NC0043532_Enforcement_20110929

Beverly Eaves Perdue
Governor
1 Ai r...rrr.
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Coleen H. Sullins
Director
September 29, 2011
CERTIFIED MAIL 7009 1680 0002 2464 9860
RETURN RECEIPT REQUESTED
The Honorable Joyce H. Little
Town of Oakboro
P. O. Box 610
Oakboro, NC 28129
Subject: Remission Request of Civil Penalty Assessment
NPDES Permit Number NC0043532
Town of Oakboro WWTP
Stanly County
Case Number LV-2011-0151
Dear Mayor
Dee Freeman
Secretary
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 $1,750,00 of the $1,836.74 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 Environment and
Natural Resources (DENR). Send the payment within thirty (30) calendar days of your receipt of this
letter to the attention of:
Bob Sledge
NC DENR-DWQ — Point Source Branch
Compliance & Expedited Permits Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-16.17
OR
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: www.ncwaterquality.org
An Equal Opportunity 1 Atlirmative Action Employer
One
NorthCaro ina
Naturally

Mayor Joyce H. Little
LV-2011-0151 Remission Decision
p. 2
You may decide to have the Environmental Management Commission's, (EMC) Cornmitt
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.
on
If you or your representative would like to speak before the Committee, you must complete and return
the attached Request for Oral Presentation Form within thirty (30) calendar days of receipt of this letter.
Send the completed form to:
Bob Sledge
NC DENR-DWQ — Point Source Branch
Compliance & Expedited Permits Unit
16.17 Mail Service Center
Raleigh, North Carolina 27699-1617
The EMC Chairman will review the supporting documents and your request for an oral presentation (if
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.
Please be advised that the EMC's Committee 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 [e-mail].
Sincerely,.
John 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-2011-0151 Region: Mooresville County: Stanly
Assessed Entity: Town of Oakboro WWTP Permit: NC0043532
LI (a) Whether one or more of the civil penalty assessment factors were wrongly applied to the
detriment 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 ofthe 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 ensurefuture 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
problem 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 ammonia 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 VVWTP to compliance. The TRC violation was of short duration and the result of
abnormal operational circumstances.
(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 un.budgeted funds spent to address the noncompliance.
Additional funds are proposed in the upcoming budget to fund process improvements,
DECISION (Check One)
Request Denied 0
Full Remission Ulletain Enforcement Costs? Yes 2"No
Partial Remission Li $ (Enter Amount)
rev 1.0 - 8_31.09

STATE OF NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT
COMMISSION
COUNTY OF STANLY
IN THE MATTER OF ASSESSMENT
OF CIVIL PENALTIES AGAINST:
Town of Oakboro
DWQ Case Number LV-2011-0151
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 Commission 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 inmysri
no factual issues are in dispute, my presentation will be limited to five (5) minutes in length,.
st, and because
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 before 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 status as an individual, corporation, partnership or municipality, the State Bar's Opinion affects how you may
proceed with your oral presentation. See www,ncbar,comiethics, Authorized Practice Advisory Opinion 20064 and 2007 Formal
Ethics Opinion 3.
If you are an individual or business owner 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 a corporation, partnership or municipality 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: I) 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
1 a w.
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, Owner, etc.)
ADDRESS
TELEPHONE (

Mooresville Regional Office
Division of Water Quality
MEMORANDUM:
DATE: June 22, 2011
FROM: Marcia Allocco, Acting SWP Regional Supervisor
TO: Bob Sledge
BY: John Lesley
SUBJEC . Request for Remission
Town of Oakboro
NPDES Permit No. NC0043532
Case No.LV-2011-0151
Stanly County
MRO staff has reviewed the subject request for remission. Town of Oakboro was
assessed for four weekly average and the monthly average limit violations for ammonia
nitrogen during the month of February 2011. 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 (513071.39 documented) to restore the nitrification capability of the treatment system.
This office recommends a remission of the penalty.

DWQ IVI PENALTY ISS1ON FACTORS
Case Number n er: LV- g 1I-lit °l Region n; MR0 County: Stanly
Assessed Entity: Town of Oakboro Permit: NC0043
Whether one or more of the civil penalty assessment
detriment of the petitioner,
ors
ere
rongly applied to the
(b) Whether'the violator promptly abated continuing environmental damage resulting fror
the violation:
The facility took action in a timely manner to in the cause of the noncompliance;
however, because the prior ORC was reporting invalid laboratory data, there is no
of knowing hoer long the noncompliance Was actually occurring.
Whether the violation was inadvertent or aresuit of an accident,
The violations cannot be considered inadvertent or the result of an accident because the
noncompliance is the result of poor operation an improper laboratory controls. However,
the permittee was not aware of the problem and had no way of knowing the P had
lost its nitrification process:
ay
(d) Whether the violator had been assessed civil pane
es
or any previous violations;
(e) Whether payment of the civil penalty mill prevent payment for the rernaining necessary
remedial actions.
Considerable funds (1,gyt.g and approirately $79,00 per day of additional ongoing
casts) have been spent or) the attempts to taring the facility into compliance: therefore
MR0 recornrr ends a significant reduction or remission of the penalty;

Region l Recomr nd tiofl (Check One)
Request Denied Lij Rill Remission Parkm al R rn lion
Central Office Reco Recommendation (Check One)
Request Denied CD Full Remission P r* a Re mission
DirectsDecision (Check One)
Request DeniedEl Full Remission
Date
Partial Rnnissirnr
Coleen id, Sullins, Csrecto
Amount Remitted

