NC0043532_Enforcement_20120109

NCDENR
North Carolina Department of Environment and Natu
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, RE.
Governor Director
January 9, 2012
CERTIFIED MAIL 7010 2780 003 4825 5567
RETURN RECEIPT REQUESTED
The Honorable Joyce H. Little
Town of Oakboro
P. O. Box 610
Oakboro, NC 28129
Dear Mayor Little:
a
Resources
Dee Freeman
Secretary
EDGE D
ID Alt Si ON CVATERQtJALITV
J.A.N I 3 202.
toi0ORESVOL: ONAL OFFICE
Subject: Remission Request of Civil Penalty Assessment
NPDES Permit Number NC0043532
Town of Oakbbro WWTP
Stanly County
Case Number LV-2011-0191
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 $250.00 of the $586.74 civil penalty assessment. The revised civil penalty is
therefore a total amount of $336.74, which includes $86.74 in 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 27699-1617
OR
1617)11ail Service Canter, Raleigh, North Carolina 276990617
Location: 512 N. Salisbury SI Raleigh, North Carolina 27604
Phone: [phone] FAX, 919-807-6492
Internet: oAvisf ncwaterqualrty.org
An Equal Opportunity \ Affirmative ktior Employer
NorthCarolina
,Vaturally

Mayor Joyce }1. Little
LV-2011-0191 Remission. Decision
p. 2
You may decide to have the Environmental Management Commission's (EMC) Commit
Civil Penalty Remissions make the final decision on your remission request.
on
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 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
1617 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].
Sine
ohn E. Dressy, Supervi "
Compliance & Expedited Permits Unit
Attachments
cc: Mooresville Regional Office — SWP Section
Enforcement File
DWQ Central Files

I IVISION OF WATER QUALITY
CIVIL PENALTY REMISSION -FACTORS
Case Number: LV-2011-0191 Region: Mooresville County.: Stanly
Assessed .Entity: Town of Oakboro WWTP
Permit: NC0043532
Q (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 violations in question occurred during one week when the WWTP experienced heavy flow due to i&i
that upset a fragile WWTP. The remainder of April was compliant for DOD and TSS.
While acknowledging the WWTP did recover quickly, the cited causes of the violations were a long time
in coming. By the Town's own words, wastewater infrastructure and operations have been neglected for a
long time. This neglect had more to do with these violations than the rainfall and l&l. Ammonia
noncompliance persisted for a few more weeks.
(c) Whether the violation eras inadvertent or a result of an accident:
The facility states the violations were the result a combination of factors. High flows reached the WW TP
at a time when its biomass was producing light solids that did not adequately settle. Only one of three
permitted clarifiers was in operation at the time, and some solids washout occurred.
While the WWTP staff has done a good job dealing with a difficult situation during the winter, these
particular violations have less connection with those of prior months. These violations would have been
avoidable had the Town been committed to better operations and maintenance over the years.
(d) Whether the violator had been assessedcivil penalties for any previous violations:
'The facility was assessed six
s 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
medial actions:
The Town has documented almost $20,000.00 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 0
Full Remission 0t- etain Enforcement Costs? Yes No
Partial Remission $ (Enter Amount)
rev 10-8.31 )9

STATE OF NORTH CAROLINA ENVIRONMENTAL MANAGEMENT
COMMISSION
COUNTY OF STANLY DWQ Case 'Number LV-2011-0191
IN THE MATTER 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 Commission and may be either granted or
denied.
Making a presentation will require the presence of myself andlor 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 request, 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 layers who are active members of the bar_ Proceedings before the Conunittee 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,corniethics, Authorized Practice Advisory Opinion 2006-1 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 pemnssible.
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
law.
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: August 17, 2011
FROM: Rob Krebs, SWP Regional Supervisor a`
TO: Bob Sledge
THROUGH: Marcia Alloccc
BY: John Lesle
SUBJECT: Request for Remission
Town of Oakboro
NPDES Permit No. NC0043532
Case No. LV-20i1-0191
Stanly County
MRO staff has reviewed the subject request for rry ission. The Town of Oakboro
reported violations of the effluent weekly average limits for BOD and TSS for the week of March
27 — April 2, 2011. The request for remission claims the violations were the result of excessive
ICI, however, the rainfall data submitted with the remission request shows rainfall events as
follows: 3/26/11 = 0.9 inches; 3/27/11 == 0.25 inches; 3/28/11 ,= no rainfall; 3/29/11 = 0.2
inches; 3/30111 -= 0;75 inches; and 3/31/11 = 0.1 inches. The rainfall amounts should not
cause significant I&I issues, The remission request also noted that only one clarifier was in
operable condition (three clarifiers are included in the facility description of the permit); The
NPDES Permit states that the WWTP and collection system must be maintained to attain
optimum treatment of the wastewater. The facility also violated the effluent ammonia nitrogen
weekly and monthly average limitations (not assessed a civil penalty), It is recommended that
the .full civil .penalty be assessed.

