration our frankness in this matter,as well as the corrective measures taken, when determining enforcement action on this Notice of Violation, staff members operating and Sincerely, Bar Sp ` i s CC: Mike Myers, Envirolink DavidStrum, Envirchnk Rebecca Manning, Envirolink Chris Bitterman, Envirolink D V SION OF WATER RESOURCES - CIVIL PENALTY ASSESSMENT Violator: Bariu- . Springs Home for Children Facility Name: Barium Springs WWTP Permit Number; NC0045471 County: Iredell Case Number: LV-2019-0141 ASSESSMENT FACTORS I.) 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 discharge oftreated wastewater in excess of NPDES pert 'led limits has the potential to adversely impact natural resources. 2) The duration and gravity of the violation; As documented in attachment A. 3) The effect on ground or surface water quantity or quality or on air quality; The discharge o " reared wastewater in excess of NPDES permitted limits has the ,potential to adversely impact surface waters. 4) The cost of rectifying the damage; Unknown. 5) The amount of money saved by noncompliance; tink-nOlVa 6) Whether the violation was committed willfully or intentionally; Was not believed to be uillfil or intentional, 7) The prior record of the violator in complying or failing to comply with programs over which the Environmental Management Commission ha.s regulatory authority; and NOV-20.15-LV-0422 —.Ammonia (MAT") February 2015; NOV-201 7-LV-04 26 — pH minim UM violation — February 2017: NOV-201 7-1V-0598 — BOD (DM/ & MA V) — May 2017; Case 4: L V-.201 7-0321 — BOD (MTV Fecal ColOrm (D.,141'7) and pH minimum violation — July 2017; 1VOV-201 7-1V-0812 — Fecal Coliform August 20.17; NOV-2018-LV-0388 — BOD (DMV & MA V) and Ammonia MA V — January 2018; Case #: LV-2018-0184 —.Ammonia (111.4V) — February 20.18; NOD-2018-LV-0.110 — TSS (DAM —June 2018; NOV-2018-1V-0724 — Fecal Colifi.».-m (MIT") — July 2018: NOV-2018-LM-0074 BOD (DAB" & MAO and (4) Dissolved Oxygen monitoring violations August 2018; NO V-.2018-LM-0089 BOD (DAB/ & M4P') and (3) Dissolved Oxygen monitoring 'violations — September 2018; Case #: 1V-2019-0098 —.BOD MA V) and :4mmonia (11/L-If9 — February 2019. 8) The cost to the State of the enforcement procedures. $111.38 Enforcement Cost: 1 hour staff time. . $ 38,66 1 hour supervisor time. $ 5772 Administrative /CO staff cost 5 15.00 Total enforcement cost $ 111,38 6.26.19 Date W. Corey Basinger, R gionnl a perviso Water u lit Regional Operations Section Mooresville Regional Office Di ision of Water Resources„ NCDEQ ROY COOPER Governor MICHAEL S. REGAN Sc rru, LINDA CULPEPPER. h Certified Mail #7018 0360 0002 2099 1833 Return Receipt Requested Celeste Domingue2, President & CEO Barium Springs Home for Children PO Box 1 Barium Springs, NC 28010 NORT)-4 CAROLINA Environmental Quality June 11, 2019 SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY Tracking Number: N0V-2019-LV-0390 Permit No. NC0045471 Barium Springs WWTP Iredell County Dear Ms. Dominguez: A review of the April 2019 Discharge Monitoring Report (DMR) for the subject facility revealed the violation(s) indicated below: Limit Exceedance Violation(s): Sample Location Parameter Limit Reported Date Value Value Type of Violation 001 Effluent BOD, 5-Day (20 Deg, C Concentration (C0310) 4/2/2019 7.5 33.5 Daily Maximum Exceeded 001 Effluent Nitrogen, Ammonia Total (as N) - Concentration (C0610) 4/2/2019 10 17.47 Daily Maximum Exceeded 001 Effluent BOD, 5-Day (20 Deg. C) - Concentration (C0310) 4/30/2019 001 Effluent Nitrogen, Ammonia Total (as 4/30/2019 N) - Concentration (C0610) 18.6 Monthly Average Exceeded 9.91 Manthly Average Exceeded "Port*, :a Depassratarttt e E