NC0046809_Remission Request (LV-2021-0365)_20220218

February 4,2022
Mr. Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources,NCDEQ
R
Subject:Notice of Violation and Assessment of Civil Penalty ECEI VED
for Violations of North Carolina General Statute(G.S.) 143-215.1(a)(6) c.F
and NPDES WW Permit No. NC0046809 8 2022
Western NC Conference Center
Cornerstone Conference and Resource Center WWTP NCDEQ/DWR/NPDES
Case No. LV-2021-0365
Guilford County
Mr. Snider,
Thankyou for allowingCornerstone Conference Center the opportunity to respond to the Notice of Violation dated
PP ty P
January 11,2022;received January 12,2022. Our response below is in regard to the following violations that occurred
during the July 2021 monitoring period.Of concern was(1)BOD daily maximum exceedance;(3)Fecal Coliform daily
maximum exceedances;(1)fecal coliform monthly geometric mean exceedance; and(1)TSS daily maximum exceedance.
The Cornerstone Conference Center WWTP effluent exceeded permit levels for fecal coliform on July 1st and July 28th,
resulting in two daily maximum violations and a monthly geometric mean violation.There were concurrent violations of
BOD and TSS on July 1st.On this date,it was discovered that the return line had become clogged,of which caused pin
floc to leave the clarifier and pass through the effluent,resulting in the violated BOD,TSS,and coliform levels exceeding
the allowable limit. This event triggered the discovery of a hole in the return line,which required contractors to come in
and assess the damage.Contractors responded by pumping the plant down and locating the hole in the line,and returned
on the 28th to begin repairs. Septic company personnel drained the clarifier again to enable the repairs to take place,and
once repairs were completed,it was pumped back in.
In addition to causing disturbances to the plant,the pumping out and refilling of the clarifier posed challenges in the
treatment process.The fecal coliform exceedances that occurred on July 28th and in the repeat sample taken on July 29th
were influenced by the pumping and repair activities taking place at that time.By early August,the sealing of the hole
was complete,and a screen was installed to prevent any further foreign matter from entering the return pipe.
It is always the goal of Cornerstone Conference Center to remain in compliance with regulations set forth by the Division
of Water Resources. The factors contributing to this violation have been addressed carefully to prevent future
noncompliance events. It is our request that our cooperation and action in these matters be taken into account by the
Division when proceeding with enforcement.
Sincerely, )Darrell Gaines
Western NC Conference Center
CC:
Josh Powers,Envirolink, Inc.
Todd Robinson, Envirolink,Inc.
Ronald Wall, Envirolink,Inc.
1

JUSTIFICATION FOR REMISSION REQUEST
Case Number: LV-2021-0365 County: Guilford
Assessed Party: Western NC Conference Center
Permit No.: NC0046809 Amount Assessed: $619.11
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);
x (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);
X (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:
On July 1st, it was discovered that the return line had become clogged,of which caused pin floc to leave the clarifier and pass
through the effluent,resulting in the violated BOD,TSS,and coliform levels exceeding the allowable limit. This event triggered
the discovery of a hole in the return line, which required contractors to come in and assess the damage. Contractors responded by
pumping the plant down and locating the hole in the line,and returned on the 28th to begin repairs. Septic company personnel
drained the clarifier again to enable the repairs to take place,and once repairs were completed, it was pumped back in.
In addition to causing disturbances to the plant,the pumping out and refilling of the clarifier posed challenges in the treatment
process. The fecal coliform exceedances that occurred on July 28th and in the repeat sample taken on July 29th were influenced by
the pumping and repair activities taking place at that time. By early August,the sealing of the hole was complete,and a screen was
installed to prevent any further foreign matter from entering the return pipe.
It is always the goal of Cornerstone Conference Center to remain in compliance with regulations set forth by the Division of Water
Resources. The factors contributing to this violation have been addressed carefully to prevent future noncompliance events. It is our
request that our cooperation and action in these matters be taken into account by the Division when proceeding with enforcement.