DWQ — CIVIL PENALTY REMISSION FACTORS
Case Number: ILV-2011-0191 Region: MR©
Assessed Entity: Ion of
t: NC0O43'32
County: Stanly
El (a) Whether one or more of the civil penalty assessment factors were wro
detriment of the petitioner;
Y ap
ad to the
(b) Whether the violator promptly abated continuing environmental damage resulting from
the violation,
Because the violator had failed to properly maintain the facility in an operable condition (only
one of three clarifiers were operable) and the Town knew the collection system had serious I&I
issues, It is the contention of this office that the conditions leading up to the BOD and TSS
weekly limit violations were not promptly abated, The Technical Assistance requested by the
Town did not address these issues, only the ammonia nitrogen noncompliance which was not
assessed a penalty in this case-
(c) Whether the violation was inadvertent or a result of an acc%dent;
The violations were the direct result of failure to adequately maintain the process euquiprent and
collection system. This office c'oes not agree that the subsequent violations are "accidents" or,.
"inadvertent' since the Town knew beforehand the process equipment was not operable.
E
(d) Whether the violater had been assessed civil penalties for any previoa s violations:
(e) Whether payment of the oivi6 penalty will prevent payment for the remaining necessary
remedial actions.
The Town has spent considerable funds to correct the ammonia nitrogen nonconrpiiance. The
Town was granted a $2,019.292 revolving loan by the Executive Committee of the NC Local
Government Commission} on July 12, 2011 for collection system rehabilitation. Tfre Town has
budgeted funds for one or the two inoperable clarifiers to be repaired. The rem(:)n request
states, in years past, utilities planning, infrastructure, maintenance, and process control have
been badly neglected at the Town of Oakboro for a variety of reasons." It is good commendable
for the Town to take responsibility and see the need for more diligence in the operation and
maintenance of their facilities; however, that does not change the facts that poor maintenance
and operation led to the violations.

Regional Rego
Request Dented
endation (Check One)
Full Rene s am
PaiifReri1ii`n
Cu tr 1 Office Reco endat"r r (Check l One)
Rectiest Denied Ei Full Remission Pat
"Rectoi i (Check Ore)
Request Denied Full Remission
P r i l Remission
Cate Coleco F. lice Dire
m 'ten

11
Violator: Mo\.r caf taakboro
Facili : O ikhoro \\' V1`r"TP
County:
Case Number:
Permit Humnber:
The deg and extent of i
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taticans for tl
atalpaicts or
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assessed a
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4

N4 DENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coley H. Sullins Dee Freeman
Governor Director Secretary
August 11, 2011.
Via E-Mail
Mr. David Austin Nichols
Town of Oakboro
P. O. Box 61.0
Qakboro, NC 28129
Subject.; Remission. Request of Civil. Penalty Assessmen
Town of 0akboro WWTP
NPDES Permit NC0043532
Case Number LN-2011-0191
Stanly County
Dear Mr. Nichols:
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.
have any questions about this matter, please contact me at [phone] or via e-mail at
[e-mail],
Sincerely,
xi/4
Bola Sledge, Environmental Specialist
Point Source Branch
cc: Enforcement File w/originals
Central. Files w/attachments
Mooresville Regional Office w/attachments
enter, Ralaugh, North Carolina 27699.1617
ton: 512 N. Salisbury Sr. Raleigh, Norh Carolina 27604
ne: 9194307.63001 FAX: 919-B07i64921 Customer Service:1-877-62'3.6748
Internet [e-mail]
An Equal apporlunnty i Affirmative Acton Employer
One
North Carolina
Naturally

vwn Of Oak6Qr©
109-A N. Main St. — PO Box 610
Oakboro, NC 28129
704-485-335111704-485-2439 (fax)
www.oakbora.com
August 5, 2011.
David Austin Nichols
Public Utilities Director
Town of Oakboro
POBox 610
Oakboro, NC 28129
704-485-3351x110
Point Source Compliance/Enforcement Unit
Division of Water Quality
1.617 Mail Service Center
Raleigh, North Carolina 27699-1617
Written Request for Remission of Civil Penalty File No. LV-2011-0191
The Division of Water Quality has transnutted a Notice of Violation and assessed
a civil penalty of $586.74 for noncompliance with weekly and monthly average effluent
ammonia concentration limits and BOD weekly average and TSS monthly average limits
by the Town of ©ak.boro Wastewater Treatment Plant for the month of April 2011. We
stipulate the facts of these violations but request omission of civil penalty in
consideration of the circumstances and response.
In response to ammonia violations:
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 an 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 trouble
problem,
DENRWATER
POINT SOUK:i

0-own Of Qukboro
109-A N, Main St. — PO Box 610
Oakboro, NC 28129
704-485-3351/ 704-485-2439 (fax)
www,oAborozorn
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 nitrifters 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 MISS 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 and 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 performed a 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.
DENR-WATER QUAL
POINT SOURCE BRAN

dawn Of Oa kbaro
109-A N, Main St. — PO Box 610
0akboro, NC 28129
704-485-33511704-485-2439 (fax)
www.aakboro.ccxn
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 $ 8389.86
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 $ 4480.00
Total $ 19693.42
We expect to continuously spend due to process improvements and have
approved these expenditures in our 201.1-2012 budget:
1. 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. The first
two weeks of July effluent ammonia averaged 0.12 mg/L while influent ammonia
averaged 33 mg/L.
Now we have approximately four times as much active biomass in aeration than
in February. Our aeration basin DO's are between 2 and 4 mg/L with 26C water
temperatures and one aerator out of service due to a lightning strike. We have an SVI
less than 100 and very rapid settling sludge. July effluent TSS averages 3.5 mg/L, BOD
averages 2.6 mg/L and ammonia averages 0.12 mg/L. Our plant is operating much better
now after repairs, process control improvements and new management.
In response to BOD and TSS violations:
During the last week of March, 2011.a series of rainfalls resulted in high flows
through the treatment plant and an upset of the single operating clarifier. Biosolids were
lost in the effluent with resulting high BOD and TSS values.
There were three contributing causes to this upset all of which have
continue to be addressed,
DENR-WATER QUALCTI'
POINT SOURCE BRANCH