Vi..ottattnris
tiounlyi
Case.. Numbtin: ...
NORTH-. iiiiiNROLINsk.
ihP
.:A.:S,SESSMENT
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 ha.s beep documed.ted, AITUTImaa nitrogen discharged in amounts that exceed the NPDES
Permit weekly and monthly averages would be predicted to cause adverse impacts downstrearn of the
facility. The discharge would be expected to stress niplatic life due to toxicity and louvered dissolved
oxygen, and increase nutrient loading of the receiving xvather
The .duration and gelititr:of thinvitilatihtu•
ncietaffidd .durinut the lattofhal.:f fthe ::mon.th of Jantttity..2.011.
•weok• of 1.13.0.215/TIth.e itveekly axitentigefainindtila littithiyas •ex..o."•:•ede4:•.by•4••Q,:T7H%, the Wee1(..o.f.'.
l2 11 hYttaistfifif the watikOI 3 Ii)111 hat and that -yank °PIM. 2•6•111 c 51•14°,4: 'The
•• arilmonia nitrogenlittitwas:.ex.oeeded by.:33.••:0,,•6°,4.,.. •
-.The•••••it!ffect on .ground or surface ss ater fittattlityhohignality orcomain.qualitt
NoHeffehittiihe ••exp•otted n ground AquaticHtoxicity,..lowered diss01.-ited:oxygett
and. increasedinutrienti.oad.ingstriiithe rifealifing 1111 11 11b.e•oxpected,
• .Thu)enst::of rectiileing the :daiitattel;
the
5) The amount of none saved 1)y noncompliance;
An undetermined arnount of pioney :nay have ifeen SaVCd by failing to properly maintain the
process equipraent.
6) \VI -tether the violation itAas committed p filthily or Intentionalh;;
The violation does rmt appear to 1e willful or iraentional.

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
June 13, 2011
Via E-Mail
Mr, David Austin Nichols
Town of Oakboro
P. O. Box 610
Oakboro, NC 2.81.29
Subject: Remission Request of Civil Penalty Assessment
Town of Oakboro WWTP
NPDES Permit. NC004353°2
Case Number LV-2011-0151
Stanly County
Dear Mr. Nichols:
Dee Freeman
Secretary
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. s ledge C@ ncden r. go v.
Sincerely,
Bob Sledge, Environrnental Specialist
Point Source Branch
cc: Enforcement File wloriginals
Central Files w/attachments
Mooresville Regional Office w/attachments
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: www.ncwaterquality.org
An Equal Opportunity 1 Affirmative Action Employer
One
NorthCarolina
ati ra1y

STATE OF NORTH CAROLINA
COUNTY OF STANLY
IN THE MATTER OF ASSESSMENT
OF CIVIL PENALTY AGAINST
TOWN OF OAKBORO
PERMIT NO. NC0043532
DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
WAIVER OF RIGHT TO AN
ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
FILE NO, LV-2011-0151
Having been assessed civil penalties totaling $ 1836.74 for violation(s) as set forth in the assessment
document of the Division of Water Quality dated June 2, 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 day of , 2011
ALIA ‘laaptpl'A 716d
BY
ADDRESS
TO » of 0" a ro
PO Bo 6/0
TELEPHONE
7Q�
q
3 351

DWQ Case Number:
Assessed Party:
County:
Permit Number:
Amount Assessed:
JUSTIFICATION FOR REMISSION REQUEST
LV-2011-0151
Town of Oakboro
Stanly
NC0043532
51836.74
Please use this form when requesting remission of this civil penalty. You must also complete the "Request For
Remission, Waiver of Right to an ,4dministrative Wearing, 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 applies. 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.Q.G.S. 143B-282.1fb) were wrongfully
applied to the detriment of_the petitioner the assessment factors are listed in the civil penalty assessment
document);
(b) oiatorromtIabatedcontinuinen'jronrnenta1damaeresu1tjnfrorntherjo1atjon
explain the steps that you took to correct the violation and prevent uture occurrences);
(c)
the violation was inadvertent or a result of an accident (i,e., explain why the violation was
unavoidable or something you could not prevent or prepare jr):
(d) the violator had not been assessed civil penalties for any previous violations;
(e) paymentof the civil penalty will prevent payment for the remaintnnseces— remedial actions.
(i.e., explain how payment of the civil penalty will prevent you from petforming the activities necessary to
achieve compliance),
EXPLANATION: (use additional pages as necessary.

gown Of Oakboro
109-A N. Main St. — PO Box 610
Oakboro, NC 28129
704-485-3351/ 704-485-2439 (fax)
www.oakboro,com
June 6, 2011
David Austin Nichols
WWTP ORC
Town of Oakboro
PO Box 610
Oakboro, NC 28129
704-485-3351x1
Point Source Compliance Enforcement Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Written Request for Remission of Civil Penalty File No. LV-2011-0151
The Division of Water Quality has transmitted a Notice of Violation and assessed
a civil penalty of $1836.74 for noncompliance with 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.
From January 4, 2011.to January 13, 2011, Ryan measured effluent ammonia
concentrations of 5.19, 4.43, 6.27, 6.27, 5.87 and 7.20 mg/L NH3-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.
Meanwhile 1 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

gown of Oakoro
109-A N. Main SI — PO Box 610
Oakboro, NC 28129
704-485-3351/ 704-485-2439 (fax)
wvinN,oakboro.com
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 WW1P.
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 rng/L in one week.
6. We have replaced expired reagents and the ammonia ion probe.
7. We began sampling our influent for amrnonia, realizing we can have over
100 rng/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 holiday on comp time. I have not had a day off since then. We enlisted a
community service worker to help expedite cleaning the aeration basin.

