NC0043532_Enforcement_20110628

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
September 29, 2011
CERTIF 'FD MAIL 7009 1680 0002 2464 9860
RETURN RECEIPT REQUESTED
The Honorable Joyce H. Little
Town of Oakboro
P.O.Box 610
0akboro, NC 28129
Subject; Remission Request of Civil. Penalty Assessment
NPDES Permit Number NC0043532
Town of ©akboro WWTP
Stanly County
Case Number LV-2011.0177
Dear Mayor Little:
In accordance with North Carolina General Statute 143-215:6A(f), the Director of the North Carolina
Division of Water Quality considered the information you submitted in support of your request for
remission and remitted $2,250.00 of the $2,336.74 civil penalty assessment. The revised amount due is
$86.74, for the investigative costs. A copy of the Director's decision is attached.
Two options are available to you at this stage of the remission process:
You may pay the penalty.
If you decide to pay the penalty please make your check payable to the Department of Environ
Natural Resources (DENR). Send the payment within thirty (30) calendar days of your receipt o
letter to the attention of:
Bob Sledge
NC DENR-DWQ — Point Source Branch
Compliance & Expedited Permits Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
OR
1617 Mail Service Center, Raleigh, North Carolina 27699.1617
Location:512 N, Salisbury St. Raleigh, North Carolina 27604
Phone:919-8©7-63001 FAX: [phone] Customer Service: 1-877-623-6748
Internet: www.ncwaterquality.org
An Equal opportunity k Affirmative Action Employer
nt and
One.
NorthCarolina
Natifiray

Mayor Joyce :I1., Little
LV-201 1-0177 Remission Decision.
p. 2
You may decide to have the En ironnnental Management Corrrrnission's (EMC) Committee on
Civil Penalty Remissions make the final decision on your remission request.
If payment is not: received within 30 calendar days from your receipt of this letter your request for
remission with supporting documents and the recommendation of the Director of the North Carolina
Division of Water Quality will be delivered to the Committee on Civil Penalty Remissions for final
agency decision,
If you or your representative would like to speak before the (Tornmitt ee, you must complete and, return
the attached Request for Oral Presentation Form within thirty (30) ea
Send the completed form to:
Bob Sledge
NC DENR-DWQ -. - Point Source :Branch
Compliance & Expedited Permits Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
dar days of receipt of this letter.
The -EMC Chairman will review the supporting documents and your request for an oral presentatio
you make the request). If the Chairman determines that there is a compelling reason to require a
presentation, you will be notified of when and where you should appear. If a presentation is not
required, the final decision will be based upon the written record.
(i f
Please be advised that the ENIC's Ccrrmmittee on Civil Penalty Remissions will make its remission
decision based on the original assessment amount. Therefore, the EMC may choose to uphold the
original penalty amount and offer no remission, they may agree with the DWQ Director's
remission recommendation detailed above, or the penalty amount may be further remitted.
Thank you for your cooperation in this matter. If you have any questions, please contact Bob Sledge at
[phone], or via e-mail at boh,[e-mail].
Sincerely,
crhn E. Hennessy, Supervisor
Compliance & Expedited. Permits Unit
Attachments
cc: Mooresville Regional Office — SWP Section
Enforcement File
DWQ Central Files

DIVISION OF WATER QUALITY
CIVIL PENALTY REMISSION FACTORS
Case Number: LV-2011-0177 Region: Mooresville County: Stanly
Assessed Entity: Town of Oakboro WWTP Permit: NC0043532
fl (a) Whether one or more of the civil penalty assessment factors were wrongly applied to the
detritnent of the petitioner:
(b) Whether the violator promptly abated continuing environmental damage resulting from
the violation:
The facility employed a Grade 4 operator, who immediately began to take steps toward evaluation of the
problem and its resolution. Process control was increased, the collection system was sampled, the WWTP
was reseeded, an unused aeration basin was brought back into service, and all available resources were
utilized, including DWQ technical assistance and community service worker labor. The circumstances of
the TRC violation was diagnosed and addressed to lessen the chance or reoccurrence.
It is clear that upon its awareness of the magnitude of the noncompliance, the Town took appropriate
steps to correct the problem. The nature of the problem accounts for the extended period of time it took
to regain compliance, The TRC exceedence was promptly addressed to help ensure future compliance.
Whether the violation was inadvertent or a result of an accident:
The facility states the violations were the result of an inexperienced operator not recognizing an imminent
problern arising at the WWTP. Some poor operational decisions were made which, accompanied by cold
temperatures, exacerbated the.problems, hindering the growth of nitrifying bacteria. Testing revealed
unexpectedly high concentrations of anrunonia in the influent. The TRC violation occurred as new staff
became accustomed to WWTP operations during high flow situations.
The beginnings of the noncompliant episode at the Oakboro WWTP involved questionable operational
practice. Violations persisted because the conditions leading to high ammonia concentrations can take
considerable time to rectify. New operational staff took responsible steps in addressing the situation,
eventually returning the WWTP to compliance.. The TRC violation was of short duration and the result of
abnormal operational circumstances.
Li (d) Whether the violator had been assessed civil penalties for any previous violations:
The facility was assessed six times during the 5 years prior to the date of this assessment.
(e) Whether payment of the civil penalty will prevent payment for the remaining necessary
remedial actions:
The Town has documented over $13,000.00 in unbudgeted funds spent to address the noncompliance.
Additional funds are proposed in the upcoming budget to fund process improvements.
DECISION (Check One)
Request Denied
Full Remission t6 Retain Enforcement Costs? Yes
Partial Remissionn $ Enter Amount)
rev LO-8„3L09

STATE OF NORTH CAROLINA ENVIRONMENTAL MANA.GEMEN'T
COMMISSION
COUNTY OF ,STANLY DWQ Case Number L1/-2011-0E77'
IN THE MAT1:ER OF ASSESSMENT
OF CIVIL :PENALTIES AGAINST:
Town of Oakboro
REQUEST FOR ORAL PRESENTATION
I hereby request to make an oral presentation before the Environmental Management Commission's Committee On Civil Penalty
Remissions in the matter of the case noted above. In making this request, I assert that I understand all of the following statements:
• This request will be reviewed by the Chairman of the Environmental Management Com „ ission and may be either granted or
denied.
• Making a presentation will require the 'presence of myself and/or my representative during a Committee meeting held in Raleigh,
North Carolina.
• My presentation will be limited to discussion of issues and information submitted in my original remission reqi, and because
no factual issues are in dispute, my presentation will be limited to five (5) minutes in length.
The North Carolina State Bar's Authorized Practice of Law Committee has ruled that the appearance in a representative capacity at
quasi-judicial hearings or proceedings is limited to lawyers who are, active .members of the bar. Proceedings betbre the Committee on
Remissions are quasi-judicial. You should consider how you intend to present your case to the Committee in light of the State Bar's
opinion and whether anyone will be speaking in a representative capacity for you or a business or governmental entity, If you or your
representative would like to speak before the Committee, you must complete and return this form within thirty (30) days of receipt of
this letter.
Depending on your statu.s as an individual, corporation, partnership or municipality, the State Bar's Opinion affects how you may
proceed with your oral presentation. See www.ncbarcorrilethics, Authorized Practice Advisory Opinion .2006- I and 2007 Formal
Ethics Opinion 3.
If you are an individual or businessowner and are granted an opportunity to make an oral presentation before the Committee,
then you do not need legal representation before the Committee; however, if you intend on having another individual speak
on your behalf regarding the factual situations, such as an expert, engineer or consultant, then you must also be present at the
meeting in order to avoid violating the State Bar's Opinion on the unauthorized practice of law.
If you are joiationanershior munici. a and are granted an opportunity to make an oral presentation before the
Committee, then your representative must consider the recent State Bar's Opinion and could be considered practicing law
without a license if he or she is not a licensed attorney. Presentation of facts by non -lawyers is permissible..
If you choose to request an oral presentation, please make sure that signatures on the previously submitted Remission Request form
and this Oral Presentation Request form are: 1) for individuals and business owners, your own signature and 2) for corporations,
partnerships and municipalities, signed by individuals who would not violate the State Bar's Opinion on the unauthorized practice of
la ,
Also, be advised that the Committee on Civil Penalty Remissions may choose not to proceed with hearing your case if the Committee
is informed that a potential violation of the statute concerning the authorized practice of law has occurred.
This the day of , 20_
SIGNATURE
TITLE (President, Ow:ner, etc.)
ADDRESS
TELEPHONE (

Mooresville Regional Office
Division of Water Quality
MEMO ©UM
DATE: July 26, 2011
t , Y4 ;—
FROM : Rob Krebs, Surface Water Protection Regional Supervisor
TO: Bob Sledge
THROUGH: Marcia Allocco
BY: John Lesley;
SUBJECT: Request for Remission
Town of Oakboro
NPDES Permit No. NC0043 32
Case No.LV-2011-0177
Stanly County
MRCi staff has reviewed the subject request for remission. Town of Oakboro was
assessed for one effluent residual chlorine daily maximum limit violation, four effluent weekly
average ammonia nitrogen limit violations, and one effluent monthly average nitrogen ammonia
limit, violation. The violations were the result of the loss of nitrification processes experienced
during the month of January 2011. The facility laboratory, under the direction of an
inexperienced ORC, was using out of date reagents for ammonia nitrogen testing. The ORC left
employment with Oakboro in mid January 2011. Ammonia nitrogen was then being sent to a
commercial laboratory which reported elevated ammonia nitrogen in the effluent. The Town of
Oakboro requested technical assistance from the Division of Water Quality when the
noncompliance was discovered. The Town also spent significant funds (313071.39
documented) to restore the nitrification capability of the treatment system.
This office recommends a partial remission of the penalty. The total residual chlorine daily
maximum limit violation is not related to the ammonia noncompliance and was lot addressed
by the Technical Assistance investigation performed by MO Staff.