5-own 0 Qak6oro
109-A N. Main Si, PO Box 610
Oakboro, NC 28129
704-485-33511704485-2439 (fax}
www.oakboro„com
Date Rain al (inch)
ch26,2011 0.9
Effluent Flow (MGD)
0.8856
.ch 27, 2011 0.25
ch 28, 2011 0
0.'7467
0.8023
ch 29, 2011 0.2
March 30, 2011 0.75
arch 31, 2011 0.1
0.5069
1.1473
0.7561
Cause one is very poor mixed liquor settleability. As explained above, during
March we were very aggressively trying to increase autotrophic biomass to treat our
excessive influent ammonia and remove us from ammonia effluent limit violations.
On March 23, 2011 we measured MLSS of 4200 mg/L. At this time we only had three
aerators operating in one aeration basin. Nitrification, was depleting our aeration basin
dissolved oxygen to an average of 0.6 mg/L over the period of March 26 to March 31.
Without enough oxygen to consume all the ammonia and BOD, heterotrophic bacteria
were generating excessive extracellular storage polymers resulting in an almost
gelatinous diffuse growth. Settling was extremely slow. During typical flow days,
clarification was adequate and effluent quality was good. During high storm flow days,
clarifier upset resulted in biosolids loss and poor effluent quality. After opening aeration
basin #2 on April 15th, MLSS has been stabilized to 2700 mg/L, aeration basin dissolved
oxygen has been above 3 mg/L except for the hottest days of July, SVI has dropped to
below 100 and settling is extremely good. This cause has been eliminated.
Cause two is only having one operational clarifier. For many years the treatment
plant has been running solely on clarifier #3 with design and peak flow ratings of
approximately 400 and 900 GPM. During much of the storms of the week of March 26
to 31, our effluent meter was peaked beyond its range of 999 GPM. The other two
clarifiers are rusted out and not in operable condition. Recognizing this is a terribly
dangerous situation, we met with Mike Matousek of Kemp, Inc to discuss rehabilitation
of our other two inoperable clarifiers in middle March. We included his estimate in our
2011-2012 budget proposal. Funding to rehabilitate one clarifier was approved in our
budget in June. In July, we worked with Special Projects Coordinator Larry Branch
exploring other sources of funding such as grants or low interest loans at the request of
our Town Board. After failing to find alternative financing, we are moving forward with
a competitive bid process. We are meeting with the contractor that built our operating
clarifier today and the contractor that is doing our Main Pump Station rehabilitation on
Monday. We hope to have another operating clarifier before the winter rainy season sets
in.
DENR-VVATER OUAL1W
POINT SOURCE BRANCH

gown 0 OakEloro
109-A N. Main Si — PO Box 610
Oakboro, NC 28129
704-485-33511704-485-2439 (fax)
WVAV oak bora corn
Cause three is a severe inflow and infiltration problem. Oakboro has a very aged
collection system. In 2005 a Sanitary Sewer Evaluation Study was done to determine the
extent and causes of our 1 & I.
A 300,000 gallon equalization basin has been built to mitigate heavy I & I flows
successfully reducing the number and extent of SSO from our Main Pump Station. This
also buffers flows to the treatment plant. Unfortunately extended rainfall will overflow
the EQ basin.
On July 12, 2011 the Executive Committee of the NC Local Government
Commission approved a $2,019,292 revolving loan to the Town of Oakboro for the
purpose of collection system rehabilitation to decrease 1 & I. Plans and specifications for
the work are in progress. We hope to get this badly needed work started soon.
In years past, utilities planning, infrastructure, maintenance and process control
have been badly neglected at the Town of Oakboro for a variety of reasons. Recently
there has been personnel turnover in the Town Administrator, Collections and
Distribution ORC and Wastewater Treatment Plant ORC positions. Additionally there is
a shift in our Town Board both in makeup and thinking. We are in the process of hiring
new more qualified and responsible employees and retraining old employees. A huge
push has begun to uncover and solve many of the problems that have been swept under
the rug for years. Critical flaws and deficiencies are discovered daily. We are working
diligently with limited financial, manpower, expertise and equipment resources to triage
and fix or stabilize the most critical problems first and catalog the many lesser problems
to be addressed as soon as possible. Many of the problems are quite extensive and
require coordinating with multiple outside contractors over a period of time. The process
is long and very frustrating but we are making headway. We sincerely appreciate the
patience and assistance of DENR and DWQ.
We accept the facts that the plant has been out of compliance and DWQ's right to
fine the Town of Oakboro. We have been working to identify and correct the causes of
the violations. However the funds that would pay fines would be much better spent in
our continued process improvements and rehabilitation work. We request that no fines be
levied.
David Austin 'Nichols
DER -WATER QUALITY
POINT soyRcE BRANCH

DWQ Case Number:
Assessed Party:
County:
Permit Number:
Amount Assessed:
JUSTIFICATION FOR
LV-2011-0191
Town of Oakboro
Stanly
NC0043532
$586.74
SS ON REQUEST
Please use this form when requesting remission of this civil penalty. You must also complete the "Request For
Remission, Waiver of Right tganAdministrative 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 an of the factual statements contained in the civil penalty
assessment document. Pursuant to N.C,G,S. § I.43B-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,C.G..S. 143B-282.1(b) were wrongfully
led to the detriment of the petitioner (the assessment factors are listed in the civil penalo; assessment
document);
(h) the violator prom_ntiv abated continuing environmental damage resulting from the violation
explain the steps that you took to correct the violation and prevent lieture occurrences);
(c) the violation was inadvertent or a result of an accident (i.e., explain -why the violation was
unavoidable or some -zing you could not prevent or prepare Ibr);
(d)
the violator had not he
en as essed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary remedial actions
(i.e., explain how paylnent of the civil penalty will preverzt ou Jror performing the activities neeessar_y to
achieve compliance),
EXPLANATION: (use additional pages as necessary)
4e7:17-BW-6TTALJTY
T SOURCE BRANCH

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
COUNTY OF STANLY
IN THE MATTER OF ASSESSMENT
OF CIVIL PENALTY AGALNST
TOWN OF OAKBORO
PERMIT NO, NC0043532
WAIVER OF RIGHT TO AN
ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
FILENO. LV-2011-0191
Having been assessed civil penalties totaling $ 586.74 for violation(s) as set forth in the assessment
document of the Division of Water Quality dated August 1, 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
ADDRESS
TELEP ONE
7C) q 416
29(
AUG 0 9 2011
DE -WATER OUALtTY
POINT SOURCE BRANCH

