NC0001899_Notice of Violation_20220823

ROY COOPER
Garr
ELIZABETH S. BISER
Secretory
RICHARD E. ROGERS, JR.
Dlreaor
Certified Mail # 7020 3160 0000 4115 4156
Return Receipt Requested
T Chet Mann
City Of Sanford
PO Box 3729
Sanford, NC 27330-3729
NORTH CAROLINA
Envtron nral Quality
August 23, 2022
SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY
Tracking Number: NOV-2022-LV-0575
Permit No. NC0002861
Sanford WTP
Lee County
Dear Permittee:
A review of the June 2022 Discharge Monitoring Report (DMR) for the subject facility revealed the violation(s)
indicated below:
Sample
Location Parameter
Limit Reported
Date Value Value Type of Violation
001 Effluent Copper, Total (as Cu) (01042) 6/14/2022 10.5 10.8 Daily Maximum Exceeded
001 Effluent Copper, Total (as Cu) (01042) 6/30/2022 7.9 10.8 Monthly Average Exceeded
A Notice of Violation/Intent to Issue Civil Penalty is being issued for the noted violation of North Carolina General
Statute (G.S.) 143-215.1 and the facility's NPDES WW Permit. Pursuant to G.S. 143-215.6A, a civil penalty of
not more than twenty-five thousand dollars ($25,000.00) may be assessed against any person who violates or
fails to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S.
143-215.1.
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If you wish to provide additional information regarding the noted violation, request technical assistance, or
discuss overall compliance please respond in writing within ten (10) business day after receipt of this Notice. A
review of your response will be considered along with any information provided on the submitted Monitoring
Report(s). You will then be notified of any civil penalties that may be assessed regarding the violations. If no
response is received in this Office within the 10-day period, a civil penalty assessment may be
prepared.
Remedial actions should have already been taken to correct this problem and prevent further occurrences in the
future. The Division of Water Resources may pursue enforcement action for this and any additional violations of
State law. If the violations are of a continuing nature, not related to operation and/or maintenance problems,
and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by
Consent.
Reminder: Pursuant to Permit Condition 6 in Section E, the Permittee is required to verbally notify the Regional
Office as soon as possible, not to exceed 24 hours, from first knowledge of any non-compliance at
the facility including limit violations, bypasses of, or failure of a treatment unit. A written report may
be required within 5 days if directed by Division staff. Prior notice should be given for anticipated or
potential problems due to planned maintenance activities, taking units off-line, etc.
If you have any questions concerning this matter or to apply for an SOC, please contact Joshua Brigham of
the Raleigh Regional Office at 919-791-4200.
Sincerely,
r( Scott Vinson, Regional Supervisor
/ Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Cc: WQS Raleigh Regional Office - Enforcement File
NPDES Compliance/Enforcement Unit - Enforcement File
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ROY COOPER
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ELIZABEfH S. BISER
senelmy
RICHARD E ROGER5, JR.
Di eor
Certified Mail # 7020 3160 0000 4115 4156
Return Receipt Requested
T Chet Mann
City Of Sanford
PO Box 3729
Sanford, NC 27330-3729
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August 23, tuz
SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY
Tracking Number: NOV-2022-LV-0575
Permit No. NC0002861
Sanford 1NTP
Lee County
Dear Permittee:
A review of the June 2022 Discharge Monitoring Report (DMR) for the subject facility revealed the violation(s)
indicated below:
Limit Exceedance Violation(s):
Sample
Location Parameter
Limit Reported
Date Value Value Type of Vlolation
001 Effluent Copper, Total (as Cu) (01042) 6/14/2022 10.5 10.8 Daily Maximum Exceeded
001 Effluent
Copper, Total (as Cu)1010421. 6/-VVZ 22
7-9 IMR Monthly Average Fxnapded
A Notice of Violation/Intent to Issue C■Complete
Statute (G.S.) 143-215.1 and the facile
hems 1, 2, and 3.
■ Print your name and address on the reverse
not more than twenty-five thousand d
so that we can return the card to you.
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NPDES PERMIT NO.: NC0002861
FACH-TTY NAME: Sanford WTP
OWNER NAME: City Of Sanford
GRADE: PC-1
eDMR PERIOD: 06-2022 (June 2022)
PERMIT VERSION: 4_0
CLASS: PC-1
ORC: Scott Michael Christiansen
ORC HAS CHANGED: No
VERSION: 1.0
PERMIT STATUS: Expired
COUNTY: Lee
ORC CERT NUMBER: 987801
STATUS: Submitted
SAMPLING LOCATION: EFFLUENT DISCHARGE NO.: 001 NO DISCHARGE*: NO
I
mi
•••• No Reporting Reason: ENFRUSE=No Flow-R../Recycle; ENVWTHR=No Visitation -Adverse Weather; NOFLOW=No Flow; HOLIDAY=No Visitation - Holiday
Discharge Monitoring Report - Copy Of Record (COR_NC0002861_Ver 1.0_6_2022.pdf)

