NC0044253_Response to NOV-2023-LV-0087_20230329

March 29, 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. NCO044253
North Carolina Lions Foundation Inc
Camp Dogwood WWTP
Case No. LV-2023-0087
Catawba County
Mr. Pitner,
Thank you for allowing the North Carolina Lions Foundation, Inc. the opportunity to respond to the Notice of
Violation dated March 16, 2023; received March 20, 2023; regarding the (1) fecal coliform daily maximum
exceedance event that occurred at the Camp Dogwood WWTP during the December 2022 monitoring period.
On December 28th, 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. 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,
d"441-1VI Maw -
Carlton Metts
North Carolina Lions Foundation, Inc.
Camp Dogwood WWTP
CC:
Daniel Gatewood, Envirolink, Inc.
Todd Robinson, Envirolink, Inc.

JUSTIFICATION FOR REMISSION REQUEST
Case Number: LV-2023-0087 County: Catawba
Assessed Party: North Carolina Lions Foundation Inc
Permit No.: NCO044253 Amount Assessed: $458.03
Please use this form when requesting remission of this civil penalty. You must also complete the "Request For Remission,
Waiver ofRight to an Administrative Hearing, and Stipulation ofFacts" 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 maybe 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. 143 B-282. I (b) were wrongfully applied to the
detriment of the petitioner (the assessmentfactors are listed in the civilpenalty 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 andpreventfuture occurrences);
(c) the violation was inadvertent or a result of an accident (Le., explain why the violation was unavoidable or
something you could not prevent or preparefor);
(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
howpayment ofthe civilpenalty will prevent youftom performing the activities necessary to achieve
compliance).
RNPLANATION:
On December 28th, 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. 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-2023-0087
Having been assessed civil penalties totaling $458.03 for violation(s) as set forth in the assessment document of the Division
of Water Resources dated March 16, 2023.1 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 am 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 29 day of MARCH
2023
&b41V' M"Mr—SIGNATURE
ADDRESS
7062 CAMP DOGWOOD DR
SHERRILLS FORD, NC 28673
TELEPHONE
[phone]