aown Of Oa kboro
109-A N, Main St. - PO Box 610
Oakboro, NC 28129
704-485-33511704-4.85-2439 (fax)
vivAtoakboro.com
We have spent considerable unbudgeted funds to rectify this situation:
1. 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 a.erators safely $ 110.00
6. Rewind motor of aerator 42-2 $ 3040.00
7. Electrical components and tools $ 1017.51
8. Hardware, hoses and piping $ 117.60
9. Additional electricity for aerators $ 1640.00
Total $ 13071.39
We expect to continuously spend due to process improvements and have included
these expenditures in our 2011-2012 budget proposal;
1. Electricity $ 40/day
2. Lime $ 39/day
Total $ 79/day
Manhours dedicated to lime addition: 20.5 man*hr/week out of 40 man*hr/week
available.
We have been in contact arid 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 concentration was in compliance averaging 0.9
mg/L.
Now we have approximately four times as much active biomass in aeration than
in February. Our aeration basin DO's are above 4 mg/L. We have an SVI of 66 and very
rapid settling sludge. Effluent TSS is 6 mg/L, BOD is 3 mg/L and ammonia is < 0.3
mg/L. Our plant is operating much better now after repairs, process control
improvements and new management.
For over a month, we have been sampling major contributors to our collection
system and analyzing for ammonia. We have identified the Browns Hill Pump Station in
Locust as our largest ammonia contributor. We continue to work with the Town of
Locust to further pinpoint and minimize the source.

We accept the facts that the plant has been out of c mp d t)'s right t
fine Tovim of hart). Flowever the funds that pay the fine a mild be much better
spent ire our process improvements. We request that the fines be mined.
Respectfully,
David Austea Nichols

Beverly Eaves Perdue
Governer
Mr, Larry Branch
Town of Oakboro
109-A N. Main St.
P.O. Box 610
Oakboro, NC 28129
Dear Mr. Branch:
NCDENR
North Carolina Department of Environment and Natura
Division of Water Quality
Coleen H. Sullins
Dire,ctor
March 7, 2011
Resources
Subject: Technical Assistance Evaluation
Town of Oakboro
NPDES Permit No. NC0043532
Stanly County, NC
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 of January 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 #2 (lof 3) was out for the last two weeks in January. This resulted in a lower DO levels leaving
the aeration basin but wa.s not recorded below 1.0 mgli. 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.
l',Iocresville Regional Office
L3cation: 610. East Cemer AVe„ Ste 301 Mcoresville, NC 28115
Phone: (,7041 663-1699 Fax [phone] 'l, Customer SerViCe: 1-877-623-6748
lnternet vevr#vsicwaterquality,org
•
Eapel CpacrarrRy Artrmeive Ac;tor) Emptyer 5G Reeycled, Past ansumer paper

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 matters please call my direct number at 704-
96 in the Mooresville Regional Office.
Sincerely,
Barbara Sifford
Technical Support
Mooresville Regional Office
CC: David Nichols

EPA
s ^vurc r'l8.,+tao t ct on Aar y
+NasrTc;cn.
0. 204sa
ate Compliance Inspection Report
Section A: National Data system Coding 1,i.e. PCS)
Fcnn Approved
CfvtB No. 2040-0057
Approval expires 3-31-96
21
Transaction Code
I'1I 2 I s
NFCES
.,4_5?2.
11 121
Remarks
1 I I I I 1 _1 l I I 1 I
Inspection Work Days Facility Self -Monitoring Evaluation Rating
69
761 I
71
B1
Inspection Type
17 18I 11
QA
3
Inspector
19 LI
ILA
L I
Reserved---
75I
Fac Type
201 II
sta
ection B: Facility Data
Name and Location of Facility Inspected (For Industnal Users discharging to POTW, also include
POTVW name and NPDES permit Number)
Cakboro WWTP
24933-B Barbees Grove Rd
Cakborc NC 29129
Entry T
:01: "00 :ail 11/02/27
Permit Effective Date
10/02/01
Exit Time/Date
04:C0 P-M. 11/02/22
Permit Expiration Date
14/=01/31
Names) of Onsite Representatives}/Titles(s)/Phone and Fax Number(s)
ry G Bran c /GRC/707-=195-8322/
Leon Marti71 Dead
5-49 3/
Name, Address of Responsible CfticiaE1 stteiPhone and Fax Number
H Lit°-e,2C Sox, 610 Cakoorr NC 23129/Mayor/704-455-3351,
Contacted
t+CS
Other Facility Data
Section C Areas Evaluated During Inspection (Check only (those areas evaluated
Records/Reports • Self -Monitoring Program • Sludge Handling Disposal R'acility Site Review
Compliance Schedules ■ Laboratory
Section D; Summary of Finding Comments (Attach additional streets of narrattv°e and checklists as necessa
(See attachment summary)
Names) and Signature(s) of Inspector(s)
Agency/Office/Phone and Fax Numbers Date
Barbara 5i__ord mR0 War/704- 63-1699 Ex.2196/
ature of Management Q A Reviewer
Agency/OffocelPhone and Fax Numbers Date
EPA Form 3560-3 (Rev9-94) Previous editions are cbet0
Page #

u vaxtara f Fi omComments (Attach add of nar~at ire and cKlists as ~necessary
Page