trsarttertta',,t7t,t.it:tta, Littota,,,ort ca. mat et taesouToe,s ottatatata' Rtagrorta Off sta EICt E3tCtantet tttatentis... Sat tte 3CI1 t MostattaatI tatatltt Cats as 26111 463-1695t 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 ($25,000.00) 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, iDocuSignetl by: 14,...614u il P161F1369A2DB4A3 for 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) r, Departr,,,ertf Er:v. Tor m.er,ts,Q6,4,1'?: I Ci.vs,c,r. .atRerF,avrs M-Dcq...esv- -Et c,r,:a.Qffc Eta East. C rAerL,aci wx.resv,e, na .731,1.5 7 C.4 S-1,ES Facili Name: Barium Springs V "s 'TP Report Period: April 2019 DNMR REVV* RECORD Mooresville Regional Office Prior Assessments: Permit Number: lilt .flt)4547 1 Enforcement Factor: 1MO Outfall Outfall Description Waterbody Name Waterbody Classification 001 effluent to UT Duck Creek Duck Creek c y Average Limit Vriolations Sample Location: Outfall 001 - Effluent Violation Pa ramete 4/30/2019 B©D. 5-Day (20 Deg. C) - Concentration Unit of Limit Calculated % Over Frequency Measure Value Value Limit Action 2 X month mg/I 5 16.60 272.0 4130/2319 Nitrogen, Ammonia Total (as N) - Concentration 2 X month mg/1 2 9.90 395.5 Q t)r Limit Violations Sample Locati Violation Date Parameter Outfall 001 - Effluent Unit of Limit Calculated % Over Frequency Measure Value Value Limit Action 4/212019 BQD, 5-Day (20 Deg. C) - Concentration 2 X month mg/1 7,50 33.50 346.7 4/2/2019 Nitrogen, Ammonia Total (as N) Concentration 2 X month mg/1 10 17.50 74,7 Otlrer Violations/Staff' Remar Page 1 of 4 SupervisotR m# C001111 tRe Supe Si Regional rvi mt «af Date g 2# 4 Permit Number: NC )45471 th Enforcement History Report Period: April 2&)19 Limit Violation Sample Location: Dutfall 001 - Violation Report Date Period Parameter cent Violation Type NOD NOV CPA 2/4/2019 2-2019 BOD, 5-Day (20 Deg. C) - Concentration Daily Maximum Exceeded NOV-2019-LV-0249 LV-2019-0098 2/2812019 2-2019 BOD. 5-Day (20 Deg. C) - Concentration Monthly Average Exceeded NOV-2019-LV-0249 LV-2019-0098 2128/2019 2-2019 Nitrogen, Ammonia Total (as - Concentration Monthly Average Exceeded NOV-2019-LV-0249 LV-2019-0098 6/20/2018 6-2018 Solids, Total Suspended - Concentration Daily Maximum Exceeded NOD-2018-LV-0110 7/11/2018 7-2018 CoRorm, Fecal MF, MFC Broth, 44.5 C Daily Maximum Exceeded NOV-2018-LV-0724 8/712018 8-2018 BOD. 5-Day (20 Deg. C) - Concentration Daily Maximum Exceeded NOV-2018-LM-0074 LM-2018-0054 8/31/2018 8-2018 9/6/2018 9-2018 9/30/2018 9-2018 BOD, 5-Day (20 Deg. C) - ntration BCD, 5-Day (20 Deg. C) Concentration Monthly Average Exceeded Daily Maximum Exceeded NOV-2018-LM-0074 LM-2018-0054 NOV-2018-LM-0087 BOO, 5-Day (20 Deg. C) - Concentration Monthly Average Exceeded NOV-2018-LM-0087 Monitoring Violation Sample Location: Outfall 001 - Effluent Violation Report Date Period Parameter Violation Type NOD NOV CPA 8/4/2018 8-2018 Oxygen, Dissolved (DO) Frequency Violation NOV-2018-LM-0074 LM-2018-0054 29 18 8-2018 Oxygen, Dissolved (DO) Frequency Violation NOV-2018-LM-0074 LM-2018-0054 8/1812018 8-2018 Oxygen, Dissolved (DO) Frequency Violation NOV-2018-LM-0074 LM-2018-0054 8/25/2018 8-2018 Oxygen, Dissolved (DO) Frequency Violation NOV-2018-LM-0074 LM-2018-0054 9/1/2018 9-2018 Oxygen, Dissolved (DO) Frequency Violation NOV-2018-LM-0087 9/8/2018 9-2018 9/15/2018 9-2018 Oxygen, Dissolved (DO) Frequency Violation NOV-2018-L.M-0087 Oxygen, Dissolved (DO) Frequency Violation NOV-2018-LM-0087 Page 3 of 4 Other Violeti n Vio Report PeriodParameter Violation Type NOD NOV CPA 10/2512018 Violation detected NOD-2018-PC-031 during inspection 1 /2dJ2018 Violation detected N -2018 Pt -t783 91 during inspection Page 4ot