NCDENR
Nort-i Carolina department of Environment and Natural Resources
Division of Water Quail
Beverly Eaves Perdue Caleen R. Sullins Dee Freeman
Governor Dfrector Secretary
Mr. Larry Branch
ToM-n of Oakboro
109-A N. Main St.
P.O. Box 610
Oakboro, NC 281.29
Dear Mr. Branch:
Subject: Technical Assistance Evaluation
Town of Oakboro
NPDES Permit No. NC0043532
Stanly County, NC
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 42 (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/1. 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 inter
. ntl s 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 pe er otrophic bacteria (BOD bugs) and comprise a very small amount of the total biomass.
4
LSE 4R WATER gliGLi -y
POIKT SOURCE Bu&7
olina
wally

:;ai:boro
7-tb7UltrY 2C11
Analytical E 'siva'tion:
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 NEI3. 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 ofthe biological system.
2. Increased sludge return rate to get them back in the aeration basin quicker. (Back to food)
. March 4, added 5400 gallons of 1vMLSS 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 rn.atter please call my direct number at 704-
196 in the Mooresville Regional Office.
Sincerely,
Barbara Sifford
Technical Support
Mooresville Regional Office
CC: David Nichols

EPA
n Agency
A: Nati
rspeotion Report
y
tef
2 40-OO 7
Approval expires 8-31.98
2
Inspection b"1ar"c Days
NPDES
t4C0043532
11 12
yrrmo1day
_1/ .2/< 2
Remarks
.1►LJJ,
Facility Self -Monitoring Evaluation Rating
70U
71
91
72
QA
Inspection Type Inspector Fec Type
1BI r:. 191 s] 2011
Se
F,
Data
Reserved
751 1 1
of Facility Inspected (Fort
NPDES permit Number)
3 Barbees Grove Rd
281299
e(s) of De Pepresentative(s)fl7
22.
0/704-485-4613/
Cress of
ustn
H Lit1e Box 610 Cakboro NC 26
Reoords/Repor s
c nplianoe Sc„lecules
aoru 'C: Areas
Self-Mon(t
Laboratory
f Find(ngtC € rnents (Atta t eddst ono( sheets of narrative a
Users discha
Number('s)
to P
u
Entry 3me? ate Perrrait Effective Date
2/2
PM 11/©2/2
Other Faclity Data
urine, Rraspe ion iQhedk rrt@y those areas evaluate
e attachment summa.
Program
10/02/01
Permit Expiration
udge Handling 1 isp©sat Facility Site Review.
Signaturres} of Inspector(s) cy/Officelhone and Fax Numba Date
S.*ffo d MF'0 w0//704-563-16 9 Lxt.2196/
14/01/31
ature of Management n A Reviewer
EPA Form. 3550-3 (Rev 9.94) Previous edd ions are obsolete.
Agency/Offi'P.hone anC Fax Numbers
Date
Page #

NEDES
NC0043S32.
SectionSummary of Pen
AUG9
DENR-WATER OUAL9°
PONT SOURCE BRA
Page 2

Permit: NCC3532 Owner - Facitity:aldst�rt
Inspect't©n Date: 022212011 Inspection Type: 7eonnical Assistance
Compliance Schedules
is there a compliance schedule for this facility?
is the Facility ccmpfiant with the permit and conditions for the review pedod?
Comment: Comfirmed the data from K&W Tabs, 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 nitrifiers.
Effluent Sarrl�ling
is composproportional?
Is sample
II° all treatment units?
is proper volume collected?
is the tubing clean?
is proper temperature set
Is the facility sampling pertc
sample storage (kept at less than or equal to 6.0 degrees Celsius)?
red as required by the permit (frequency, sampling type representative)?
Comments Additional gamples need to be collected and analyzed to trend data for
plant performance.
Influent Sampiin�
is compcs to sampling flow proporti nal"
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 ail required inform readily a.vailabie, complete and current?
Are all records maintained for 3 years (lab. reg. required 5 years)?
Are analytical results .nsistent with data reported an Dfbt
Is the: chair -of -custody complete?
gates, to ~es nd iccsticn 'sampling
Name of individual performing the semolina
° 'E.R QUALt
MCA iROE r3RANCH
Yes No NA NE
1 0 0 ©
On00
Yes No NA NE
O 050
O 0 1 0
O 0100
O 0 E n
O 0 e 0
n011 0
Yes No NA NE
O 00II
O 00n
O 000
O 0011
O 0 0 m
0 0 0 m
Yes No NA NE
■ ©❑00
s000
$ 0 0 0
m 0 0 0
s 0 0 0
0
Page # 3

Inspect
Pe it. NC0043,532
nDate:
Facility: CaKbor
Type:
ys
darn of person pert ring n
Transported U
,re DWIRs co,pieta: do they in
p
ararrkete
the facility submitted is annul complain report to users and
ty°
the O D
a
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SAGO perm ea flow)
avaSabie and came
grade aqua
Bey^ aperte 2417 vrith a certified
ipher than the facility ciassktt
p
Tatar ea
ti'os No NE
de teas nr greater than the facility alassif t,nnp
py of he PurrsPDES permit ava.la le nn site,
Fac ty has dray of prey pus years , nr
ent,
r file far revie 5

From: dnicholsCoakboro.tom <d IcholsZtoakboro,coma
To: barbare.sifford©ncdenr.gav
Cc: rholshouser©oakbor©.com
Date: Wednesday, March 02, 2011 05:14 pm
Subject:
Attachments:
l ls. 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
95° © 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 oxid"rzing
bacteria, We haven't wasted since you were here. We'll check the MLSS and RAS SS tomorrow and I"11
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:// ail.aakbora.c©m/edgedeski .exe?id= 16a1cacc467e237c87dde77ae... 6 7/2011

