WQ0014306_Assessment of Civil Penalty_PC-2024-0003_20240220

NORTH CAROLINA
FnYhvn rental Quay
Cartifled Mail #7622 1670 0000 9974 6101
Return ReceiRt Reau%W
February 20, 2024
Raymond L Gottlieb, Manager
Sandler Utilities at Mill Run LLC
448 Viking Dr Ste 200
Virginia Beach, VA 23452-7331
SUBJECT: Assessment of Civil Penalty
for Violations of NC General Statute (G.S.) 143-215.1(a)(6)
and Non -discharge Permit No. WQ0014306
Sandler Utilities at Mill Run L L C
Eagle Creek WWTP
Case No. PC-2024-0003
Currituck County
Dear Mr. Gottlieb;
This letter transmits a assessment of civil penalty in the amount of $8,635.36
($8,500.00 civil penalty + $135.36 enforcement costs) against Sandler Utilities at Mill Run L L C.
This assessment is based upon the following facts: an inspection of the Eagle Creek WWTP was conducted on
October 30, 2023. This' inspection was conducted to verify that the facility is operating in compliance with the
conditions and limitations specified in Non -discharge Permit No. WQ0014306. This inspection has shown the
subject facility to be in violation of the conditions and limitations found in Non -discharge Permit No.
WQ0014306. The violations found during the Inspection are summarized in Attachment A to this letter.
Based upon the above facts, I conclude as a matter of law that Sandler Utilities at Mill Run L L C violated the
terms, conditions or requirements of Non -discharge Permit No. WQ0014306 and G.S. 143-215.1(a)(6) in the
manner and extent shown in Attachment A and the provided Findings and Decision and Assessment of Civil
Penalties document. 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).
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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,
David May, Regional Supervisor, Washington Regional Office hereby make the following civil penalty
assessment against Sandler Utilities at Mill Run L L C:
$8,500.00 For 4 violations of the conditions and limitations specified in Permit No.
WQ0014306.
$8,500.06 TOTAL CML PENALTY
$135.36 Enforcement Costs
635.36 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 Environmental Quality (do not include
walver form). Payment of the penalty will not foreclose further enforcement action for any continuing or
new violatlon(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 wrltben request for remission or mitigation lnduding 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 W 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 W 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

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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 §1506-23.2) 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 David May with the Division of Water Resources staff of the
Washington Regional Office at [phone] or via email at [e-mail].
Sincerely,
i'
David May, Regional Supervisor
Water Quality Regional Operations Section
Washington Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS
cc: Laserfiche
NON -DISCHARGE Compliance/Enforcement Unit - Enforcement File

COUNTY OF Currituck
WHIVOINu/1109:1 Z671
Eagle Creek WWTP
Reclaimed Water Generation,
Dedicated Reclaimed Water Utilization, and
High Rate Infiltration System
FOR VIOLATIONS OF
Eagle Creek WWTP
PERMIT No. WQ0014306
NORTH CAROLINA
DEPARTMENT OF
ENVIRONMENTAL QUALITY
PURSUANT TO NORTH CAROLINA
GENERAL STATUE 143-215.1
File No. PC-2024-0003
FINDINGS AND DECISION
AND ASSESSMENTS OF
CIVIL PENALTIES
Acting pursuant to delegation provided by the Secretary of the Department of Environmental
Quality, I, David May, Water Quality Regional Operations Supervisor of the Division of Water
Resources, Washington Regional Office make the following:
L FINDINGS OF FACT:
A. Sandler Utilities at Mill Run, LLC owns and operates the Eagle Creek WWTP Reclaimed
Water Generation, Water Utilization, and High Rate Infiltration System, a wastewater
treatment and disposal system in Currituck County.
B. The Eagle Creek wastewater treatment and disposal system was permitted under Reclaimed
Water Generation, Dedicated Reclaimed Water Utilization, and High Rate Infiltration System
Permit No. WQ0014306 on August 4, 2021, effective upon issuance, with an expiration date
of June 30, 2027.
C. Condition No. I. Schedules, 7. of Permit No. WQ0014306 states that "The gauge to monitor
waste levels in the 5.5 MG high -rate infiltration basin shall be repaired and functional within
60 days of the effective date of this permit. Caution shall be taken not to damage the integrity
of any liner (if present) when installing the gauge. [15A NCAC 02T .0108(b)(1)(B), 02T
.0705(c)]"
D. Condition No.I. Schedules, 10. of Permit No. WQ0014306 states that "Within 1 year of the
effective date of this permit, all trees, shrubs, and other woody vegetation shall be removed
from all earthen dikes and embankments of the 5.5 MG high -rate infiltration basin and the
7.431 MG wet weather storage/irrigation pond to comply with Condition III.17. The
Washington Regional Office shall be notified upon completion of these repairs. [15A NCAC
02T .0108(b)(l)(B), 02U .0801(g)]"
E. Condition No. H. Performance Standards, 1. of Permit No. WQ0014306 states that "The
Permittee shall maintain and operate the subject non -discharge facilities so there is no

