WQCS00124_Remission Request (DV-2021-0185)_20211216

RECEIVED
ROBBINS 6 2021
NCDEQIDWR/NPDES
To: PERCS Branch, Division of Water Resources 13 DEC 2021
From: Clint Mack, Robbins Town Manager
For: Request for Remission of Civil Penalties
In reference to Case Number DV-2021-0185, the Town of Robbins formally requests
remission of the 2 violations totaling $1,135.17 ($1,000 penalty, $135.17 Enforcement Costs).
Incident# 202101860 occurred on 9/1/2021. During the town's WWTP
operator's morning PMCS of the plant noticed the intake sewer pump had malfunctioned
resulting in a sewer overflow out of the adjacent manhole. Town employees immediately began
controlling the spillage with dolomitic hydrated lime carbonite and troubleshooting the pump.
The pump was able to be restarted and resume operation, returning the manhole to normal
operating level. To ensure the pump would continue to operate properly, we ordered a
complete maintenance overhaul of the pump as shown in attachment 1. We feel that Under
N.C.G.S. 143B-282.1(c)(b) and (c), the Town of Robbins promptly abated continuing
environmental damage resulting from the violation and the violation was inadvertent or a result
of and accident. The malfunction of the pump was unavoidable and completely unpredictable
however, addressing the violation was done in a timely and efficient manner.
Incident # 202101957 occurred on 9/22/2021. Town maintenance workers responded to
a sewer overflow call. They immediately cordoned the area, doused the surface area with
dolomitic hydrated lime carbonite, and immediately unclogged the obstructed sewer line. The
incident was then reported to the town's Wastewater ORC for proper reporting. Under N.C.G.S.
143B-282.1(c)(b), the Town of Robbins promptly abated continuing environmental damage
resulting from the violation.
Post Office Box 2961101 N. Middleton Street 1 Robbins1 North Carolina) 27325
Phone: [phone] Fax: [phone]

I '
ROBBINS
Neither of these incidents was a result of negligence or ill intent toward any
environmental considerations. Both incidents followed strict spill response procedures and was
property reported as required by NCDEQ therefore, we humbly request remission of these fines.
These fines cannot change neither of the incents from occurring. Additionally, we are assessing
our preventive maintenance procedures and refining our spillage SOP to ensure proper
environmental safety is adhered to during any sewer overflow.
The point of contact for this memo is undersigned or [e-mail]
6EK,'CLl'iT''
1;)- OB81NS
Clint Mack ; f Attachment 1: Xylem Pump Rebuild Receipt
Town Manager \. 4,0
I
Robbins, NC. � 8eors,Mc;1..''`
Post Office Box 2961101 N. Middleton Street 'Robbins' North Carolina' 27325
Phone: [phone] Fax: [phone]

Invoice
i( , . I
xylem Sold by: Branch Remit to:
,� 300 Sigma Drive 26717 Network Place
Garner, NC 27529 Chicago, IL 60673-1267
Let's Solve Water Tel: [phone] Phone: [phone] (opt 1)
Fax: [phone]
NOTE:Valued customers, please note the NEW remit
godwin I, FLYGT address change included on this invoice.
S S Cust. No. Invoice Date Invoice No.
O H
L Town of Robbins I Town of Robbins 00012327 09-07-2021 401114399
D PO Box 296 P PO Box 296
Robbins NC 27325-0296 Robbins, NC 27325-0296 Page 1 of 2
T T
O 0
Customer PO Ordered By Contract Date Completed Date Wf0 Number Sales Order Taken By Payment Terms
Representative
09-03-2021 09-03-2021 712020477 Freddie Hudson, Jr. Freddie Hudson, Jr. Net 30
UNIT EXTENDED
ITEM DESCRIPTION QUANTITY AMOUNT AMOUNT
Repair On: CD150M 6"T'CAE-55-FT4 RGT
Made a service call on 9/3/21 to service customer owned CD150 Ser#
U1100918. Replaced MAF sensor. Decarbed compressor, serviced
engine, checked all fluid levels and greased bearings.Tested unit
32009687 JCB TMAF Sensor 1 555.42 555.42
333D2696 JCB TCAE-55/93 Main Air Filter 1 90.58 90.58
32007382 JCB TCAE-55/93 Fuel Filter RECEIVED SO____I
58.42 58.42
� ,� 1BY
32007853 JCB TCAE-55/93 CCV Filter Element 1 53.72 53.72
320A7123 JCB TCAE-55/93 Primary Fuel Filter APPROVED BY Clint Mack 1 27.69 27.69
---f.yvi,Manage' -
ninn-cei ownofrobbin<.
32925683 JCB TCAE-55/93 Safety Air Filter DATE PAID CK# 0 24.73 24.73
320B4420 JCB TCAE-55/93 Oil Filter 1 20.58 20.58
5423719912/2 Compressor Air Cleaner Element 1 13.57 13.57
IS068Q Quart ISO68 Hyd Biodegradable Oil 2 9.42 18.85
ALL PAST DUE INVOICES ARE SUBJECT TO
1 1/2% PER MONTH SERVICE CHARGE
Important Information: Due to fraud attempts any communication for changes of bank account
details have to be confirmed by a call-back with your respective Xylem contact person.

