NC0077615_Remission (Request) LV-2023-0084_20230417

April 13, 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 Civil Penalty
for Violations of North Carolina General Statute (G.S.) 143-215.1(a)(6)
and NPDES Permit No. NC0077615
Origin Food Group, LLC
Origin Food Group, LLC WWTP
Case No. LV-2023-0084
Ircdell County
Mr. Pitner,
Thank you for allowing Origin Food Group the opportunity to respond to the Notice of Violation issued March
16, 2023; received March 17, 2023; regarding the fecal coliform daily maximum exceedancc that occurred during
the December 2022 monitoring period.
On December 12, 2022, the plant received a fecal coliform result of 2419.6/col, exceeding the daily maximum
limit of 400/col, which also resulted in a subsequent monthly average exceedance. We believe that there may have
been potential contamination at the sampling point that may have caused fecal coliform contamination. A process
control total residual chlorine was analyzed in the chlorine contact chamber prior to sampling, and it was
determined that chlorine levels were adequate. Going forward, operators are going to continue batch discharging
and collecting process control samples; in addition to resizing the effluent sampling port to provide more control
n sampling technique. No other exceedances or violations occurred during the remainder of the monitoring
period.
It is always the goal of Origin Food Group to remain in compliance with regulations set forth by the Division of
Water Resources. It is our request that our cooperation and action in these matters be taken into account by the
Division when proceeding with enforcement.
Siticerely,
George Buff
Origin Food Group, LLC
CC:
Dennis Murdock, Envirolink, Inc.
Todd Robinson, Envirolink, Inc.

JUSTIFICATION FOR REMISSION REQUEST
Case Number: LV-2023-0084 County: Iredell
Assessed Party: Origin Food Group LLC
Permit No.: NCO077615 Amount Assessed: 1$ ,058.03
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 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. 14313-282.1(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);
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 December 12, 2021 the plant received a fecal coliform result of 2419.6/col, exceeding the daily maximum limit of 400/col, which
also resulted in a subsequcnt monthly average exceedance. We believe that there may have been potential contamination at the
sampling point that may have caused fecal coliform contamination. A process control total residual chlorine was analyzed in the
chlorine contact chamber prior to sampling, and it was determined that chlorine levels were adequate. Going forward, operators are
going to continue batch discharging and collecting process control samples; in addition to resizing the effluent sampling port to provide
more control in sampling technique. No other exccedances or violations occurred during the remainder of the monitoring period.

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
COUNTY OF IREDELL
IN THE MATTER OF ASSESSMENT
)
WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST
)
ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
Origin Food Group LLC
)
Origin Food Group, LLC
)
PERMIT NO. NC0077615
)
CASE NO. LV-2023-0084
Having been assessed civil penalties totaling $1,058.03 for violation(s) as set forth in the assessment document of the
Division of Water Resources dated March 16.2023, 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 day of z `/_lam' / 20 23
SIGNATLkt
ADDRESS
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TELEPHONE
7N - 76�9- 9oof�

ATTACHMENT A
Origin Food Group LLC
CASE NUMBER: LV-2023-0084
PERMIT: NCO077615
FACILITY: Origin Food Group, LLC
REGION: Mooresville
COUNTY: Iredell
LIMIT VIOLATION(S)
SAMPLE LOCATION: Outlall 001 - Effluent
Violation Report Unit of Limit Calculated %Over Violation Penalty
Date Month/Yr Parameter Frequency Measure Value Value Limit Type Amount
12/12/2022 12-2022 Colifonn, Fecal MF, Weekly #1100ml 400 2,419.6 504.9 Daily $250.00
MFC Broth, 44.5 C Maximum
Exceeded
12/31/2022 12-2022 Colifonn, Fecal MF, Weekly #/100m1 200 2,419.6 1,109.8 Monthly $625.00
MFC Broth, 44.5 C Geometric
Mean
Exceeded