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HomeMy WebLinkAboutWQ0039488_Remission (Request)_20210401 (2)Justification for Remission Request Case Number: LV-2021-0056 & LV-2021-0057 County: Camden County Assessed Party: Camden County Permit No: WQ0039488 Amount Assessed: $ 296.35 & $296.35 (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) The treatment plant came on-line in October 2019 and is a new process to the Camden County staff. Our technical support person has not been able to come to the treatment plant to assist in any corrective action. The treatment process technician has a special needs person at home and isn't able to travel because of the coronavirus. We continue to work on the treatment process and are talking with other operators who have similar treatment processes. We have been able to reduce our total nitrogen levels to below permit limits but not consistently. We believe the problem is with our bar screen. We have a conventual bar screen with one -inch spacing but all our pump stations have grinder pumps installed. We are receiving a slurry and the paper comes back together in the influent tank, and then works thru the plant. We clean the bar screen daily, we pump the influent tank out, but the paper keeps coming back. We have tried different screen materials but the small screen that can catch the paper will also clog up quickly. The paper seems to be the issue with our process, it can slow down flows and chemical feeds so the process doesn't react as it should. We believe a micro -bar screen will catch enough of the paper to correct the problem. We have signed a proposal with Timmons Group/ Kim Hamby to do the engineering work necessary for the wastewater permit modification. The micro -bar screen has a lead time of 12-18 weeks and will be ordered as soon as approved by Timmons Group. (d) the violator had not been assessed civil penalties for any previous violations; Camden County has not been assessed any civil penalties for previous violations and we are committed to insuring this treatment plant process is corrected as soon as possible. (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 preforming the activies necessary to achieve compliance) Funds in our Utilities Operations Budget is extremely tight and the needs always outlast the revenues. The additional cost of the engineering, the cost of the permit modification, the cost of the micro -bar screen and the contractors cost to get the water and electrical power connected are all items that weren't included in the budget. We do understand how important it is to get the treatment plant into compliance and ask for remission of the civil penalties to allow the activities necessary to achieve compliance be completed. JUSTIFICATION FOR REMISSION REQUEST Case Number: LV-2021-0057 Assessed Party: Camden County Permit No.: W00039488 County: Camden Amount Assessed: 296I Please use this form when requesting remission of this civil penalty. You must also complete the 'Request For Remission, Waiver ofRight 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 assessmentfactors 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 frAure occurrences); ti% (c) the violation was inadvertent o' a result of an accident (i.e., explain ivhy the violation was unavoidable or something you could not prevent or prepare foi); (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 pa)nnent of the civil peiaalty trill prevent you front per forming the activities necessary to achieve compliance). EXPLANATION: See a �-lcac t�-e d STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY COUNTY OF CAMDEN IN THE MATTER OF ASSESSMENT ) WAIVI R OF RIGHT TO AN OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND STIPULATION OF FACTS Camden County ) Courthouse Area WWTP ) PERMIT NO. W00039488 ) CASE NO. LV-2021-0057 Having been assessed civil penalties totaling 2476.35 for violations) as set forth in the assessment document of the Division of Water Resources dated March 3, 2021, 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 % day of I L �1 , SIGNATURE ADDRESS �OImicn l �y ocin �I PD GUX' I qD La,wdeinCN C- Z 7c[ Z I TELEPHONE z52 � Zor1-