NC0021369_MV-2015-0006_20150317

ATA
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory Donald R.van der Vaart
Governor Secretary
Certified Mail#7014 0510 0000 4466 0356
Return Receipt Requested
March 17,2015 RECEIVED/DENR/DWR
MAR 2 0 20Th
Tim Barth,Manager Town
Town of Columbus Water Quality
PO Box 146 Permitting Sectint
Columbus,NC 28722
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 Permit No.NC0021369
Town of Columbus
Columbus WWTP
Case No.MV-2015-0006
Polk County
Dear Permittee:
a
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of$359.26($200.00 civil penalty
+$159.26 enforcement costs)against Town of Columbus. 1
This assessment is based upon the following facts: a review has been conducted of the discharge monitoring report
(DMR) submitted by Town of Columbus for the month of October 2014. This review has shown the subject facility to
be in violation of the discharge limitations and/or monitoring requirements found in NPDES Permit No. NC0021369.
The violations,which occurred in October 2014,are summarized in Attachment A to this letter.
Based upon the above facts, I conclude as a matter of law that Town of Columbus violated the terms, conditions or
requirements of NPDES Permit No. NC0021369 and G.S. 143-215.1(a)(6) in the manner and extent shown in
Attachment A. In accordance with the maximums established by G.S. 143-215.6A(a)(2), a civil penalty may be
assessed against any person who violates the terms, conditions or requirements of a permit required by G.S.
143-215.1(a).
Based upon the above findings of fact and conclusions of law, and in accordance with authority provided by the
Secretary of the Department of Environment and Natural Resources and the Director of the Division of Water
Resources, I, G. Landon Davidson, Regional Supervisor, Asheville Regional Office hereby make the following civil
penalty assessment against Town of Columbus:
2090 U.S.70 Highway.Swannanoa,NC 28778
Phone:[phone] \Internet:www.ncdenr.gov<http://www.ncdenr.gov>
An Equal Opportunity\Affirmative Action Employer-Made in part by recycled paper 7

200.00 for 4 of the 4 failures to properly monitor CHLORINE in violation of NPDES Permit No.
NC0021369.
$200.00 TOTAL CIVIL PENALTY
$159.26 Enforcement Costs
$359.26 TOTAL AMOUNT DUE
Pursuant to G.S. 143-215.6A(c), in determining the amount of the penalty I have taken into account the Findings of Fact
and Conclusions of Law and the factors set forth at G.S. 143B-282.1(b),which are:
(1) The degree and extent of harm to the natural resources of the State, to the public health, or to private property
resulting from the violation;
(2) The duration and gravity of the violation;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violation was committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs over which the Environmental
Management Commission has regulatory authority;and
(8) The cost to the State of the enforcement procedures.
Within thirty(30)days of receipt of this notice,you must do one of the following:
(1) Submit payment of the penalty, OR
(2) Submit a written request for remission,OR
(3) Submit a written request for an administrative hearing
Option 1: Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environment and Natural Resources (do not
include waiver form). Payment of the penalty will not foreclose further enforcement action for any continuing or
new violation(s). Please submit payment to the attention of:
NPDES Compliance/Enforcement Unit
Division of Water Resources
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
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Option 2: Submit a written request for remission or mitigation including a detailed justification for such
request:
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. Because a remission request forecloses the option of an administrative
hearing, such a request must be accompanied by a waiver of your right to an administrative hearing and a stipulation •
and agreement that no factual or legal issues are in dispute. Please prepare a detailed statement that establishes why
you believe the civil penalty should be remitted, and submit it to the Division of Water Resources at the address listed
below. In determining whether a remission request will be approved,the following factors shall be considered:
(1) whether one or more of the civil penalty assessment factors in NCGS 143B-282.1(b)was wrongfully
applied to the detriment of the petitioner;
(2) whether the violator promptly abated continuing environmental damage resulting from the violation;
(3) whether the violation was inadvertent or a result of an accident;
(4) whether the violator had been assessed civil penalties for any previous violations;or
(5) whether payment of the civil penalty will prevent payment for the remaining necessary remedial actions.