discharge to surface waters, nor any contravention of groundwater or surface water standards.
In the event the facilities fail to perform satisfactorily, including the creation of nuisance
conditions due to improper operation and maintenance, the Permittee shall take immediate
corrective actions, including Division required actions, such as the construction of additional
or replacement reclaimed water generation, reclaimed water utilization, and high -rate
infiltration facilities. [15A NCAC 02T .0108(bXIXA)]"
F. Condition No. III., Operation and Maintenance Requirements, 1. of Permit No. WQ0014306
states that "The Permittee shall operate and maintain the subject facilities as a non -discharge
system." [15A NCAC 02T .0700, 02U .0101]"
G. Condition No. III., Operation and Maintenance Requirements, 13. of Permit No. WQ0014306
states that "The Permittee shall dispose or use generated residuals in a Division -approved
manner. [15A NCAC 02T .0708, 02T .1100, 2U .0802]"
H. Condition No. IV. Monitoring and Reporting Requirements, 9. of Permit No. WQ0014306
states that "The Permittee shall maintain a record of all residuals removed from the facility.
The record shall be maintained for five years, and shall be made available to the Division
upon request. This record shall include:
a. Name of the residuals hauler;
b. Non -Discharge permit number authorizing the residuals disposal, or a letter from a
municipality agreeing to accept the residuals;
c. Date the residuals were hauled; and
d. Volume of residuals removed.
[15A NCAC 02T .0708(b), 2U .0802(b)]"
I. On October 30, 2023, the Division of Water Resources (DWR), Water Quality Regional
Operations Section (WQROS), conducted a compliance inspection and noted the following:
No records of sludge hauling or disposal could be provided by the ORC or EnviroLink
The tertiary filter was non -operational and does not contain filter media.
The infiltration basin does not have a properly installed staff gauge.
Woody vegetation was present around the entire perimeter of the infiltration basin.
Reuse water has not been sent to the reuse irrigation pond for at least a year because the
tertiary filter is not operational and the effluent isn't meeting quality requirements for
irrigation on the golf course. All effluent has been directed to the infiltration basin.
The automatic valve that should be connected to and controlled by the turbidity meter to
switch flow between the reuse irrigation pond and the infiltration basin is not operational.
J. The Eagle Creek WWTP facility does not have a valid permit for the above -described
activity.
K. Sandler Utilities at Mill Run, LLC received the November 8, 2023, Notice of
Violation/Notice of Intent to Assess Civil Penalty on November 10, 2023.
L. The cost to the State of the enforcement procedures in this matter totaled $135.36.
Based upon the above Findings of Facts, I make the following:
2

H
CONCLUSIONS OF LAW:
A. Sandler Utilities at Mill Run, LLC is a "person" within the meaning of G. S. 143-215.6A
pursuant to G. S. 143-212(4).
B. Failure to adequately document sludge hauling or disposal is a violation of Conditions III.13.
and IV.9 of Permit No. WQ0014306.
C. Failure to have a properly installed staff gauge is a violation of Condition I. 7. of Permit No.
WQ0014306.
D. Failure to maintain and operate a functional tertiary filter is a violation of Conditions II.1 and
III. 1. of Permit No. WQ0014306.
E. Failure to maintain the infiltration basin in a condition free of woody vegetation is a violation
of Condition I. 10. of Permit No. WQ0014306.
F. Sandler Utilities at Mill Run, LLC may be assessed civil penalties in this matter pursuant to
G.S. 143-215.6A(a)(2), which provides that a civil penalty of not more than twenty-five
thousand dollars ($25,000.00) per violation may be assessed against a person who is required
but fails to act in accordance with the terms, conditions, or requirements of a permit required
by G.S. 143-215.1.
G. The State's enforcement costs in this matter may be assessed against Sandler Utilities at Mill
Run, LLC pursuant to G. S. 143-215.3(a)(9) and G. S. 14313-282.1(bx8).
H. The Regional Office Supervisor of the Division of Water Resources Water Quality Regional
Operations Section, pursuant to delegation provided by the Secretary of the Department of
Environmental Quality and the Director of the Division of Water Resources, has the authority
to assess civil penalties in this matter.
Based upon the above Findings of Facts and Conclusions of Law, I make the following:
III. DECISION:
Accordingly, Sandler Utilities at Mill Run, LLC owner of the Eagle Creek wastewater treatment
and disposal system, is hereby assessed a civil penalty of:
08
$ Q7(% For violating Condition No. III., 13. And IV. 9. of Permit WQ0014306
for being unable to document sludge hauling and disposal.
$
For violating Condition No. I. 7. of Permit WQ0014306 for failure to
have a properly installed staff gauge.
do
$- . oyo r.
For violating Condition No. H. 1. and III. 1. of Permit WQ0014306 for
not having an operational tertiary filter.
oa
For violating Condition No. R.I. of Permit WQ0014306 for the presence
of overgrown woody vegetation around the infiltration basin.
eo
$
TOTAL CIVIL PENALTY
`
Enforcement costs
36
TOTAL AMOUNT DUE

