NC0020354_CPRC Remission Request Response_20240319

March 19, 2024
North Carolina Department of Environmental Quality
Division of Water Resources
Attn: Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
3800 Barrett Drive
Raleigh, NC 27609
RE: Notice of Violation & Intent to Assess Civil Penalty
Case Number: LM-2024-0007
Permit No. NCO020354
Chatham Park Recovery Center
Chatham County
Dear Ms. Manuel:
This letter is formal request for remission of the Notice of Violations and Assessment of Civil
Penalty from letter dated February 23, 2024, from NCDEQ-DWR. Which was from the original
NOV & Intent to Assess letter of September 14, 2023 regarding the violations that were identified
through the review of discharge monitoring reports (DMRs) for the July 2023 monitoring period.
The letter identified one exceedance for this period and was identified as Daily Maximum
Exceedance for BOD, 5-Day and also identified two Monitoring Violations.
These exceedances for BOD are for low flow conditions and feeding of MicroC (carbon supplement
for biological reaction) which can create elevated BOD levels.
The monitoring violations we take exception with as this week of July 4th was a holiday shortened
week, and historically, sampling frequency is relaxed for holidays and weekends. As July 4th was
observed on Tuesday July 4, 2023 it only allowed for 4 days of sampling for this calendar week.
Thank you again for continuing to work with the Chatham Park Water Recovery Center. We look
forward to working with NCDEQ-DWR in a very positive and proactive manner as we continue to
improve the facility's environmental stewardship. If upon receipt and review of this information
you have any questions or would like to discuss this matter at greater length, please do not hesitate

to contact me at your earliest convenience at [phone] or our engineer, Jimmy Holland, PE,
with McKim and Creed at [phone].
Sincerely,
Chatham Park Investors, LLC
Timothy R. t
Vice President
cc: File

5TI11<ICATION FOR REMISSION REQUEST
Case Number: LM-2024-0007 County: Chatham
Assessed Party: Chatham Park Investors LLC
Permit No.: NCO020354 Amount Assessed: $347.22
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. 143B-282.I (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:
These exceedances for BOD are for low flow conditions and feeding of MicroC (carbon supplement
for biological reaction) which can create elevated BOD levels.
The monitoring violations we take exception with as this week of July 4th was a holiday
shortened week, and historically, sampling frequency is relaxed for holidays and weekends. As
July 4th was observed on Tuesday July 4, 2023 it only allowed for 4 days of sampling for this
calendar week.

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
COUNTY OF CHATHAM
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
} STIPULATION OF FACTS
Chatham Park Investors LLC )
Chatham Park Water Recovery Center )
PERMIT NO. NCO020354 ) CASE NO. LM-2024-0007
Having been assessed civil penalties totaling $347.22 for violation(s) as set forth in the assessment document of the Division
of Water Resources dated February 23, 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
SI AT{3RE
ADDRESS
105 Weston Estates Way
Cary, NC 27513
TELEPHONE
919.481.3000

ATTACHMENT A
Chatham Park Investors LLC
CASE NUMBER: LM-2024-0007
PERMIT: NCO020354
FACILITY: Chatham Park Water Recovery Center
LIMIT VIOLATION(S)
SAMPLE LOCATION: Outfall 0018 -Effluent
REGION: Raleigh
COUNTY: Chatham
Violation
Report
Unit of
Limit
Calculated %Over
Violation
Penalty
Date
Month/Yr Parameter
Frequency
Measure
Value
Value
Limit
Type
Amount
7/3/2023
7-2023 BOD, 5-Day (20 Deg.
5 X week
mg/l
7.50
13.2
76.0
Daily
$233.00
C) - Concentration
Maximum
Exceeded
MONITORING VIOLATION(S)
SAMPLE LOCATION: Outfal10018 - Influent
Violation
Report
Unit of
Limit
Calculated
% Over
Violation
Penalty
Date
Month/Yr Parameter
Frequency
Measure
Value
Value
Limit
Type
Amount
7/1 /2023
7-2023 BOD, 5-Day (20 Deg.
5 X week
mg/I
Frequency
$0.00
C) - Concentration
Violation
7/1/2023
7-2023 Solids, Total
5 X week
mg/I
Frequency
$0,00
Suspended-
Violation
Concentration

