NC0020061_Remission request for cases MV-2022-0003, MV-2022-0004_20220314

TOWN OF SPRING HOPE
P.O. Box 87
118 W. Railroad Street
Spring Hope, NC 27882
March 14, 2022
Mr. Scott Vinson
Water Quality Regional Supervisor
Raleigh Regional Office
Division of Water Resources, NCDEQ
1628 Mail Service Center
Raleigh, NC 27699-1628
RE: Town of Spring Hope WWTP
Case # MV-2022-•0003
Case # MV-2022-0004
Permit No. NC0020061
Nash County
Dear Mr. Vinson:
Phone: [phone]I86
Fax: [phone] i 3
NC Dept of Environmental Quality
MAR 2 2 2022
Raleigh Regional Office
The Town of Spring Hope appreciates the opportunity to respond to Case No. MV-2022-
0003 and Case No. MV-2022-0004 dated February 21, 2022. This letter shall serve as the
Town's response, and it is our hope that the additional information provided will result
in no further action by the Division.
Monitoring Violation:
Parameter
Date Frequency Type of Violation
• Ammonia, Total - Quantity 10/2021 2X Monthly Frequency Violation
• Ammonia, Total - Quantity 12/2021 2X Monthly Frequency Violation
Earlier this year, we responded to NOV-2022-MV-0006 and NOV-2022-MV-0018, dated
January 4, 2022, the initial violations for which this penalty assessment derived. As
expressed in our responses after receiving a second violation for the sample monitoring
issue from December 2021 we reviewed sampling procedures and discovered the
operator is pulling the sample in the bottle provided by the lab, with the appended chain
of custody also provided by the lab. Although the operator was pulling for this

2
TOWN OF SPRING HOPE
P.O. Box 87
118 W, Railroad Street
Spring Hope, NC 27882
Phone: [phone]
Fax: [phone]
parameter and the lab was suppling according to the COC, the correct COC was only
being sent once a month instead of twice of a month. We realize that ultimately it is the
operator's responsibility however we do rely on the lab for assistance. The operator has
been supplied with the proper chain of custody internally as to not allow this to happen
in the future.
We are implementing a work order program for sampling schedules in order to assist the
operators with their compliance issues as well as individual sampling plans designed for
each system.
We believe the W WTP's history of compliance demonstrates the Town's commitment to
operating this facility in a responsible manner. Therefore, we respectfully request that
the Division considers these efforts and take no further action. The Town of Spring Hope
has limited resources and we would much more readily utilize these resources to address
utility operations versus civil penalties therefore we ask for remission of penalties. If the
Town of Spring Hope can be of any further assistance or additional information is
needed, please contact me at 252-478-5186.
Sincerely,
Andrew Delonno
Town Manager
Town of Spring Hope
Cc: John Nelson, Area Manager
William Lamnn, WWTP ORC

JUSTIFICATION FOR REMISSION REQUEST
Case Number: MV-2022-0003
Assessed Party: Town of Spring Hope
Penult No,; NC0020061
County: Nash
Amount Assessed; $86,57
Please use this form when requesting remission of this civil penalty. You roust also complete the "Request For Remission,
Waiver of Right to an Administrative 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 tho reasonableness of the amount of the civil penalty assessed, Requesting
remission is not the proper procedure for contesting whether the violation(s) occurred or tho accuracy of any of the factual
statements contained in the civil penalty assessment document Pursuant to N,C.G.S. § 143B-282. I (c), remission of a civil
penalty may be granted only when ono or moro 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 moro of the civil penalty assessment factors in N,C.O,S. 143B-282,1(6) were wrongfully applied to the
detriment of the petitioner (the assessment foams are listed in the civil penalty assessment document);
X (h) 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 en 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 (le„ explain
how payment of the civil penalty will prevent youfrom performing the activities necessary to achieve
compliance).
EXPLANATION: 1
We are implementing a work order program for sampling schedules in order to assist the operators with
their compliance issues as well as individual sampling plans designed for each system

STATE OF NORTH CAROLINA DEPARTMENT OP ENVIItONMENTAI. QUALITY
COUNTY OF NASH
IN THE MATTER OF ASSESSMENT
OF CIVIL. PENALTIES AGAINST
Town of Spring Hope
Spring Hope W WTP
PERMIT NO. NC0020061
) WAIVER OF RIGHT TO AN
) ADMINISTRATIVE HEARING AND
) STIPULATION OF FACTS
) CASE NO. MV-2022-0003
Having been assessed civil penalties totaling $116,57 fur violation(s) as set forth in the assessment document oldie Division
of Water Resources dated Eebruaty 2I, 2022, the undersigned, desiring to seek remission of the civil penalty, does hereby
waive the right to an administrative hearing in the above -stated tnatter 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 dike
notice of assessment,
This the 141h
day of March , 2022
SIGNATURE
ADDRESS
P.O. Box 87
Spring Hope, NC 27882
TELEPHONB
252-478-5186

JUSTIFICATION FOR REMISSION REQUEST
Case Number; MV-2022-0004
Assessed Party: Town of Spring Hope
Perini( Noa NC0020061
County; Nash
Amount Assessed( $86..%.7
Please use this form when requesting remission of this civil penalty. You must also complete the "Request For Remission,
Waiver of Right 10 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 arc 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.t3.S. § 143B-282,I(e), remission of a civil
penalty may be granted only when ono 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, I (b) were wrongfully applied to ttie
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 (1 e., explain the
steps that you took to correct the violation and prcventfuture occurrences);
(c) the violation was inadvertent or a result of an occident (i.e., explain wiry 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 rernediai actions (i.e„ captain
how payment of the civil penalty will prevent you froth performing the activities necessary 10 achieve
compliance).
EXPLANATION:
We are implementing a work order program for sampling schedules in order to assist the operators with their
compliance issues as well as individual sampling plans designed for each system

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
COUNTY OF NASH
IN THE MATTER OF ASSESSMENT
OF CIVIL PENALTIES AGAINST
Town of Spring Hope
Spring Hope WWTP
PERM! I` NO. NC0020061
WAIVER OF RIGHT TO AN
ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
CASE NO. MV-2022-0004
Having been assessed civil penalties totaling $86.57 for violation(s) as set forth in the assessment document of the Division
of Water Resources dated February 21. 2022, the undersigned, desiring to seek remission of the civil penalty, dons hereby
waive tho 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 he submitted to the Director of the Division of Water Resources within thirty (30) days of receipt oldie notice
of assessment, No new evidence in support of a remission request will be allowed after (30) days from the receipt oldie
notice of assessment,
This the 14th
day of
March 20 22
SIGNATURE.
ADDRESS
P.O. Box 87
Spring Hope, NC 27882
TELEPHONE
252-478-5186