MVO — CIVIL PENALTY REMISSION FACTORS
Gase'umbea L`20
Assessed Entity: Town of Oakboro Permit: NC0043532
[ (a) Whether one or more of the civil penalty assessment
detriment of the petitioner;
ors
County:
ere wigly applied to the
hh (b) Whether the violator promptly abated continuing environmental damage resulting from
the violation;
The facility took action in a timely manner to find the cause of the noncompliance;
however, because the prior OR_C was reporting invalid laboratory data, there is no way
of knowing how long the noncompliance was actually occurring. The total residual
chlorine noncompliance is not related to the previously reported noncompliance.
hether the violation was inadvertent or a result of an aocident4.
The violations cannot be considered inadvertent or the result of an accident hecause the
noncompElance is the result of poor operation an improper laboratory controls. t forever,
the permittee was not aware of the problem and had no way of knowing the Vv,,l'illrFP had
last its nitrification process. Total residual chlorine noncompliance may be attributed to
operator error and should be assessed.
nether the violator had Keen assessed civil penalties for any previous violations;
ihetdrer orrynent of ties civic penalty will prevent payment for
remedial action;>.
cessary
Considerable funds ( 1 ;071 30 and approximately`_ t.CtJ per day of additional ongoir
costs) have been spent on the ripts to bring the into complir nce; thn.,a�fcare
MR0 recommends o reduction penalty (Co
assessment)

Retitortal Recoilitrierinati»it (ediesik
[Request Denied Full Remissi()ri
Partial Rentissiori
Central Office Recommendation (Check One)
Request Denied FuH Remission Partia emission
Director's Decision (Check One)
Request Denied
Date
Fun Remission F Partial Remission Li Amount Remitted $d
Coleen H, Sullins, Director

Violator:
Facility;
County:
Case Number:
Permit Number:
NORTH CAROLINA DIVISION OF WATER QU ALITY
Town of Oakboro
Oakboro WWTP
Stanly
1N-201.1-0177
NC0043532
ASSESSMENT FACTORS
I) 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 h.armhas been documented. .Ammonia nitrogen discharged in amounts that exceed the NPDES
Permit weekly and monthly averages would be predicted to cause adverse impacts downstream of the
facility. The discharge would be expected to stress aquatic lifedue to toxicity and lowered dissolved
oxygen, and increase nutrient loading of the receiving water. One daily maximum exceedance of the
total residual chlorine was reported. Chlorine is a toxicant used in the disinfection process and is likely
to have had an adverse impact on aquatic life near the discharge.
2) The duration and gravity of the violation;
The violations have continued since January 2011 into April 2011. During the month of March 2011 the
ammonia nitrogen weekly average was violated. on four occassion.s: 2/27-3/5/11, 28.5 mg/1, 58.5% over
the permit limit; 3/6-12/11, 28.7 mg/1, 59.6% over the permit limit(18 mg/I); 3/13-19/11, 22.0 mg/I,
22.4% over the permit limit; and 3/20-26/11, 22.13 mg/I, 23% over the permit limit. The ammonia
nitrogen monthly average permit limit was reported as 23.3 mg/1, 288% over the permit limit (6 mg/1).
Total residual chlorine was reported as >6() ugtl, 114.3% over the permit daily maximum limit (28 ug/1.),
3) The effect on ground or surface water quantity or quality or on air quality;
No effect on ground water or air quality are expected. Surface water is likely to have been :impacted by
the discharge to increased amounts oftoxicants (ammonia and chlorine) in the receiving stream..
Ammonia would also decrease dissolved oxygen levels and increase nutrient addition downstream of th.e
discharge.
4) The cost of rectifying the damage;
The cost to the Town of Oakboro has been significant. The Town spent $13„071.39 to replenish the
activated sludge and make repair and modifications to the process. New laboratory equipment and
reagents were also purchased. Operational costs for lime addition and increased electrical usage is
$79.00 per day. The Town is also expending 20.5 man-hours per week for lime addition. Following
the first knowledge of the violations the Town requested immediate technical assistance from the
Mooresville Regional Office TACU staff, The TACLE staff recommendations were carried out. Cold
weather hampered the biomass recovery.

5) The amount oft t ne saved by none( tin iitinee
No ixirre, has been saved by the noneoriali ruse:
6 Whether the violation as committed willfully or into.°ntio a1
h
iolations do not appear t i be willful or inter
7) The prior recordof the violator in ontitl it or faiii g to comply with prom s over rhieh the
Env roninental Management Commission has re ulatorwr authority°; and
ase Number Description
1066.7 , ammonia nitrogen s=nations iri I
- )1 l 836774, ammonia nitrogen °iolations in f
the cost tcc the State e the ifore prcc educes..
re arati n of enforce rner i package:
\ P Regional Super isor
Clerical Support
I" tal
requested ease t p
in requested ease
5/bur
.007hour
7
ng ROSupervisor
Division ofWitte r Quali

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
Via E-Mail
Mr. David Austin Nichols
Town of Oakboro
P. O. Box 610
Oakboro, NC 28129
Subject:
Dear Mr. Nichols:
July 22, 2011
Remission Request of Civil Penalty Assessment
Town of Oakboro WWTP
NPDES Permit NC0043532
Case Number 1N-2011-0177
Stanly County
Y
This letter is to acknowledge your request for remission of the civil penalty levied against the subject
facility: Your request will be scheduled for review by -the Director and you will be notified of the result.
If you have any questions about this matter, please contact me at [phone] or via e-mail at
bob.siedge(cii)ncdenr.gov,
Sincerely,
Bob Sledge, Environmental Specialist
Point Source Branch
cc: Enforcement File w/originals
Central Files vv./attachments
Mooresville 'Regional Office wiattachments
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St, Raleigh, North Carolina 27604
Phone: [phone] \ FAX: [phone] \ Customer Service: 1-877-623-6748
Internet': worw nowatergualily,org
Equal Oppoilunnyi, A11irmative Aciion Employer
NorthCarolina
Atii/trallbt.

mown Of pa
109-AN,MednSt— P©Box 610
Oakboro, NC 28129
704-485-33511 704-485-2439 (fax)
www.oakboro.com
Point Source Compliance Enfcrcen ent Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
oro
July 13, 2011
David Austin Nichols
WWTP ORC
Ton of Oakboro
PO Box 610
Oakboro, NC 28129
704-485-3351 x 110
Written Request for Remission of Civil Penalty File No. LV-2011-0177
The Division of Water Quality has transmitted a Notice of Violation and assessed
a civil penalty of $2336.74 for noncompliance with daily total chlorine residual
and weekly and monthly average effluent ammonia concentration limits by the Town of
Oakboro Wastewater Treatment Plant for the month of January 2011. We stipulate the
facts of these violations but request remission of the civil penalty in consideration of the
circumstances and response.
In January of 2011, Ryan Efird was Operator in Responsible Charge (ORC) of the
Oakboro Wastewater Treatment Plant. Ryan is a relatively inexperienced WPCSOCC
certified Grade 3 Biological WWTP Operator. Ryan also supervised the in house
laboratory and performed ammonia analysis by the ion probe method and total chlorine
residual spectroscopically using vials and DPD reagents.
From January 4, 2011 to January 13, 2011, Ryan measured effluent ammonia
concentrations of 5,1.9, 4,43, 6.27, 6.27, 5.87 and 7.20 mg/L Nf13-N. This is averaging
marginally below the winter monthly limit of 6.0 mg/L. In Ryan's inexperience, he either
did not recognize a imminent problem or did not know what to do about it. Ryan
resigned shortly after without communicating the ammonia concern to the Backup ORC
or operator remaining at the plant.
After Ryan's departure, ammonia effluent samples were collected, preserved and
submitted to K&W Laboratories for analysis because Ryan was the only one at the plant
trained in this analysis. The remaining monitoring samples for January were submitted
on January 24 and February 3 and analyzed on. February 10. Results were 20, 23, 18, 30,
20 and 24 mg/L. By the time Backup ORC Larry Branch saw the results and realized
there was a problem January was gone. Mr. Branch contacted the Division of Water
Quality and requested technical assistance from Barbara Sifford to troubleshoot the
problem.

-own Of Oarthoro
109-A rt Main - PO Box 610
Oakbao, NC 28129
704-485-33511704-485-2439 (fax)
voncoakboro.cm
Meanwhile I was hired to take over as ORC of the plant. I met with Mr. Branch
and Ms. Sifford at the WWTP on February 22, 2011. Ms. Sifford and I reviewed
operations logs and sampling data. We discussed the likelihood that low water
temperatures and low mixed liquor suspended solids had allowed the nitrifiers to wash
out of the plant. We also talked over a plan to regain nitrification. We discovered that
Ryan had been using expired reagents for the ammonia analysis. Ms. Sifford's report is
attached.
I learned that wasting had been previously determined by the clarifier blanket
depth with no concern for sludge retention time (SRT). I used plant records to perform
the environmental engineering calculation of a minimum SRT of 23 days for the
minimum January water temperature of 7C. The SRT for January 24 had dropped to 13
days. The nitrifiers were being wasted faster than they could grow. I am sure Ryan did
not understand this.
In response to our meeting with Ms. Sifford, we activated a plan to regrow
nitrifiers, a slow process with low water temperatures.
1. We seeded the plant with activated sludge containing a healthy population
of nitrifiers from Monroe WWTP.
2. We increased MLSS to 4200 mg/L and SRT to 40 days.
3. We began monitoring alkalinity and adding hydrated lime daily to
augment alkalinity.
4. We began weekly cleaning of aerators to maintain optimal oxygen transfer
efficiency.
5. We cleaned an unused aeration basin, repaired floating aerators and
electrical controls. This basin went into service on April 15, 2011
substantially increasing our aeration capacity. Effluent ammonia dropped
to 0.1 mg/L in one week.
6. We have replaced expired reagents arid the ammonia ion probe.
7. We began sampling our influent for ammonia, realizing we can have over
100 mg/L influent ammonia and typically 40 mg/L.
8. We began a composite sampling study of our collection system to identify
the source of our very high influent ammonia background and shock loads.
The plant has been monitored everyday since we met with Ms. Sifford including
weekends and holidays. I still have not had a single day off work since then. We enlisted
a community service worker to help expedite cleaning the aeration basin.
ENfRMATER OU
POINT SOURCE