Permit. NCO043532
Owner - Facility: Calworo'WfVP
Inspection Date: 0212212011 Inspection Type: Technical Assistance
Compliance Schedules
is there a compliance schedule for this facility?
Is the facility compliant with the permit and conditions for the review period?
Comment: Comfirmed the data from K&W labs, on Friday 3/4 planning to haul MLSS
from Monroe to introduce apopuiation of nitrifiers to the system. Alkalinity is suffiecient
to promote growth. Hopefully this will lead to complinace. For two weks the plant has
not wasted to age the 11/'1LSS and this has not started the nitrifiers.
Effluent Sampling
is composite sampling flaw proportional?
Is sample collected below ail treatment units?
Is proper volume collected?
Is the tubing clean?
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 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 flow proportional?
is sample collected above side streams?
Is proper volume collected?
Is the tubing clean?
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
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 3 years (lab. reg, required 5 years)?
Are analytical results consistent with data reported on DMRs?
Is the chain -of -custody complete?
Dates, times and location of sampling
Name of individual performing the sampling
Yes No NA NE
■ 0 ❑ o
0■❑❑
Yes No NA ME
n❑■❑
• ❑ ■
o nion
n n■❑
❑ 0 ■ ❑
O 0u0
Yes No NA NE
CI0❑■
n on■
O ❑❑■
O no■
❑ n n ■
o no■
Yes No NA NE
• 000
■ non
• 000
■ n n n
• 000
■
■
Page #

Permit: NE00435-2
Inspection Date: 02,22;201 t
Facility: t akocro p4vriT
ion Type: d ec hi l ss,stance
Record Keeping
Results of analysis
Dates f araiysis
Name,of person perfornrirg analyses
Transported COCs;
Are Di tRs ccmptete: do they Include all pen
Arid share
pY
reters?
Has the facility submitted its annual compliance report to users and D Q'
(f the facility is or
permitted flow) Do they operate 4 with a certified aper to pan ea
the ORO visitations log available and current`
Is the ORC certified at grade equal to or higher than the facility classrfi fiat?
1 the backup operator certified at one grade less or greater than the fa
1s a Dopy of the current NPDES perm t available on site?
Fad ity has copy of previous year's Annual Report on file for revrew0
Comment
on
Yes No NA NE
Page #

Page 1 of 1
From: dnicholsPoakboro,com <[e-mail]>
To: [e-mail]
CC: [e-mail]
Date: Wednesday, March 02, 2011 05:14 pm
Subject:
Attachments:
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. Well 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://mpil.oakboro.00miedgede cgi-bi vie Lexe?id=0 1 a1 cacc467e237c87dde77ae.„ 6/7/2011

seeding Oakboro WW1'P
Page I of I
°
To: SIfford' Barbara <hmmam^.sxro,u@ncdenroov>
CC: rhnlshouserwpmkbnm.com
Date: Thursday, March 03,2011 05:44pn
Subject: seeding Oakmmwmnp
Attachments:
Ms. SUfford:
l have talked to Nyka Ketchum at Monroe VVVVTPabout providing activated sludge with high
nitrification activity to seed our p|ant. They are agreeable but want approval from you that this
is (}K 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 rnw*inQ on this. We
have a hauler on standby.
Thanks,
David Nichols
704-984-0320ceU
704-485-4613office
704-485-4918homne
;
�
Original
-----
From: Sifford, Earbara[maUto:barbara.sKford@nojennnov]
Sent: Wednesday, March2, 201184:28PM
oo:om|[e-mail]
Subject: RE:
This means the whole month ofFebruary isout ofcompliance, (think now weneed toadd dehydrated
bugs or maybe some from annthe,VVVVTP to get them jump started. With three months of consecutive
non compliance the $ starts going upand you get onthe compliance watch list, See what Larry wants tu
do. I would buy or transport from Badin or from WSACC, Tim Mauldin is the contact for \NSACC, and I
know they m/au|d have nitdMprs in the K4L3S. At least you know where the plant effluent is now. We can
watch itprogress, Looks like you got ogreat 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. |
think Ryan had been only running one,
From: dm com[nna
Sent: Wednesday, March 02.20114:14PM
To: SifforU, Barbara
Cc:
�
/
Ms. Sifford] have received the new ISA reagent and calibrated the meter and ammonia ion probe from
scratch at 10010 1 and Q 1 ppnn | fmUcwvod the calibration with four freshly d standards and got
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 sl(yw.Do you have any other suggestions?David Nichols
hup:llmail.oakhoro.comledgedesklcgi-binlviewmail.exe?id=016alc.acc467e237c87dde77ae.,. 6/7/2011

kce: seeding Oa bozo WWI? Page 2 of 2
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, I
think Ryan had been only running one.
From: [e-mail] [mailto:[e-mail]]
Sent: Wednesday, March 02, 2011 4:14 PM
To: 5ifford, 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. l 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
retum 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.com/edgedesk/cgi-bin/viewmail,exe?id=016a1 cacc467e237c87dde77ae... 6/7/2011

Ke: seeding Uakboro W W 1 P
Page 1 of 2
From: [e-mail] <[e-mail]>
To; Sifford, Barbara <[e-mail]>
CC: [e-mail], [e-mail]
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 dropping but 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
-----Original Message -----
From: Sifford, Barbara [mailto:barbara.siffo
Sent: Friday, March 4, 2011 10:49 AM
To: [e-mail]
Subject: RE: seeding Oakboro WWTP
ncdenr.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 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: Sifford, Barbara[mailto:[e-mail]]
Sent: Wednesday, March 2, 2011 04:26 PM
To: [e-mail]
Subject: RE:.
http://mt l,oakboro.cornledgedesk/cgi-bin/viewmail.exe??d=016a1 cace467e237c87dde77ae... 6/7/2011

