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HomeMy WebLinkAboutNC0044253_Remission (Request)_20231228December 20, 2023 Subject: Notice of Violation and Assessment of Civil Penalty for Violations of North Carolina General Statute (G.S.) 143-215.l(a)(6) and NPDES Permit No. NC0044253 North Carolina Lions Foundation Inc. Camp Dogwood WWTP Case No. LV-2023-0299 Catawba County Mr. Pitner, Thank you for allowing the North Carolina Lions Foundation, Inc. the opportunity to respond to the Notice of Violation dated November 15, 2023; received November 29, 2023; regarding the (1) fecal coliform daily maximum exceedance event that occurred at the Camp Dogwood WWTP during the August 2023 monitoring period. On August 29th, the facility received a fecal coliform result of 2419.6/col, exceeding the daily maximum allowable limit of 400/col. The day after the sample was collected, operators identified a blockage consisting mainly of cloth -like material and other debris in the pipe between the clarifier outlet and the chlorine tablet feeder. The obstruction resulted from debris entering the influent, a situation likely attributed to visitors at the facility/camp. The operators were unable to predict or proactively plan for this occurrence. This blockage is believed to have caused effluent contamination and reduced disinfection efficiency. Once identified, immediate corrective actions were taken to clear the blockage, and additional chlorination was added to the affected pipe at the effluent sampling point to ensure disinfection. Following these corrective actions, no further fecal coliform exceedances have occurred at the facility. It is always the goal of North Carolina Lions Foundation 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. Sincerely, Carlton Metts North Carolina Lions Foundation, Inc. Camp Dogwood WWTP CC: Todd Robinson, Envirolink, Inc. Crystal Hutchens, Envirolink, Inc. JUSTIFICATION FOR REMISSION REQUEST Case Number: LV-2023-0299 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 of Right to an Administrative Nearing, 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. § 1438-282.1(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 faclors 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 (Le., 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 August 29th, the facility received a fecal coliform result of 2419.6/col, exceeding the daily maximum allowable limit of 400/col. The day after the sample was collected, operators identified a blockage consisting mainly of cloth -like material and other debris in the pipe between the clarifier outlet and the chlorine tablet feeder. The obstruction resulted from debris entering the influent, a situation likely attributed to visitors at the facility/camp. The operators were unable to predict or proactively plan for this occurrence. This blockage is believed to have caused effluent contamination and reduced disinfection efficiency. Once identified, immediate corrective actions were taken to clear the blockage, and additional chlorination was added to the affected pipe at the effluent sampling point to ensure disinfection. Following these corrective actions, no further fecal coliform exceedances have occurred at the facility. 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 OF FACTS North Carolina Lions Foundation Inc ) Camp Dogwood WWTP ) PERMIT NO. NC0044253 ) CASE NO. LV-2023-0 299 Having been assessed ivil penalties totaling $458.03 for violation(s) as set forth in the assessment document of the Division of Water Resources.dated November 15, 2023, the undersigned, •desiringto•seek remission ofthe 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 2111 day of December , 2023. SIGNATURE ADDRESS PO Box 39 7062 Sherrills Ford NC 28673 TELEPHONE 828-478-2135 ATTACHMENT A North Carolina Lions Foundation Inc CASE NUMBER: LV-2023-0299 PERMIT: NCO044253 FACILITY: Camp Dogwood WWTP LIMIT VIOLATION(S) REGION: Mooresville COUNTY: Catawba SAMPLE LOCATION: Outfall 001-Effluent Violation Report Unit of Limit Calculated %Over Violation Penalty Date MonthNr Parameter Frequency Measure Value Value Limit Type Amount 8/29/2023 8-2023 Coliform, Fecal MF, Weekly #/100ml 400 2,419.6 504.9 Daily $275.00 MFC Broth, 44.5 C Maximum Exceeded