NPDES PERMIT NO.: NC0002861
FACHM'Y NAME: Sanford WTP
OWNER NAME: City Of Sanford
GRADE: PC -I
eDMR PERIOD: 06-2022 (luxe 2022)
PERMIT VERSION: 4.0
CLASS: PC -I
ORC: Scott Michael Christiansen
ORC HAS CHANGED: No
VERSION: 1.0
PERMIT STATUS: Expand
COUNTY: Lee
Ls] 1,181013114 A,I liz 1 ] 8;SI3LUJ
STATUS: Submitted
SAMPLING LOCATION: EFFLUENT DISCHARGE NO.: 001 NO DISCHARGE*: NO (Continue)
•^• No Reporting Reason: ENFRUSE=No Flow-ReuelRecycle; ENVW HR- No Visitation - Adverse Weather, NOFLOW=No Flow: HOLIDAY =No Visitation - Holiday
Discharge Monitoring Report - Copy Of Record(COR_NC0002861_Ver_1.0_6_2022.pdf)

NPDES PERMIT NO.: NC0002861
FACILITY NAME: Sanford WTP
OWNER NAME: City Of Sanford
GRADE: PC-1
eDMR PERIOD: 06-2022 (June 2022)
COMPLIANCE STATUS: Non -Compliant
PERMIT VERSION: 4_0
CLASS: PC-1
ORC: Scott Michael Christiansen
ORC HAS CHANGED: No
VERSION: 1.0
CONTACT PHONE #: 777-I804
PERMIT STATUS: Expired
COUNTY: Lee
ORC CERT NUMBER: 987801
STATUS: Submitted
SUBMISSION DATE: 07252022
Electronically Certified by Scott M Christiansen on 2022-07-25 16:54:42.366
ORC/Certifier S i g n a t u r e: S c o t t M Christiansen Phone #:[phone] Date
I certify that this report is accurate and complete to the best of my knowledge.
The pemuttee 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 pemdttee 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. The written submission shall be made as required by part ILE.6 of the
NPDES permit.
Electronically Signed by Scott M Christiansen on 2022-07-25 17:03:38.003
Permittee/Submitter Signature: ***Scott M Christiansen Phone #:919-777-I800 Date
Permittee Address: 7441 Poplar Springs Church Rd Sanford NC 27330 Permit Expiration Date: 07/31/2021
1 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.
CERTIFIED LABORATORIES
LAB NAME: City of Sanford Water Filtration Facility
CERTIFIED LAB #: NC00079
PERSON(s) COLLECTING SAMPLES: C.W. Thompson, Kiefer Christian, Nathan Cotten
PARAMETER CODES
Parameter Code assistance may be obtained by visiting https://deq.nc.gov/abouttdivisions/water-resources/edmr/user-documentation.
FOOTNOTES
Use only units of measurement designated in the reporting facility's NPDES permit for reporting data.
• No Flow/Discharge From Site: YES indicates that No Flow/Discharge occurred and, as a result, no data is reported for any parameter on the DMR for the
cmire monitoring period.
•• ORC on Site?: ORC must visit facility and document visitation of facility as required per 15A NCAC 8G .0204.
••• Signature of Permittee: If signed by other than the pemvttee, then delegation of the signatory authority must be on file with the state per 15A NCAC 2B
.0506(b)(2)(D).
Discharge Monitoring Report - Copy Of Record(COR_NC0002861_Ver_1.0_6_2022.pdf)

NPDES PERMIT NO.: NC0002861 PERMIT VERSION: 4.0 PERMIT STATUS: Expired
FACILITY NAME: Sanford WTP CLASS: PC-1 COUNTY: Lee
OWNER NAME: City Of Sanford ORC: Scott Michael Christiansen ORC CERT NUMBER: 987801
GRADE: PC-1 ORC RAS CHANGED: No
eDMR PERIOD: 06-2022 (June 2022)
Report Comments:
VERSION: 1.0
Copper residual for 6-14-22's sample is 10.8 ug/L, in excess of the Permit's daily max of 10.5 ug/L.
STATUS: Submitted