Ka: Ammonia
Page 1 of 1
From: dnicholst oakboro.com <dnichols©oakboro.com>
To: Sifford, Barbara <barbara.sffford ncdenr.gov>
Cc: [e-mail], [e-mail]
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 almost 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 3-4mg/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,
avid Nichols
---original Message --
From: Sifford, Sifford, Barbara [mailto:barbara.sifford
Sent: Tuesday, March 15, 2011 03:51 PM
To: [e-mail]
Subject: Ammonia
.goy]
How is the plant running now? Haven?t heard anything, l?m afraid to think that no new is good news.
Please nate new email address
Barbara Sifford - [e-mail]
Technical Consultant
North Carolina Dept. of Environment & Natural Resources
Div. of Water Quality
610 E. Center Ave., Suite 301
Mooresville, NC 28115
Ph: 704.663.1699 Fax: [phone]
******«************** *******************
E-mail correspondence to and from this address may be subject to the
North Carolina Public Records taw and may be disclosed to third parties.
***********************************************************************
•lattp://mail.oakboro.com/edgedesk/cgi-bir viewmail.exe?id=o16a1 cacc467e237c87dde7'7ae... 6/7/2011

Arran at Uakboro W W lP
Page 1 di
From: [e-mail] <dnichols@oakboro,com>
To: Sifford, Barbara <barbara.sifford@ncdenr,gov>
Cc: Holshouser, Ross <[e-mail]>, Branch, Larry <Ibranch@oakboro,com>
Date: Friday, March 25, 2011 05:02 pm
Subject: Ammonia at aakbor© WWTP
Attachments:
Ms. Sifford
This week we got 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/L and I am maintaining it there
with the addition of hydrated time. 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. I
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.
All 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 chloramines (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
http:,(/maiLoakboro.corn/edgedesk/cgi-bin!vier rrlail.exe?id=016a1cacc467e237c87dde77ae... 6/7/20J 1

Page 1 of 1
From:
To:
Cc:
Date:
Subject:
Attachments:
[e-mail] <dnichols©oakboro.com>
Sifford Barbara <barbara.siff©[e-mail]>
Branch Larry <[e-mail]>, Holshouser Ross <rholshouser©oakbaro.com>
Tuesday, April 12, 2011 Q8:38 am
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 10omg/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.omg/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 0akboro
PO Box 610
Qakboro, NC 28129
[e-mail]
704-984-0320 cell
704-485-4613 office
704-485-2439 fax
http://mail.oakboro.c©rn/edgedesk/cgi-bin/vidwrnail.exe?id=©16a1 cacc467e237c87ddeZ7ae... 6/7/ 011

Page I of 2-
To. Sifford, Barbara " >
Cc. Branch Larry «|hmncn@pakbnr .cvm>, Hoishouser Ross <rholshnvSerr�oawoono.00m>
Date: Friday, April 1s,2Vzz 10:27am
mwhdect, Re:
OUCH! That is terrible news for those that work there and those of us you help,
Our basin DO is still hovering around 0.3mg/L. I had a COD ran on Tuesday influent composite
14
n.w gut. only �'+&to'g/4 mooaunA nyorne[hmg was dumped it is goms.
I'm wasting with a SRT=30 day targetMLSS=4100mg/L this week,
We are still nithl/hlQ but not good enough. InMuent4Q.7nlg/L, effluent 10.1, 10.0 and 7.88rng/
*ki".= `~ee . I./=eu to 9e� uno u"� up oerore _� can expect any better than this. We're starting to
III
use a'~a"/",yagain.
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
to work on
thi
noon
I've got e|ectr�a| pa�sfor the aw�chmearc o- � again [Ul � ~ aerators— ---~-'
- ~ on order Q� n (they lost my order the first time), An
one oe'p*// motor is in nomroe oeng rewound.
Thanks.
David Nichols
VVVVTP/Co||ections/0stribut/qn/CrnssConnections C]RC
Town ofOakboro
P[} Box 610
[]akboro, NC201Z9
dnicho([e-mail]
704-984-0320cel/
704-485-4613pffice
704-485-2439fex
|-----
From: Sifford, Barbans[nnaUto:barbara,sUffnnd@nojen,.00vl
Sent; Wednesday, April 23, 2011 O3:O8 PM
To:
Subject: RE:
I'll think about the issues and talk toyou tomorrow. | was teaching class yesterday. VVereceived notice
today that the NCHouse has decided toclose the MHOand all positions imDENRwill beeliminated asef
/uk/1. This has to go to senate and the Governor but who knows now what is happening,
From: o»nmFnnaUbo
'
�e�Ao�|1I,2O118;39AM
Sent: —
To: Sifford, Barbara �
'
Cm: Branch Larry; Hoshnumer Ross
Y
Barbara: �
�
hnn:llomai|ook6ocn,cn sklc`-bin/viu`mm-ailcseYid=Ol6uloacc467cJ37c87dde77me^- 6/7/281f

rye: Page 2 of 2
Good news: finally last week we started to show the needed improvement in effluent anunonia: 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 100mgfL. 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 3.0rng/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
http://mail.oakboroo.c©m/edgedeslc/cgi-bin/viewtnai l.exe `did—` 16a 1 cac467e23 7c 87dde77ae... 6/7/201.1