March 19, 2024
North Carolina Department of Environmental Quality
Division of Water Resources
Attn: Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
3800 Barrett Drive
Raleigh, NC 27609
RE: Notice of Violation & Intent to Assess Civil Penalty
Case Number: LM-2024-0007
Permit No. NC0020354
Chatham Park Recovery Center
Chatham County
Dear Ms. Manuel:
This letter is formal request for remission of the Notice of Violations and Assessment of Civil
Penalty from letter dated February 23, 2024, from NCDEQ-DWR. Which was from the original
NOV & Intent to Assess letter of September 14, 2023 regarding the violations that were identified
through the review of discharge monitoring reports (DMRs) for the July 2023 monitoring period.
The letter identified one exceedance for this period and was identified as Daily Maximum
Exceedance for BOD, 5-Day and also identified two Monitoring Violations.
These exceedances for BOD are for low flow conditions and feeding of MicroC (carbon supplement
for biological reaction) which can create elevated BOD levels.
The monitoring violations we take exception with as this week of July 4th was a holiday shortened
week, and historically, sampling frequency is relaxed for holidays and weekends. As July 4th was
observed on Tuesday July 4, 2023 it only allowed for 4 days of sampling for this calendar week.
Thank you again for continuing to work with the Chatham Park Water Recovery Center. We look
forward to working with NCDEQ-DWR in a very positive and proactive manner as we continue to
improve the facility's environmental stewardship. If upon receipt and review of this information
you have any questions or would like to discuss this matter at greater length, please do not hesitate

to contact me at your earliest convenience at [phone] or our engineer, Jimmy Holland, PE,
with McKim and Creed at [phone].
Sincerely,
Chatham Park Investors, LLC
Timothy R. Smith
Vice President
cc: File

JUSTIFICATION FOR REMISSION REQUEST
Case Number: LV-2024-0017 County: Chatham
Assessed Party: Chatham Park Investors LLC
Permit No.: NCO020354 Amount Assessed: $1,271.3G
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. § 14313-282. 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. 14313-282. 1 (b) were wrongfully applied to the
detriment of the petitioner (the assessment./actors 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:
These exceedances are contributed to plant start up and bringing plant biology online and working
through operational parameters and operating conditions for proper and efficient plant operations.
During start up many varying conditions are met and takes some time to provide for and propagate the
proper plant biology to maintain efficient and effective treatment. Our operations attempted to
supplement this with seed biology from the Sanford WWTP to help accelerate this process. We also
used this start up to obtain information for proper operation as flows experienced at he plant were
lower than optimal, and also contributed to issues or concerns with start up operations. With an
increase in flow, the plant will be able to more efficiently provide adequate and efficient
treatment.

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
COUNTY OF CHATHAM
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
Chatham Park Investors LLC )
Chatham Park Water Recovery Center )
PERMIT NO. NCO020354 ) CASE NO. LV-2024-0017
Having been assessed civil penalties totaling $1,271.36 for violation(s) as set forth in the assessment document of the
Division of Water Resources dated February 16, 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
irN T(IRE
ADDRESS
105 Weston Estates Way
Cary, NC 27513
TELEPHONE
919.481.3000

ATTACHMENT A
Chatham Park Investors LLC
CASE NUMBER: LV-2024-0017
PERMIT: NCO020354
FACILITY: Chatham Park Water Recovery Center
LIMIT VIOLATION(S)
SAMPLE LOCATION: ❑utfall 001 B - Efflue
Violation Report
Date Month/Yr Parameter
9/30/2022 9-2022 Nitrogen, Nitrate Total
(as N)
9/30/2022 9-2022 Phosphorus, Total (as
P) - Concentration
REGION: Raleigh
COUNTY: Chatham
Unit of
Limit
Calculated
% Over
Frequency
Measure
Value
Value
Limit
Monthly
mg/I
10.20
47.4
364.7
Weekly mg/1 2 5.66 183.2
Violation
Type
Monthly
Average
Exceeded
Quarterly
Average
Exceeded
Penalty
Amount
$582.50
$582.50