5-own Of Oa kboro
109-A N. Main St — PO Box 610
Oakboro, NC 28129
704-485-3351/ 704-485-2439 (fax)
www,oaklx)ro,corn
We have spent considerable unbudgeted funds to rectify this situation:
I. Hauling activated sludge seed $ 1650.00
2. Reagents and ammonia ion probe $ 518.45
3. Hydrated lime $ 4607.83
4. Spill control ramps for lime slakers $ 370.00
5. Life vests to clean aerators safely $ 110.00
6. Rewind motor of aerator #2-2 $ 3040.00
7. Electrical components and tools $ 1017.51
8. Hardware, hoses and piping $ 117.60
9. Additional electricity for aerators $ 2840.00
Total $ 13071.39
We expect to continuously spend due to process improvements and have
approved these expenditures in our 2011-2012 budget:
I Electricity $ 40/day
2. Lime $ 39/day
Total $ 79/day
We have been in contact and consultation with Ms. Sifford all along the process
of regrowth and followed her recommendations. Copies of email communication with
Ms. Sifford are attached. We have done everything in our knowledge to regrow nitrifiers
and return the plant to compliance as fast as possible. After bringing the second aeration
basin on line on April 15, our effluent ammonia was not measured above 2.1 mg/L in
April. In May our effluent ammonia concentrations were in compliance averaging 0.9
mg/L. In June all effluent ammonia concentrations were below detection levels.
Now we have approximately four times as much active biomass in aeration than
in February. Our aeration basin DO's are between 3 and 5 mg/L. We have an SVI of 50
and very rapid settling sludge. Effluent TSS averages 3.9 mg/L, ROD averages 2.7 mg/L
and ammonia is below our detection limits. Our plant is operating much better now after
repairs, process control improvements and new management.
We completed sampling major contributors to our collection system and
analyzing for ama-nonia. After correlating ammonia concentrations with flow data to
calculate pounds of ammonia contributed, there was no single outstanding contributor to
our influent ammonia. Unexpectedly our influent ammonia was dropping during this
investigation: 32 mg/L on June 28 vs greater than 100 mg/L on April 5. It is unknown if
this is the result of a seasonal situation or an illegal dumping situation that ceased after
learning of our investigation. We hope that the influent ammonia remains at these
reduced levels saving the costs of treating excessive ammonia.
DENR-"WATER QUALITY
POINT SOWRCE i3R1NCH

gown Of Oak
109 A N, Main St. PO Box 610
Oakboro, NC 28129
704.485-3351 / 704-485-2439 (fax)
www,oakboro.com
*0
On March 9, we treasured and reported a total chlorine residual of greater than 60
xceeding our daily maximum limit of 28 mg/L. This was the first major rain
we had after I began full time work at Oakboro. Because of inflow and infiltration
our flow exceeded our permitted monthly limit on June 9 and 10. I was still learning how
Oakboro's flow paced chlorinators and sulfonators responded to storm flows having been
accustomed to Badin WRiI'P's manually controlled chlorinators and sulfonators. I had
made process control field measurements of chlorine residuals in our contact chamber
and effluent earlier in the day and adjusted the feed rate slopes with maintaining
disinfection power at low contact times being the major concern. Later in the day when
my assistant collected an effluent sample at a differing flow rate the total chlorine
residual was out of compliance. The sulfur dioxide feed rate had maxed out but was
insufficient to dechlorinate the effluent. This was immediately corrected by another feed
rate slope adjustment to decrease the amount of chlorine being fed sacrificing some
disinfection power for dechlorination.
Since this time we have achieved an acceptable balance of chlorine and sulfur
dioxide feed rates utilizing our redundant equipment to set up a duplex feed system. At
low flows the feeds are dominated by a fixed rate component and at high flows they are
dominated by a flow paced component. This allows more effective and more consistent
disinfection and dechlorination under both flow regimes.
Furthermore on March 23, we performed a total chlorine residual laboratory
certification performance evaluation using the techniques and equipment used on March
9 and received unacceptable results. Before receiving the performance evaluation results,
we switched to a flow cell technique recommended to me by Chet Whiting due to
difficulties we were having with the sample vial technique. This new technique
significantly improved the precision and accuracy of our total chlorine residual results.
In a subsequent performance evaluation we measured 123 µg/L vs the reported value of
122 µg/L. I cannot conclude that the greater than 60 mg/L TRC measurement on March
9 was erroneous but it is a possibility.
We accept the facts that the plant has been out of compliance and DWQ's right to
fine the Town of Oakboro. However the funds that pay the fine would be much better
spent in our continued process improvements. We request that the fines be remitted.
Respectfully,
David Austin Nichols
R-WATER QUAL
T SOURCE BRANCH

DWQ Case Number:
Assessed Party:
County:
Permit Number:
Amount Assessed:
JUSTIFICATION FOR
LV-2011-177
Town of Oakboro
Stanly
NC0043532
$2336.74
SS
ON REOUEST
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. § I43B-282.1(c), remission of a civil penalty may be granted only
when one or more of the following five factors applies. Please cheek 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. (b)werewrongf
were vvron
applied to the detriment of the petitioner (the assessnient factors are listed in the civil penalty assessment
document);
(b) !IioIatorroinjt1vabatecontinuingenvironmenta1damage jesu1frornthe
explain the steps that you took to correct the violation and prevent future occurrences,);
ALI (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 fir);
(d)
the violator had not been assessed civil penalties for any previous violations;
ul
(e) moment of the civil penalty will prevent payment for the xemaining necessary remedial actions
(Le.., explain how payment of the civil penalty will prevent you from perbrming the activities necessary to
achieve compliance).
EXPLANATION: (use addition I pages as necessary)
JUL 1 3 2011
E N R-WA1
POINT SOURCE BRANCH

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
COUNTY OF STANLY
IN THE MATTER OF ASSESSMENT
OF CIVIL PENALTY AGAINST
TOWN OF OAKBORO
PERMIT NO. NC0043532
WAIVER OF RIGHT TO AN
ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
FILE NO. LV-2011-0177
Having been assessed civil penalties totaling $ 2336.74 for violation(s) as set forth in the assessment
document of the Division of Water Quality dated June 28, 2011, the undersigned, desiring to seek remission of
the civil penalties, 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 Quality within 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 13 day of J I I
BY
ADDRESS
G'/t
0 & 610
, 2011
Oa IC 22/29
TELEPHONE
bENR-WATER QUALITY
POINT SOURCE BRANCH

4
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
March 7. 2011
Mr. Larry Branch
Town of Oakboro
109-A N. Main. St.
P.O. Box 610
Oakboro,. NC 28129
Subject: Technical Assistance Evaluation
Town of Oakboro
NPDES Permit No. NC0043532
Stanly County, NC
Dear Mr. Branch:
Dee Freeman
Secretary'
This letter is a follow-up to the technical assistance request made on February 18, 2011 concerning the
elevated ammonia results received from K&W labs for the last two weeks ofJanuary 2011. A site visit and
plant operations was conducted on February 22, 2011. Operations records and plant data were reviewed. The
review of effluent data for BOD and TSS indicate good treatment and biological activity. The pH of the
effluent has not been below 7.0 and alkalinity tested was over 200mg/1 so those two analyses indicate that the
system is not nitrifying.
Operational Problems:
Aerator g-2. (lof 3) was out for the last two weeks in January. This resulted in. a lower DO levels leaving
the aeration -basin but was not recorded below 1.0 mg/l. BOD and TSS removal efficiencies remained within
expected ranges and compliant during this period. It appears that the .nitrifying bacteria population has died.
off. This could be the result of two much wasting or the severe cold temperatures that were present in January.
The sludge has to be "aged", as the nitrifiers are an older organism, Wasting during the extreme cold weather
may have resulted in loosing the entire population.
Using the MCRT formula the plant needs to be around 20 days for extended aeration during the winter
months to maintain nitrification. The MLSS were low and this has not allowed nitrifiers to reproduce during
January when the temperature was the coldest we have had in many years. Nitrifiers have a much slower
growth rate than heterotrophic bacteria (BOD bugs) and comprise a very small amount of the total biomass,
Mooresville Regional Office
Location: 610 East Center Ave, Suite 301 Mooresvil1e, NC 28115
Phone: [phone] \ Fax; [phone] \ Customer Servioe; 1-877-523-6748
meme;wwwmcwaterquety„org
An Equal r.)p;ar:unity AffrnrIzIA ActV Emptyer - 5n, Re,:ycled,',,7% Ps 1 Gmlsumer pare
DENRANATER QUALITY
POINT SOURCE BRANCH
pdhCarolina
it1/117/47

