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Home My WebLink About10 Notices, Corrective Actions, and Civil PenaltiesDU RHAM 1869 CITY OF MEDICINE C17Y 4F DURHAM Stormwater Services A leather belt with a solid steel truckle and numerous metal compartments placed along its length, the utility belt is one of the fofemost items in the Balman's arsenal against crime. TWO-WAY RADIO (CONCEALED IN BELT SUCKLE) It must be noted that the Gaped Cru- sader s continuously updating and improv- ing the contents of the Wity Melt, so the ao- oompanying illustration shows merely an average sampling of its contents. 8ATARMG ftTS INTO J"PARTMFNT BEHIND BELT I W EWMINB M DRPM LiIIT 13ATMAN118 OF BELT LINING FROM' UTILITY BELT SPRitvG•LQA>DEDREEL r' T >1 0 0U) F= UJI N Z (7 2 C v) o _ W �Q c 0UJ 0 lO X0 in 0 LU 0 Cc M N X DU RHAM 1869 CITY OF MEDICINE s ►1 41► C17Y 4F DURHAM Stormwater Services .�r What's the goal?. COMPLIANCE DU RHAM 1869 CITY OF MEDICINE Types of Notices ,�.1%;.� C17Y 4F DURHAM Stormwater Services D U R H AM DU RHAM a TY OF DURHAM Deportment of Public Works Shvmwntvr Cvrvrvc 101 City Hall Plaza I Durham. NC 27701 919.560.4326 1 F 919.560.4316 1 8 6 9 www.durhamnc.gov NOTICE OF COMPLIANCE Wednesday, December 16, 2015 1 8 6 9 Mr, Michael Fletcher CITY OF MEDICINE United Parcel Service- Durham Facility 3100 Flagstone Dr. Greensboro, INC 27406 Dear Mr. Michael Fletcher. Your opertation is found to be in compliance with Durham's Stormwater Management and Pollution Control Ordinance as a result ofaStormwater inspection ( 15-I5WI.11,Lj conducted by_ Jim Azarelo on 11 1 2015 as allowed by Ordinance 4 70-525. Please be aware that this Notice of Compliance will not excuse any future violations and that follow up inspections may be conducted by our staff at any reasonable time to check for continued compliance. We encourage you to continuously check your operation for potential Stormwater pollution + issues. Should a pollution issue arise that you'd like us to investigate, whether at your operation or elsewhere in the City of Durham, please contact us using our Hotline ` (919) 560-SWIM (79461 or our email Storm WaterQuality@a durhamnc.gay. * Respectfully, Jim Azarelo Stormwater inspector C17Y OF DURHAM (919) 560-4326x30210 Stormwater Services Durham — Where Great Things Happen IV V-q- NU A violation was committed You set a required corrective action and deadline You determine the proposed penalty (using the calculator) You conduct a follow-up and adjust the proposed penalty accordingly Unless the $ spent to correct the violation (after 75% credit) equals or is greater than the penalty amount, there WILL be a penalty Only rain in the storm drain! A violation was committed, OR There is no violation, BUT § 70-511(c) applies You set a required BMP to be completed by a deadline You conduct a follow up to check that the BMP is completed or implemented If the BMP isn't completed or implemented, that's a violation If the thing you wanted fixed could have been a violation, you can now issue an NOV for it www durhamnc. gov/stormwater DU RHAM Options 1869 CITY OF MEDICINE NOV NOR NOR � ►►;►, C17Y 4F DURHAM Stormwater Services DURHAM NOR/NOV Content Requirements 1 8 6 9 1. Location of the property where the violation(s) occurred CITY OF MEDICINE 2. Nature of the violation(s) 3. Description of the remedies and penalties that may be incurred if the violation(s) is not corrected 4. The action(s) needed to correct the violation(s) as well as deadlines for completing the action(s) 5. How to contact a Stormwater Services staff member to discuss +` the violation 4 ►�r`ri 6. How to request a meeting with the director to share explanatory or additional information C17YOFDURHAM 7. The deadline for providing information or requesting a meeting stUlmwater Services ;�� Opportunity to Meet or Provide 1869 CITY OF MEDICINE Evidence • Everyone who gets an NOV/NOR/NOP • Submit within 10 business days - Request for meeting; OR - Exculpatory evidence C17Y OF DURHAM Starmwater Services DURHAM Database Notice Generator • Has all required content built-in 1869 • Fill