NC0044253_Remission (Request)_20230309

March 9, 2023
Andrew H. Pitner, P.G., Assistant Regional Supervisor
Water Quality Regional Operations Section
Mooresville 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. NC0044253
Camp Dogwood WWTP
Case No. LV-2023-0041
Catawba County
Mr. Pitner,
Thank you for allowing the North Carolina Lions Foundation, Inc. the opportunity to respond to the Notice of
Violation dated February 8, 2023; received February 10, 2023; regarding the (2) fecal coliform daily maximum
exceedance events that occurred at the Camp Dogwood WWTP during the November 2022 monitoring period.
On November 2nd and November 16', the facility received fecal coliform results of 2419.6/ 100ml and
488.4/100ml respectively, both of which exceeded the daily maximum allowable limit of 400/100ml. Upon
discovery, operators responded by performing additional chlorination to ensure that the effluent was adequately
disinfected. The plant experiences occasional rapid flow events due to the transient usage of the camp facilities,
which can result in reduced contact time in the chlorine contact chamber during those instances, preventing
adequate chlorination from taking place. As of February 2023, Kemp, Inc. advised that operations staff raise the
V-notch weir at the chlorine contact chamber to increase contact time. The months of January and February 2023
were both compliant for fecal coliform, and no further fecal coliform exceedances have occurred since this time.
Operations staff also received additional training on sampling technique and chlorine addition, and will perform
refresher training annually.
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,
CW�frxo-�w
Carlton Metts
North Carolina Lions Foundation, Inc.
Camp Dogwood WWTP
CC:
Daniel Gatewood, Envirolink, Inc.
Todd Robinson, Envirolink, Inc.

JUSTIFICATION FOR RENUSSION REQUEST
Case Number: LV-2023-0041 County: Catawba
Assessed Party: North Carolina Lions Foundation Inc
Permit No.: NCO044253 Amount Assessed: $633.03
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 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. 14313-282.1(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 November 2nd and November 161h, the facility received fecal coliform results of 2419.6/100ml and 488.4/100ml respectively, both
of which exceeded the daily maximum allowable limit of 400/100ml. Upon discovery, operators responded by performing additional
chlorination to ensure that the effluent was adequately disinfected. The plant experiences occasional rapid flow events due to the
transient usage of the camp facilities, which can result in reduced contact time in the chlorine contact chamber during those instances,
preventing adequate chlorination from taking place. As of February 2023, Kemp, Inc. advised that operations staff raise the V-notch
weir at the chlorine contact chamber to increase contact time. The months of January and February 2023 were both compliant for fecal
coliform, and no further fecal coliform exceedances have occurred since this time. Operations staff also received additional training on
sampling technique and chlorine addition, and will perform refresher training annually.

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
COUNTY OF CATAWBA
IN THE MATIER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
STIPULATION OFFACTS
North Carolina Lions Foundation Inc )
Camp Dogwood WWTP )
PERMIT NO. NCO044253 ) CASE NO. LV-2023-0041
Having been assessed civil penalties totaling $633.03 for violation(s) as set forth in the assessment document of the Division
of Water Resources dated February 8. 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 tharthe'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 ofreceipt 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 9th day of March 2023
ADDRESS
SIGNATURE
7062 Camp Dogwood Drive
Sherrills Ford NC 28673
TELEPHONE
828-478-2135

ATTACHMENT A
North Carolina Lions Foundation Inc
CASE NUMBER: LV-2023-0041
PERMIT: NCO044253
FACILITY: Camp Dogwood WWTP
REGION: Mooresville
COUNTY: Catawba
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
11/2/2022 11-2022 Coliform, Fecal MF, Weekly #/100ml 400 2,419.6 504.9 Daily $275.00
MFC Broth, 44.5 C Maximum
Exceeded
11/16/2022 11-2022 Coliform, Fecal MF, Weekly #/100ml 400 488.4 22.1 Daily $175.00
MFC Broth, 44.5 C Maximum
Exceeded