WQCS00010_Remission Request (DV-2022-0136)_20230104

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NORTH CAROLINA'S INTERNATIONAL CITY-
December 28, 2022 RECEIVED
Attn: PERCS Branch CNN 0 4 2023
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617 NCDEQID WRINPDE
RE: Notice of Violation & Intent to Issue Civil Penalty
for Violations of North Carolina General Statute (G.S.) 143-215.1(a)(6)
and Collection System Permit No. WQCS00010
City of High Point
High Point Collection System
Case No. DV-2022-0136
To Whom It May Concern,
This letter is in response to the Notice of Violation and Assessment of Civil Penalty, Case No.: DV-
2022-0136, concerning a Sanitary Sewer Overflow (SSO) that occurred on August 7, 2022, on an
outfall leading to the Shadybrook Lift Station at 3300 Hillside Dr, High Point, Guilford County, North
Carolina.
The City of High Point requests remission of this civil penalty based on the violation was inadvertent or
the result of an accident.
Crews were on site quickly. Additional crews were also called in for assistance with containment and
cleanup.
The wastewater spill was determined to be caused by a bubbler system malfunction at the Shadybrook
Lift Station. The bubbler system malfunction caused incorrect wet well levels to be communicated
through the SCADA system. This was compounded by a failure in the backup level float system that
caused it to fail to alarm as the wet well reached critical levels. The combined communication failure of
both primary and secondary systems caused the SCADA system to display acceptable wet well levels
as well as no alarms despite wastewater backing up in the sewer gravity main.
Once City of High Point crews were dispatched to the spill site and arrived, all pumps in the station
were manually turned on to begin to pump down the level of the wet well and prevent additional
spillage. Plant maintenance crews were called to repair both the primary bubbler system and the
backup float system. By replacing the floats, they were able to restore the communication through
SCADA.
City of High Point, P.O. 230, 211 South Hamilton Street, High Point, NC 27261 USA
Office: 336-883-3691 Fax: [phone] TDD 336.883.8517

2
Both primary and secondary level monitoring systems were inspected by Plant Maintenance crews
within the previous two months of the SSO. They both performed as they should at that time. To
prevent any similar future issues, an alarm was added to the SCADA system to alarm when the pumps
at a lift station have not turned on for a predetermined period regardless of the reported wet well levels.
Additionally, the float system was re-wired to be energized at all times. Potential future failures in any
components in the float system will immediately break the circuit and trigger an alarm which will alert
Plant Maintenance personnel to respond onsite.
City of High Point crews removed all solids and residual debris from the contaminated area of the
Sanitary Sewer Overflow. They excavated the soiled dirt from the area and replaced it with clean stone
and uncontaminated dirt. Crews also laid out lime in the area which raised the pH of the soil to disinfect
it. They additionally flushed the nearby creek with hydrants to dilute the remaining pollution.
A Public Notice was issued immediately to the City of High Point Public Information Office for
publication.
If you have any questions or require further information, please feel free to call me at [phone].
Sincerely,
Sall &ett 7/2crkocy
Sarah Beth McAvoy
ORC VWVCS
cc: Robby Stone- Public Services Director, Derrick Boone-Assistant Public Services Director,
Joseph Holden -W/S Mains Superintendent, Carrie Hyler-Pretreatment Supervisor, File
City of High Point, P.O. 230, 211 South Hamilton Street, High Point, NC 27261 USA
Office: 336-883-3691 Fax: [phone] TDD 336.883.8517

JUSTIFICATION FOR REMISSION REQUEST
Case Number: DV-2022-0136 County: Guilford
•
Assessed Party: City of High Point
Permit No.: WQCS00010 Amount Assessed: $891.41
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);
(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:
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.
STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
COUNTY OF FORSYTH
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
) STIPULATION OF FACTS
City of High Point )
High Point Collection System )
)
PERMIT NO. WQCS00010 ) CASE NO. DV-2022-0136
Having been assessed civil penalties totaling$891.41 for violation(s)as set forth in the assessment document of the
Division of Water Resources dated December 05,2022,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 2_9 -ram day of e c , 20 2,
SIONAURE
ADDRESS
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NCDEQIDWRIF4PDES TELEPHONE
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