Invoice
II Sold Branch 012 Remit to: Xylem Dewatering Solutions, Inc.
• le m 300 Sigma Driveby: 26717 Network Place
�� Garner, NC 27529 Chicago, IL 60673-1267
Let's Solve Water Tel: [phone] Phone: [phone] (opt 1)
Fax: [phone]
NOTE:Valued customers, please note the NEW remit
godwin FLYGT address change included on this invoice.
S S Cust.No. Invoice Date Invoice No.
O H
L Town of Robbins I Town of Robbins 00012327 09-07-2021 401114399
D PO Box 296 P PO Box 296
Robbins NC 27325-0296 Robbins, NC 27325-0296 Page 2 of 2
T T
0 0
Customer PO Ordered By Contract Date Completed Date W/O Number Sales Order Taken By Payment Terms
Representative
09-03-2021 09-03-2021 712020477 Freddie Hudson, Jr. Freddie Hudson, Jr. Net 30
UNIT EXTENDED
ITEM DESCRIPTION QUANTITY AMOUNT AMOUNT
1540Q Quart Oil 14 4.52 63.31
MILEAGE Mileage 170 2.00 340.00
LABOR Labor Standard Rate 2.50 117.00 292.50
TRAVEL Travel Charge 3.00 0.00 0.00
ALL PAST DUE INVOICES ARE SUBJECT TO Merchandise Labor Shipping Misc.Charges Taxes 1
1 1/2% PER MONTH SERVICE CHARGE $ 926.87 $ 292.50 $ 0.00 $ 340.00 $ 109.16
Important Information: Due to fraud attempts any communication for changes of bank account Total Invoice $ 1,668.53
details have to be confirmed by a call-back with your respective Xylem contact person.

JUSTIFICATION FOR REMISSION REQUEST
Case Number: DV-2021-0185 County: Moore
Assessed Party: Town of Robbins
Permit No.: WQCS00124 Amount Assessed: $1,135.17
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);
c (b) the violator promptly abated continuing environmental damage resulting from the violation(i.e., explain the
steps that you took to correct the violation and prevent future occurrences);
(c) the violation was inadvertent or a result of an accident(i.e., explain why the violation was unavoidable or
something you could not prevent or prepare for);
(d) the violator had not been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary remedial actions (i.e., explain
how payment of the civil penalty will prevent you from performing the activities necessary to achieve
compliance).
EXPLANATION:
7/c- ,(( 5—e f=7&o, __Z-, e ) , ----"2 - _i--1--,-G
4..„......----,0,._,
Clint Mack
Town Manager I
[e-mail]

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
COUNTY OF MOORE
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
) STIPULATION OF FACTS
Town of Robbins )
Robbins Collection System )
)
PERMIT NO. WQCS00124 ) CASE NO. DV-2021-0185
Having been assessed civil penalties totaling$1,135.17 for violation(s)as set forth in the assessment document of the
Division of Water Resources dated December 08,2021,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.
/3 "11-1 !�
This the day of �'G L'7""yD C ,20 7/
SIGNATURE
ADDRESS
RECEIVED /G / /19, rI . /e--ta//1
DEC 16 2021 po
NCDEQ/DWR/NPDcS
TELEPHONE
// - 79� - Z93 > *,`c

ATTACHMENT A
Town of Robbins
CASE NUMBER: DV-2021-0185
PERMIT NO: WQCS00124 REGION: Fayetteville
FACILITY: Robbins Collection System COUNTY: Moore
Other Violations
INCIDENT VIOLATION TOTAL VOLUME PENALTY
NUMBER DATE VIOLATION TYPE VIOLATION DESCRIPTION (GALLONS) AMOUNT
202101860 9/1/2021 CSO/SSO(Sewer Overflow) Discharge without valid permit 1,500 $250.00
202101957 9/22/2021 CSO/SSO(Sewer Overflow) Discharge without valid permit 5,000 $750.00