Page .2
Oakbora
February 2011
Analytical Evaluation:
During this evaluation of laboratory data for the months of January and February 2011 the test results
for ammonia were reported by two different methods. Prior to the ORC leaving (Ryan Efird) was using the ion
probe on site that the WWTP laboratory was certified to do. Upon his leaving this was contracted out to K&W
labs using a different method. Investigation is being made into the probe and standards that were being used to
determine if a malfunction had occurred in the equipment at the WWTP lab to provide this drastic change in
concentrations of NH3, The specific ion meter has been recalibrated a new curve has been run with great
results so the meter and probe are working properly. These results will be compared to the commercial
laboratory for the next week to determine reliability. Currently it will be used for process control.
Corrective Actions Taken:
1. Immediately stopped sludge wasting to increase the MCRT of the biological system.
2. Increased sludge return rate to get them back in the aeration basin quicker. (Back to food)
3. March 4, added 5400 gallons of MLSS from Monroe WWTP to reseed the WWTP.
4. Monitor pH and alkalinity levels and monitor ammonia for process control.
5. Monitor influent for ammonia levels to determine removal rate and any slug loadings.
Wait and see the results, patience.
If you need any additional assistance on any compliance
35-2. 96 in the Mooresville Regional Office.
Sincerely,
a
p
le
Barbara Sifford
Technical Support
Mooresville Regional Office
CC: David Nichols
se ca
direct number at 704-
4

EPA
es vrrnmerrau gin; ee
Wasno vtcn, 0.0. 20460
Ag
ater Compliance tnsptian Repo
CAE No. 2040-0957
Approval expires 5-31-98
Al National Oata
y
em Caodinot (i_e_, PCS
Transaction Code NPDES
2 ILJ 31 N00043532 11 121
I
yrfmorday
n2 /22
Remarks
I111 L1111111tJ11
Inspection Work Days Facility Self -Monitoring Evaluation Rating
671 159
701
Fa
and Lctidn of F
le Arad NPDES p
4939 3 arbees Grove Rd
a:aboro NC 23129
Indust raal Users discihargl
i Narne(s) of Cns4e Representative(s)(Ttles(s)/Phone and Fax Numbers)
' Larry G sra.nchloac T04-485-83'22/
Martin dennis/0RC_/704-485-4613/
01
y©
1 17
72
Inspection Type Inspector
18 191J
Fac Type
201
QA
OTW, also `snd(ude
Name. Address of Responsible Officialfht6e/Phone and Fax Number
Sox. EiC cakrtrs NC 23023/Mayor/704-435-3351/
Contacted
Nc
Entry Tier ,tDte
it Tim Date
—Reserved
---
75[ 1
4:00 3N 11/02/22
er Fatality Data
10/©2/01
14/01/31
on C` Areas Evaluated Duri
only those area
RecordsReports el f,tonitaring Program tSitsdge Handling disposal Faci6ity Site Review
Compliance. Schedules &-aboratary
Bastian. C. Summar? of inding/Comments (Attach additianei sheets of narrative and checklists as meow a
(See attachment summary)
e(s) and Signatures) of Inspectors) Agency/e&Phone and Fax Numbers
nature of Management ( A Reviewer
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
MR0 .a21,/704-333-1 69
/Office/Phone and Fax Numbers Date
JUL 1 3 Z011
Page #

NPOEP yrenceday
111 12
NC0043532
4
Inspection Type
17 18
Section Di Summary of FinargiComments (Attach additignaLi sheets of narrative and checklists as necessary
R
JUL1SZO1l
DEN „NvEttratl--uALI
poiNT souRcE sivoiGN
Page # 2

Permit NCOO4
inspection Date: 02/22/2
pliance Schedules
Owner FaciI ty: Oakbaro MT?
Inspection Type: Technical Assistance
Is there a compliance schedule for this facility?
Is the facility compliant with the permit and conditions for the review period?
Comment: Comfirnned the data from K&W labs, on Friday 3/4 planning to haul MLSS
from Monroe to introduce apopulation of nitrifiers to the system. Alkalinity is suffiecient
to promote growth. Hopefully this will lead to compiinace. For two weks the plant has
not wasted to age the MLSS and this has not started the nitriflers.
Effluent Sampling
Is composite sampling flow proportional?
Is sample collected below all treatment units?
Is proper volume collected?
Is the tubing clean?
# Is proper temperature set for sample storage (kept at less than or equal to 5.0 degrees Celsius)?
Is the 'facility sampling performed as required by the permit (frequency, sampling type representative)?
Comment: Additional samples need to be collected and analyzed to trend data for
plant performance.
Influent Sampling
# Is composite sampling Row proportional?
is sample collected above side streams?
Is proper volume collected?
Is the tubing clean?
# Is proper temper tore set sor sample storage (kept 'at less tt sn or equal to 5.g degrees e(sius)"
Is sampling performed according to the permit?
Comment: Influent data should be performed for ammonia to determine removal rate
and if any slug loads are indicated.
Record Keeping
Are records kept and maintained as required by the permit?
Is all required information readily available, complete and current?
Are all records maintained for 3iyears (lab. r eg. required 5 years)?
Are analytical results consistent with data reported on DMRs"?
Is the chain- piete?
Dates, times and location of sampling
Name orfindividual ing the sampling
Yes No NA NE
n G
DEGO
Yes No NA NE
OJD■D
n0in
Q nan
n n■n
D ©■ D
n n ■
Yes No NA NE
nnnl.
o p no
n on•
n n0XI
■
nlnnyI
Yes No NA NE
I•000
■ nnnl
III 00nn
■ non
� nnn
R
■
Page # 3

Permit NC0043532
inspection Date: 021221201
Owner -Facility: Oakborp WV\00P
Inspection Type: Technics Assistance
Record Keeping Yoe No NA NE
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
Are DN1Rs complete: do they include all permit parameters? *000
Has the facility submitted its annual compliance report to users and DINO? 0 0 0
Of the facility is or>. 5 MOD permitted flow) Do they operate 24f7 with a certified operator on each shift? 00=0
is the ORC visitation lag available and current? n000
is the ORC certified at grade equal to or higher than the faclity classification? n0E30
Is the backup operator certified at one grade less or greater than the facility classification? Vann
Is a copy of the current NPDES permit avatlable on site? MOOn
Facility has copy of previous year's Annual Report on file for review? CI 0 0
Comment
0 0 R:VIA7'"ER -CiUALITY
PON'', SOURCE BRANCH
Page # 4
4

From: dnichols©oakboro.com <[e-mail]>
To: barbara.siffordOncdenr.gov
Cc: rholshouser@oakboro,com
Date: Wednesday, March 02, 2011 05:14 pm
Subject:
Alttachments:
Ms. Sifford:I have received the new ISA reagent and calibrated the meter and ammonia ion probe from
scratch at 100, 10, 1 and 0.1 ppm. I followed the calibration with four freshly made up standards and got a
98% slope and correlation coefficient of 1, so the meter and probe are good. I checked a grab of effluent
and got 25.9 ppm which agrees much better with the numbers we are getting back from K&W. I'm going to
run split samples with K&W on the next few composites just to confirm. We have increased the sludge
return rate trying to get more bacteria into aeration and jump start the recovery of ammonia oxidizing
bacteria, We haven't wasted since you were here. We'll check the MLSS and RAS SS tomorrow and I'll
calculate a WAS flow for a SRT target of 40 days. I think Larry is impatient, but I realize the regrowth of
ammonia oxidizing bacteria is very slow.Do you have any other suggestions? David Nichols
DENP-WATT, o AI iTy
POINT SOURCE BRANCH
http://rrlail,©akboro.cornledgedesllcgi-binfvieirai.exe?id=016alcacc467e27c87dde'77ae.., 6/7/2011

From: dnchots @ oakboro.com cdnicholsOoakbomcom>
To: Sifford, Barbara <[e-mail]>
Cc: rhoishouserVoakboro.com
Date: Thursday, March 03, 2011 0544 pm
Subject: seeding Oakboro WWTP
Attachments:
Ms, Sifford:
I have talked to Kyle Ketchum at Monroe WWTP about providing activated sludge with high
nitrification activity to seed our plant. They are agreeable but want approval from you that this
is OK and to know if there is any paperwork we need to do.
Please give Kyle a call at 704-282-4612 as soon as possible so we can get moving on this. We
have a hauler on standby.
Thanks,
David Nichols
704-984-0320 cell
704-485-4613 office
704-485-4918 home
-----Original Message -----
From: 5ifford, Barbara [mailto:[e-mail]
Sent: Wednesday, March 2, 2011 04:26 PM
To: [e-mail]
Subject: RE:
This means the whole month of February is out of compliance. 1 think now we need to add dehydrated
bugs or maybe some from another WWTP to get them jump started. With three months of consecutive
non compliance the $ starts going up and you get on the compliance watch list. See what Larry wants to
do. I would buy or transport from Badin or from WSACC. Tim Mauldin is the contact for WSACC, and 1
know they would have nitrifiers in the MLSS. At least you know where the plant effluent is now. We can
watch it progress. Looks like you got a great curve for the standardization.
Chet had said that you are to run more than one standard to match the curve when you run the results. I
think Ryan had been only running one.
From: dnichols@oakboro,com [mailto:[e-mail]
Sent: Wednesday, March 02, 2011 4:14 PM
To: Sifford, Barbara
Cc: [e-mail]
Subject:
Ms. Sifford:I have received the new ISA reagent and calibrated the meter and ammonia ion probe from
scratch at 100, 10, 1 and 0.1 ppm. I followed the calibration with four freshly made up standards and got a
98% slope and correlation coefficient of 1, so the meter and probe are good. I checked a grab of effluent
and got 25.9 ppm which agrees much better with the numbers we are getting back from K&W. I'm going to
run split samples with K&W on the next few composites just to confirm. We have increased the sludge
return rate trying to get more bacteria into aeration and jump start the recovery of ammonia oxidizing
bacteria. We haven't wasted since you were here. We'Il check the MLSS and RAS SS tomorrow and I'll
calculate a WAS flow for a SRT target of 40 days. 1 think Larry is impatient, but I realize the regrowth of
ammonia oxidizing bacteria is very slow.Do you have any other suggestions?David Nichols
fittp://maloakboro.c9m/edgedeskicgi-binhiewmail.exe?id=0 16a1 cacc467e2,37c87dde77ae... 6/7/2011