From: dnicholakbaro,com c€ nicholsCoakboro.com>
To: Sifford, Barbara <barbara,[e-mail]
Cc: rholshouser©oakboro,eom
Date; Thursday, March 03, 2011 05:44 pm
Subject seeding oakboro WWTP
Attachments:
UG 0 9 2011:
DENR-WATER QUALITY
POINT SOURCE BF.ANCH
Ms. Sifford:
1 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—_--
Frorn: Sifford, Barbara[mailto:barbara.sifford@ncdenr,gov]
Sent: Wednesday, March 2, 2011 04:26 PM
To: dnichals oekboro,com
Subject: RE:
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.
Frorn: [e-mail] [maiito:[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. 1 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 pprn 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
teria. We haven't wasted since you were here. We'll check the MLSS and RAS SS tomorrow and I'll
curate a WAS flow for a SRT target of 40 days. I think Larry is impatient, but 1 realize the regrowth of
ammonia oxidizing bacteria is very slaw.Do you have any other suggestions7David Nichols
http:/mail.oakboro,corm/edgedeslo''cgi-binitiie t ail.exe?id=016a1c c467e237c87dde77ae... 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. I
think Ryan had been only running one
From: [e-mail] [malfto:[e-mail]]
Sent: Wednesday, Mardi 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 € onfirrn. 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.©o you have any other suggestions?David Nichols
OENR-WATER UAL:TY
r!.0IN'T SOURCE SRANCH.
http://mail.o kboro.carte'edgedes !cgi-bin0\Tim a l exe"?id=01.6a1cacc467e237c$7dde77ae... 6/7/2011

From: [e-mail] cdnicholsCboakboro,com>
To: Sifford, Barbara <barbara„siffordtgpncdenr,gov>
CC: rholshouserCoakboro,com, IbranchOoakboro.com
Date: Ftiday, March 04, 2011 05:25 pm
Subject: Re: seeding Oakboro WWTP
A nts:
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: Stfford, Barbara [[e-mail]]
Sent: Friday, March 4, 2011 10:49 AM
To: [e-mail]
Subject: RE: seeding Oakboro WWTP
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 alkaiinity,
because they wiU 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: rholshousergoakboro.com
Subject: seeding Oakboro WWI?
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- 82-4612 as soon as possible so we can get moving on this. Ve 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;
i-r\L'G 0 9 2011
DENR-WATER QUALITY
POINT SOURCE BRANCH
'maiLoakboro.corriledgedesk/cgi-bin/vie 1. x ?id=016a1cacc467e237c87dde77ae... 6/7/2011

From: dnichois©oakboro.corn <dniChols©oakboro.com>
To: Sifford, Barbara <barbara.siffo.gov>
Cc: rholshouserrPoakboro.cam, Ibranch©oakboro.com
©ate: Tuesday, March 15, 2011 05:08 pm
Subject: Re: Ammonia
Attachments:
We added another 5400ga1 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
mplement.) 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
---Ciriginal Message -----
From: Sifford, Barbara [mailto:barbarra.,
Sent: Tuesday, March 15, 2011 03°:51 P
To: [e-mail]
Subject: Ammonia
0
ncdenr.gov]
How is the plant running now? Haven?t heard anything, i?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 & Natural Resources
Div. of Water Quality
610 E. Center Ave,, Suite 301
Mooresville, NC 28115
Ph: 704.663.1699 Fax: 704.663,6040
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
http://'m t.€ akboro. camiedgedeslc./cgi-bini'viewmaiI.exe?id= o I6a 1 cacc467e237c87dde77ae... 6/7/2011

From; driicholspoakbaro.com ‹dnichols
kborocom>
To: Sifford, Barbara <barbara.siffordancidenr.gov>
Cc: Hoishouser, Ross <rholshousereboakboro.com>, Brarch, Larry <lbranchaoakboro,com>
Date: Friday, March 25, 2011 05:02 pm
Subject: Ammonia at Oakboro WWTP
Attachments:
s. Sifford:
This week we got the plant MUSS 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 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, 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. Ail 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 clarifiqrs. 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 unuseabie 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 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
AUG 0 9 2011
DENRWATER QUALITY
PONT SOURCE BRANCH
http://m ail. oakb comiedgedesk/cgi-binIviewmaitexe?id=016alcacc467e237c87dde77ae... 6/7/2011

kboro.cdi hats@
To:
Cc:
Siffor
Branch La
<barbara,siff' ord ncdenr.gov>
branchaoakboro.com>, Holshauser Ross <rholsh
©ate: Tuesday, April 12, 2011 08:38 am
subject:
Adchments:
e
oakboro.com>
bara:
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 rng/L of ammonia everyday.
Bad news: about Thursday of last week our aeration basin DO dropped to 4.3rng/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 80p'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 00 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 Cakboro
PO Box 610
Oakboro, NC 28129
dnich©[e-mail]
704-984-0320 cell
704-485-4613 office
704-485-2439 fax
http://rnail.o lkbaro.camiedgedeskr"cgi-biniview°r aail.exe?id=E? 16a1 cacc467e237c87dde77ae... 6/7/2011