in the database fields: CITY OF MEDICINE - Names - Addresses - Certified Mail Number - Location of violation - WQ reference number - Date of investigation 4 ►�r`ri - Nature of violation - Required corrective action - Deadline C17Y OF DURHAM Stormwater - Penalty criteria Services DU RHAM 1869 CITY OF MEDICINE ►►;►► C17Y 4F DURHAM Stormwater Services How to issue (serve) a Notice 1. Certified or registered mail, return receipt requested; 2. Hand delivery a. to the individual, if the violator is an individual; b. to an adult at the business or institutional address of the violator if the violator is an entity; 3. Other means in NC Rules of Civil Procedure Rule 4; or 4. First class mail addressed to the violator, if notice of the violation is also posted at the violator's residence or place of business, as may be appropriate. DU RHAM ■ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ■ Print your name and address on the reverse A. Signature Q Agent X ❑ Addressee B. pecelved by ( Printed Name) C. Date of Deuvery SO that we can return the card to you. ■ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to; D. Is deliveryaddress different from item t? Dyes If YES, enter delivery address below: Q No Reggie Redbird 123 State St 1 8 6 9 Normal IL 61761 S Service Type #CedfiedMail ❑ Express Mall ' ered Wetum Receipt for Merchandise CITY OF MEDICINE 01nsu D. 4. Restricted Deliveo (Extra Fee} mail slip 2. Ankle Number (Trsnslerfromservicel # from certified Receipt 102595-021-W1540 ; P February 2004 Domestic Return +Tl r C17Y 4F DURHAM Stormwater Services +l �� rq M rry 1• _ - (I U.S. Postal Serunice - m CERTIFIED MALL... RECEIPT 1'. m MOFFICIAL USE ydMIR r r -.D J Q � F v � IYY�GcykRa A� i �I m ff� Irt*.4 l it. O rLL �fl � G a �Jtlil4 uN1i9 BMifbPOMr�6hm[E I I I I �xahr9w • PM1it your remo, etlCrmq aM bP LaGa F V,k hoe Investigator address! DU RHAM 1869 CITY OF MEDICINE s ► � 1b C17Y 4F DURHAM Stormwater Services Vinintien Tips for Notice Comments Proposed Penalty Automotive: Fluids stored outside without containment and/or cover. (Durham $200.00 City Code Article 5, Division 2, § 70-515 (a)) Corrective Action Deadline 1. 1 - Keep this part simple to read and understand. 2- Use short sentences. Avoid uncommon words. Remember who will be reading the letter. 3- Be specific. Describe the problem so the reader kno-.vs what you're talking about. This also helps you remember what to check on follow-up. 4- Don't tell a violator how to solve a problem. Just specify the end result. 5- Use spell check! You can always print out some photos and include guidance flyers! DURHAM 1869 CITY OF MEDICINE 4 ►�r`ri C17Y OF DURHAM Starmwater Services Typical Corrective Actions • No secondary containment/cover - Dispose of containers; OR - Move containers indoors; OR - Install prefab or build containment/cover • Mobile washing discharge - Get kit for contain, collect, proper disposal and complete compliance demo; OR - Agree to no longer wash cars DURHAM 1869 CITY OF MEDICINE 4 ►�r`ri C17Y OF DURHAM Starmwater Services Typical Corrective Actions • No spill cleanup kit - Purchase preassem bled; or - Purchase components separately • Spill or illicit discharge - Clean up immediately using dry methods if practical - Remove product from affected parts of drainage system DU RHAM Deadlines 1869 CITY OF MEDICINE • Can beset - Solely at your discretion - With input from the responsible party • Granting extensions - Good Faith - Bad Faith/No progress C17Y 4F DURHAM Stormwater Services DURHAM 1869 CITY OF MEDICINE 4 ►�r`ri C17Y OF DURHAM Starmwater Services Corrective actions and 3rd parties • You CAN'T control - a third party, so set careful deadlines - e.g.. contractor hired to build enclosure, Planning Dept. approval, NC DEQ NOR requirements, etc. • You CAN control - when the violator does things like applies for permits or submits site plans - that the violator follow another agency's directions DU RHAM 1869 CITY OF MEDICINE 616 106, C17Y 4F DURHAM Stormwater Services When has your required corrective action been completed? The violation is not corrected until the violation is actually corrected. You could say that it's an iterative process. DURHAM 1869 CITY OF MEDICINE 4 ►�r`ri C17Y OF DURHAM Starmwater Services Record keeping • Print two copies of each Notice - Sign both - One copy to violator, other copy in WQ file • Export the generated Notice to PDF for storage in the investigation server folder W i�� E* PDF DU RHAM 1869 CITY OF MEDICINE Getting the most out of a Notice of Requirement When there just isn't a violation. ..yet. C17Y 4F DURHAM Stormwater Services DU RHAM 1869 CITY OF MEDICINE How would you deal with thms'? 