This means the whole month of February is out of compliance, I think now we need to add dehydrated
bugs or maybe some from another WWTP to get them jump started. With three months of consecutive
non compliance the $ starts going up and you get on the compliance watch list. See what Larry wants to
do. I would buy or transport from Badin or from WSACC. Tim Mauldin is the contact for WSACC, and I
know they would have nitrifiers in the MLSS. At least you know where the plant effluent is now. We can
watch it progress. Looks like you got a great curve for the standardization.
Chet had said that you are to run more than one standard to match the curve when you run the results. 1
.. �__.m .
think Ryan had n only running one,
�.._
From: [e-mail] [rnaifto:[e-mail]]
Sent: Wednesday, March 02, 2011 4:14 PM
To: Sifford, Barbara
Cc: [e-mail]
Subject:
Ms. Sifford:l have received the new ISA reagent and calibrated the meter and ammonia ion probe from
scratch at 100, 10, 1 and 0.1 ppm. I followed the calibration with four freshly made up standards and got a
98% slope and correlation coefficient of 1, so the meter and probe are good. I checked a grab of effluent
and got 25.9 ppm which agrees much better with the numbers we are getting back from K&W. I'm going to
run split samples with K&W on the next few composites just to confirm. We have increased the sludge
return rate trying to get more bacteria into aeration and jump start the recovery of ammonia oxidizing
bacteria. We haven't wasted since you were here. We'll check the MLSS and RAS SS tomorrow and I'll
calculate a WAS flow for a SRT target of 40 days. I think Larry is impatient, but I realize the regrowth of
ammonia oxidizing bacteria is very slow.Do you have any other suggestions?David Nichols
http://mail.oakboro.comledgedesk/cgi-bin"vie waii.e• e?id-016a1 cacc467e237c87dde77ae... 6/7120 1
M 9

From; [e-mail] <dnicholsOoakboro.com>
To; Sifford, Barbara <barbara.siford9ncdenr.gov>
Cc; rholshouser©oakboro.com, !branch©oakboro.com.
Date: Friday, March 04, 2011 05:25 pm
Subject: Re: seeding Oakboro WWTP
Attachments:
Today (3-4-11) we added 5400 gallons of fresh mixed liquor from the Monroe WWTP into our
aeration basin. Kyle Ketchum advised me that Monroe had about 3600 mg/L MLSS and very
strong nitrification so this should help. This was enough that our DO had dropping to 1.04
mg/L. I want to let the DO recover some before adding more from Monroe possible Monday.
Our pH hasn't changed. Ammonia on grab samples appears to be droppingbut is waivering
enough with influent that it is hard to be sure yet. I will keep an eye on DO, pH and ammonia
over the weekend. I need to set up to test alkalinity in house when I get a chance.
Thanks,
David Nichols
-----©rigiinal Message ---
From: Slfford, Barbara [mailto:barbara.siffo
Sent: Friday, March 4, 2011 10:49 AM
To: [e-mail]
Subject: RE: seeding Oakboro WWTP
n
enr.gov]
Sorry I was out yesterday afternoon for a doctors appointment. Wes said the talked to you and left Kyle a
message. Good luck and we'll see what happens. It is definitely OK with us just document how much and
when and then you can monitor the ammonia to see it drop. As Wes said what the pH and alkalinity,
because they will take it up, but you know that.
From: [e-mail] [mailto:[e-mail]
Sent: Thursday, March 03, 2011 4:45 PM
To: Sifford, Barbara.
Cc: [e-mail]
Subject: seeding Oakboro WWTP
Ms. Sifford:
I have talked to Kyle Ketchum at Monroe WWTP about providing activated sludge with hi
seed our plant. They are agreeable but want approval from you that this is OK and to know
we need to do.
Please give Kyle a call at 704-282-4612 as soon as pos
standby.
Thanks,
David Nichols
704-984-0320 cell.
704-485-4613 office
704-485-4918 home
nitrification activity to
there is any paperwork
ible so we can get moving on this. We have a hauler on
-----Original Message -----
From: Sifford, Barbara [mailto:[e-mail]]
Sent: Wednesday, March 2, 2011 04:26 PM
To: [e-mail]
Subject: RE:
http://mail,oakboro.comledgedesklcgi-bin/viewrnail.exe?id=016a t cacc467e237c87dde77ae... 6/7/2011

From: dnichols oakboro.co <dnlcholscloakborv.com>
To: Safford, Barbara <barbara.slflordi ncdenr.gov>
Cc: rholshouseroakboro.com, Ibranch©oakboro.com
Date: Tuesday, March 15, 2011 05:08 pm
Subject: Re: Ammonia
Attachments:
We added another 5400gal of mixed liquor from Monroe WWTP last week. I checked our MLSS
today and got 2840mg/L, much higher than expected considering we have had an upset clarifier
twice in the last two weeks from I&I. I've stored biosolids in the aeration basin both times. This
is &most double MLSS what we had in January. Ammonias from 3-9-11 and 3-10-11 were 21.9
and 21.4mg/L. I checked and our influent ammonia is running about 40mg/L. Not great news..
Leon and I cleaned our aerators which has driven our basin DO from struggling to maintain 1 up
to 3-4rng/L. Our effluent pH is starting to drop a little which may mean nitrifiers using up
alkalinity. I've ordered some test strips to keep a close eye on alkalinity. (Setting up to do the
titration is on my long list of things to do but the test strips are cheap, easy and quick to
implement.) I'm afraid we will be out of compliance for March on ammonia because it takes time
to grow back the nitrifiers especially since we are still at only 12C for water temps,
Thanks,
David Nichols
- --Original Message -----
From: Sifford, Barbara[mailto,[e-mail])
Sent: Tuesday, March 15, 2011 03:51 PM
To; [e-mail]
Subject: Ammonia
How is the plant running now? Haven?t heard anything, l?m afraid to think that no new is good news.
Please note new email address
Barbara Sifford - [e-mail]
Technical Consultant
North Carolina Dept, of Environment & Natura
Div. of Water Quality
610 E. Center Ave., Suite 301
Mooresville, NC 28115
Ph: 704,663.1699 Fax: [phone]
ounces
E-mail correspondence to and from this address may be subject to the
North Carolina Public Records Law and may be disclosed to third parties.
* *1******************** ** ****;******.**11*1*****
http://mail.oakboro.com/edgedesk/cgi-birtivie
xe?idr016al cacc467e237 87dde77ae... 6/7/2011

From: dnicholsOoakboro.com <dnich I
Pil
akboro.corn>
To: Sifford, Barbara <barbara.sifforcroncdenr.gov>
Cc: Holshouser, Ross <rholshouser oakboro.com>, Branch, Larry <lb
Date: Friday, March 25, 2011 05:02 pm
Subject: Ammonia at Oakboro WWTP
C meets:
s. Sifford:
This week we gat the plant MLSS up to 4200mg/L and started wasting at a rate to establish a
40 day SRT. Also our alkalinity has dropped to around 100mg/1.. and I am maintaining it there
with the addition of hydrated lime. pH remains 7-7.3. And our water temp has warmed to
15C. I continue to ramp up our RAS rate.
Again this week, Leon and I cleaned our aerators to give maximum DO input. It appears the
aeration basis has a lot of stringy material at the bottom that keeps clogging the aerators.
want to drain and clean it when we get the other aeration basin going.
We are progressing on getting the second aeration basin into shape. Leon, a community
service worker and I are shoveling the grass and weeds from the bottom. All the aerators
work and I spent some time today diagnosing the motor controls. We need to order some
electrical parts, move one aerator around to the basin and restring the guy wires.
Leon and I have drained the unused clarifiers. But we need to enter them and clean out some
rust and heavy solids from the drains before we can use them as interim EQ basins to relieve
the one serviceable clarifier under heavy flows. (The troughs are unuseable but they are OK
as holding tanks.) Kemp is getting me an estimate on rehabilitating the troughs and arms of
the unused clarifiers so we can propose that for the 2011-2012 budget.
We tried to clean the 2.5ft of sludge from our chlorine contact chamber but Rain for Rent
brought the wrong pump, There are no drains. We will try again ASAP. The sludge is septic
and may be a source of NH3.
Ali this and we are still hovering around 20mg/L on our effluent ammonia. Out influent
ammonia was 44mg/L this week. (Our influent sampler Is at the main pump station 4 miles
upstream from the plant so the real influent ammonia is probably higher.) I don't know if the
removal we are seeing is volatilization, nitrification or formation of chlorarnines (I am slowly
dropping the chlorine feed with no change in ammonia). But the last 20mg/L is elusive. I
don't know what else to do, but keep promoting the right conditions and wait.
Any more suggestions?
Thanks,
David Nichols
111
JUL 1 3 2011
D NR-WATER OU
NT SOURCE BRANCH
)1ttp://mail.oakboro.com/edgedeskicgi-binkiewmail.exe?id=016a1catc467e237c87dde77ae... 6/7/2011