xe: u
pro wwlr Page 1 of 2
From: [e-mail] [e-mail]>
To: Sifford Barbara <[e-mail]>
Cc: Branch Larry <[e-mail]>, Hoishouser Ross <rholshouser@oakboro,com>
Date: Sunday, April 17, 2011 08:42 am
Subject: Re: ©akboro WWTP
Attachments:
Barbara:
Knock on wood, I think we are turning the corner.
With a lot of long days and hard work, we were able to start filling aeration basin #2 Friday night and turned on two aerators
Saturday 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 D© is 2.4mg/L, we are using alkalinity again and unofficai 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 Conn
Town of 0akboro
P© Box 610
©akboro, NC 28129
dnicholsfoakboro.com
704-984-0320 cell
704-485-4613 office
704-485-2439 fax
ions ORC
---Original Message ---
From: Slfford, Barbara[mailto:[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:[e-mail]]
Sent: Tuesday, April 12, 2011 8:39 AM
To: Sifford, Barbara
Cc: Branch Larry+; Holshouser Ross
Subject:
Barbara:
Help!
Good news: finally last week we started to show the needed improvement in effluent ammonia; 6.0, 1 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 1 have is someone is sporatically dumping into our collection system something with
huge oxygen demand. 1'nn waiting for the influent BOD numbers. We aren't set up in house for COD.
http://mail,oakboro.corn/cdgedesk/egi=binhie rrzai1.exe?id-016a1cacc467e237c,87ddeThe _,.' 6/712011

working quickly as possible to rehab the second aeration basin
hree we operating gave DO'DO's over IhragiL a few weeks ag
P e2f2
yore i capacity. Ho
Do you have any suggestions on tracking down; our DO problem? Should we pulling NTI3 and COD samples
from the collection system and try to track down the source?
Thanks for any help you can give;
David Nichols
1
W /Collections ORC
Town of Oakboro
POBox 61
Oakboro, NC 28129
[e-mail]
'704-984-0320 cell
704-485-4613 office
704-485-2439
l ttp:// ail oak ha orriled ed klc i•-biviewrnajl.cxe? d o1 6a 1 cacc467e23 7c 8 7ddeflae... /7/2011

UaKboro W W 1 F nitrification
Page 1 of 1-
From: [e-mail] <[e-mail]>
To: Sifford Barbara <barbara.siffordOncdenr.gov>
Cc: Branch Larry <Ibranchoakboro.com>, Holshouser Ross <rholshouse
Date: Saturday, April 23, 2011 01:00 pm
Subject: Oakboro WWTP nitrification
Attachments:
,(11
oakboro.com>
Barbara:
This week our effluent ammonia results were 2.1, 1.0 and <1.0 mg/L N.
W000 h000! 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
http://mail.oakbpro.corn/edgedesktcgi-biniviewrnail.exe?id--016a1cacc467e237c87dde77ae... 6/7/2011

„ uaKooro wwir ntintteation
Page 1 of 1
From: dnicho s
oakboro,com <dnicho
q.1
oakboro.com>
To: Sifford Barbara <[e-mail]>
CC: Branch Larry <lbranch®oakboro.com>, Holshouser Ross <rholshouser
Date: Sunday, May 01, 2011 10:13 am
Subject: Oakboro WWTP nitrification
Attachments:
oak
Barbara:
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 lbs 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
dnichols©oakboro.com
704-984-0320 cell
704-485-4613 office
704-485-2439 fax
http://mail.oakboro.cornledgedesickgi-bin/viewmail.exe?id;--016alcacc467e237c87dde77ae... 6/7/2011

Beverly Laves Perdue
Goveraor
NCDENR
North Caroiirut Deparutlent oh Env iromneros and Natural Kee:emcee.
Division of Water Quality
(LeiH. ukIUi
Direoor
CERTIFIED MAIL 7009 2250 0004 3266 3696
RETVRN RECEIPT REQUESTED
'The Honorable ,Joyce H. L ale, Mayor
Town of Oakboro
Post Office Box 610
Oakboro, North Carolina 28'129
SUBJECT:
June 2, 2011
Dee Free Mani
Secretary
'Notice of Violation and Assessment of Civil
Penalty for Violations of N.C. General Statute
143-215.1.(a)(6) and PDES Permit N. NC0043532
'fowl of Oakboro 'WWTP
Stanly County
Case No. EV-2011-0151
Dear Mayor Little:
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of $1836.74
($ 1750.00 civil penalty 4.- $86,74 enforcement costs) against the Town of Oakboro.
This assessment is based upon the following facts: „;\ review has been conducted of the self -monitoring
data reported for February 2011. This review has shown the subject facility to he in violation. of the discharge
limitations found in NPDES Permit No. NC0043532Fheviolations are summarized in Attachment A to this
letter.
Based upon the above facts. 1 conclude as a tn.atter of law that the Ton of 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 ELS, 143-21.5.6A(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 EI1Vironment and Natural. Resources and the Director of the
Division of Water Quality, I, '.Robert. B. Krebs, Surface Water Protection Regional Supervisor for the
Mooresville Region, hereby make the ifollowing civil penalty assessment against the '1:own of Oakboro:
Mcoresville kel 1Office
1.ocallon' 610 ErkFit Center Ave . Surkr 301 MooresNr1k., NC 28115
Phone: (.704) 663-1699 %. Fax' [phone] \ ()Jr:lower Service. 1-877-621-674
ntenit,
ATI ninunii Opportunity Anniruniture 50% deriritYni Posi Curcio -on' Finor
one .
Nort.11(7.a.r.)Iirra