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Please note that all evidence presented in support of your request for remission must be submitted in writing. The
Director of the Division of the Division of Water Resources will review your evidence and inform you of his decision
in the matter of your remission request. The response will provide details regarding the case status, directions for
payment, and provision for further appeal of the penalty to the Environmental Management Commission's Committee
on Civil Penalty Remissions (Committee). Please be advised that the Committee cannot consider information that
was not part of the original remission request considered by the Director. Therefore, it is very important that you
prepare a complete and thorough statement in support of your request for remission.
In order to request remission, you must complete and submit the enclosed "Request for Remission of Civil Penalties,
Waiver of Right to an Administrative Hearing, and Stipulation of Facts" form within thirty (30) days of receipt of this
notice. The Division of Water Resources also requests that you complete and submit the enclosed "Justification for
Remission Request."
Both forms should be submitted to the following address:
NPDES Compliance/Enforcement Unit
Division of Water Resources
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
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Option 3: File a petition for an administrative hearing with the Office of Administrative Hearings:
If you wish to contest any statement in the attached assessment document you must file a petition for an
administrative hearing. You may obtain the petition form from the Office of Administrative Hearings. You must file
the petition with the Office of Administrative Hearings within thirty (30) days of receipt of this notice. A petition is
considered filed when it is received in the Office of Administrative Hearings during normal office hours. The Office of
Administrative Hearings accepts filings Monday through Friday between the hours of 8:00 a.m. and 5:00 p.m.,
except for official state holidays. The petition may be filed by facsimile (fax) or electronic mail by an attached file
(with restrictions) - provided the signed original, one (1) copy and a filing fee (if a filing fee is required by NCGS
§150B-23.2) is received in the Office of Administrative Hearings within seven (7) business days following the faxed
or electronic transmission. You should contact the Office of Administrative Hearings with all questions regarding the
filing fee and/or the details of the filing process.
The mailing address and telephone and fax numbers for the Office of Administrative Hearings are as follows:
Office of Administrative Hearings
6714 Mail Service Center
Raleigh,NC 27699-6714
Tel: [phone]
Fax: [phone]
One(1)copy of the petition must also be served on DENR as follows:
Mr. Sam M.Hayes,General Counsel
Department of Environment and Natural Resources
1601 Mail Service Center
Raleigh,North Carolina 27699-1601
Please indicate the case number(as found on page one of this letter)on the petition.
Failure to exercise one of the options above within thirty (30) days of receipt of this letter, as evidenced by an internal
date/time received stamp (not a postmark), will result in this matter being referred to the Attorney General's Office for
collection of the penalty through a civil action. Please be advised that additional penalties may be assessed for violations
that occur after the review period of this assessment.
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If you have any questions, please contact Janet Cantwell with the Division of Water Resources staff of the Asheville
Regional Office at(828)296-4667 or via email at [e-mail].
Sincerely,
for S.Jay Zimmerman,P.G.
Director,Division of Water Resources,NCDENR
By G.Landon Davidson,Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources,NCDENR
ATTACHMENTS
Cc: WQS Asheville Regional Office-Enforcement File (w/attachments)
NPDES Compliance/Enforcement Unit-Enforcement File (w/attachments)
Central Files,Water Quality Section (w/attachments)
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JUSTIFICATION FOR REMISSION REOUEST
Case Number: MV-2015-0006 County: Polk
Assessed Party: Town of Columbus
Permit No.: NC0021369 Amount Assessed: $359.26
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 (ie., 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:

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
COUNTY OF POLK
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
Town of Columbus )
Columbus WWTP )
)
PERMIT NO.NC0021369 ) CASE NO. MV-2015-0006
Having been assessed civil penalties totaling $35926 for violation(s) as set forth in the assessment document of the
Division of Water Resources dated March 17, 2015, 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 day of ,20
SIGNATURE
ADDRESS
TELEPHONE
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ATTACHMENT A
Town of Columbus
CASE NUMBER: MV-2015-0006
PERMIT: NC0021369 FACILITY: Columbus WWTP COUNTY: Polk REGION: Asheville
Monitoring Violations
MONITORING OUTFALL! VIOLATION UNIT OF CALCULATED %OVER
PENALTY REPORT PPI LOCATION PARAMETER DATE FREQUENCY MEASURE LIMIT VALUE LIMIT VIOLATION TYPE
$50.00 10-2014 001 Effluent CHLORINE 10/4/14 2 X week ug/I Frequency Violation
$50.00 10-2014 001 Effluent CHLORINE 10/11/14 2 X week ug/I Frequency Violation
$50.00 10-2014 001 Effluent CHLORINE 10/18/14 2 X week ug/I Frequency Violation
$50.00 10-2014 001 Effluent CHLORINE 10/25/14 2 X week ug/I Frequency Violation
......i i.. . . ...