4 �1% 161� v C17Y 4F DURHAM Stormwater Services W T" Pmw" Y -'• :f T-+ .• ~`- DU RHAM 1 8 6 9 Notice of Requirement: CITY OF MEDICINE Do something about those grease drums! • Dispose; or • 2 ° contain & cover; or • Move indoors ■ r C17Y 4F DURHAM Stormwater Services DU RHAM 1869 CITY OF MEDICINE �1% 161� v C17Y 4F DURHAM Stormwater Services How many issues can you spot*.? i Assume this is a first-time issue on property zoned for and used as a residence. DURHAM 1869 CITY OF MEDICINE C17Y 4F DURHAM Stormwater Services Notice of Requirement: Do something about those drums! • Poor condition • Dispose • 20 contain/cover • Labels • Proper lids/bungs • Move inside a �" DU RHAM 1869 CITY OF MEDICINE s ►1 41► C17Y 4F DURHAM Stormwater Services What are the issues here'.? (DATA Bus Maintenance Center @ Fay St.) DU RHAM 1869 CITY OF MEDICINE C17Y 4F DURHAM Stormwater Services Notice of Violation: • Failure to clean up spill • Illicit discharge Additional Required BMPs: 1. Better PM 2. Spill patrol 3. Drain filters/booms 4. Drip trays 0 DU RHAM 1869 CITY OF MEDICINE s ►1 41► C17Y 4F DURHAM Stormwater Services How would you deal with this? Translation. "No. DURHAM Notice of Requirement: ■ Apply for an NPDES permit! ' Have you seen a teenage boy 1 8 6 9 CITY OF MEDICINE traveling with an old man and two droids? C17Y 4F DURHAM Stormwater Services MW "Wrong movie!" Obtain right of entry if Conduct Investigation or Record evidence of **I LA LA necessary Inspection violation(s) Issue NOV/NOR to responsible individual(s) J Conduct Show Cause meeting if requested by violator(s) Set type and terms of remedy and/or penalty Amend violation notice, corrective actions, and/or remedy/penalty according to evidence if necessary Determine corrective action(s) and deadline(s) Issue Notice of Penalty/Remedy to responsible individual(s) Only rain in the storm drain! www durhamnc. gov/stormwater DU RHAM Notice of Penalty Assessment 1869 CITY OF MEDICINE C17Y 4F DURHAM Stormwater Services Total Amount Payable Payment Due Date 1 $41.02 Within 30 days of receipt of this notice City Ordinance § 70-540(2) stales that first-time violators are subject to limited civil penalties. The base penalty for each violation may be up to $500 for residential use properties. S2,000 for non-residential use, and S10,000 for NPDES facilities. After the first offense, violators may be subject to increased penalties. Refer to the attached Civil Penalty Calculation Worksheet for a determination of the total penalty amount. Your check should be made payable to the -City of Durham" with the account number -5500 212009' in the memo area Payment delivery options include- Hana-delivery Stormwater Services 3rd Floor, City Hall Mad: Water Quality Manager Stormwater Services City of Durham 101 City Hall Plaza Durham, INC 27701 If sent by mall or delivery service, the payment should be post -marked within 30 days of receipt of this Notice Call the Water Quality Manager at (919) 560-4326 x30212 to confirm that your payment was received The City is authorized to use civil actions to collect penalties unpaid within 30 days of receipt of a penalty notice issued to a violator. In addition, State Statute permits the City to place liens on any property within the City owned by a violator in the amount of the City's expenditures in remediating illegal discharges Respectfully, Paul Wiebke, PE Assistant Stormwater Manager 919.560.4326 x30239 DURHAM 1869 CITY OF MEDICINE v C17Y OF DURHAM Stormwater Services DURHAM rrrr of DummaM Department of Pudic Works Stormwater Services 101 City Hall Plaza I Durham, NC 27701 919,560.43261 F 919 560 4316 wwwAurhamncgov 1869 rm n.ffxw NOTICE OF PENALTY ASSESSMENT Monday, March 19. 