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HomeMy WebLinkAboutNC0044253_LV-2023-0003 Remission (Request)_20230208February 8, 2023 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. NC0044253 North Carolina Lions Foundation Inc Camp Dogwood WWTP Case No. LV-2023-0003 Catawba County Mr. Pitner, Thank you for allowing the North Carolina Lions Foundation, Inc. the opportunity to respond to the Notice of Violation dated January 6, 2023; received January 9, 2023; regarding the (1) fecal coliform daily maximum exceedance event that occurred at the Camp Dogwood WWTP during the October 2022 monitoring period. On October 27th, the facility received a fecal coliform result of 2419.8/col that exceeded the daily maximum allowable limit of 400/col. Upon discovery, operators responded by ensuring that adequate chlorination was restored to prevent the recurrence of future fecal coliform exceedances. The plant experiences occasional rapid flow events due to the transient nature of the usage of the camp facilities. This has resulted in reduced contact time in the chlorine contact chamber during those instances, preventing adequate chlorination from taking place prior to leaving the effluent. At this time, the plant is utilizing (2) chlorine tablet tube feeders; however we are recommending installing two additional tablet feeders for a total of (4) to ensure that enough chlorine is being supplied. In the meantime, operators have been adding extra chlorine tablets to accommodate. It is always the goal of North Carolina Lions Foundation to remain in compliance with regulations set forth by the Division of Water Resources. The factors contributing to this violation are being addressed 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, CaiLk&IL7114. Carlton Metts North Carolina Lions Foundation, Inc. Camp Dogwood WWTP CC: Daniel Gatewood, Envirolink, Inc. Todd Robinson, Envirolink, Inc. JUSTIFICATION FOR REMISSION REOUEST Case Number: LV-2023-0003 Assessed Party: North Carolina Lions Foundation Inc Permit No.: NC0044253 County: Catawba Amount Assessed: $388.03 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 ofa 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 (Le.. explain how payment of the civil penalty will prevent youfrom performing the activities necessary to achieve compliance). EXPLANATION: On October 27th, the facility received a fecal coliform result of 2419.8/col that exceeded the daily maximum allowable limit of 400/ col. Upon discovery, operators responded by ensuring that adequate chlorination was restored to prevent the recurrence of future fecal coliform exceedances. The plant experiences occasional rapid flow events due to the transient nature of the usage of the camp facilities. This has resulted in reduced contact time in the chlorine contact chamber during those instances, preventing adequate chlorination from taking place prior to leaving the effluent. At this time, the plant is utilizing (2) chlorine tablet tube feeders; however we are recommending installing two additional tablet feeders for a total of (4) to ensure that enough chlorine is being supplied. In the meantime, operators have been adding extra chlorine tablets to accommodate. COUNTY OF CATAWBA ✓ua a aa, a •.aua ♦ a •• ua • • a!\Vl I l•l Ll ♦ 1 f 1L.a �VllL1 f 1 IN THE MATTER OF ASSESSMENT OF CIVIL PENALTIES AGAINST North Carolina Lions Foundation Inc Camp Dogwood WWTP PERMIT NO. NC0044253 ) WAIVER OF RIGHT TO AN ADMINISTRATIVE HEARING AND ) STIPULATION OF FACTS CASE NO. LV-2023-0003 Having been assessed civil penalties totaling $388.03 for violation(s) as set forth in the assessment document of the Division of Water Resources dated January 6.2023, 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 8th day of FEBRUARY 70 23 SIGNATURE ADDRESS 7062 CAMP DOGWOOD DR. SHERRILLS FORD, NC 28673 TELEPHONE (828) 478-2135