As required by G. S. 143-215.6A(c), in determining the amount of the penalty I have considered
the factors listed 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;
(2) The duration and gravity of the violation;
(3) The effect on ground or surface quantity or quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violation was committed willfully or intentional;
(7) The prior record of the violator in complying or failing to comply with programs over which
the Environmental Management Commission has regulatory authority;
(8) The cost to the State of the enforcement procedures.
r
aa- aaa. y 0
(Date) David May, Supervi hington Regional Office
Water Quality Regional Operations Section
Division of Water Resources
E

JUSTIFICATION FOR REMISSION REOUE�T
Case Number: PC-2024-0003 County: Currituck
Assessed Party: Sandler Utilities at Mill Run L L C
Permit No,: WQ0014306 Amount Assessed: $8,635.36
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 Healing, 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 Asted in the civil penalty
assessment document
(b) the violator promptly abated continuing environmental damage resulting from the violation (Le.,
explain the steps that you took to correct Me 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 firm performing the activities necessary to
achieve compliance).

aa-
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l
STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
COUNTY OF CURRITUCK F
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
Sandier Utilities at Mill Run L L C )
Eagle Creek WWTP )
;i
PERMIT NO. WQ0014306 ) CASE NO. PC-2024-0003
i i
Having been assessed civil penalties totaling $8,635.36 for violation(s) as set forth in the assessment ?#
document of the Division of Water Resources dated February 20, 2024, 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
PERMIT NO: W00014306
FACILITY: Eagle Creek WWTP
VIOLATION
DATE AREA
Sandier Utllitles at MITI Run L L C
CASE NUMBER: PC-2024-0003
REGION: Washington
COUNTY: Currituck
VIOLATION
TYPE VIOLATION DESCRIPTION
PENALTY
AMOUNT
10/302023 End Use -Infiltration Violation detected during Monitoring wells MW1 and MW2 were $0.00
inspection not locked and did not have well ID
labels. This is a violation of Condition
11.3 of Permit No. WQD014306 that
requires the monitoring wells to comply
with the Standards for of Construction
for Wells Other Than Water Supply (15A
NCAC 02C .0108).
10/302023 Record Keeping Violation detected during No records of sludge hauling or $1,000.00
inspection disposal could be provided by the ORC
or Environlink. This is a violation of
Condition 111.13 of Permit No.
WQ0014306 that requires the permittee
to dispose of residuals in a
Division -approved manner. It Is also a
violation of Condition IV.9 of Permit No.
W00014306.that requires the permittee
to maintain a record of all residuals
removed from the facility.
10/302023 End Use -Infiltration Violation detected during The infiltration basin does not have a $1,000.00
inspection property installed staff gauge. The
current one Is not tied to the berm height
by a survey and cannot be used to
accurately measure freeboard. This is a
violation of Condition 1.7 of Permit No.
WQ0014306 that requires to permittee
to properly install a staff gauge at the
infiltration basin within 60 days after the
effective date of the permit (August 4,
2021).
10/302023 Treatment Violation detected during The tertiary filter was non-operabonal. $4,000.00
Inspection The ORC stated that it can only be
operated in manual mode and did not
contain any filter media. He also stated
that it has been In this condition since
he started operating the system, which
is over a year ago. This is a violations of
Conditions 11.1 and 111.1 of Permit No.
W00014036 that require the permittee
to property operate and maintain the
facility and to take immediate corrective
actions if needed to return the facility to
proper operation.