2012 Certified Mail # 7008 1 140 7490 4049 Mr Chris Toth Snappy Lube 112 E Nc Highway 54 Durham- NC 27713 Dear Mr Chris Toth, This Notice is the Director's determination regarding assessment of civil penalties in response to inspection # 12-ISW I-046 conducted on 3114/2012 by Jim A7arelo You are advised to refer to the enclosed copy of the original Notice of violation That Notice was Issued to you as a party responsible for violation(s) of the City of Durham Code of Ordinances Article V Stormwater Management and Pollution Control (the "Ordinance"). Pursuant to Article V. § 70-541 of the Ordinance, as a party responsible for one or more violations observed, you were extended the right to an explanatory meeting with Stormwater Services to discuss the violations. corrective actions- deadlines- and proposed penalties. You also had the right to submit additional information to be considered in setting the amount of penalty in this Notice. You did not request an explanatory meeting. The amount of the civil penalty was determined, per violation, after considering the factors set forth in § 70-540 of the Ordinance (listed below) according to guidelines adopted by the City's Stormwater Services division: 1) The degree and extent of harm to the environment. the public health, public property. and private property; 2) The duration and gravity of the violation: 3) The effect on ground or surface water quality or on air quality or on flood hazard. 4) The cost of rectifying the damage: 5) The amount of money saved by noncompliance: 6) Knowledge of the requirements by the violator, and/or reasonable opportunity or obligation to obtain such knowledge: 7) Whether the violation was willful. 8) Actions taken by the violator to prevent or remediate the Impacts: 9) Whether the violation is a repeat violation. and 10) The costs of enforcement to the city Durham - Where Great Th mas Haoc, DURHAM Penalty Notice Requirements 1 8 6 9 § 70-541(e) Procedures CITY OF MEDICINE - Notice of Penalty MUST contain: • Copy of the Notice of Violation initially issued • The director's written determination regarding the civil penalties to be assessed and the reasons (the calculator summary) ►►�;�� - Proper service is essential C17Y OF DURHAM Starmwater Services DU RHAM 1869 CITY OF MEDICINE lb C17Y 4F DURHAM Stormwater Services Opportunity to Meet or Provide Evidence • Everyone who gets an NOV/NOR/NOP • Submit within 10 business days request for meeting • Or, submit evidence within 10 business days DURHAM 1869 CITY OF MEDICINE CITY 0f UURHAM Stormwater Services Base Penalty Amounts Violation Amount Permits & Plans: Stormwater Pollution Prevention Plan not readily available for inspection. (Durham City Code Article 5, Division 2, § 70-514(a)) $200.00 Permits & Plans: NPDES Permit Certificate of Coverage not readily available for inspection. (Durham City Code Article 5, Division 2, § 70-514(a)) $200.00 Illicit Discharge Prevention: Storage of materials on property in such a manner that may cause a significant illicit discharge. (Durham City Code $200.00 Article 5, Division 2, § 70-511(c)(1)) Tanks Management: Secondary containment and/or cover not in place where necessary. (Durham City Code Article 5, Division 2, § 70-515(a) $200.00 and/or § 70-517) Spill Response: Failure to report a spill to Durham City -County EMS within one working day. (Durham City Code Article 5, Division 2, § 70-511(b) $50.00 and § 70-518(b)) Automotive: Failure to contain and capture vehicle wash water. (Durham City Code Article 5, Division 2, § 70-511(a) & (b)) $175.00 Permits & Plans: Failure to apply for and/or obtain a NPDES stormwater permit or No Exposure exemption. (Durham City Code Article 5, Division $200.00 2, § 70-514(a)) Permits & Plans: Failure to conduct analytical and/or visual stormwater runoff monitoring, as directed by your facility's NPDES permit or by the City $150.00 of Durham. (Durham City Code Article 