nich s akboro c rr: t 1 a35 oakborn:coms
Ta: Slfford, Barbara <barbara.siffordencdenr.gov>
Cc: Branch Larry <IbranchOoakboro.com>, Holshouser Ross arholshwuseri iakboro,com>
Gate: 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 DO is still hovering around 0.3mg/L. I had a COD ran on Tuesday influent composite
and got only 344rng/L, indicating if something was dumped it is gone.
I'm wasting with a SRT=30 day target. MLSS=4loomg/L this week.
We are still nitirying but not good enough. Influent 40.7mg/L, effluent 10.1, 10,0 and 7.88mg/
this week. I need to get the DO up before I can expect any better than this. Were 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). An
one aerator motor is in Monroe being rewound.
Thanks,
David Nichols
WWTP/Collections/Distriibution/Cross Connections ORC
Town of 0akboro
Po Box 610
Qakboro, NC 28129
[e-mail]
704-984-0320 cell
704-485-4613 office
704-485-2439 fax
----original Message -----
From: Sifford, Barbara[rnailto:[e-mail]]
Serit: 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@oakboro,comj
Sent: Tuesday, April 12, 2011 8:39 AM
To: Sifford, Barbara
Cc: Branch Larry• Hoishouser Ross
Subject:
Barbara:
Help!
t'rinaii.o ;boro.carn/edgedesk/cgi-bi➢/viewmail.exe?id=016a1cacc467e2
DENR-WATER �1
POINT SOURCE
7
7dde77ae.,. 6/7/2011

ly last week we started to show the needed improvement in effluent ammonia: 6.0, 1 and 8.1 mg/L.
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 1Q0mg/L. Our effluent B©D's are
running a little high as well.
The only
huge oxy
onable explanation I have is sttnteone is sporatically dumping into our collection system something wi
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. o
three we are operating gave D0's over 3.0mg/L a few weeks ago.
Do you have any suggestions on tracking down our DO problem? Should we s
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
P© Box 610
Oakboro, NC 28129
dnichols"aoak.boro.com
704-984-6320 cell
704-485-= 613 office
704-485-2439 fax
d COD samples
ENR-WVkTE.E
ItTSOUK,
f.oa boro.cornledgebi.n viev, 1 exe?id=416a1cacc467e237c87dde77ae... 6/7 2011

Iscrakboro.co
To: Sifford Barbara <barbara.siFfordncdenr.gov>
Cc: Branch Larry <IbranchQoakbaro.comn, Holshouser Ross <rholshousertoakbo
Date: Sunday, April 17, 2011 ©8:42 am
Subject; Re, Oakboro WWTP
Attachments;
Barbara:
Knock on wood, I think we are turning the comer.
itt1 a lot of long days and hard work, we were able to start filling aeration basin #2 Friday night and tumed 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 DO is 2.4mg,/L, we are using alkalinity again and unoffical ammonia on an
effluent grab is 3,6rng/L not quite in summer compliance limit but close,
Thanks for your heip and support.
David Nichols
WWTP/Collections/Distribution/Cross Connections ORC
Town of ©akboro
P© Box 610
©akboro, NC 28129
dnicholsgoakboro,com
704-984-0323 cell
704-485-4613 office
704-485-2439 fax
Original Message --
From: Sifford, Barbara[malIto:barbara,sifford@ncdenr,goyj
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:
This is with
DENR-WATER s
POINT SOURCE
lust week we started to show the needed improvement in effluent ammonia: 6.0, 15 and 8.1 mg/L.
uent amrtaonia greater than 100 mgt.. We were augmenting about 40 mg/L of ammonia everyday.
Bad news: about Thursday of last week our aeration basin DO dropped to 0.3nag/ 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 whichhovers at 100mg'L. Our effluent BOD's are
running alittle high as well.
The only reasonable explanation l have is sonaeone 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,
il.oakboro.comledgedeskcgi-bin/vieu°
il.exe?id=O16a l cacc467e237c87dde77ae... 6/7'2011

orking as quickly as possible to rehab the secot
e we offing gave DD's over 3.4mg11 a few weeks ago.
Do you have any suggestions on tracking down our DO problem? Should we start puling 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 Qakboro
PC Box 610
Dakboro, NC 28129
[e-mail]
704-984-0320 cell
704-485-4613 office
704-485-2439 fax
http %/m
0
basin to get soste more DO capacity. However the
DE NR-WWT ;
P©G!T SOURCE
ro.co edgedesklcgi-bin viewmail.exe?id=o1.6a1cacc467e237c87dde77ae,,. 6/7/2011

Eram m __cl,bro ccarrs«cdnlcholsCoakboro.corn->--
To: Sifford Barbara <barbara.siflordencdenr.gov>
Cc: Branch Larry <[e-mail]>, Holshouser Ross <rholshouser©oakbor,.com>
Date: Saturday, April 23, 2011 01:00 pm
Subject: Oakboro WWTP nitrification
Attachments:
Barbara
This week our effluent ammonia results were 2.1, 1.0 and <1.0 mg/L N.
Woo© 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 ciariifier 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
E VR-WATER QUALIi
O NT SOURCE BRANCH
http://mail.oakboro.cam/edgedesk/cgi-binlvieu 7„e ;e` id = 16a1cacc467e237c87dde77ae... 6/7/2011

From: dnichoisapakbordcom !cdnEcholsElpoakboro.com>,
To; Sifford Barbara <barbara..s'EffordOncdenr.g v>
Cc: Branch Larry <1branchoakboro.com>, Holshouser Ross <[e-mail]>
Date: Sunday, May 01, 2011 10;13 am
Subject: Oakboro WWTP nitnfication
Attachments:
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 sources) of our ammonia. 40 mg/L influent just seems too
high for domestic with our HU. 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
DENR-WATER QUALETY
POINT SOURCE BRANCH
http://mail.oakboro. comiedgedesicicgi-bin/viewmail .ex e?i d=016alcacc467e237c87dde77ae.., 6/7/2011