Permit Enforcement History by Permit
Permit: NC0002861
Facility: Sanford VJTP
Owner:
City Of Sanford
Region: Raleigh
County: Lee
Penalty
Remission
Enforcement
EMC Collection
Has
Assessment
Penalty
Enforcement
Request
Conference
Hearing Memo Sent
Payment
Case
Case Approved
Amount
Costs Damages
Received
Held
Held To AGO
Total Paid
Balance Due
Plan
Closed
LV-2001-0135 05/29/01
$1,000.00
$29.96
$1,029,96
$0.00
No
06/29/01
LV-2005-0140 04/22/05
$1,000.00
$43,60
05/24/05
08/15/05
$1043.60
$0.00
No
11/15/05
LV-2005-0142 04/22/05
$1,250.00
$43,60
05/24/05
08/18/05
$1.293.60
$0.00
No
11/15/05
LV-2021-0119 05/10/21
$250.00
$29.53
$279,53
$0,00
No
06/15/21
Total Cases: 4
$3,500.00
$146.69
$3,646.69
$0.00
Total Penalties:
$3,646.69
Total Penalties after
$3,646.69

� � f
A
Permit NC0002861
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of North Carolina General Statute 143-215.1, other
lawful standards and regulations promulgated and adopted by the North Carolina
Environmental Management Commission, and the Federal Water Pollution Control Act,
as amended, the
City of Sanford
is hereby authorized to discharge wastewater from a facility located at the
Sanford WTP
7441 Poplar Springs Church Road
Northeast of Sanford
Lee County
to receiving waters designated as an unnamed tributary to the Cape Fear River in sub -basin
03-06-07 of the Cape Fear River Basin in accordance with effluent limitations, monitoring
requirements, and other conditions set forth in Parts I, II, III and IV hereof.
This permit shall become effective April 1, 2017.
This permit and authorization to discharge shall expire at midnight on July 31, 2021.
Signed this day March 10, 2017.
S/,d'ay Zimmerman, P.G. Director, Division Division of Water Resources
By Authority of the Environmental Management Commission
Page 1 of 8

Permit NC0002861
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked, and as of this issuance, any previously issued permit bearing this number is no longer
effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the
permit conditions, requirements, terms, and provisions included herein.
The City of Sanford
is hereby authorized to:
1. Continue to discharge filter backwash wastewater from a conventional water
treatment plant. The water treatment plant has a design potable flowrate of 12
MGD. For the period of September 2013 to August 2016, the maximum, monthly
average wastewater discharge was 0.545 MGD.
The facility is at the Sanford WTP, (7441 Poplar Springs Church Road), northeast
of Sanford, in Lee County.
2. Discharge from said treatment works via Outfall 001, at the location specified on
the attached map into an unnamed tributary to the Cape Fear River [18-(4.5)]
currently classified WS-V waters in sub -basin 03-06-07 [HUC: 0303000401] of the
Cape Fear River Basin.
Page 2 of 8

IF
Permit NC0002861
Part I
A. (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
[15A NCAC 02B.0400 et seq., 15A NCAC 02B.0500 et seq.)
Beginning with the effective date of this permit and lasting until expiration, the Permittee is
authorized to discharge treated wastewater from Outfall 001. Such discharges shall be limited
and monitored' by the Permittee as specified below:
EFFLUENT CHARACTERISTICS
Parameter Code
EFFLUENT LIMITATIONS
MONITORING REQUIREMENTS
Monthly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample
Location
Flow 50050
Monitor & Report
Continuous
Recording
Effluent
Total Suspended Solids C0530
30.0 mg/L
45.0 mg/L
Weekly
Grab
Effluent
pH 00400
? 6.0 and < 9.0
standard units
Weekly
Grab
Effluent
Total Residual Chlorine 2 50060
1 17 Ng/L
Weekly
Grab
Effluent
Turbidity 00070
Monitor & Report
Weekly
Grab
Effluent
Total Aluminum 01105
Monitor & Report
Quarterly
Grab
Effluent
Total Manganese 01055
Monitor & Report
Quartedy3
Grab
Effluent
Total Copper ^ 01042
7.9 pg/L
1 10.5 Ng/L
Monthly
Grab
Effluent
Total Zinc 01092
Monitor & Report
Quarterly 3
Grab
Effluent
Total Fluoride 00951
Monitor & Report
Quarterly
Grab
Effluent
Total Hardness (as CaCO3) 00900
Monitor & Report
Quarterly
Grab
Effluent
Ammonia Nitrogen C0610
Monitor & Report
Quarterly
Grab
Effluent
Total Nitrogen (TN) C0600
Monitor & Report
Quarterly
Grab
Effluent
Total Phosphorus (TP) C0665
Monitor & Report
Quarterly
Grab
Effluent
Whole Effluent Toxicity TGP3B
Monitoring
Monitor & Report
Quarterly
Grab
Effluent
Footnotes:
1. The permittee shall submit discharge monitoring reports electronically using the NC DWR's eDMR
application system [see A. (6)].
2. The Division shall consider all effluent TRC values reported below 50 µg/1 to be in compliance with
the permit. However, the Permittee shall continue to record and submit all values reported by a
North Carolina certified laboratory (including field certified[, even if these values fall below 50 µg/l.
3. Monitoring should be performed in conjunction with toxicity testing.
4. See A. (5) for schedule of compliance.
5. Ceriodaphnia dubia 7-day pass/fail test @ 90% concentration. See Condition A. (2.) for toxicity
testing requirements. Toxicity testing should be performed during the months of March, June,
September and December.
THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR VISIBLE FOAM IN OTHER THAN
TRACE AMOUNTS.
Page 3 of 8