5, Division 2, § 70-514(a)) Illicit Connection: Existence of a pipe, ditch, or other conveyance that carries process wastewater or wash water to the municipal separate storm $175.00 sewer system or watercourses. (Durham City Code Article 5, Division 2, § 70-512) Permits & Plans: Failure to conduct self -inspections as directed by your facility's NPDES permit or by the City of Durham. (Durham City Code $125.00 Article 5, Division 2, § 70-514(a)) Permits & Plans: Failure to complete Tier 1/2 Responses, as directed by your NPDES Stormwater Permit. (Durham City Code Article 5, Division 2, $100.00 § 70-514) Spill Response: Spill cleanup kit(s) missing and/or inadequately stocked. (Durham City Code Article 5, Division 2, § 70-515(a)) $50.00 Automotive: Parts stored outside without containment and/or cover. (Durham City Code Article 5, Division 2, § 70-515(b)(4)) $200.00 Automotive: Fluids stored outside without containment and/or cover. (Durham City Code Article 5, Division 2, § 70-515(a)) $200.00 Automotive: Automotive service or maintenance being conducted outside shop bays. (Durham City Code Article 5, Division 2, § 70-515(b)(3)) $125.00 Spill Response: Improper/incomplete cleanup of spilled materials. (Durham City Code Article 5, Division 2, § 70-518(a)) $275.00 Permits & Plans: No Stormwater Pollution Prevention Plan developed. (Durham City Code Article 5, Division 2, § 70-511 (c)(1), § 70-514, § 70-516) $200.00 Permits & Plans: Stormwater Pollution Prevention Plan not up to date. (Durham City Code Article 5, Division 2, § 70-514(a)) $50.00 Permits & Plans: Stormwater Pollution Prevention Plan is incomplete. (See comments for details.) (Durham City Code Article 5, Division 2, § 70- $50.00 514(a)) Training: Failure to conduct Stormwater Pollution Prevention Training. (Durham City Code Article 5, Division 2, § 70-511(c)(1)(a)) $100.00 Illicit Discharge: Failure to contain the discharge of a solid, liquid, or gas, other than stormwater either directly or indirectly to the drainage system. $175.00 (Durham City Code Article 5, Division 2, § 70-511(a) & (b)) BMPs: Failure to implement proper Best Management Practices to prevent stormwater pollution. (Durham City Code Article 5, Division 2, Section $100.00 70-511(c)(1)) �uR§70=540(2)(d) -Penalty Adjustment Criteria for assessing penalty. In determiningthe amount of the penalty, the director shall consider the following factors in addition to any factors set forth in guidelines: 1 8 6 9 1. The degree and extent of harm to the environment, the public health, CITY OF MEDICINE public property, and private property; 2. The duration and gravity of the violation; 3. The effect on ground or surface water quality or on air quality or on flood hazard; 4. The cost of rectifying the damage; 5. The amount of money saved by noncompliance; 6. Knowledge of the requirements by the violator, and/or reasonable ►; opportunity or obligation to obtain such knowledge; 4 ►�r`ri 7. Whether the violation was willful; ` 8. Actions taken by the violator to prevent or remediate the impacts; C17Y OF DURHAM g. Whether the violation is a repeat violation; and Starmwater p Services 10. The costs of enforcement to the city. DU RHAM Degree and Extent of Harm 1869 CITY OF MEDICINE A fish kill or similar mass death of wildlife is observed as a result of a violation. The public health is placed at severe risk. There is significant damage to public and/or private property. 2x C17Y 4F DURHAM Stormwater Services Moderate property damage and potential to adversely affect the environment. 1.5x No mass death of wildlife observed as a result of a violation. Violation is unlikely to have detectable harmful effects. No permanent property damage. 