STATE OF NORTH CAROLINA
DEPARTMENT OF STATE TREASURE
State and Local Government Finance Division
and the Local Government Commission
JANET COWELL
TREASURER
July 15, 2011
The Honorable, Joyce H. Little, Mayor
Town of Oakboro
PO Box 610
109-A N. Main Street
Oakboro, North Carolina 28129
Re: Town of Oakboro - 82,019,292 Wastewater - Revolving Loan
Dear Mayor Little:
T. VANCE HOLLOMAN
DEPUTYrREA.SURER
,The Executive Committee of the N.C. Local Government. Commission on July 12, 2011
formally approved the above -referenced Revolving Loan in the amount of .$2,0.19,292 for a
term of twenty (20) years, The rate as established under this program for the respective loan,
State or Federal, is not to exceed. 4%. The above -referenced application is subject to the five-
day appeal period in G,S. 159-4(b).
We are pleased to have had this opportunity to serve you.
Sincerely.,
6„)
T. Vance Holloman, Secretary
Local Government Commission
TVH/jinl
cc: Ross Holshouser
Town Administrator
Don Evans
State Revolving Loan and Grant Program
AEI 09 2011
R-WATER QUALITY
POINT SOURCE BRANCH
325 NORTH SALISBURY STREET, RALEIGH, NORTH CAROLINA 2760.3-1385
Courier #56-20-45 Telephone: [phone] Fax, [phone]
Physical Address: 4505 Fair Meadow Lane, Blue Ridge Plaza, Suite 1.02, Raleigh, NC 27607
Website, www..nctreasurer.com
An Equal Opportunity/Affirmative Action Employer

Town of Oakboro
Sewer Fund
2011-2012 Budget
ER FUND EXFENDITURES
Page 2 of 3

0101.1290 000 4565 0489
RED°1E:11'" 4 UEQUF.STF ;)
ratbl , .lt c: ! 1. lslttlt \favor
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low"
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NCDENR
Notice a; f`Virtl4ttt n and A
Peitalty
1. 4 2 ! 5.
':{own of () klm
Starter (.`}uttty
Case No, 1:. V-201 1-0191
Dee 1:%tinan
this
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Pursuant to
143 15
yn:o{.
been (1)violation of( .14-2131()and
\R 3 \(
Permit No,
State it
43 33
A6a
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f(>T\£ C J£ 'E A 1v
Enforcement costs,.
TOT \C &\LA/\ƒ 9CE
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21mo11
lmdns0(( S.143 15,1(

s of receipt of this notice,
Submit payment of the pe.
Payment should be made cl
Resources (do not include waf
enforcement action for any contt
Please subunit payitrertt to the atte
t do one of the foil
rder of
Payment of the penalty will not foreclose
iolati.on(s).
Point Source Compliance/Enforcement Unit
Division of Water Ctrality
1617 Mail Service Center
Raleigh, North Carolina 27 9 617
O1
equest for renis
g a detailed justilticatiou for such request:
Please be aware that a request for consiclerr iic>rt of`the five. facto s listed
below as they may relate to the reasonableness of the amount of the penalty a
Requestin , re tt tssic n is tncnt the proper procedure for contesting, whether the violitticnza s} occurred
or the accuracy of any of tf e f rctual staters ents eonttnitted in the civ=iI penalty assessment:
document. Because a remission request i:rtrecicsses th.e option of an administrate hearin , such
a request. must be accompa
tb,.lt..nca f nc.tlttnl c
y you
a factors
and submit it ten tlto. l+
rcnmssicoi request
,d statement that
beam ri C
ill b
lrlg neeess:
7 dispu
shou1d be re
below: In determining the
c.orlsidered:
dvcrternt c r t
result clfac
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C(lnl"r'al l,ssl ;?l:
y
tot the (.".ell inn

o request ret rission, y oo must complete arid strlr ritit the en losc.d ''' <iiv cr of Ri Pub to an
;ative l-learir and Stipulation of Facts" orm ithin thirty (30) d.a> s of receipt )t this
e Division of Water Quality also requests that you complete and suhmit tl e enclosed
for .Remission Request." Both tcirrns should be submitted to the follo\\Tir
Source C.`oi ipli
-4 'Water t)ri tlity
7 Mail. Service Center
i,h, North Carolina. ? 769
adniin
You must file the
of this notice. Ape.
during normal office fv_ii.irs.
Friday between the hours of
he tiled by facsimile. (tat) or electro
original, one (l) copy and a filing
Office of Adniinistrat. Hearings \v
transmission. Yati should contact the Office o
ffi1ini fee and=''ci the details of the filing 1i.roce.ss,
for the Office of Administrative f leis in:s are as fc
OR
7
'or an :r dministratid e hearing sm ith the 0 .
•1° statemen
ou may o
Office of Ad
6714 Mail Service C or
Raleigh, NC 27(
l el: (919) 4 1-3000
Fax.: [phone]O0
Hearings
attached asc s:sn
ain the petition form f
cc o.f Administrative I:lear
en it is received rn
iling fee is rcclu
en t"7`t lusiratws
loves:
d i°n
doc_uinen
e C)fticc o
IIthi.n thirty (30) days
of Administrative
accepts filirs Monday t.
ictl state holidays. The petitic t� r
fictions) - provided the
NC;GS 5150l3- 3,2) is reed\ ec
ing.. the faxed or electronic
questions regarding
and telephone :u
a rings:
he served on 1).1:rN1as follows:
s:

Please be advised ƒS GOed ed§e9 n
fth a K I t he
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11Note1tiNt9.201...14)191.:
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COUNTY OF S"FA
R OF
LT Y AGA
OF 0. KBURO
l NO, N('O)043 5
'Hayti lcez tsse:sed ci
document of the Division
of the. cis°i1 pemi.lties, ilrae hetehy waive
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ew`idence presented ire support of renns
of Water °ithi.n 3() days
iota r-ec'ed after 30 d
This the
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DI PAR F . II:.N T ()E F:NVIR0N M N.!.
AND N,,\.1 I»R 1L RE .1)1TRt ES
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`l f Pt_., L.`TI()N (F FA(
FILF NO. I..V-2011-0191.
4a.74 for tzolr.tion
2011, the undersine
o adtttstr tti e hearing
document, The undersi
nust be submitted toy tl e F)ircc.tc$t rat the
ment. No new e\Widence ire support of'
naent.,.
AF)I aRF.
1