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
COUNTY OF GUILFORD
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
) STIPULATION OF FACTS
Western NC Conference Center )
Cornerstone Conference and Resource Center WWTP )
PERMIT NO.NC0046809 ) CASE NO. LV-2021-0365
Having been assessed civil penalties totaling$619.11 for violation(s)as set forth in the assessment document of the Division
of Water Resources dated December 16,2021,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.
"ra
This the 7 day of FE3��t ,207z
SIGNATURE
ADDRESS
RECEIVED testis �5 a,�,�w zQ
r Fg 18 2022 ��� .,� .� T-1,,cr Z -x z
NCDEQ/DWR/NPDES
TELEPHONE
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ATTACHMENT A
Western NC Conference Center
CASE NUMBER: LV-2021-0365
PERMIT: NC0046809 REGION: Winston-Salem
FACILITY: Cornerstone Conference and Resource Center WWTP COUNTY: Guilford
LIMIT VIOLATION(S)
SAMPLE LOCATION: Outran 001 -Effluent
Violation Report Unit of Limit Calculated %Over Violation Penalty
Date Month/Yr Parameter Frequency Measure Value Value Umit Type Amount
7/1/2021 7-2021 BOD,5-Day(20 Deg. Weekly mg/I 45 51.3 14.0 Daily $0.00
C)-Concentration Maximum
Exceeded
7/1/2021 7-2021 Coliform,Fecal MF, Weekly #/100m1 400 600 50.0 Daily $100.00
MFC Broth,44.5 C Maximum
Exceeded
7/28/2021 7-2021 Coliform,Fecal MF, Weekly #/100m1 400 600 50.0 Daily $100.00
MFC Broth,44.5 C Maximum
Exceeded
7/29/2021 7-2021 Coliform, Fecal MF, Weekly #/100m1 400 600 50.0 Daily $0.00
MFC Broth,44.5 C Maximum
Exceeded
7/31/2021 7-2021 Coliform, Fecal MF, Weekly #/100m1 200 249.71 24.9 Monthly $200.00
MFC Broth,44.5 C Geometric
Mean
Exceeded
7/1/2021 7-2021 Solids,Total Weekly mg/I 45 66 46.7 Daily $100.00
Suspended- Maximum
Concentration Exceeded

February 4,2022
Mr. Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources,NCDEQ
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. NC0046809
Western NC Conference Center
Cornerstone Conference and Resource Center WWTP
Case No.LV-2021-0365
Guilford County
Mr. Snider,
Thank you for allowing Cornerstone Conference Center the opportunity to respond to the Notice of Violation dated
January 11,2022;received January 12,2022. Our response below is in regard to the following violations that occurred
during the July 2021 monitoring period.Of concern was(1)BOD daily maximum exceedance;(3)Fecal Coliform daily
maximum exceedances;(1)fecal coliform monthly geometric mean exceedance;and(1)TSS daily maximum exceedance.
The Cornerstone Conference Center WWTP effluent exceeded permit levels for fecal coliform on July 1st and July 28th,
resulting in two daily maximum violations and a monthly geometric mean violation.There were concurrent violations of
BOD and TSS on July 1st.On this date,it was discovered that the return line had become clogged,of which caused pin
floc to leave the clarifier and pass through the effluent,resulting in the violated BOD,TSS,and coliform levels exceeding
the allowable limit. This event triggered the discovery of a hole in the return line,which required contractors to come in
and assess the damage. Contractors responded by pumping the plant down and locating the hole in the line,and returned
on the 28th to begin repairs. Septic company personnel drained the clarifier again to enable the repairs to take place,and
once repairs were completed,it was pumped back in.
In addition to causing disturbances to the plant,the pumping out and refilling of the clarifier posed challenges in the
treatment process. The fecal coliform exceedances that occurred on July 28th and in the repeat sample taken on July 29th
were influenced by the pumping and repair activities taking place at that time. By early August,the sealing of the hole
was complete,and a screen was installed to prevent any further foreign matter from entering the return pipe.
It is always the goal of Cornerstone Conference Center to remain in compliance with regulations set forth by the Division
of Water Resources.The factors contributing to this violation have been addressed carefully to prevent future
noncompliance events. It is our request that our cooperation and action in these matters be taken into account by the
Division when proceeding with enforcement.
Sincerely,
Darrell Gaines
Western NC Conference Center
CC:
Josh Powers,Envirolink, Inc.
Todd Robinson,Envirolink,Inc.
Ronald Wall, Envirolink,Inc.