DIVISION OF WATER RESOURCES-CIVIL PENALTY ASSESSMENT(FILE)
Violator: Town of Columbus/ NC0021369
(October 2014 DMR)
County: Polk
Case Number: MV-2015-0006
8 ASSESSMENT FACTORS
As required by G.S.143-214.6A(c),in determining the amount of the penalty I considered the factors
set out in G.S. 143B-282.1(b),which are:
1) The degree and extent of harm to the natural resources of the State,to the public health,or to
private property resulting from the violation;
All effluent violations may be detrimental to the receiving stream but may not
be immediately quantified.
2) The duration and gravity of the violation;
Four Total Residual Chlorines were not monitored per the NPDES Permit.
3) The effect on ground or surface water quantity or quality or on air quality;
All effluent violations may be detrimental to the receiving stream but may not
be immediately quantified.
4) The cost of rectifying the damage;
The cost is unknown.
5) The amount of money saved by noncompliance;
The amount of money saved would include the cost of the time it would take to
do the sampling and the cost of the lab work to run the samples.
6) Whether the violation was committed willfully or intentionally;
It does not appear to be either.
7) The prior record of the violator in complying or failing to comply with programs over which
the Environmental Management Commission has regulatory authority;and
There have been four civil penalty enforcements in the twelve months prior to
this violation.
8) The cost to the State of the enforcement procedures.
$159.26.
Date G.Landon Davidson,Regional Supervisor
Water Quality Regional Operations Section
03/17/2015 Asheville Regional Office, NCDENR

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EFFLUENT '
NPDES PERMIT NO. NC0021369 DISCHARGE NO. 001 MONTH OCT YEAR 2014
FACILITY NAME_ TOWN OF COLUMBUS WWTP CLASS 2 COUNTY POLK
CERTIFIED LABORATORY(1) ETS CERTIFICATION NO.. _ 600
(list additional laboratories on the backside/page 2 of this form)
OPERATOR IN RESPONSIBLE CHARGE(ORC) ROSSETER GRADE 3 CERT.# 15928
PERSON(S)COLLECTING SAMPLES ROSSETER ORC PHONE_828.894.8236
CHECK BOX IF ORC HAS CHANGED 0 A:3NO FLOW/DISCHARGE FROM SITE• Q
Mail ORIGINAL and ONECOP I l,25_1
ATTN:CENTRAL FILES C 1 1 20 4 x
DIVISION OF WATER QUALITY (S F OPERATOR IN RESPONSIBLE CHARGE) OE A1E 8 2014
1617 MAIL SERVICE CENTER BY THIS SIGNATURE,I CERTIFY THAT THIS REPORT IS G
RALEIGH, NC 27699-1617 ACCURATE AND COMPLETE TO THE BEST OF MY KNOWLEDGE. K N\R]
50050 00010 00400 50060 00310 00610 00530 31616 00300 00600 00665 I I -
W F : FLOW FL a 1 0 8 q Z W ii
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Facility Status:(Please check one of the following)
All monitoring data and sampling frequencies meet permit requirements
(including weekly averages,if applicable) X
Compliant
All monitoring data and sampling frequencies do NOT meet permit requirements
Noncompliant
The permittee shall report to the Director or the appropriate Regional Office any noncompliance that potentially threatens
public health or the environment. Any information shall be provided orally within 24 hours from the time the permittee
became aware of the circumstances. A written submission shall also be provided within 5 days of the time the permittee
becomes aware of the circumstances.
If the facility is noncompliant,please attach a list of corrective actions being taken and a time-table for
improvements to be made as required by Part ILE.6 of the NPDES permit.
"I certify,under penalty of law,that this document and all attachments were prepared under my direction or supervision in
accordance with a system designed to assure that qualified personnel properly gather and evaluate the information
submitted. Based on my inquiry of the person or persons who managed the system,or those persons directly responsible
for gathering the information,the information submitted is,to the best of my knowledge and belief true,accurate,and
complete. I am aware that there are significant penalties for submitting false information,including the possibility of fines
and imprisonment for knowing violations."