March 19, 2024
North Carolina Department of Environmental Quality
Division of Water Resources
Attn: Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
3800 Barrett Drive
Raleigh, NC 27609
RE: Notice of Violation & Assessment of Civil Penalty
Case Number: LV-2024-0022
Permit No. NC0020354
Chatham Park Recovery Center
Chatham County
Dear Ms. Manuel:
This letter is formal request for remission of the Notice of Violations and Assessment of Civil
Penalty from letter dated February 16, 2024 from NCDEQ-DWR. Which was from the original
NOV & Intent to Assess letter of January 31, 2023 regarding the violations that were identified
through the review of discharge monitoring reports (DMRs) for the October 2022 monitoring
period.
The letter identified two exceedances for this period and were identified as Monthly Average
Exceedance for Total Nitrogen and Daily Maximum Exceeded for October 7, 2022 for 5-Day BOD.
These exceedances are contributed to plant start up and bringing plant biology online and working
through operational parameters and operating conditions for proper and efficient plant operations.
During start up many varying conditions are met and takes some time to provide for and
propagate the proper plant biology to maintain efficient and effective treatment. Our operations
attempted to supplement this with seed biology from the Sanford WWTP to help accelerate this
process. We also used this start up to obtain information for proper operation as flows
experienced at he plant were lower than optimal, and also contributed to issues or concerns with
start up operations. With an increase in flow, the plant will be able to more efficiently provide
adequate and efficient treatment.

Thank you again for continuing to work with the Chatham Park Water Recovery Center. We look
forward to working with NCDEQ-DWR in a very positive and proactive manner as we continue to
improve the facility's environmental stewardship. If upon receipt and review of this information
you have any questions or would like to discuss this matter at greater length, please do not hesitate
to contact me at your earliest convenience at [phone] or our engineer, Jimmy Holland, PE,
with McKim and Creed at [phone].
Sincerely,
Chatham Park Investors, LLC
Timothy R. Smith
Vice President
cc: File

March 19, 2024
North Carolina Department of Environmental Quality
Division of Water Resources
Attn: Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
3800 Barrett Drive
Raleigh, NC 27609
RE: Notice of Violation & Assessment of Civil Penalty
Case Number: LV-2024-0023
Chatham Park Recovery Center
Chatham County
Dear Ms. Manuel:
This letter is formal request for remission of the Notice of Violations and Assessment of Civil
Penalty from letter dated February 16, 2024 from NCDEQ-DWR. Which was from the original
NOV & Intent to Assess letter of March 1, 2023 regarding the violations that were identified
through the review of discharge monitoring reports (DMRs) for the December 2022 monitoring
period.
The letter identified one exceedance for this period and was identified as Quarterly Average
Exceeded for Total Phosphorus.
These exceedances are contributed to plant start up and bringing plant biology online and working
through operational parameters and operating conditions for proper and efficient plant operations.
During start up many varying conditions are met and takes some time to provide for and
propagate the proper plant biology to maintain efficient and effective treatment. Our operations
attempted to supplement this with seed biology from the Sanford WWTP to help accelerate this
process. We also used this start up to obtain information for proper operation as flows
experienced at he plant were lower than optimal, and also contributed to issues or concerns with
start up operations. With an increase in flow, the plant will be able to more efficiently provide
adequate and efficient treatment.