1 ,000 fio
For 4 of the four 14) violations of Ci.S 143-215.103)(6) and
\PDES Permit No. NC0043532. by discharging, waste into the
\voters of the State in Violation of the permit weekly average
effluent Unlit for ammonia nitrogen.
,.. 750.00 For 1 of the one (1) violation of G;S; 143-2-15.1.(a)(6) and
_........_.
N.PDES Permit No; NC0043532, by discharging waste into the
waters of the State in violation of the permit monthly average
effluent limit for ammonia nitrogen.
4-4
750.0o
86;74
TOTAL CIVIL PENALTY
Enforcement costs;
1.;836.74 TOTAL AMOUNT DUE
Pursuant to GS. -1 43 -215.6A(c), in determining the amount of tile penalty I have taken into account the
Findings of Fact and Conclusions of Law and the factors set forth at (LS 14B2.1(b), which are:
(1) The degree and extent of harm to the natural resources of the State, to the public healtl., or to
private property resulting from the violations:
The duration and gravity of the violations:
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage:
(5) The amount of money saved. by noncompliance;
(6) Whether the violations were committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programsprogran over whichvhich thc
Environmental Management Commission has regulatory authority; and
(8) The cost to the State of the enforcement procedures.
Within thirty days of receipt of this notice, you must do one of tle following:
Submit payment of the penalty:
Payment should be made directly to the order of the Department of .Environment and Natural
Resources (do not include -(t: (liver limn). 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/Enforcernent Unit
Division of Water Quality
1617 Mail Service Center
-Raleigh., North Carol na 27699-161. 7

ulatiol
OR
2. Submit a written request for remis,
Please
below as t
Requestin;
or the accuracy
document,. Be'cau
n including a detailed justifi
rentissictn is limited to colt
the reasonallerless ctf the amount of
proper procedure'
factual statements co
n request forecloses the option of
a request must be accompanied by a waiver of your right to an admix
stipul°ation that no factual or legal issues are in dispute, Please prepare a detailed state
establishes why you believe the civil penalty should be remitted, and submit it to the Division o
Water Quality at the address listed below, In determirnitnp vllether a remission. request will be
e considered:
it penalty assessment factors in G.S, 14 B-282,1(h) were
ent of the petitioner:
:feed. continuing environmental damage resultingfrom
on for such request:
(4)
(5)
whether on
wrongfully.. appl
Nether the violator promp
.ion;
N. vim lter the violat
whether the violator had been assess
whether payment of the cavil pen,
remedial taetiiills.
Please note that all in.iTormation
submitted in writing. The Directorof dte i i ision of Water
�eci'sion In the in
case status direction 3iir payllletit, and prc
agement Commissions Commit tee on Civil Penally
Please he advised that the Committee cannot consider information that
emission request considered by the Director. Therefore, it is very,
a complete and thorough statement in support of y'oilr request for
and inform
provide detin
the penalty to the
Remissions (Committee
-vas not part of the orngt
important that you prep
remission.
j,lhether th
five fa
essed,
a
penalty assessineil
lministrative bean
ident:
previous
•the r `maiming necessary
ecu
s
a
eh
inistrativc. Ilearirt licettlt
-he Division of Water Quality
sioi Request." Both forms sho
n
ed in support of your re~quest.
uptete at
:acts" corn
Unit
n must. be
ou conlple
the enclosed. "
play
ind s
his

3. File a petition for an administrative hearing %with the Office, of Administrative Hearings:
If you wish to contest any statement in the attached assessment document you must file a petition for an
administrative hearing. You may obtain the petition form from the Office of Administrative Hearings.
You must file the petition with the Office of Administrative Hearings within thirty (30) days of receipt
of this notice, A petition is considered tiled when it is received in the Office of Administrative Hearings
during normal office hours, The Office of Administrative Hearings accepts filings Monday through
Friday between the hours of 8:00 a.m. and 5:00 p.m., except for official state holidays. The petition may
be filed by facsimile (fax) or electronic mail by an attached tile (with restrictions) - provided the signed
original, one (I) copy and a filing fee (if a 01in fee is required by NCOS §150B-23.2) is received in the
Office of Administrative Hearings within seven (7) business days following the faxed or electronic
transmission. You should contact the Office of Administrative Hearings with all questions regarding the
filing fee andlor the details of the: filing process. The mailing address and telephone and fax numbers
for the Office of Administrative Hearings are as follows:
Office of Administrative Flemings
6714 Mail Service Center
Raleigh, NC 27699-671.4
Tel: [phone]
Fax: [phone]
One '1. • ropy of the petition must also be served on DENR as :follows:
Mary Penny Thompson. Ger eral Counsel
.DENR
1601 Mail Service Center
Raleieh, NC 27699-1601.
Failure to exercise one of the options above within thi •,y (30) days of receipt of this letter, as evidenced
by an internal date/time received stamp (not a postmark), Will result in this matter being referred to the, Attorney
General's Office .for collection of the penalty througha civil. action.

'Please be advised that additionalitiona penaltics Inas, assess;
his assessment. ent, l ,l r . ` f a Conti
tc x°ctnclcnstrtact
Order
1" v_ (ns nt please contac
Re( ittrial OfficeCon pliann c l
E� om li nce;L1 CT t fµlIL I atttc.lin
( Llrtt�al t`iics "NI attachments
d for
not r
ed to
Section stat't cat the Ntooressiit_tt�n.