ATTACHMENT A
Sandier Utllities at MITI Run L L C
CASE NUMBER: PC-2024-0003
PERMIT NO: W00014306
REGION: Washington
FACILITY: Fagle Creek WWTP
COUNTY: Currituck
VIOLATION VIOLATION
PENALTY
DATE AREA TYPE
VIOLATION DESCRIPTION AMOUNT
10/30/2023 End Use-Inflltration Violation detected during
Woody vegetation was present around $2,500.00
inspection
the entire perimeter of the Infiltration
basin. This Is a violation of Condition
1.10 of Permit No. WQ0014306 that
requires the permittee to remove all
woody vegetation from around the
Infiltration basin within one year after the
effective date of the permit (August 4,
2021).

DIVISION OF WATER RESOURCES - CIVIL PENALTY ASSESSMENT
Violator: Sandler Utilities at Mill Run LLC
Facility Name: Eagle Creek WWTP
Permit Number: WO0014306
County: Currituck
Case Number: PC-2024-M3
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;
Significant, failure to operate the tertiary filter results in production of lower quality effluent, which is being disposed of
directly into the groundwater system via the infiltration basin. The infiltration basin was not designed to manage 100% of
wastewater disposal needs. Inability to accurately determine water levels in the infiltration basin prevents determination
of whether the basin is functioning properly. Lack of a properly set staff level gauge in the infiltration basin also prevents
determination of whether water levels are such where structural integrity of the basin may be jeopardized, which could
place the structure at risk of failure. Overgrown trees and vegetation on the infiltration dike wall places the structure at
risk, increasing potential for structural failure.
2) The duration and gravity of the violation;
Very Significant, The tertiary filter hasn't worked in more than a year; excessive vegetative growth has been present along
the infiltration basin dike walls for greater than a year; the staff gauge has not been accurately set in over a year; sludge
accumulation has been documented within the wastewater plant during past site inspections. The wastewater system is
designed for primary disposal to be performed via irrigation of reclaimed quality effluent on the golf course. Since
effluent hasn't met reclaimed quality standards over an extended period, all flow has been directed to the infiltration basin,
which is not designed to be used for continuous year around disposal. Management of the system in its current state of
operations is jeopardizing long term viability of the infiltration basin, which is currently serving as the sole means of
disposal.
3) The effect on ground or surface water quantity or quality or on air quality;
Significant, Groundwater monitoring wells in the vicinity of the infiltration basin have shown repeated exceedances of
groundwater quality standards.
4) The cost of rectifying the damage;
Significant, The permittee hasn't conducted a required groundwater assessment to document the extent of groundwater
quality impacts. Groundwater conditions are unlikely to improve until the wastewater treatment plant is managed and
operated in a condition where reclaimed quality effluent is consistently produced. Continued operational practices of
sending all effluent to the infiltration basin could compound groundwater restoration efforts.
5 The amount of money saved by noncompliance;
Very Significant, The perimeter of the infiltration basin is approximately 1,600' long. The estimated cost for clearing the
infiltration dike wall and perimeter by a commercial land management company would be several thousand to tens of
thousands of dollars. The estimated cost to repair or replace the tertiary filter would likely be in the tens to hundreds of
thousands of dollars range., To accurately set the staff gauge to the low point of the dike wall around the infiltration basin
would require some level of survey work to identify the low point. Such would be difficult to complete prior to removal of
vegetation along the dike wall. Survey work and a properly set staff gauge is estimated to cost in the thousands of dollars
range. Without adequate sludge disposal records to fully document sludge management activities, the money saved related
to sludge management and records is unknown.
6) Whether the violation was committed willfully or intentionally;
Very Significant, The permittee has had awareness of operational and compliance issues at the facility for an extended
period of greater than 12 months with action not taken to correct the tertiary filter, staff gauge, or vegetative growth along

the infiltration basin. Although the violations are not considered willful, they are the result of active decisions to not
correct issues related to the tertiary filter, vegetative growth along the infiltration basin dike wall, and the staff gauge. The
facility's November 17, 2023 NOV response indicates the tertiary filter would not be addressed until facility ownership is
transferred.
'n The prior record of the violator in complying or failing to comply with programs over which the
Environmental Management Commission has regulatory authority; and
Very Significant, The WWTP has been chronically out of compliance. The permittee is under a Judicial Order requiring
action to betaken regarding the Eagle Creek sewer collection system since July 2021. Since 2021, the permittee has been
issued approximately 21 civil penalty assessments.
8) The cost to the State of the enforcement procedures.
$135.36
Date
r
olvm 9�5
David May, Region u ' or
Water Quality Regional Operations Section
Washington Regional Office
Division of Water Resources, NCDEQ