Thank you again for continuing to work with the Chatham Park Water Recovery Center. We look
forward to working with NCDEQ-DWR in a very positive and proactive manner as we continue to
improve the facility's environmental stewardship. If upon receipt and review of this information
you have any questions or would like to discuss this matter at greater length, please do not hesitate
to contact me at your earliest convenience at [phone] or our engineer, Jimmy Holland, PE,
with McKim and Creed at [phone].
Sincerely,
Chatham Park Investors, LLC
��I
V V v
Timothy R. Smit
Vice President
cc: File

JUSTIFICATION FOR RMiOIMREQUEST
Case Number: LV-2024-0022 County: Chatham
Assessed Party: Chatham Park Investors LLC
Permit No.: NCO020354 Amount Assessed: 9�21.86
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 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. 1438-282.1(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 chat 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:
These exceedances are contributed to plant start up and bringing plant biology online and working
through operational parameters and operating conditions for proper and efficient plant
operations. During start up many varying conditions are met and takes some time to provide for
and propagate the proper plant biology to maintain efficient and effective treatment. Our
operations attempted to supplement this with seed biology from the Sanford WWTP to help
accelerate this process. We also used this start up to obtain information for proper operation
as flows experienced at he plant were lower than optimal, and also contributed to issues or
concerns with start up operations. With an increase in flow, the plant will be able to more
efficiently provide adequate and efficient treatment.

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
COUNTY OF CHATHAM
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
Chatham Park Investors LLC )
Chatham Park Water Recovery Center )
PERMIT NO. NCO020354 ) CASE NO. LV-2024-0022
Having been assessed civil penalties totaling $921.86 for violation(s) as set forth in the assessment document of the Division
of Water Resources dated February 16, 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
?!GPIATURE
ADDRESS
105 Weston Estates Way
Cary, NC 27513
TELEPHONE
919.481.3000

ATTACHMENT A
Chatham Park Investors LLC
CASE NUMBER: LV-2024-0022
PERMIT: NCO020354
FACILITY: Chatham Park Water Recovery Center
LIMIT VIOLATION(S)
SAMPLE LOCATION: ❑ut#all 001B - Effluent
Violation Report
Date Month/Yr Parameter
10/7/2022 10-2022 BOD, 5-Day (20 Deg.
C) - Concentration
10/31/2022 10-2022 Nitrogen, Nitrate Total
(as N)
REGION: Raleigh
COUNTY: Chatham
Unit of Limit Calculated % Over
Frequency Measure Value Value Limit
5 X week mg/I 7.50 49.1 554.7
Monthly
Violation
Type
Daily
Maximum
Exceeded
mg/I 10.20 36.78 260.5 Monthly
Average
Exceeded
Penalty
Amount
$233.00
$582.50

JUSTIFICATION FOR REMISSION Ri UES'l'
Case Number: LV-2024-0023 County: Chatham
Assessed Party: Chatham Park Investors LLC
Permit No.: NCO020354 Amount Assessed: 428.8G
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. § 14313-282.1(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 f rom performing the activities necessary to achieve
compliance).
EXPLANATION:
These exceedances are contributed to plant start up and bringing plant biology online and working
through operational parameters and operating conditions for proper and efficient plant operations.
During start up many varying conditions are met and takes some time to provide for and propagate the
proper plant biology to maintain efficient and effective treatment. Our operations attempted to
supplement this with seed biology from the Sanford WWTP to help accelerate this process. We also used
this start up to obtain information for proper operation as flows experienced at he plant were lower
than optimal, and also contributed to issues or concerns with start up operations. With an increase in
flow, the plant will be able to more efficiently provide adequate and efficient treatment.

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
COUNTY OF CHATHAM
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
Chatham Park Investors LLC )
Chatham Park Water Recovery Center )
PERMIT NO. NCO020354 ) CASE NO. LV-2024-0023
Having been assessed civil penalties totaling $428.86 for violation(s) as set forth in the assessment document of the Division
of Water Resources dated February 16, 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
�J
S NATURE
ADDRESS
105 Weston Estates Way
Cary, NC 27513
TELEPHONE
919.481.3000

ATTACHMENT A
Chatham Park Investors LLC
CASE NUMBER: LV-2024-0023
PERMIT: NCO020354
FACILITY: Chatham Park Water Recovery Center
LIMIT VIOLATION(S)
SAMPLE LOCATION: Outfall 001 B - Effluent
Violation Report
Date MonthNr Parameter
12/31/2022 12-2022 Phosphorus, Total (as
P) - Concentration
REGION: Raleigh
COUNTY: Chatham
Unit of Limit Calculated % Over Violation
Frequency Measure Value Value Limit Type
Weekly mg/1 2 2.62 31.1 Quarterly
Average
Exceeded
Penalty
Amount
$322.50