JUSTIFI(: TTON 7OR REMI ON RE OC ST
Assessed Party.
Count=:
Permit Number: 'SC+Qtt435
Amount Assessed. SS'dfi.74
Please use this form when requesting of this c
Waiver of Right to an )1417.
1. penalty. You should attar
form to request rem
'at you beliiev"e, support vour° request and are necessary
Director to consider in evaluating your request for remission. Please he aware that a request for
si.on is limited to consideration of the law-e 1*rc.tors listed below as they may relate to the reasonableness of
ion is r c t ti e: proper procedure for ontestin4
nt tai` the civil penalty assessed,
viol
t document,
t:U'l l SLITw
d or the aceura
§ 14313.282.
`e of tlae l:oliowin five factors applie , Please check: each fa.
your ease and provide a detailed e planat.ion. inc:ludin copies of supportinl
- additional pages as needed),
one"._o?'z
the detrirac.r
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something went CO?
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NORTH CAROLINA DIVISION OF WATER QUALITY
Violator:
Facility:
Count):
Case Number:
own f Oakboro
rboro WWTP
Stanly
LV-2011.-0191
Permit Number: NC0043532
ASSESSMENT FACTORS
I) The degree and extent of harm to the natural resources of the Staite. to the public health, or to
private property resulting from the violation;
No harm has been documented. The facility violated the \veekly average BOD and suspended effluent
limitations for the period of M.arch 27-April 2, 2011_ Because the BOD dilution was in adequate to
provide an actual BOD value, it was reported as >18.4 ing/1, Total suspended solids (TSS) for the same
period was reported as 60,43 mgli. Both reported values would be predicted to have water quality
impacts on the receiving stream for lowered dissolved oxygen and turbidity. Ammonia nitrogen was in
excess of permit limitations for the month of April 2011. Noncompliance for ammonia nitrogen was not
assessed a civil penalty (See Assessment Factor 5).
2) The duration and gravity of the violation;
The violations lasted for the week of March. 27-April 2, 2011. The facility returned to compliance the
week of April 3-9, 2011. BOD Was reported at >36% over the permit limit and 'TSS reported at 34%
over the permit limit, The facility experienced poor sludge settleablility and inflow/infiltration problems
that led to the noncompliance according to the Town's response to NOV-2011.-EV-0282. The response
also stated that the facility only had one operable clarifier at the time the violations occurred (NPDES
permit description requires three operable clarifiers). Only one ammonia limit violation exceeded 20%
of the permit limit.
3) The effect on ground or surface water quantity or quality or on air quali
No effect is expected on ground water or air quality. Surface wateers may have been impacted by
causing lower available dissolved oxygen and increased turbidity downstream of the facility.
The cost of rectifying the damage;
The cost is unknown.
5) The amount of .money' saved by noncompliance;
The Town was awarded a revolving loan from the Executive Committee of the NC Local Government
Commission on July 12, 2011 for $2,019,29.2,00 to make necessary repairs to the collection system to
reduce inflow/infiltration.. The Town approved funds for the rehabilitation of one of the out of service
clarifiers since the noncompliance occurred in April 2011. The 'Town addressed the ammonia nitrogen
noncompliance in a timely manner and has spent considerable funds ($13,071 plus $791day for chemical.
addition and additional aeration) to correct the problem including changes in WWTP operational

procedures. n exact monetary amount of savings cannot he determined for the previous lack of
maintenance of the collection system and WWIP facilities%
6) Whether the violation was committed willfully or intentionally;
The violation does not appear to he IPS'i !Ifni or intentional:
7) The prior record of the violator in complying or failing to comply oath programs o er which the
Environmental Management Commission has regulatory authority; and
Case Number FDCSerip_--tion
1 V-2011-0106 Remission requested ease open
17 V -20 1 1 -015 1 Remission requested case open
laV -20 1 1-01 77 Remission requested case open
8) The cost to the State of the enforcement procedures.
Staff preparation of enforcement package: 1 hour at $33.1 9/hour
SWP Regional Supersisor re 1 hour at $38,55/hour
Clerical Support: 1 hour at SI 5.00/hour
Total: $86,74
Date RO Supervisor
Disision of Water Quality

MONITORING REPORT tMRI'VIOIu4TIONS for:
PER
T; NCOO4
2 FACILITY: Town of Oakboro - Oakboro WWTP
COUNTY: Stanly
Report Date. 07111/11 Page: 10 of 11
REGION; Mooresville
Limit Violation
MONITORING 0UTFALL
REPORT PRI
LOCATION PARAMETER
04 .2011 002 Effluent
600, 5-pay (20 Deg. C) -
Concentration
VIOLATiiON
DATE FREQUENCY
04/02l11 3 X 'week
UNIT OF CALCULATED
MEASURE LIMIT VALUE OVER LRMIT VIOLATION IYPE
tdlt 13.5 18A
VIOLATION ACTION
36.3 Weekly Average Exceeded None
04 -2011 t7C32 Effluent Nitrogen, Ammonia. Total (as 04d02/11 3 X week mg/I 9 15.03 67.04 Weekly Average Exceeded None
N) - Concentration
04 -2011 002 Effluent. Nitroe en, Ammonia Total (as 04/09/11 3 X week mgl'I 9 9,6n6 7,33 Weekly Average Exceeded None '
N) - u xncentt ation
04 -2011 002 E iuerlt. Nitrogen, Ammonia Total (as 04/16/11 3,X week mg/l 9 9.33 3.63 Weekly Average Exceeded None
N) - Concentration
04 -201'1 002 Effluent Nitrogen, Ammonia Total (as 04/30/11 3 X week mg/I 3 3.39 13.06 Monthly Average Exceeded None
N) - Concentration
1'04-2011 002 Effluent Solids, Total Suspended - 04/02/11 3 X week, mg/I 45 60.43 34.'3 Weekly Average Exceeded None
Concentration