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002
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*ASE 1 .1..V- 11- 1lib
Reported Value
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„MST CAT FOR REMISSION REQUEST
DWQ Case Number: LV-2011-0151
Assessed Party: Town of Oakboro
County: Stanly
Permit Number: NC0043532
Amount Assessed: S1836.74
Please use this .form when requesting remission of this civil penalty. You must also complete the "Reque.st .For
li!cmission, Waiver of Riaht to an Administrative Hearinct. 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 -live 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
\vhether 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 applies,. 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) oneormore of the civil penalty assessment factors in N,C.G.S. 143B-282,1 (b) vere wron.gfullv
applied to the detriment of the petitioner (the assessment factors are listed in the civil penalty assessment
clocument);
(b) the violator promptly a ated continuing environmental damage resulting from the violation (1..e.,
_ —
explain the s cps that )0u took to correct the violation and prevent „it alive occurrences);
) 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 or,);
(d) the violator had not been asse:sscdeivii penalties for an previous violations;
(e) payment of the ,eivil pLn ilill. prevent payment tor the remaining -iecessary remedial actions
explain how payment of the civil penalty will prevent you from petjOrtning the activities necessary to
achieve cornpliance)
EXPLANATION: ise additional pages as necessary)

Violator:
Facility:
County:
Case Number: I.,V-_2011-0151.
Permit Number: NC0043532
)
NORTH CAROLINA DIVISION OF WATER QUALITY
Town of Oakboro
Town of Oakhoro WWTP
Stanly
ASSESSMENT FACTORS
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. Ainnaonia nitrogen discharged in amounts that exceed the NPDES
Permit weekly and m.onth.ly averages would be predicted to cause adverse impacts downstream of the
facility. The discharge would he expected to stress aquatic life due to toxicity and lowered dissolved
oxygen, and increase nutrient loading of the receiving water.
The duration and gravity of the violation;
The violations occurried during the latter half of the month of January 2011 and continued into April
2011. The week of 1130-2/5i 11 the weekly average ammonia limit was exceeded by 40.7%, the week of
2/6-12/11 by 53.7%, the week, of2/13/-19/1 1 by 27.8%, and the week of 2/20-26/11 by 5119%. The
monthly average ammonia nitrogen limit was exceeded by 330.6% ..
The effect on ground or surface water quantity or quality or on air quali
No effects are expected on ground water or air quality. Aquatic toxicity, lowered dissolved oxygen
availability, and increased nutrient loading of the receiving stream would he expected.
The cost of rectifying the damage;
The cost is unknown.
5) The amount of money saved by noncompliance;
An undetermined amount of money may have been saved by failing to properly maintain the WWTP
process equipment.
fi) Whether the violation was committed. willfully or intentionally;
The violation does not appear to be willful or intentional.

The
for record of the violator in complying or failing to compwith pro rai
ntal Management (otn issi n has regulatory authority; and.
Case NumberDV-2010-0036
DV-2010-0075
DV-2011-0018
The cost to
Staff prepay
ler`
rota
ascription
00190, SSO assessed 20 „8
WQCS00190,assessed 1 paid on 8/30/10
\\ CS O 1 Qi , SSO assessed $594.87, open
January 2011 ammonia limit violations, assessed 't .7 , remission
equested, ease open
he State of the enforce procedu
s
on of enforeernent packa e 1 hour at 3 .1 1hour
Regional Supe r i o r re
l Support:
1 hou
5/hour
hour at Si .00/h ur
$86.74
O Supervisor
Division of Water Quality
0
avhich the

MONITORING REPORT(MR) VIOLATIONS for:
ertmt 141418' 13etvveen: 2-2011 and 2.2011 Region: N400-Tesvilie
Pao ity Name: A Pram Name: .clio Countyall:
major moor: %
Report Date 06/01/11 Page 3 of 4
Violation Category: Limit V101atIOn Program Category:- NPDES ',An"
V
subtxtsin: 14, Violation Action: None
PERMIT: NC0043532
FACILITY: Town of Oakboro Oakboro WWTP
COUNTY: Stanly
REGION: Mooresville
Limit Violation
MONITORING OUTFALL /
REPORT PPI
LOCATION
02 -2011 002 Effluent
02 -2011 002 Effluent
PARAMETER
Nitrogen, Ammonia Total (as
N) - Concentration
Nitrogen, Ammonia Total (as
N) Concentration
02 -2011 002 Effluent Nitrogen, Ammonia Tot
N) Concentration
VIOLATION
UNIT OF CALCULATED
DATE FREQUENCY MEASURE LIMIT
02/05/11 3 X week mg/I 18 25 33 40 74
VALUE % OVER LIMIT
02/12/11 3 X week mg/I 18 27 67 53,7
I (as 02/19/11 3 X week
02-2011 002 Effluent Nitrogen, Ammonia Total (as 02/26/11 3 X week
N) - Concentration
02 -2011 002 Effluent
Nitrogen, Ammonia Total (as
N) - Concentration
02/28/11 3 X week
VIOLATION TYPE VIOLATION ACTION
Weekly Average Exceeded None
Weekly Average Exceeded None
mg/I 18 23 27.78 Weekly Average Exceeded None
mg/I 18 27 33 51 85 Weekly Average Exceeded
mg/I 6 25 83 330 56 Monthly Average Exceeded
, v 7 k, - 6" A A :CA., 4$1. /71, t$, „ 70 z ) pi" 1),pr )7( 7
-
PERMIT: NC0044024
FACILITY: City of Albemarle - Highway 52 WTP
COUNTY: Stanly
None
REGION: Mooresville
Limit Violation
MONITORING OUTFALL /
REPORT PPI LOCATION
02 -2011 001 Effluent
02 -2011 001 Effluent
02 -2011 001 Effluent
02 -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 CALCULATED
DATE FREQUENCY MEASURE LIMIT VALUE % OVER LIMIT
02/28/11 See Permit mgd 0.114 0.1401 22,9
02/04/11 2 X month mg/I 45 84 86 67
02/12/11 2 X month mg/I 45 176 291,11
02/28/11 2 X month mg/I 30 130 333,33
VIOLATION TYPE VIOLATION ACTION
Monthly Average Exceeded None
Daily Maximum Exceeded None
Daily Maximum Exceeded None
Monthly Average Exceeded None