March 19, 2024
North Carolina Department of Environmental Quality
Division of Water Resources
Attn: Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
3800 Barrett Drive
Raleigh, NC 27609
RE: Notice of Violation & Assessment of Civil Penalty
Case Number: LV-2024-0042
Permit No. NC0020354
Chatham Park Recovery Center
Chatham County
Dear Ms. Manuel:
This letter is formal request for remission of the Notice of Violations and Assessment of Civil
Penalty from letter dated February 23, 2024 from NCDEQ-DWR. Which was from the original
NOV & Intent to Assess letter of March 1, 2023 regarding the violations that were identified
through the review of discharge monitoring reports (DMRs) for the May 2023 monitoring period.
The letter identified two exceedances for 5-Day BOD with those being Daily Maximum Exceeded
for the dates of May 15 and May 18, 2023.
These exceedances are contributed to regrowth in sample tubing for the composite sampler. This
tubing has been replaced and plant staff will work to maintain an adequate level to operate,
maintain, repair, and test as required to ensure compliance with the terms and conditions of the
NPDES permit.
Thank you again for continuing to work with the Chatham Park Water Recovery Center. We look
forward to working with NCDEQ-DWR in a very positive and proactive manner as we continue to
improve the facility's environmental stewardship. If upon receipt and review of this information
you have any questions or would like to discuss this matter at greater length, please do not hesitate
to contact me at your earliest convenience at [phone] or our engineer, Jimmy Holland, PE,
with McKim and Creed at [phone].

Sincerely,
Chatham Park Investors, LLC
Timothy R. Smith
Vice President
cc: File

JUSTIFICATION FOR REMINSIQN REOUEST
Case Number: LV-2024-0042 County: Chatham
Assessed Party: Chatham Park Investors LLC
Permit No.: NCO020354 Amount Assessed: 1397.22
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. § 14313-282.1(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;
(c) payment of the civil penalty will prevent payment for the remaining necessary remedial actions (i.e., explain
how payment of the civil penally will prevent you from performing the activities necessary to achieve
compliance).
EXPLANATION:
These exceedances are contributed to regrowth in sample tubing for the composite sampler.
This tubing has been replaced and plant staff will work to maintain an adequate level to
operate, maintain, repair, and test as required to ensure compliance with the terms and
conditions of the NPDES permit.

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
COUNTY OF CHATHAM
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
Chatham Park Investors LLC )
Chatham Park Water Recovery Center )
PERMIT NO. NCO020354 ) CASE NO. LV-2024-0042
Having been assessed civil penalties totaling $397.22 for violation(s) as set forth in the assessment document of the Division
of Water Resources dated February 23,2024, 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
f S E ATURE
ADDRESS
105 Weston Estates Way
Cary, NC 27513
TELEPHONE
919.481.3000

ATTACHMENT A
Chatham Park Investors LLC
CASE NUMBER: LV-2024-0042
PERMIT: NCO020354
FACILITY: Chatham Park Water Recovery Center
LIMIT VIOLATION(S)
SAMPLE LOCATION: Outl`0 001B - Effluent
REGION: Raleigh
COUNTY: Chatham
Violation Report Unit of Limit Calculated % Over Violation
Date Month/Yr Parameter Frequency Measure Value Value Limit Type
5/15/2023 5-2023 BOD, 5-Day (20 Deg, 5 X week mg/l 7.50 17.2 129.3 Daily
C) - Concentration Maximum
Exceeded
5/18/2023 5-2023 BOD, 5-Day (20 Deg.
C) - Concentration
5 X week mg/I 7.50
8.3 10.7 Daily
Maximum
Exceeded
Penalty
Amnon}
uts3mu
$0.00