1x DURHAM 1869 CITY OF MEDICINE 4 ►�r`ri t C17Y OF DURHAM Starmwater Services Duration and Gravity of the Violation Base Penalty Amount * Number of Days Violation Occurs 1st observation of violation = 1 day N days after deadline without correction = 1+N (must actually observe violation on those days) DURHAM 1869 CITY OF MEDICINE 4 ►�r`ri t C17Y OF DURHAM Starmwater Services Effect on Water/Air Quality Base Penalty Amount * 1 or 2 Must actually find an in -stream violation of Water Quality Standards DURHAM Cost of Rectifying the Damage 1869 CITY OF MEDICINE Responsible Party gets a CREDIT for 75% of qualifying expenses toward taking corrective action. The credit is applied against the total penalty amount. Qualifying expenses: • Waste disposal fees • Cleanup and repair contractor costs • Cost of equipment purchased for the purpose of achieving ►; ; compliance 4 ►�r`ri The City may recover 100% of its expenses incurred C17YOFDURHAM in remediating a violation. StUlmwater Services DU RHAM 1869 CITY OF MEDICINE + ►► 4►► C17Y 4F DURHAM Stormwater Services Cost Avoided by Noncompliance $1,500 $200 $200 $200 $100 $400 $75 $10 $60 $50 $150 $80 When a violator has actually completed the required corrective action, replace the "minimum cost of compliance" penalty criterion with the violator's actual cost if it's less than minimum cost in the table. DURHAM Knowledge of Requirements 1869 CITY OF MEDICINE Violator knew or should have known of the requirements a-L Effect on Penalty 2x Violator was unaware and had no 1x opportunity to learn 4 ►�r`ri t C17Y OF DURHAM Starmwater Services DURHAM Whether the Violation was Willful 1869 CITY OF MEDICINE umv I Effect on Penalty Violator has proven prior compliance or continues 2x wrongdoing despite warning No evidence of willfulness 1 x 4 ►�r`ri t C17Y OF DURHAM Starmwater Services DURHAM 1869 CITY OF MEDICINE 4 ►�r`ri t C17Y OF DURHAM Starmwater Services Actions Taken to Correct Violation Total Penalty Amount * 0.25 Once the Responsible Party completes the required corrective action(s), 25% of the total penalty amount is excused. DURHAM 1869 CITY OF MEDICINE 4 ►�r`ri C17Y OF DURHAM Starmwater Services Repeat Violation 7- At a residential property At a non-residential property Not a repeat violation 2x 1.25x Once the Responsible Party completes the required corrective action(s), 25% of the total penalty amount is excused. DU RHAM 1869 CITY OF MEDICINE v C17Y OF DURHAM Stormwater Services How to calculate Violations I Add Violation I Click here to add a violation for NORs and NOVs 54 rVI-0-lia-It"on., 1 ViolationType Illicit Discharge: Failure to contain the discharge ofa solid, liquid, orgas, otherthan starmwater either directly or indirectlytathe drainage system. (Durham City Cade Article 5, Division 2, § 74511(a)ID 2 Base Penalty (Base): $175.00 Violation of State WQ Standard(C)? No Knowledge of Code (G): No Corrected (J}? No Degree/Extent of Harm (A): Low Violators Cost to Correct (D): $0.00 Amt_ Saved by Violation (F)= $0.00 Repeat Violation (K)? No Duration (# days) (B): 1 Cast to City (E}: $0.00 Willful/Knowing (H)? No or Delete Violation Total Penalty (Base x A x B x C x G x H x K x J+ F- (0.75 x D) + E): $175.00 12j11jZ0154:15:11 PM Edited By James4z Edited When 1 12j11j20154:15:11 PM Created By FJ, e-A.7 Created When DURHAM 1869 CITY OF MEDICINE C17Y 4F DURHAM Stormwater Services Penalty Caps Maximum 1st time base per violation Maximum base per violation thereafter Illicit discharge addition (�1,000 gallons) Repeat violations increase base Non-residential NPDE Use 10:000 $10.000 10 per gallon 25° Non-residen#ial, non-N AIDES Use $_000* 10, 000 10 per gallon 251% *Maximum Total Penalty Amount as sat in § 70-540(2)(b)(3) Residential Use $500 $500 NSA 100% • We have no base penalty in excess of either figure • The penalty calculator is programmed for the repeat violation percent increase DU RHAM 1869 CITY OF MEDICINE C17Y 4F DURHAM Stormwater Services Civil Penalty Collection • Due within 30 days of receipt of the NOP • Finance Dept. handles non-payment issues • All penalty money goes to public schools, per state statute DU RHAM 1869 CITY OF MEDICINE Other Authorized Enforcement Powers C17Y 4F DURHAM Stormwater Services Consent Order I H Injunction Administrative I Abatement Order H Mandatory Criminal Security for Prosecution Compliance I H Termination of I Collection of Utility Service HCivil Penalties Costs Added to Utility Bill Termination of Access Withholding of... approvals