'Or A. v., •
From: dnIchols@oakboro,com <dnIcholsgoakboro.com>
To: Sifford Barbara <barbara.siffordOncdenr.gov›
Cc: Branch Larry <Ibranch©oakboro.com>, Holshouser Ross <rholshouser@tioakboro,com>
Date: Tuesday, April 12, 2011 08:38 am
Subject:
Attachments:
Barbara:
Help!
Good news: finally last week we started to show the needed improvement in effluent
ammonia: 6.0, 15 and 8.1 mg/L. This is with an influent ammonia greater than 100 mg/L.
We were augmenting about 40 mg/L of ammonia everyday.
Bad news: about Thursday of last week our aeration basin DO dropped to 0.3mg/L and has
hovered there since. I was away at Well school when this happened. Monday morning early
Leon and cleaned all our aerators which are running well but this hasn't helped. The plant has
stopped using alkalinity which hovers at 100mg/L. Our effluent BOD's are running a little high
as well.
The only reasonable explanation I have is someone is sporatically dumping into our collection
system something with a huge oxygen demand. I'm waiting for the influent BOD numbers.
We aren't set up in house for COD.
We are working as quickly as possible to rehab the second aeration basin to get some more
DO capacity. However the three we are operating gave DO's over 3.0mg/L a few weeks ago.
Do you have any suggestions on tracking down our DO problem? Should we start pulling NH3
and COD samples from the collection system and try to track down the source?
Thanks for any help you can give.
David Nichols
WWTP/Collections ORC
Town of Oakboro
PO Box 610
Oakboro, NC 28129
[e-mail]
704-984-0320 cell
704-485-4613 office
704-485-2439 fax
ry
NT SOtdiV::::
http://mail.oakboro. com/edgedeskicgi-bin/vi ewmai I. exe?id=016alcacc467e237c87dde77ae... 617/2011

From: dnicholsoakboro.com <dnicholsCoakboro.com>
To: Sifford, Barbara <barbara.sifford©ncdenr.gov>
Cc: Branch Larry <Ibranch@oakboro,com>, Holshouser Ross <[e-mail]>
Date: Friday, April 15, 2011 10:27 am
Subject: Re:
Attachments:
OUCH! That is terrible news for those that work there and those of us you help.
Our basin D© is still hovering around 0.3mg/L. I had a COD ran on Tuesday influent composite
and got only 344mg/L, indicating if something was dumped it is gone.
I'm wasting with a SRT=30 day target. MLSS=4100mg/L this week.
We are still nitirying but not good enough. Influent 40.7mg/L, effluent 10.1, 10.0 and 7.88mg/L
this week. I need to get the D4 up before I can expect any better than this. We're starting to
use alkalinity again.
I'm working on getting the other aeration basin going as hard as I can. We've cleaned out the
weeds. I tested the drain yesterday. I'm going to work on cabling for aerators this afternoon.
I've got electrical parts for the switchgear on order again (they lost my order the first time). Any
one aerator motor is in Monroe being rewound,
Thanks,
David Nichols
WWTP/Collections/Distribution/Cross Connections ORC
Town of 0akboro
PO Box 610
oakboro, NC 28129
[e-mail]
704-984-0320 cell
704-485-4613 office
704-485-2439 fax
-----original Message -----
From: Sifford, Barbara [male.lto:[e-mail])
Sent: Wednesday, April 13, 2011.03:08 PM
To: [e-mail]
Subject: RE:
I'll think about the issues and talk to you tomorrow. I was teaching class yesterday. We received notice
today that the NC House has decided to close the MRO and all positions in DENR will be eliminated as of
July 1. This has to go to senate and the Governor but who knows now what is happening.
From: [e-mail] [mailto:dnichols@oakbaro,com)
Sent: Tuesday, April 12, 2011 8:39 AM
To: Sifford, Barbara
Cc: Branch Larry; Holshouser Ross
Subject:
Barbara:
Help!
hftp://mail.oa born.cornledgedeskicgi-binfviewmail.exe?id-016a1 cacc467e237c87dde77ae... 6/7/2011
DENR-WATER QU
POINT SOURCEBRANCF'

Good news: finally last week we started to show the needed improvement in effluent ammonia: 6.0, 15 and 8.1 mg/L.
This is with an influent ammonia greater than 100 mg/L. We were augmenting about 40 mg/L of ammonia everyday.
Bad news: about' Thursday of last week our aeration basin DO dropped to 0.3mg/L and has hovered there since. 1 was
away at Well school when this happened. Monday morning early Leon and cleaned all our aerators which are running
well but this hasn't helped. The plant has stopped using alkalinity which hovers at 100mg/L. Our effluent BOD's are
running a little high as well.
The only reasonable explanation I have is someone is sporatically dumping into our collection system something with
huge oxygen demand. I'm waiting for the influent BOD numbers. We aren't set up in house for COD.
We are working as quickly as possible to rehab the second aeration basin to get some more DO capacity, However the
three we are operating gave DO's over 3.0mg1L a few weeks ago.
Do you have any suggestions on tracking down our DO problem? Should we start pulling and COD samples
from the collection system and try to track down the source?
Thanks for any help you can give.
David Nichols
WWTP/Collections ORC
Town of Oakboro
PO Box 610
Oakboro, NC 28129
[e-mail]
704-984-0320 cell
704-485-4613 office
704-485-2439 fax
http://mail.oakboro.cony'edgedesk/cgi-bin/viewmail.exe?id=01,6a1 cacc467e237c87dde77ae... 6/7/2011

dnicholsCoakboro.corn <dn cholsCPoakboro.com>
To: Sifferd Barbara <barbara.sIffordeancdenr,gov>
Cc: Branch Larry <Ibranch oakboro.com>, Hvlshouser Ross <[e-mail]>
Irate: Sunday, April 17, 2011 08:42 am
Subject Re: ©akboro WWTP
Attachments:
bare:
Knock on wood, I think we are turning the comer.
With a lot of long days and hard work, we were able to start filling aeration basin #2 Friday night and tumed on two aerators
Satuniay morning. The basin isn't full yet and we still need to work on the third aerator which is being rewound, but the
situation is looking up. Sunday morning the basin Do is 2.4rng/L, we are using alkalinity again and unoffical ammonia on an
effluent grab is 3,6mg/l. not quite In summer compliance limit but close.
Thanks for your help and support.
David Nichols
WWTP/Collections/Distribution/Cross Connections ORC
Town of oakboro
PO Box 610
oakboro, NC 28129
dnichols©oakboro.com
704-984-0320 cell
704-485-461.3 office
704-485-2439 fax
-----Original Message -----
From: Sifford, Barbara [mailto:barbara,sifford
Sent: Wednesday, April 13, 2011 03:08 PM
To: [e-mail]
Subject RE:
enr.gov]
I'll think about the issues and talk to you tomorrow. I was teaching class yesterday. We received notice
today that the NC House has decided to close the MRO and all positions in DENR will be eliminated as of
July 1. This has to go to senate and the Governor but who knows now what is happening,
From: [e-mail] [mailto:[e-mail]]
Sent: Tuesday, April 12, 2011 8:39 AM
To: Siff€rd, Barbara
Cc: Branch Larr*, Holshouser Ross
Subject:
Barbara:
Help!
C NR-WATER t'3UAL
PONT SOURCE BRA
Good news: finally last week we started to show the needed improvement in effluent ammonia: 6.0, 15 and 8.1 mg/L.
This is with an influent ammonia greater than 100 mg/L. We were augmenting about 40 mg/L of ammonia everyday.
Bad news: about Thursday of last week our aeration basin DO dropped to 0.3mg!L and has hovered there since. I was
away at Well school when this happened. Monday morning early Leon and cleaned all our aerators which are running
well but this hasn't helped. The plant has stopped using alkalinity which hovers at I00mm,g/L. Our effluent BOD's are
running a little high as well..
The only reasonable explanation I have is someone is sporatically dumping into our collection system something w
huge oxygen demand. I'm waiting for the influent BOD numbers, We aren't set up in house for COD.
h1 r://mai1.oakbaro.comtedgedesk/cgi-bin/vieivrrtail.exe?id=016a1cacc467e237c87dde77ae... 6/7/2011

in g s quickly as possible rehab tine second aeration basin to get so
ee we are ope .:, g gave DOS over 3:OmgIL a f ks ago.
Do you have any su eslions on trackirtg downourDO proble
from the collection system and try to =ck down the source?
Thanks for any help you can give.
David Nichols
WWTP/Collections ORC
Town of Oakboro
PO Box 610
Oakbofo, NC 28129
"chol akbor .c rl:
704-84-032 cell
7 44 5.4 1 office
704-485-2439 fax
Should
to:
DO capacity L oweve
pulling d COD s pies
NR.WAT i.�A
POINT SOURCERANCH
ht%://mm bor .cot /ed ed s a"`c i-birr 'vie il. ` id— o 1 hal c c4 7e237c 7dde77 , , 6/7/2011

From: fn cholst' oakbaro.com <[e-mail]>
To: 5rifford Barbara <barbara.sifFordOncdenr.gov>
Cc: Branch Larry <[e-mail]>, Hoishouser Ross <rholshousertPoakboro.com>
Data: Saturday, April 23, 2011 01:00 pm
Subject: Oakboro W WTP nitrification
Atiachments:
arbara:
This week our effluent ammonia results were 2.1, 1.0 and <1.0 mg/L N
W000 hoot)! I am taking extra composite samples for the rest of the month to
factor into our average but it will still be on the edge of 3.0 mg/L summer
compliance. I think 7 weeks is pretty good recovery time considering 10-15 C
water temps.
The second aeration basin helps tremendously. Our DO stays in the 3-4mg/L
range. our aerators are still clogging and must be cleaned weekly. Settling is
much much improved. We had a moderate storm yesterday that didn't phase
the plant.
I included clariifier repairs in my 2011 budget proposal. I have my fingers
crossed. I want to get the town board down to the plant and explain how it
works and why the clarifiers are so important.
Thanks for your help.
David Nichols
WWTP/Collections/Distribution/Cross Connections ORC
Town of Oakboro
PO Box 610
Oakboro, NC 28129
[e-mail]
704-984-0320 cell
704-485-4613 office
704-485-2439 fax
ham://Trail.©akbor .c© +"'edgedesklegi-bin/view m a1. xe?id=?16 .1c cc467e23.7c87dde77ad... 6/7/2011