Permit NC0002861
A. (2) CHRONIC TOXICITY MONITORING (QUARTERLY)
[15A NCAC 02B.0500 et seq.]
The permittee shall conduct quarterly chronic toxicity tests using test procedures outlined
in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised
December 2010, or subsequent versions.
The effluent concentration defined as treatment two in the procedure document is 90%.
The testing shall be performed as a Ceriodaphnia dubia 7-day pass/fail test. The tests will
be performed during the months of March, June, September and December. These months
signify the first month of each three-month toxicity testing quarter assigned to the facility.
Effluent sampling for this testing must be obtained during representative effluent
discharge and shall be performed at the NPDES permitted final effluent discharge below
all treatment processes.
All toxicity testing results required as part of this permit condition will be entered on the
Effluent Discharge Monitoring Form (MR-1) for the month in which it was performed, using
the parameter code TGP313. Additionally, DWR Form AT-1 (original) is to be sent to the
following address:
Attention: North Carolina Division of Water Resources
Water Sciences Section/Aquatic Toxicology Branch
1621 Mail Service Center
Raleigh, NC 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section no
later than 30 days after the end of the reporting period for which the report is made.
Test data shall be complete and accurate and include all supporting chemical/physical
measurements performed in association with the toxicity tests, as well as all
dose/response data. Total residual chlorine of the effluent toxicity sample must be
measured and reported if chlorine is employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity
monitoring is required, the permittee will complete the information located at the top of
the aquatic toxicity (AT) test form indicating the facility name, permit number, pipe
number, county, and the month/year of the report with the notation of "No Flow" in the
comment area of the form. The report shall be submitted to the Water Sciences Section at
the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is
required, then monthly monitoring will begin immediately. Upon submission of a valid test,
this monthly test requirement will revert to quarterly in the months specified above.
Should any test data from this monitoring requirement or tests performed by the North
Carolina Division of Water Resources indicate potential impacts to the receiving stream,
this permit may be re -opened and modified to include alternate monitoring requirements
or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as
minimum control organism survival, minimum control organism reproduction, and
Page 4 of 8

DIVISION OF WATER RESOURCES - CIVIL PENALTY ASSESSMENT
Violator: City Of Sanford
Facility Name: Sanford WTP
Permit Number: NC0002861
County: Lee
Case Number: LV-2022-0294
ASSESSMENT FACTORS
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;
No known damage to the environment, public health or private property. However, discharging effluent exceeding permit
limits increases risk of adverse impacts to waters of the state.
2) The duration and gravity of the violation;
Total Copper was exceeded 2.9% above the daily average limit on June 14, 2022, Total Copper was exceeded 36.7% above
the Monthly average limit on June 30, 2022.
3) The effect on ground or surface water quantity or quality or on air quality;
The receiving stream for the authorized effluent discharge is an unnamed tributary to the Cape Fear River, classified as
WS-V waters in the Cape Fear River Basin. The effects on water quantity or quality because of these permit limit
exceedances include increased risk to impact waters of the state.
4) The cost of rectifying the damage;
The cost of rectifying the damage is not documented.
5) The amount of money saved by noncompliance;
It is not believed that any money was saved by these violations.
6) Whether the violation was committed willfully or intentionally;
It is not believed that the violations were 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
There have been no penalty assessments issued in the past 12 months to the permittee for violations occurring at Sanford
WTP.
8) The cost to the State of the enforcement procedures.
$47.77
Date IQ Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ

ROY COOPER
Gwemor
ELIZABETH S. BISER
secretary
RICHARD E. ROGERS, JR.
Dfi ttar
Certified Mail # 7020 3160 0000 4115 3234
Return Receipt Requested
T Chet Mann
City Of Sanford
PO Box 3729
Sanford, NC 27330-3729
NORTH CAROLINA
Environmental Quality
November 7, 2022
SUBJECT: Notice of Violation and Assessment of Civil Penalty
for Violations of North Carolina General Statute (G.S.) 143-215.1(ax6)
and NPDES W W Permit No. NC0002861
City Of Sanford
Sanford WTP
Case No. LV-2022-0294
Lee County
Dear Permittee:
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of $1,047.77 ($1,000.00 civil
penalty + $47.77 enforcement costs) against City Of Sanford.
This assessment is based upon the following facts: a review has been conducted of the Discharge Monitoring Report
(DMR) submitted by City Of Sanford for the month of June 2022. This review has shown the subject facility to be in
violation of the discharge limitations and/or monitoring requirements found in NPDES W W Permit No. NC0002861. The
violations, which occurred in June 2022, are summarized in Attachment A to this letter.
Based upon the above facts, 1 conclude as a matter of law that City Of Sanford violated the terms, conditions or
requirements of NPDES W W Permit No. NC0002861 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).
Noah Cardlna Deem-ro of Eavhmommtal QualftY l q oaon o7 Waar Resources
RWM,hi gl WOfte I MOOBarren DrNe I Ra 1,1h.Noah UaAlna27604
919.791.4200

Based upon the above findings of fact and conclusions of law, and in accordance with authority provided by the
Secretary of the Department of Environmental Quality and the Director of the Division of Water Resources, I, Scott
Vinson, Regional Supervisor, Raleigh Regional Office hereby make the following civil penalty assessment against City Of
Sanford:
$0.00 0 of I violations of G.S. 143-215.1(a)(6) and Permit No. NC0002861, by discharging waste water
into the waters of the State in violation of the Permit Daily Maximum for Copper, Total (as Cu)
1 000.00 1 of 1 violations of G.S. 143-215.1(a)(6) and Permit No. NC0002861, by discharging waste water
into the waters of the State in violation of the Permit Monthly Average for Copper, Total (as Cu)
1 000.00 TOTAL CIVIL PENALTY
47.77 Enforcement Costs
1 047.77 TOTAL AMOUNT DUE
Pursuant to G.S. 143-215.6A(c), in determining the amount of the penalty 1 have taken into account the Findings of Fact and
Conclusions of Law and the factors set forth at G.S. 143B-282.I (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 Environmental Quality (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:
Wastewater Branch
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617

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.
Please note that all evidence presented in support of your request for remission must be submitted in writing. The
Director 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:
Wastewater Branch
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617

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 § 15013-23.2) 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:
6714 Mail Service Center
Raleigh, NC 27699 6714
Tel: [phone]
Fax: [phone]
One (1) copy of the petition must also be served on DEQ as follows:
Mr. William F. Lane, General Counsel
Department of Environmental Quality
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.
If you have any questions, please contact Stephanie Goss with the Division of Water Resources staff of the Raleigh
Regional Office at [phone] or via email at [e-mail].
Sincerely,
ld12Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS
Cc: WQS Raleigh Regional Office - Enforcement File
Laserfiche

JUSTIFICATION FOR REMISSION REQUEST
Case Number:
LV-2022-0294
Assessed Party:
City of Sanford
Permit No.:
NC0002861
County: Lee
Amount Assessed: $1,047.77
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. 4 14313-282.1(c), remission of 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 (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:

STATE OF NORTH CAROLINA
COUNTY OF LEE
IN THE MATTER OF ASSESSMENT
OF CIVIL PENALTIES AGAINST
City Of Sanford
Sanford WTP
PERMIT NO. NC0002861
DEPARTMENT OF ENVIRONMENTAL QUALITY
WAIVER OF RIGHT TO AN
ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
CASE NO. LV-2022-0294
Having been assessed civil penalties totaling $1,047.77 for violation(s) as set forth in the assessment document of the
Division of Water Resources dated November 7, 2022, 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

ATTACHMENT A
City Of Sanford
CASE NUMBER: LV-2022-0294
PERMIT: NC0002861
REGION:
Raleigh
FACILITY: Sanford WTP
COUNTY:
Lee
LIMIT VIOLATION(S)
SAMPLE LOCATION: Ouffall 001 - Effluent
Violation Report
Unit of
Limit
Calculated %Over
Violation
Penalty
Date Month/Yr Parameter
Frequency
Measure
Value
Value Limit
Type
Amount
6/142022 6-2022 Copper, Total (as Cu)
Monthly
ugA
10.50
10.8 2.9
Daily
$0.00
Maximum
Exceeded
6/30/2022 6-2022 Copper, Total (as Cu)
Monthly
ugA
7.90
10.8 36.7
Monthly
$1,000.00
Average
Exceeded