JUSTIFICATION FOR REMISSION REQUEST
Case Number: LV-2021-0365 County: Guilford
Assessed Party: Western NC Conference Center
Permit No.: NC0046809 Amount Assessed: $619.11
Please use this form when requesting remission of this civil penalty. You must also complete the "Request For Remission,
q g Pe h' P 4
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);
x (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);
x (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:
On July 1st, it was discovered that the return line had become clogged,of which caused pin floc to leave the clarifier and pass
through the effluent,resulting in the violated BOD,TSS,and coliform levels exceeding the allowable limit. This event triggered
the discovery of a hole in the return line,which required contractors to come in and assess the damage. Contractors responded by
pumping the plant down and locating the hole in the line,and returned on the 28th to begin repairs. Septic company personnel
drained the clarifier again to enable the repairs to take place, and once repairs were completed, it was pumped back in.
In addition to causing disturbances to the plant,the pumping out and refilling of the clarifier posed challenges in the treatment
process. The fecal coliform exceedances that occurred on July 28th and in the repeat sample taken on July 29th were influenced by
the pumping and repair activities taking place at that time. By early August,the sealing of the hole was complete, and a screen was
installed to prevent any further foreign matter from entering the return pipe.
It is always the goal of Cornerstone Conference Center to remain in compliance with regulations set forth by the Division of Water
Resources. The factors contributing to this violation have been addressed carefully to prevent future noncompliance events. It is our
request that our cooperation and action in these matters be taken into account by the Division when proceeding with enforcement.

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
COUNTY OF GUILFORD
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
) STIPULATION OF FACTS
Western NC Conference Center )
Cornerstone Conference and Resource Center WWTP )
PERMIT NO.NC0046809 ) CASE NO. LV-2021-0365
Having been assessed civil penalties totaling$619.11 for violation(s)as set forth in the assessment document of the Division
of Water Resources dated December 16,2021,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.
is
This the 7 day of Ce3-lia-1 evat ,20 Z Z
@-ei-J2C2_
SIGNATURE
ADDRESS
']'S`-t G4WCie( n
wlot a+�awVt t4-- i 7 Z
TELEPHONE
336- 65t-1g

ATTACHMENT A
Western NC Conference Center
CASE NUMBER: LV-2021-0365
PERMIT: NC0046809 REGION: Winston-Salem
FACILITY: Cornerstone Conference and Resource Center WWTP COUNTY: Guilford
LIMIT VIOLATION(S)
SAMPLE LOCATION: Outfall 001 -Effluent
Violation Report Unit of Limit Calculated %Over Violation Penalty
Date Month/Yr Parameter Frequency Measure Value Value Limit Type Amount
7/1/2021 7-2021 BOD,5-Day(20 Deg. Weekly mg/I 45 51.3 14.0 Daily $0.00
C)-Concentration Maximum
Exceeded
7/1/2021 7-2021 Coliform, Fecal MF, Weekly #/100m1 400 600 50.0 Daily $100.00
MFC Broth,44.5 C Maximum
Exceeded
7/28/2021 7-2021 Coliform, Fecal MF, Weekly #/100m1 400 600 50.0 Daily $100.00
MFC Broth,44.5 C Maximum
Exceeded
7/29/2021 7-2021 Coliform, Fecal MF, Weekly #/100m1 400 600 50.0 Daily $0.00
MFC Broth,44.5 C Maximum
Exceeded
7/31/2021 7-2021 Coliform, Fecal MF, Weekly #/100m1 200 249.71 24.9 Monthly $200.00
MFC Broth,44.5 C Geometric
Mean
Exceeded
7/1/2021 7-2021 Solids,Total Weekly mg/I 45 66 46.7 Daily $100.00
Suspended- Maximum
Concentration Exceeded