From: dnichols
o kboro.com <[e-mail]>
To: Sifford Barbara <barbara.siffordancdenr.gov>
Cc: Branch Larry‹Ibranch©oakboro.com>, Hoishouser Ross <rhoishouser©oakboro.com>
Date: Sunday, May 01, 2011 10:13 am
Subject: Oakboro WWI? nitrification
Attachments:
arbara:
This week our effluent ammonia stabilized around 0.1 mg/L. It took 7 weeks,
or just over 3 minimum SRTs of 15 days, just what the microbiology kinetics
predict. I did extra sampling but the monthly average was 4.0 mg/L so we
are still out of compliance for April (limit 3.0 mg/L).
We are still having DO dips but not as severe or prolonged with the extra
aerators. We have another aerator and switchgear repaired and ready to
install as soon as Tommy is available with the backhoe to set it in the basin.
This week I ordered 10 tons of lime to give us a consistent supply. We are
adding 100-400 Ibs per day to keep the alkalinity at 100 mg/L. This keeps our
pH at 7.0. This is where I have heard as minimal for nitrification. Can we
drop a little lower to save cost? What is your experience?
We have started a program of composite sampling in our collection system to
isolate the major source(s) of our ammonia. 40 mg/L influent just seems too
high for domestic with our I&I. Early indications are the majority is from the
Locust/Stanfield force main. We are starting at the bottom of the tree trunk
and working back testing each branch. Do you have any suggestions? We are
hoping on cooperation from Locust/Stanfield. We do not have an enforceable
SUO or a pretreatment program. These are on my long term TO DO list.
Thanks for your help and patience.
David Nichols
WWTP/Collections/Distribution/Cross Connections ORC
Town of Oakboro
PO Box 610
Oakboro, NC 28129
[e-mail]
704-984-0320 cell
704-485-4613 office
704-485-2439 fax
a 1 3 201
(JAU
POINT SOURCE BRANC
http://mail.oakboro.comJedgedesk/cgi-birjkie aitexe?id=0 1 6a1 cacc467e23 7c87dde77ae..,. 6/7/2011

Bever:y Eaves Perclue
( iovernor
NCDENR
North. Carohna Departmeu: of Environment irad Naturril Resources
Division of Water Quality
(Aileen FL Sullins
Director
CERTIFIED MAIL 7010 0290 0000 4565 0434
RETURN RECEIPT REQUESTED
The I lonorable Joyce 11. Little, Mayor
Town of Oakboro
Post Office Box 610
Oakboro, North Carolina 28129
Dear .Mayor Little:
June 28, 2011
Dec Fftunlan
Seeletary
SUBJECT: Notice of Violation and Assessment of Civil
Penalty for Violations of N.C. General Statute
143-215.1(a)(6) and NRDES Permit No. NC0043532
T w:n of Oakboro WWTP
StablyCounty
Case No. 1 V-2011-0177
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of $2336.74
'$2250.00 civil penalty -t $8(,74 enforcement. costs) against the TOWLI of Oakboro (Oakboro).
This assessment is based. upon the following facts: A review has been conducted of the self -monitoring
data reported for March 201:1. This review has shown the subject facility to he in violation of the discharge
limitations found in 'NPDES Permit No, NC0043.532. The violations are summarized in Attachment .,,tk to this
letter.
Based upon the: above facts, 1 conclude as a matter of law that Oakboro violated the terms, conditions, or
requirements of 'NPDES 'Permit No. NC0043532 and North Carolina General Statute (G.S.) 143-215,1(a)(6) in.
the manner and extent. shown in Attachment A. A civil. penalty may be assessed in accordance with the
maximums established by G.S. 1.43-215.6A(a)(2).
Based upon the above :findings of fact and conclusions of law, and in accordance with authority
provided by the Secretary of the Department of Environment and Natural Resources and the Director of the
Division of Water Quality, 1, Marcia Alloceo, Acting Surface Water Protection Regional Supervisor for the
Mooresville Region, hereby make the following civil penalty assessment against Oak.boro:
Moorts i 47. Regional Office
(310 Eas Centzr A vo.. SlidelI N,loot,n lc, NC .I 115
(704 ) I (09 \ Fax. [phone] Cnso.on ler icc: 1-877.,623 .6 748
IUt,J1L(
One
Nor
Niituraik
An Equal. ripes CAffirnonme es0KM Mniplayor Mrs, esemskut Post Consumer paper

(3)
(4)
(5)
(6)
(7)
(8)
250.00
000.0(
2250.00
86,74
-'336.74
For 1 of the one (1) violation of G.S. 1.43-215.1(a)(6) and
NPDES Permit- No. NC0043532, by discharging Waste into the
waters of the State in violation of the permit daily maximu.m
effluent limit for total residual chlorine.
For 4 of the four (4) violation of G.S. 143-215.1(a)(6) and.
NPDES Permit No. NC0043532, by discharging waste into the
-waters of the State in violation of the permit -weekly average
effluent limit for ammonia nitrogen.
For of the one (1) violation. of G.S. 143-215.1 (a)(6) and
NPDFS Perinit No. NC0043532, by discharging waste into the
waters of the State in violation of the permit .monthly average
effluent limit or ammonia nitrogen.
TOTAL CIVIL PENALTY
Enforcement costs.
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 violations;
The duration and gravity of the violations;
The effect on ground or surface water quantity or quality or on air quality;
"fhe cost of rectifying the damage;
The amount of money saved by noncomplian.ce;
Whether the violations were committed Willfully or intentionally;
The prior record of the violator in complying or failing to comply with programs over which the
Environmental Management Commission has regulatory authority; and.
The cost to the State of the enforcement procedures.
Within thirt),,' days ofreceipt of this notice, you must do one of -the .following:
Submit payment of the penalty:
Pay -II -lent should be made directly- to the order of the Department of Environm.ent and Natural.
Resources (do not include .waiver :PO. Payment of the penalty will not foreclose further
enforcement action for any continuing or new violation(s).
Please submit payment to the attention of:

Point Source Compliance/Friforeement init
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699 161 7
OR
2. Submit a written request for remission including a detailed justification for such request:
Please be aware that a requ.est for remission is limited to consideration of the five factors listed
below as they may relate to the reasonableness of the amount of the penalty assessed.
Requesting remission is not the proper procedure (Or contesting whether the violation(s) occurred.
or the accuracy of any of the factual statements contained in the civil penalty assessment
d.ocument. 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 that no factual or legal issues are in dispute. Please prepare a detailed statement that
establishes ‘Yhy you believe the civil penaltyshould be remitted, and submit it to the Division of
Water Quality 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 Ci:S. 143.B-282.1( h) were
vs,Tongfully applied to the detriment of the petitioner:
(1,) wheth.er the violator promptly abated continuing, en irorimenhd 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 intbrmation presented in support of your request for remission must be
submitted in writing: "the :Director of the Division of Water Quality will review your evidence
and inform you of his decision in the matter of your remission request: The response will
provide details regarding ease status, directions for payment, and provision 'for further .appeal of
the penalty to the Environmental Management Commission's Committee on Civil Penalty
Remissions ,(ommittee). Please be advised, that th.e 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:
la order to request remission, yOU must: complete and submit the enclosed "Waiver of „Right to an
Administrative Hearing and Stipulation of Facts" :form within thirty (30) days of receipt of this
notice, '.Ihe Division of Water Quality also requests that you complete and submit the enclosed.
"Justification for Remission Request." Both forms should be submitted to the following address:

1617 Mail Servi.
rnpllanc .=`1
Q u a
'(.'halter
Raleigh, North Carolina 7Ci f)Rl617
OR
File a petition for an adnaini,stratihearing with the Office of Administrative He r.ngs:
ad
:inst file the pe
notice. A petiti
during normal office hours. The
lay hetwcen. the hours of 8:00 a.
led by
ginal,
e of Min
in the attached assessment. document you must file a petit
the petition fbrxn t:rorn the Office of Administrative flea
f Administrative Hearings within thirty (30) days of receipt
.d 'when it is received in the Office of Administrative. Hearings
Adrninistrat.Rc ll.eaa.rirags accepts filings Monday throa,r
in, and 5:00 p.rn., except for ofticial state holidays. The petition
fax) or electronic mail by an attached ii1e { ith restrictions) - provided the s
and a tiling lee cif as filing fee is reelutrecl Tad I C`CiS ti 15013-`? 3. ) is received in the
Hearings Within seen (7) business days ttsllc ing; the faxed or electronic:
d contact the Of.lic,e of A.dministraative He,. Nvith all questions regarding the
filing fee andlor the cietaails of the filing process. The mailing address and telephone and flax numbers
for the Office of Administrative Hearings are a
['if`tic.e aaf"Adn:.
67)4 Mail Service
Raleigh, RC 27699-6714
Tel: ()19)431-3000
) 431-3100
copy oi°
he petiti
Thompson, General C,oa
C:'cnte
lei' 2769)-1601
e to exercise one of
rnal date/time received s
1's Office for collection of the pen
options above wit
ahirty
postmark), will rest
gl� a civil action.