March 19, 2024
North Carolina Department of Environmental Quality
Division of Water Resources
Attn: Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
3800 Barrett Drive
Raleigh, NC 27609
RE: Notice of Violation & Assessment of Civil Penalty
Case Number: LV-2024-0043
Permit No. NC0020354
Chatham Park Recovery Center
Chatham County
Dear Ms. Manuel:
This letter is formal request for remission of the Notice of Violations and Assessment of Civil
Penalty from letter dated February 23, 2024 from NCDEQ-DWR. Which was from the original
NOV & Intent to Assess letter of August 28, 2023 regarding the violations that were identified
through the review of discharge monitoring reports (DMRs) for the June 2023 monitoring period.
The letter identified three exceedances for 5-Day BOD with those being Daily Maximum Exceeded
for the dates of June 1, June 2, and June 12, 2023 and one exceedance for Total Nitrogen Monthly
Average.
These exceedances are contributed to regrowth in sample tubing for the composite sampler. This
tubing has been replaced and plant staff will work to maintain an adequate level to operate,
maintain, repair, and test as required to ensure compliance with the terms and conditions of the
NPDES permit.
Thank you again for continuing to work with the Chatham Park Water Recovery Center. We look
forward to working with NCDEQ-DWR in a very positive and proactive manner as we continue to
improve the facility's environmental stewardship. If upon receipt and review of this information
you have any questions or would like to discuss this matter at greater length, please do not hesitate

to contact me at your earliest convenience at [phone] or our engineer, Jimmy Holland, PE,
with McKim and Creed at [phone].
Sincerely,
Chatham Park Investors, LLC
Timothy R. Smith
Vice President
cc: File

JUSTIFICATION FOR REMISSION REQUEST
Case Number: LV-2024-0043 County: Chatham
Assessed Party: Chatham Park Investors LLC
Permit No.: NCO020354 Amount Assessed: $1,104.72
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. I (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 fusture 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 front performing the activities necessary to achieve
compliance).
EXPLANATION:
These exceedances are contributed to regrowth in sample tubing for the composite sampler due to low flow
conditions at the WWTP. This tubing has been replaced and plant staff will work to maintain an adequate
level to operate, maintain, repair, and test as required to ensure compliance with the terms and
conditions of the NPDES permit.

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
COUNTY OF CHATHAM
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
Chatham Park Investors LLC )
Chatham Park Water Recovery Center )
PERMIT NO. NCO020354 ) CASE NO. I.V-2024-0043
Having been assessed civil penalties totaling $1,104.72 for violation(s) as set forth in the assessment document of the
Division of Water Resources dated February 23, 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
IG ATURE
ADDRESS
105 Weston Estates Way
Cary, NC 27513
TELEPHONE
919.481.3000
,20

ATTACHMENT A
Chatham Park Investors LLC
CASE NUMBER: LV-2024-0043
PERMIT: NCO020354
FACILITY: Chatham Park Water Recovery Center
LIMIT VIOLATION(S)
SAMPLE LOCATION: Outfail 0018 - Effluen
Violation Report
Date Month/Yr Parameter
6/1/2023 6-2023 BOD, 5-Day (20 Deg.
C) - Concentration
6/2/2023 6-2023 BOD, 5-Day (20 Deg
C) - Concentration
6/12/2023 6-2023 BOD, 5-Day (20 Deg.
C) - Concentration
6/30/2023 6-2023 Nitrogen, Nitrate Total
(as N)
REGION: Raleigh
COUNTY: Chatham
Unit of
Limit
Calculated % Over
Violation
Frequency Measure
Value
Value Limit
Type
5 X week mg/I
7.50
7.8 4.0
Daily
Maximum
Exceeded
5 X week mg/I
7.50
8.4 12.0
Daily
Maximum
Exceeded
5 X week mg/I 7.50 15.6 108.0 Daily
Maximum
Exceeded
Monthly mg/I 10.20 23 125.5 Monthly
Average
Exceeded
Penalty
Amount
$0.00
$0.00
$283.00
$707.50