Permittee nifty
print or type)
Signature of p'ermittee*** Date
(Required unless submitted electronically)
PO Box 146 Columbus NC 28722 828-894-8236
Permittee Address Phone Number e-mail address Permit Expiration Date
ADDITIONAL CERTIFIED LABORATORIES
Certified Laboratory(2) Certification No.
Certified Laboratory(3) Certification No.
Certified Laboratory(4) Certification No.
Certified Laboratory(5) Certification No.
PARAMETER CODES
Parameter Code assistance may be obtained by calling the NPDES Unit at(919)733-5083 or by visiting the Surface Water
Protection Section's web site at h2o.enr.state.nc.us/wgs and linking to the unit's information pages.
Use only units of measurement designated in the reporting facility's NPDES permit for reporting data.
* No Flow/Discharge From Site: Check this box if no discharge occurs and,as a result,there are no data to be
entered for all of the parameters on the DMR for the entire monitoring period.
** ORC On Site?: ORC must visit facility and document visitation of facility as required per 15A NCAC 8G.0204.
Page 2

WATER QUALITY REGIONAL OPERATIONS
ASHEVILLE REGIONAL OFFICE E;t' =!VD
Division of Water Resources
2090 U.S.HWY 70
SWANNANOA,NC 28778
FEB 1 7 2015
RE:NOTICE OF VIOLATION
#NOV-2015 MV-0008 Water Ouaflty Regional Operations
COLUMBUS WWTP PERMIT#NC0021369 Asheville Regional Office
POLK COUNTY
SIR/MADAM;
I HAVE RECEIVED THE NOTICES OF VIOLATION FOR FAILING TO MONITOR FOR CHLORINE RESIDUAL,
TWO TIMES A WEEK,AND FOR ONE OF THE SEMI-ANNUAL TOTAL PHOSPHORUS AND TOTAL NITROGEN
TESTS AT THE COLUMBUS WWTP.
I HAVE CHECKED BACK THROUGH THE DMR'S AND FOUND THAT THE CHLORINE RESIDUALS AND TOTAL
NITROGEN AND TOTAL PHOSPHORUS IN QUESTION ARE MISSING FROM THE MONTHLY REPORTS.THERE
IS ONE CHLORINE RESIDUAL REPORTED FOR THE WEEKS IN QUESTION,JUST NOT THE TWO AS
REQUIRED.
I AM AT A LOSS TO EXPLAIN WHY MONITORING THE CHLORINE RESIDUAL FELLTO ONCE A WEEK
INSTEAD OF TWO.
THE PLANT WAS UNDER CONSTRUCTION AT THAT TIME,WHICH REQUIRED MUCH OF MY ATTENTION,
AND SOMEHOW I THOUGHT THE REQUIREMENT FOR THE CHLORINE RESIDUAL WAS ONCE PER WEEK.
THE OW LAB BUILDING WAS BEING VACATED AND RECORDS AND DATA WERE BEING MOVED INTO THE
NEW LAB BUILDING.THAT MAY HAVE BEEN WHY,BUT STILL SHOULD HAVE CAUGHT IT.
THE TOTAL NITROGEN AND TOTAL PHOSPHORUS WAS MISSED DUE TO A COPY OF THE PERMIT,DONE IN
HOUSE,AND POSTED AT THE PLANT FOR EASY READING,WAS MISSING THE SECOND SERIES OF TESTS
NEEDED FOR THOSE TWO PARAMETERS.
THE MISSING CHLORINE RESIDUALS,TOTAL PHOSPHORUS AND TOTAL NITROGEN ARE ERRORS ON MY f.
PART AND AS ORC,I TAKE FULL RESPONSIBIUTY.
I HOPE YOU WILL TAKE INTO ACCOUNT MY YEARS OF SERVICE. I HAVE NOT HAD ANY MAJOR MISTAKES
UNTIL THIS.I WAS RESPONSIBLE FOR CONVINCING THE TOWN OF THE NEED FOR AN UPGRADE AT THE
WWTP AS I TAKE THE TREATING OF WASTE WATER SERIOUSLY.
I REGRET THE ERRORS THAT WERE MADE AND WILL MAKE SURE THIS WILL NOT HAPPEN AGAIN.
ROBERT ROSSETER
TOWN OF COLUMBUS WWTP
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