Please he advised that additional penalties may be assessed for violations that occur after tile review
period of this assessment. If the, oktions are of a n1 iiiuLijg nature not relatgd to operation and or
nrairitcnance prhttleinst and vomantigi fate remedial construction activities„, then you may nyish to consider
applyingfor a Special Oritershy Consent 11youthiwe anVquestions about this civil perialtynissegstnent 01a
pecial Order b illonsentgplettese contact the Witten Quality Section staff of the MooreavilleRegionat Office at
704166 3it 699
(1)ittett
sett, hterty eglehlth
Marcia tkliocco
Actin Regional Supervisor
Surface Water Protection
Mooresville Regional ()Rice
Division of Water Quaint"
ATTACHMENillS
cc: Mooresville 'Regirmal Office Coniplitinee File v attachments
Raleigh Compliance/ Enfrircernent File wf attachments
Central Filesv attaghtrients

Ott tfall Date
002 3/9,11
002 2/27-3/5/11
1102 3/6-12/11
(1(12 3113-19/11
002 3/20,-26211
002 3/11
ONTIACIIMENT
CiA.SE ro..112‘0/201111-01.737.
Parameter
111R(.1
ammonia nitrogen.
ammonia nitrogen
ammonia nitrogen
ammotain nitrogen
a M. it ()Ilia tit trog,en
• 'it: 11tetiotesreititiMperialty assesgmeot.
Reported Vulue
*060 owl
*28,5 ingll
*28,7 mgil
*21.0 ingli
*22.1 mg/1
*03,3 mg/1
Permit Limit
8 !tut! (daily maximum)
18 trigll (weekly average)
1,8 argil (weekly average)
18 mgil (weekly average)
18 01111 (weekl) average')
6 nig/1 imorithl y average)

STA*IT OF NORIA CAROLINA DERARTMENT OF EN VIRONMEN'l
..AND NATURAL RESOURCES
COUNTY OF S 1 AN[ Y
IN 'fin MATTER OF ASSESSMENT'
OF CIVIL PENAI„.TY AGAINST
TOWN OF OAKIIORO
PERMIT NO. NC0043532
Wl\IVER OF RIGHT TO AN
ADMINIS7FRATIVE HEA.RIN(.1 A.
S'ElPEjl....A,TION OF FACTS
FILF N(.)LV-20 11-01 77
Having been assessed civil penalties totaling S 2.336.74 for violation(s) assc-t forth in the assessment
document of the Division of Water Qu.ality dated June 28, 2011, the undersigned, desiring to seek remission of
the civil penalties, 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 Mrther understands that all
evidence presented. in support of remission of this civil penalty must be submitted to the Director of the
Division of Water Quality within 30 days of receipt of the notice of assessment.. No new evidence in support of
a remission request will be allowed after 30 days -front the receipt of the notice of assessment.
This the
AD1)R SS
To„,'PI{0N1.
BY
2011

E)A%Q Case Number:
Assessed Party:
County:
Permit Number:
IN-2[)11-177
Town of Oakboro
Stanly
NC 0043532
Amount Assessed: S2336,74
Please use ibis frrty when r
Rem talrcr cR%/rt,to ?`A
an :�•o�rarar le p�..�
ttf}this a it l maltYou should a
for the lmirectrar twa consider in evalu
as consideration of the
)N FOR RI M
request trr
utrars listed
perrtalt assessed, Request"
whether the °ical atirrn(s) occurred or the accuracy o
assessment document, Pursuant to N..(,..(li.S. § 143F3-282.1
kvhen one or more of the following live factors applies,
your case and provide a detailed explanation, including -opies
applies (attach additional pages as needed).
one or naca e tad the yil penalty.
applied to the d trirnent oltlre t(l trt ftlze assessment
document);
explain the steps
unalY
en as
:,QUEST
lust also cc:,naplete t:lre 'dl trr?. t For°
form to request rerr2ission
believe support your request and are nec.sstr.
mission. Please he aware that a request for
the reasonableness of
ow as they may relate
n is not the proper procedure for contesting
al statements contained in the civil penalty°
a civil penalty may be granted only
that you believe applies to
as to the .factor
upporting doe
LI-1-22.1h) tiiere wrongfully
the c
1 eontir rrin nvj ont ental l at ttge r ° taltn
nd prevent /Idlure oc[zar"epees
ent of tl r rc l_penalty
nt or a result
event tar' pr.e.por°
pre*.�,°ertt ay tent to
(i. ecivil pet will prevent vot
achl'c: a e# e'earrlpliarrc'E
AN ATI
i.nu nec
ent
etions
necessary to.

Violator:
Facility:
County:
Case Number:
Permit Number:
NORTH CAROLINA DIV1 'ION OF WATER QUALITY
Town of Oakboro
Oakboro WWTP
Stanly
1.-V-2011-0177
NC0043532
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 harm has been documented. Ammonia nitrogen discharged in amounts that exceed the NPDES
Permit weekly, and monthly averages would be predicted to cause adverse impacts downstream of the
facility. The discharge would be expected to stress aquatic lifie. due to toxicity and lowered dissolved
oxygen, and increase nutrient loading of the receiving water. One daily maximum exceedance of the
total residual chlorine was reported. Chlorine is a toxicant used in the disinfection process and is likely
to have had an adverse impact on aquatic life near the discharge.
2) The duration and gravity of the violation;
The violations have continued since January 2011 into April 2011. During the month of March 2011 the
ammonia nitrogen weekly average was violated on four oecassions:. 2/27-3/5/1 I., 28.5 mg/I. 58.5% over
the permit limit; 3/6-12/11, 28.7 mg/I, 59.6%, over the permit limit( 18 mg/.1); 3/1349/11, 22..0 m,g/I,
22.4% over the permit limit; and 3/20-26/11, 22.13 mg/I. 234)/0 over the permit limit. The ammonia
nitrogen monthly average permit limit was reported as 23.3 mg/1, 2889/0 over the permit limit (6 mg/1).
Total residual chlorine was reported as >60 ug/i, 114..3% over the permit daily maximum limit (28 ug/l).
3) The effect on ground or surface water quantity or quality or on air quality;
No effect on ground water or air quality are expected. Surface water is likely to have been impacted by
the discharge to increased amounts of toxicants (ammonia and chlorine) in the receiving stream.
Ammonia would also decrease dissolved oxygen levels and increase nutrient addition down.strearn of the
discharge.
4) The cost of rectifying the damage;
The cost to the Town of Oakboro has been significant. The Town spent $1.3„071..39 to replenish the
activated sludge and make repair and modifications to the process. New laboratoryequipment and
reagents were also purchased. Operational costs for lime addition and increased electrical usage is
$79.00 per day. The Town is also expending 20..5 man-hours per week for lime addition. Following
the first knowledge of the, violations the Town requested immediate technical, assistance from the
Mooresville .Regional Office TACU staff The TACU staff recommen.dations were carried out. Cold
weather hampered the biomass recovery.

The mount of money saved tad noncompli nce
No money has been saved by'the onc nwharoce.
Whether the v7io1ation was committed vv 1lfuil or i
[he violations do not appear to be willful r intentional,
nt
n
The prior* record of the violator in comp inf or failing to comply with programs over which the
Environmental Management Commissiiin has regulatory authority; and
Case Number
LV-2011-01 fi
TV-2011-
io
6, 4i ammonia nitrogen \
6. 4, ammonia nitrogen vio
open
ns rta t ► 1,
'ins in 2/11
ion requested case open
ssion requested case
The Bost to the State rtf the enforce ent procedures
Strati' preparation of enforcement package:
SWP Regional Sundryscr ret ier
Clerical Suppi�rt
Total:
l hour at Su,i 9/hour
1 hour at g. /hour
1 he ur at Sl ,00./hc ur
a.74
Acting RO Supervisor
Division of Water Qual

MONITORING REPORT(MR) VIOLATIONS for:
Fad
Major M n
PERMIT: NC0043532
Parrs tat
FACILITY: Town of Oakboro - Oakboro
ubasirt
COUNTY: Stanly
Report Date. 06/14111 Page. 7 of 8
trorrl1 Ctegoty: NPDE S
Violation Adioni None
REGION: Mooresville
Limit Violation
MONITORING
REPORT
OUTFALL/
PPI LOCATION
03 -2011 002 Effluent Chlorine, Total Residual
03 -2011 002 Effluent
03 -2011 002 Effluent
03 -2011 002 Effluent
03 -2011 002 Effluent
03 -2011 002 Effluent
PARAMETER.
Nitrogen, Ammonia Total (as
N) - Concentration
Nitrogen, Ammonia Total (as
N) - Concentration
Nitrogen, Ammonia Total (as
N) - Concentration
Nitrogen, Ammonia Total (as
N) Concentration
Nitrogen, Ammonia Total (as
N) - Concentration
VIOLATION
DATE FREQUE
03/09/11 3 X week
03/05111 3 X week
03/12/11 3 X week
03119/11 3 X week
03/26/11 3 X week
03/31/11 3 X week
UNIT OF CALCULATED
y MEASURE LIMIT VALUE % OVER LIMIT
ug/I 28 60 114.29
mg/l 18 28 53 5fi.52
mg/I 18 28.73 59,63
mg/I 18 22,03 22.41
mg/I 18 2213 22,96
6 23.29 288,22
VIOLATION TYPE
Daily Maximum Exceeded
Weekly Average Exceeded
VIOLATION ACT
None
None
Weekly Average Exceeded None
Weekly Average Exceeded None
Weekly Average Exceeded None
Monthly Average Exceeded None
N
PERMIT: NC0044024
FACILITY: City of Albemarle - Highway 52 WTP
COUNTY: Stanly
REGION:
ooresville
Limit Violation
MONITORING
REPORT
OUTFALL!
PPI LOCATION
03 -2011 001 Effluent
03 -2011 001 Effluent
03 -2011 001 Effluent
03 -2011 001 Effluent
PARAMETER
Flow, in conduit or thru
treatment plant
Solids, Total Suspended -
Concentration
Solids, Total Suspended -
Concentration
Solids, Total Suspended
Concentration
VIOLATION UNIT OF CALCULATE
FREQUENCY MEASURE LIMIT VALUE % OVER LIMIT VIi7LATiON TYPE
03/31/11 See Permit mgd 0.114 0.1359 19.19 Monthly Average Exceeded None
03/03111 2 X month mg/1 45 253 462.22 Daily Maximum Exceeded None
03/16/11 2 X month mg/I 45 282 526,67 Daily fsaxurnum Exceeded None
t73131/11 2 X month mgll 30 267.5 791,67 Monthly Average Exceeded None
VIOLATION ACTION